The cFocus Mission: Help any company to double (2x) its revenue within the next 12 months 
by means of our web platform of tools, training and services in web marketing and operations automation.

Privacy Policy

SECTION 1 - GENERAL TERMS AND CFOCUS TOOLS
This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from cfocus.ca (the “Site”).

PERSONAL INFORMATION WE COLLECT 

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.” 

We collect Device Information using the following technologies: 

    - “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. 
    - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
    - “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers [[INSERT ANY OTHER PAYMENT TYPES ACCEPTED]]), email address, and phone number. We refer to this information as “Order Information.” 

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information. 


HOW DO WE USE YOUR PERSONAL INFORMATION? 

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to: 
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). 


SHARING YOUR PERSONAL INFORMATION 
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. 


BEHAVIOURAL ADVERTISING 

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. 


DO NOT TRACK 

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. 


YOUR RIGHTS 

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. 

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. 


DATA RETENTION 

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. 


CHANGES 

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. 


CONTACT US 

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at marketing@cfocus.ca or by mail using the details provided below: 

21, boulevard Gréber, Gatineau, QC, J8T 3P4, Canada 
SECTION 2 - CFOCUS ACADEMY
Commitment to protect your privacy

In your relationship with cFocus Academy you share personal information with us. Such information may include your first name, email address and other personal details in connection with transactions entered into by you with us. We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information you provide to us. Further privacy information may apply depending on the business in cFocus Academy with which you deal with. If additional terms and conditions apply to you, they will appear on the website. We encourage you to visit our website regularly for any updates to our privacy policies.

What we collect

cFocus Academy will collect and hold your personal information for the purpose of:

- Providing you with the relevant product and/or service;
- Letting you know about other products and/or services which might interest you; or
- Assisting us generally in managing your transactions with us.

We may collect the following information:

- Name
- Contact information including email address
- Demographic information such as postcode, preferences and interests
- Other information relevant to customer surveys and/or offers

What we do with the information we gather

We may keep and file all personal information you provide when dealing with us to assist us in providing you with our services and information of interest in respect of your business. For example, a member of cFocus Academy may send publications or other market information on our products and services to you or follow up on your interest in particular products and services. cFocus Academy discloses your personal information to those employees or advisers who need to know that information to assist us in providing you with our range of products and services. We may also disclose information to affiliates and other third parties necessary to process your transactions or service your account (including our share registry, print service providers, call centres and mail houses, our accountants, auditors and lawyers and credit reporting agencies). We may also disclose your personal information in corporate transactions involving the transfer of all or part of the assets or business of a member of cFocus Academy or in a corporate restructure. If we do this, we generally require these parties to protect your information in the same way we do. We may also be required or authorized by law to disclose your personal information. For example, we may disclose your personal information to a court in response to a subpoena. We will also disclose information to other persons where you have provided your consent to do so.

What rights do you have in relation to personal information which we collect and hold?

cFocus Academy takes all reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. If you become aware of any errors in your personal information or you change your personal details, we ask you to contact us as soon as possible so that we may update our records. You can contact our Privacy Officer if you would like details of your personal information which we may hold about you or if you would like us to correct it. We will disclose to you such information, subject to certain exceptions allowed by law. We may require you to complete a request form before disclosing information. We also reserve the right to charge a fee. You may also contact our Privacy Officer to request us to stop using your personal information to contact you about our products and services. If you no longer conduct business with us, you can ask us to remove your personal information we hold about you. Subject to our legal obligations and responsibilities, we will take reasonable steps to destroy or de-identify your personal information.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

This privacy policy applies to the various websites operated by cFocus Academy under various domain names cFocus Academy operates websites which may utilize ‘cookies’ to collect personal information. If you transact electronically with a member of cFocus Academy you should refer to the website of that member for more information on its website privacy and security procedures.

Information collected from this website

When you visit a website of cFocus Academy , we may collect the following information from you: domain name, your name, information you volunteer such as email addresses. We may also collect statistical data, such as the date and times of visits as well as the number and pages viewed by each visitor, which is utilized to evaluate the performance and usefulness of our website.

Email usage

While we take care that the personal information you give us on our websites is protected, the Internet is not a secure environment. If you send us information, including your email address, it is sent at your own risk. Our websites do not capture email addresses without your permission. If, however, you provide your email address to us, it may be used by cFocus Academy to send you information relating to our and related products and services. If we send you an email which you do not wish to receive in the future, please use the unsubscribe link or follow the unsubscribe instructions at the bottom of that email or notify us and your email address will be removed from our system.

Private information security

cFocus Academy takes all reasonable security measures to protect personal information from loss, unauthorized access, destruction, misuse, modification or disclosure. For your safety and protection, your credit card information is not stored on our servers. Our payment gateway provider PayPal keeps this information encrypted and secure on your behalf. We do not, however, accept any responsibility for the unauthorized access of personal information held by cFocus Academy You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to the privacy standards of cFocus Academy and we are not responsible for their privacy practices or the content of such other websites. You should contact those websites directly to ascertain their privacy standards, policies and procedures.

3rd party disclosure

Personal details, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without the consent of the customer, other than for the express purpose of delivering the purchased product or service requested by the customer.

Who do you contact?

Our Privacy Officer can be contacted at:

E-mail: web@cfocus.ca

Changes to this privacy statement

We may change our privacy policies from time to time to comply with new laws or industry codes of practice which are developed. It is your responsibility to refer to our privacy policies from time to time to familiarize yourself with any changes.
SECTION 3 - CFOCUS SERVICES
cFocus and its affiliates (“cFocus”, “we”, “us”, “our”, or the “Company”) are committed to protecting the privacy of individuals who visit our websites (“Websites”), individuals who access and/or use our software (“Platform and Solutions”), including our associated mobile applications owned and controlled by cFocus (“Mobile Apps”). This Privacy Policy describes cFocus’ privacy policy practices in relation to your access and uses of Platform and Solutions and its products and Mobile Apps (collectively, the “Services”), your use and access to our Websites and your choices regarding use, access, correction and deletion of your personal information.

If you do not agree with the terms, do not access or use the Services and Websites or any other aspect of cFocus' business.

By accepting this Privacy Policy, either by clicking a box indicating your acceptance, or by executing or electronically accepting an agreement that references this privacy policy, you agree to the terms of this Privacy Policy.

Contents
1. The Information We Collect
     a. When you visit our Websites
     b. When you visit our Platform and Solutions
     c. Import Option

2. The Uses of Information Collected
     a. Your Profile
     b. Legitimate Interests under the GDPR
     c. Websites and Services
     d. Administration
     e. Marketing

3. Disclosure to Third Party
     a. No Selling Of Your Personal Data
     b. Your Instruction
     c. Third Party Services/Marketplace Vendors
     d. Third Party Service Providers
     e. Mergers and Acquisitions
     f. Anonymized Data
     g. To Comply with Laws

4. Navigational Information
     a. Cookies
     b. Log Files, IP Addresses
     c. Flash Cookies and Other Third Party Tracking
     d. Do Not Track
     e. Social Media Features and Single Sign On
     f. Link

5. Correct, Update, Delete Information

6. International Transfer

7.Security

8. Age Limitation

9. Public Forum, Refer a Contact, Customer Testimonial

10. Mobile Apps

11. Changes and Notices


1. The Information We Collect
     a. When you visit our Websites
When you come to visit our Websites, we collect information about your browser type, Internet Protocol (“IP”) address, geographical location, referral source, length of visit and pages viewed (“Navigational Information”). Navigational Information is described in further detail below.

     b. When you visit our Platform and Solutions
When you request more information about the Services, we require you to provide the following personal information: your name, email address, your company name, and telephone number (“Primary Information”).

When you purchase or subscribe to our Services, we require you to provide the following personal information: Primary Information, company address, billing name and address, the number of employees within the organization and any other information you choose to provide to us (“Personal Data”).

     c. Import Option
Through our “import option”, we may also collect Personal Data or email addresses of contacts that you choose to share with us. When you provide us with personal information about your contacts, they are subject to your own privacy policy and you are responsible. We will only use this information for the specific manner under this Privacy Policy, such as to add new accounts to your cFocus account.

2. The Uses of Information Collected
     a. Your Profile
When you register with us, you create your own public profile and configure your own privacy settings. You can view your profile to verify what information you provide is being shared publicly and you can edit your profile to remove information you do not want to be displayed publicly. We may use information about you that we collect from other sources, including but not limited to newspapers and internet sources such as blogs, instant messaging services, Platform developers, social media websites and other users of our Websites, to supplement your profile.

     b. Legitimate Interests under the GDPR
To the extent that cFocus' processing of your Personal Data provided by you is subject to the General Data Protection Regulation (“GDPR”) in the European Union (“EU”), cFocus relies on its legitimate interests to process your data. This may include keeping your information after you deactivate your account for the period of time needed for us to pursue legitimate business interests, direct marketing purposes, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

     c. Websites and Services
We use Navigational Information alone or in combinations with publicly available information about you to operate, enhance, improve and personalize your experience on our Websites. In addition, we use Navigational Information, Personal Data you have provided, publicly available information about you or in any combination of these to understand, operate, enhance, improve, research, and analyze the usage trends and preferences to the features of our Services and to create new features and functionality.

     d. Administration
We will use your email address or phone number to contact you for administrative purposes, for customer service purposes, to address intellectual property notice, to notify you of changes to our services, provide important notices, rights of privacy, or defamation issues. When you provide us with credit card information, we use it to check your financial qualifications and to collect payment from you. We use a third party service provider to manage credit card processing and we do not store any financial credit card information in our system.

     e. Marketing
We may use your Personal Data to send information about new product features or marketing communications from the business of carefully selected third parties which we think may be of interest to you. These are third party marketing communications and you can control settings whether to receive them.

3. Disclosure to Third Party
     a. No Selling Of Your Personal Data
At cFocus, we are not in the business of selling your information to any third party.

     b. Your Instruction
We will share, disclose, and update your Personal Data in accordance with your instructions, including any applicable Agreement, Terms of Conditions, and Terms of Use.

     c. Third Party Services/Marketplace Vendors
When you access our Platform and Solutions, you will have access to purchase from third parties. For example, in our Marketplace, you are able to engage with third party companies or individuals as service providers (called “Vendors”) to process and support your business. When you enable a service or purchase a product with our Vendors, we may share some of your Personal Data. These third parties are not owned or controlled by cFocus and they have their own sets of terms and conditions and privacy policies. Please refer to their privacy settings and notices of these Vendors.

     d. Third Party Service Providers
We employ third party companies or individuals to provide service improvements or complimentary services. For example, we may employ third party companies or individuals for website creation and development, hosting, maintenance and support; virtual computing and storage services. These third party companies may have access to or process your information.

     e. Mergers and Acquisitions
In the event that cFocus is engaged in a merger, acquisition, bankruptcy, dissolution, reorganization, financing, public offering of securities, sale of some or all of cFocus’s assets or stock, acquisition of some or all of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Personal Data may be shared or transferred, subject to confidentiality agreements.

     f. Anonymized Data
We may disclose or use aggregated or anonymized Data for any purposes including research.

     g. To Comply with Laws
We may be compelled to disclose Personal Data if we reasonably believe such disclosure is to protect our rights, protect your safety or the safety of others] in accordance with or required by any applicable law, regulation or legal process.

4. Navigational Information
     a. Cookies
Cookies are small text files sent by us to your computer or mobile device. Cookies are unique to your account or your browser. Cookies can be used to recognize you and your preferences when you visit our Websites or Services and give you a personalized experience in a faster and more secure way.

We use cookies and other ad technology such as Web beacons, pixels and tags or in any combination to compile information about your usage of our Websites or Services and give you a personalized experience in a faster and more secure way. They also help us market more effectively to users, provide aggregated auditing, research, and reporting.

Session cookies are automatically deleted once the user closes the browser or Mobile App, whereas persistent cookies last until you or your browser deletes them, or they expire.

You may choose to disable this cookie feature in your browser.

In addition, we use third party cookies like Google Analytics. For more information, click here.

     b. Log Files, IP Addresses
As is true of most websites and technology services offered via internet, our servers automatically collect information when you access or use our Websites or Services and record them in log files. This information may include IP address, the address of the web address you have come from and you are going to, browser type and settings, your internet service provider or mobile carrier, your searches, your operating system, your location, the date and time you have accessed or used Services, information about your browser configuration and plugins, language preference and cookie data.

     c. Flash Cookies and Other Third Party Tracking
cFocus or our third party partners may use Flash cookies to remember settings, preferences and usage and volume information from you to provide personalized settings, enhanced interactions and more relevant communications, and to track the performance of our advertisements.

     d. Do Not Track
Currently, the Company’s Websites or Services do not respond to your web browser “do not track” signals or other mechanisms.

     e. Social Media Features and Single Sign On
The Company’s Websites and Services may use social media features, such as the Facebook “like” button. These features may collect your IP address and which page you are visiting on the Company’s Websites, and may set a cookie to enable the feature to function properly. Your interaction with these features are governed by the privacy policy of such social media companies providing the relevant features.

     f. Links
Our Websites may contain links to other sites. We are not responsible for the privacy practices of other sites.

5. Correct, Update, Delete Information
Access and control over most Personal Data on our Websites and Services are readily available through the profile editing tools. Users of our Services may modify, export or delete any of their profile information at any time by logging into their account. Information will be updated immediately. Individuals who wish to deactivate their Services may do so. Deleted information may persist in backup copies for a reasonable period of time but will not be generally available to members of the Services.

We may correct, update, export, delete or otherwise modify any of the personal information that you have previously provided to us through the Company’s Websites and Services.

6. International Transfer
By using our Services, you are consenting to have your personal data transferred to and processed in the United States.

We may transfer Personal Data you provided to countries other than the one in which you live. The Company primarily stores your Personal Data in the United States.

We offer EU Model Clauses to meet the adequacy and security measures for our customers that operate in the EU, and other international transfers of data. A copy of our standard Data Processing Addendum is found here.

7. Security
At cFocus, we take security of data seriously and is a priority. Our Websites and Services take appropriate precautions to protect Personal Data. Your account information is located on a secured server protected by identity and access management checks. All of our Services are served using Transport Layer Security (TLS) to protect data in transit, and all passwords are one-way hashed prior to storage to prevent discovery in the event of a data breach.

Although we allow you to set privacy options that limit access to your pages, we cannot guarantee that information, during transmission through the internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others. Please be aware that no security measures are perfect or impenetrable.

8. Age Limitation
To the extent prohibited by applicable law, we do not allow use of Websites and Services by anyone younger than 18 years old. In the event that we learn we have collected personal information from anyone under the age of 18, we will delete that information as quickly as possible.

9. Public Forum, Refer a Contact, Customer Testimonials
We may provide boards, blogs, or chat rooms on the Company’s Websites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. We are not responsible for any personal information you provide to these forums.

You may elect to refer a friend by submitting a name and email address to us. We will send the contact a one-time email about Websites and Services and we do not store this information.

We post customer testimonials and comments on our Websites, which may contain Personal Data. We obtain prior consent before we post any information our Websites.

10. Mobile Apps
In addition to information we collect on our Websites and Services, when you use our Mobile Apps we may also collect further information including your city location, device model and version, device identifier (or “UDID”), OS version, and your subscription. We use mobile analytics software to better understand functionality of our apps on your mobile device.

You may set your settings to receive push notifications and allow other access to your phone such as camera and contracts.

Mobile Apps may transmit information to and from Devices to provide the Mobile Application services.

11. Changes and Notices
cFocus reserves the right to change this Privacy Policy from time to time, in order to comply with laws, regulations, changes in our business, and changes in industry standards including security. Your use of our Services and any disputes arising from it, is subject to this Privacy Policy as well as our Terms and Conditions (click here).

If we make material changes, we will provide thirty (30) days notice via email, through the Services, or through mutually agreed channel of communication.

If you disagree with the changes or any part of this Privacy Policy, you should deactivate your Services account immediately and refrain from using our Services.

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