Privacy Policy

Last updated on March 5, 2021

ABC Intelligence Inc. (“ABC Intelligence”, “we”, “our”, or “us”) recognizes the importance of your right  to privacy and wants you to be familiar with how we collect, use and disclose personal information that  individually identifies you and our commitment to meet our obligations under applicable Canadian  privacy laws. 

This Privacy Policy explains how we collect, use, disclose and protect your personal information. It also  explains how you can contact us if you have questions about how we handle your personal information.  We will only collect, use and disclose your personal information in accordance with this Privacy Policy. 

  1. Acceptance of this Privacy Policy 

This Privacy Policy is incorporated into and is subject to the ABC Intelligence General Terms and  Conditions. By visiting or using the ABC Intelligence website (, or ABC  Intelligence software, or ABC Intelligence application, (collectively the “Website”), and the ABC  Intelligence services (the “Services”), you acknowledge that you have read and understood this Privacy  Policy and that you agree to the terms and conditions of this Privacy Policy, and that you consent to the  collection, use, disclosure and other processing of your personal information and other non-personally  identifying information by ABC Intelligence in accordance with the terms and conditions of this Privacy  Policy. If you do not agree to the terms and conditions of this Privacy Policy or the General Terms and  Conditions, please do not provide us with any information and do not use the Website or Services. 

  1. Application of this Privacy Policy 

This Privacy Policy applies to all personal information provided by visitors or users (“visitors”, “users”,  or “you”) on the ABC Intelligence Website, in the ABC Intelligence software, inside the ABC Intelligence applications, emailed to ABC Intelligence, verbally communicated to ABC Intelligence, and any  information that may be automatically retrieved through the use of the ABC Intelligence Website, the  ABC Intelligence software and application, or the Services. 

  1. Changes to this Privacy Policy 

We will update this Privacy Policy from time to time. Any changes will be posted on this page with an  updated revision date. Please review our Website periodically for any changes to this Privacy Policy. Your continued access or use of the Website after any such changes constitutes your acceptance of the  Privacy Policy as revised. If we make any material changes, we will provide notice through the Website or by other means. 

  1. Accountability 

ABC Intelligence is accountable for compliance with this Privacy Policy and applicable Canadian privacy  laws. We are responsible for personal information in our possession or custody as well as personal  information that we may transfer to third parties for processing. We will require our service providers to  agree to contractual requirements that are consistent with our privacy and security policies. We will  require that our service providers are prohibited from using personal information, except for the specific  purpose for which we supply it to them and to maintain a level of privacy protection comparable to our  own privacy policies and practices.

  1. What Personal Information We Collect 

As used in this Privacy Policy, personal information means information about an identifiable individual,  whether or not in recorded form, within the meaning of applicable privacy laws. Anonymous data means  data that is not associated with or linked to any individual’s personal information or will not easily  permit the identification of individuals (“Anonymous Data”). We do not consider personal information  to include Anonymous Data. 

The type of personal information we collect will depend on various factors such as the nature and  purpose of our interaction, the type of products or services you may request or use, and any applicable  legal and regulatory obligations. This information may include: 

  • contact information that allows us to communicate with or contact you (e.g., your name, home  address, telephone number, e-mail or other electronic address, and fax number); identification information that allows us to confirm your identity (e.g., your name, date of birth,  occupation, and government-issued identification); 
  • your actions on the Website (e.g., where you are clicking and how you are using the Website); relationship information that helps us to improve service and understand more about you (e.g.,  language and communication method preferences, or types of products, services or offers you may  like); and 
  • IP address and referral source. 
  1. Aggregate Information  

We may track the total number of visitors to our Website, the number of visitors to each page of the  Website, the number of External Website (defined below) pages you have visited, technical information  about your computer, system and browser software and IP addresses. The aggregate information  extracted from this data will be maintained, used and disclosed in aggregate form only and will not  contain personal information. We may use such aggregate information to analyze trends, improve the  Services we provide, administer the Website and gather broad demographic information for aggregate  use. 

  1. When Your Personal Information is Collected 

We may collect your personal information when you voluntarily provide it to us by using our Website or Services or from third party sources. For example, we may ask you to provide personal information if  you: 

  • Use our Website or Services; 
  • Send us a communication by email, telephone, online chat, fax, text message (SMS), the Internet, or  by other means; 
  • Register to receive newsletters, articles or updates about our Services; or 
  • Otherwise participate in features of our Website or our Services that ask for personal information. 

We may receive personal information about you from third party sources. We use this information to: (i)  assist with our business operations; and (ii) to ensure that the Services that we provide you are  delivered appropriately. You authorize the collection of your personal information from these sources 

and, if applicable, you authorize these sources to give us your personal information for the above  mentioned purposes. 

If you speak with one of our representatives by email, telephone, online chat, fax, text message (SMS),  the Internet, or by other means, you may be asked to provide personal information for the following  reasons: 

  • To establish a record of the information that you provide; 
  • To take or verify instructions from you; 
  • To confirm your identity; 
  • To maintain quality service levels; 
  • To assist in staff training; or 
  • To facilitate our Services to you. 
  1. Purposes for Collecting Your Personal Information 

We collect, use and disclose your personal information in order to provide you with our Services. We  also collect, use and disclose your personal information to comply with legal and regulatory  requirements and as otherwise may be permitted or required by applicable laws. We will only use the  personal information that we collect for the purposes for which it was collected. We may collect, use  and disclose your personal information for any of the following purposes: 

  • To present our Website and its contents to you; 
  • To provide you with information, products, or Services that you request from us; To provide, activate and manage your access to and use of the Services; 
  • To process and fulfill a request, order, download, subscription, or other transaction; To verify and confirm your identity; 
  • To verify your instructions and decisions; 
  • To fulfill the purposes for which you provided the information or that were described when it  was collected, or any other purpose for which you provide it; 
  • To notify you about changes, updates and other announcements to our Website or Services we  offer or provide though it or any other products and services; 
  • To provide technical, product and other support and to help keep the Services working, safe and  secure; 
  • To establish and maintain commercial relations with you, including responding to your questions  regarding our Services; 
  • To communicate with you by various methods including email, text (SMS), telephone and  through our Website;  
  • To improve our Website, Services, other products, events, or services; 
  • To improve marketing, or customer relationships and experiences; 
  • To develop new products, services or benefits; 
  • To customize the appearance of the Website displayed to you and other personalisation to  make the Services more relevant to your interests; 
  • To obtain your feedback regarding our Website and Services, including any surveys, user testing  draws, sweepstakes, competitions and similar promotions; 
  • To track behavioural information on the Website to serve similar content upon future visits;
  • To identify usage trends and develop data analysis, including for purposes of research, audit,  reporting and other business operations, including determining the effectiveness of our  promotional campaigns, evaluating our business performance, or in other ways; 
  • To support our business functions such as internal business processes, marketing and  advertising;  
  • To deliver targeted advertisements, promotional messages, notices and other information  related to the Services or other products and services and your interests; 
  • To notify you about other products, services or events provided by us, by affiliates, or third  parties, which may be of interest to you; 
  • To comply with our legal obligations, meet regulatory requirements, resolve disputes, or enforce  our agreements; and/or 
  • As otherwise permitted or required by law. 

If a new purpose for using your personal information should develop, we will identify that purpose to  you and request your consent before using it for such purpose, unless the new purpose is required or  permitted by law. 

  1. Limiting Collection of Personal Information 

We limit the collection of personal information to information that is necessary to fulfill the purposes  identified in this Privacy Policy and we collect, use and disclose your personal information only in  accordance with this Privacy Policy. 

  1. Consent, Limitation of Use, Disclosure 

Your personal information will not be used without your consent for purposes other than those for  which it was collected, or as required or permitted by law. Generally, we will seek your consent to use  and disclose your personal information for identified purposes at the time of collection. In some  circumstances, however, where we identify a new purpose after collection, we may seek your consent  to use and disclose your personal information for such new purpose after it has been collected.  Consent may be express or implied. Express consent may be given orally, electronically or in writing.  Implied consent is consent that may reasonably be inferred from your action or inaction. 

We may generate Anonymous Data from personal information collected through the Website and  Services by removing information that makes the data personally identifiable to an individual. Such  Anonymous Data includes, but is not limited to, information we collect from your use of our Website  and Services. We may use this Anonymous Data and aggregated data for any reasonable purpose  subject to applicable laws. We do not disclose this data to third parties. 

We may also use and disclose your personal information including to service providers, data processors  and other third parties (“Third Parties”) under the following limited circumstances: To Third Parties that assist with our operations and Website and Services including, without  

limitation, for customer services, our business operations, monitoring and analyzing Website  activity, and operating and maintaining the Website. Such Third Parties may only use your personal  information for the purposes described in this Privacy Policy. 

  • When necessary to protect (i) our safety, property, or other rights; (ii) our representatives,  customers and users of the Website and stakeholders; (iii) to conduct investigations of possible  breaches of law, including, including to detect and prevent fraud;
  • To identify, contract, enforce or bring legal action against someone who may be violating an  agreement that they have with us, including without limitation our General Terms and Conditions; To investigate breaches of security safeguards or cooperate with government or regulatory  authorities pursuant to a legal matter; 
  • With your consent; or 
  • As otherwise required or permitted by law, regulation or other government authority or otherwise  in cooperation with an investigation of a governmental authority. 

We will not sell your personal information to any company or organization without your permission,  except we may transfer your personal information and/or aggregate information to a successor entity  upon a merger, consolidation or other corporate reorganization in which ABC Intelligence participates or  to a purchaser of all or substantially all of ABC Intelligence’s assets to which the Website or the Services 


  1. Withdrawing Consent 

Subject to certain legal or contractual restrictions, you may withdraw your consent to the collection, use  or disclosure of your personal information at any time upon giving us reasonable notice. We will inform  you of the implications of doing so. For instance, withdrawing your consent may limit or prevent us from  being able to provide or continue to provide you with certain products or services. In certain  circumstances your consent cannot be withdrawn. For example, you may not withdraw your consent  where our collection, use or sharing is required by law.  

  1. Electronic Marketing Communications; Canadian Anti-Spam Legislation (CASL) 

Subject to applicable law, from time to time, we may send you electronic communications notifying you  of new and existing products or services, including special offers or promotions, that may be of interest  to you. You may unsubscribe at any time from receiving our electronic marketing messages by clicking  on the unsubscribe or opt-out link or following any other unsubscribe instructions included in any such  message. Please allow at least up to 10 business days for the change to take effect. Please note that this  will not limit our right to send you certain communications relating to your account or your existing  products, services or transactions with us, or as otherwise permitted or required by applicable law, and  these transactional account messages and other non-commercial electronic messages will not be  affected by your choice to unsubscribe or opt-out from electronic marketing messages. 

  1. Retention of Personal Information 

We retain personal information only for as long as necessary to fulfill the purposes for which it was  collected, or as required by law, regulation, or other government authority or for other essential  purposes such as maintaining business and financial records, resolving disputes, maintaining security,  detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Services  through a subscription administered or sponsored by your organization, we retain your organizational  contact details after the termination of your organization’s subscription to continue to communicate  with you. 

  1. Storage, Processing and Transfer 

Your personal information may be stored, processed or transferred in Canada, or in any other country in  which we, our service providers, and other parties with whom we share information under this Privacy 

Policy may operate (which may include locations outside of Canada). In such event, your personal  information may, while in another country, be subject to the laws of that country and may be accessible  to courts, law enforcement and government or regulatory agencies in that country in accordance with  such laws. By using the Website and/or Services, you agree to this Privacy Policy and you acknowledge  this Privacy Policy may not offer an equivalent level of protection of that required in the European Union  or other countries. 

  1. Accuracy of Personal Information 

We will use our best efforts to keep personal information that is used on an ongoing basis and  information that is used to make a decision about an individual as accurate, complete, and up to date as  is necessary for the purposes for which it is to be used. While we take care to keep your personal  information in our records as accurate, complete and as up to date as necessary for the purposes for  which it is to be used, we rely on you to notify us when your information changes.  

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information  held by us, we will correct or update the information as required. If we do not agree to amend or delete  the personal information as requested by you, you may challenge our decision. We will make a record of  this challenge, and, if necessary, disclose the challenge to any third parties to whom we have disclosed  the personal information. 

  1. Security 

We implement safeguards to seek to ensure a level of security appropriate to the level of sensitivity of  the information we process. Our methods of protection may include physical measures (e.g., locked file  storage and restricted access to offices), organizational measures (e.g., security clearances and limiting  access on a need-to-know basis), or technological measures (e.g., the use of passwords, encryption,  firewalls, secure socket layer). These measures are aimed at ensuring the integrity, confidentiality, and  availability of personal information. We also require our outside service providers to provide a  comparable level of protection to personal information that we may supply to them. We will exercise  care in the disposal or destruction of personal information to prevent unauthorized access to the  information. 

  1. Access to Personal Information 

Upon written request, we will inform you of the existence, use and disclosure of your personal  information and give you reasonable access to that information. We may deny access for legally  permissible reasons, such as situations where the information is prohibitively costly to provide, if it  contains references to other individuals, or where it cannot be disclosed for legal, security, or  proprietary reasons, are subject to solicitor-client or litigation privilege, or in other circumstances  prescribed by law. If there will be a charge to access your information, we will inform you of the  approximate cost prior to providing access. In order to verify that the information is being released to  the proper individual, you may be asked to provide suitable identification, or to otherwise identify  yourself. We will advise you of any reason for denying an access request. 

  1. Children’s Privacy 

We do not knowingly collect information from children under the age of 13 or target the Services to  children under 13.

  1. Links to Third Party Sites 

The Website may provide links to other websites or resources over which we do not have control  (“External Websites”). Such links do not constitute an endorsement by ABC Intelligence of those  External Websites. You acknowledge that we are providing these links to you only as a convenience, and  further agree that we are not responsible for the content of such External Websites. Your use of External  Websites is subject to the terms of use and privacy policies of the External Websites. 

  1. Cookies 

A cookie is a small piece of text sent to your browser by a website you visit. It helps the website  remember information about your visit, which can make it easier to visit the website again and make  the website more useful to you. 

Our Website may use “cookies” to enhance user experience. User’s web browser places cookies on their  hard drive for record-keeping purposes and sometimes to track information about them. Users may  choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they  do so, note that some parts of the Website may not function properly. 

  1. Third Party Analytics 

We may use Google Analytics to help analyze how visitors engage with our Website. Google Analytics  uses cookies to collect standard Internet log information (e.g. IP address) and to track visitor behaviour  information (e.g. the web address of the page you visit), in an anonymous form. The information  generated by Google Analytics about your use of the Website is transmitted to Google, Inc. and is  processed to compile statistical reports on website activity for the Website. These reports would be  used to evaluate aggregate visitor usage so that we can manage and improve the Website and its  content to better meet our visitors’ needs. You may opt out of Google Analytics. For more information  on opting out of being tracked by Google Analytics across websites you use, please visit For further information about Google Analytics, please refer  to

  1. Filing Inquiries and Complaints 

If you have any questions about this Privacy Policy, wish to request access to personal information  about you in our possession or control, change your consent to the ways in which we may use or  disclose your personal information, or have a complaint about our Privacy Policy or the manner in  which we may have handled your personal information, please contact us in writing at: 

By email: 

By mail: ABC Intelligence Inc., 1 Scarsdale Rd., Toronto, Ontario, M3B 2R2 

We will investigate all written complaints and respond to all written inquiries. If we find a complaint to  be justified, we will take appropriate measures to resolve it. 

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