Privacy Policy | Multireach

1. Introduction

This Privacy Policy sets out how Multireach Technology Inc. (“Multireach”, “we”, “us” or “our”) collects and processes personal data, and explains your rights in relation to your personal data.

Multireach Technology Inc. is incorporated in Alberta, Canada, with its registered office at 58 Carringsby Way NW, Calgary, Alberta T3P 1T4, Canada. Multireach provides customer relationship management and sales software to business customers worldwide.

This Privacy Policy affects your legal rights and obligations, so please read it carefully. If you do not wish for us to process your personal data as set out in this Privacy Policy, please do not provide your personal data to us, and ask your employer to ensure that they do not do so. By using our services, you agree to the collection, use, disclosure and procedures this Privacy Policy describes. Your use of our platform is also subject to our Terms of Private Beta.

We may update this Privacy Policy from time to time, in particular to reflect changes in applicable law. Where changes substantially affect your rights or obligations, we will take reasonable measures to notify you. Otherwise, you are responsible for reviewing this Privacy Policy so that you are aware of any changes to it.

2. Our role in relation to personal data

We determine the purposes and means of processing personal data, and are accountable for it, where you:

Provide personal data to us directly, including by requesting access to the Private Beta, corresponding with us, or subscribing to receive communications from us (section 3.1);
Visit our website or use our services, in which case we automatically collect information about that use (section 3.2);
Connect a third party service to our services (section 3.3); or
Are an individual whose business contact details we obtain from a data supplier (section 3.4).

We process personal data on a customer’s behalf, and only on that customer’s instructions, where:

A customer uploads or enters personal data relating to you into their workspace; or
A customer connects a Google account and we receive mail and contact data through it (section 4).

Where we process personal data on a customer’s behalf, that customer determines the purposes of the processing. Requests relating to that data should be directed to the relevant customer. Where you contact us directly in respect of such data, we will notify that customer as soon as reasonably practicable and assist them in responding to you.

3. What personal data we collect and from whom

By personal data we mean any information that identifies you or relates to an identifiable individual, including your name, email address, telephone number, job title, employer, location and IP address.

We do not seek to collect special categories of personal data, being data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, or data concerning health, sex life or sexual orientation. Our services are not designed to hold such data.

3.1 Data you provide to us

We collect personal data from you where you:

Request access to the Private Beta;
Register for an account and sign in;
Create a workspace or invite colleagues to a workspace;
Enter or upload records relating to companies and individuals;
Subscribe to receive communications from us; or
Otherwise contact us, including with queries, comments, complaints or support requests.

Personal data you provide may include your name, email address, workspace name, the size range of your team, how you came to hear of us, and any information you choose to submit in free text fields. Records you enter may include names, email addresses, telephone numbers, job titles, seniority, department, professional profile links, locations, company details, deal information, notes and tasks.

The request for access to the Private Beta is hosted on a third party form service. Your response is collected by that service and transmitted to us.

Certain personal data is required in order for us to provide our services. Where you do not provide it, we may be unable to provide the services to you.

All personal data you provide must be true, complete and accurate. Where you provide personal data relating to another individual, you confirm that you are entitled to do so.

3.2 Data we collect automatically

When you use our website or our services, we automatically collect and store information about your device and your activity. This may include:

Technical information about your device, such as device type, browser and operating system;
Your preferences and settings, such as time zone and language;
Information about your use of our website and services, including the pages and features you access, referring website, and the dates and times of your visits;
Location information inferred from your IP address; and
Information about our communications with you, including whether emails were delivered, opened, or interacted with.

We use cookies and similar technologies for these purposes. Cookies that are not strictly necessary are set only where you have consented to them, and you may withdraw that consent at any time. Declining does not affect your ability to use our services.

3.3 Data we collect from connected third party services

Where you choose to connect a third party service to our services, we will collect and store data from that service. Connection is optional and our services operate without it. Data collected may include your profile with that service, your name, your email address, and, where you connect a Google account, your mail messages and contacts. Section 4 applies to data received from connected Google services.

3.4 Data we receive from others

Your employer or a colleague may provide personal data relating to you, including your work email address, so that you may be given access to a workspace. Where a third party provides us with a personal rather than a business email address for you, you should notify us and we will remove it.

We obtain business contact data from third party data suppliers in order to identify companies and individuals relevant to our customers’ businesses. Such data may include name, employer, job title, business email address, business telephone number and publicly available professional profile information. Section 12 sets out your rights in relation to this data, including your right to object.

We may also receive personal data relating to you from our payment provider or our security service providers, in particular in connection with any misuse of our services.

Data received from connected Google services is not disclosed to data suppliers and is not used to compile, verify or enrich any third party database.

4. Using data from connected Google Services

Where you choose to connect a Google account, we will access your Google user data, which may include your mail messages and your contacts, in order to associate correspondence with the relevant company or contact record, maintain contact details, and surface records requiring attention. Google presents the scope of access requested before you grant it.

We handle data received from connected Google services only on your instructions and for the purposes you direct. We do not use it for our own purposes.

Additional limits on use of your Google user data. Notwithstanding anything else in this Privacy Policy, where you provide us with access to data from connected Google services, our use of that data is subject to the following restrictions:

We will only use access to data from a connected Google service to provide or improve user facing features that are prominent in the Multireach user interface.
We will not transfer this data to others unless doing so is necessary to provide or improve features that are prominent in the user interface, to comply with applicable law, or as part of a merger, acquisition or sale of assets.
We will never use Google user data for serving advertisements, including retargeting, personalised or interest based advertising.
We will not transfer or sell Google user data to advertising platforms, data brokers, enrichment providers or information resellers.
We will not retain, use or transfer Google user data to develop, improve or train any machine learning or artificial intelligence model, other than a model personalised to you for a user facing feature you are using.
We will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and then only where the data has been aggregated and anonymised.
Multireach’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

You may disconnect a connected Google account at any time within our services or through your Google account security settings, and may request deletion of data already received.

We collect, use and disclose personal data with your consent, which may be express or implied from the circumstances and the purpose for which the data was provided, except where applicable law permits or requires us to process personal data without consent.

We rely on grounds other than consent, to the extent applicable law permits, where processing is:

Necessary to perform a contract with you or to take steps at your request before entering into a contract;
Necessary for our legitimate business interests, including securing our services, preventing fraud and abuse, understanding how our services are used, maintaining business records, obtaining professional advice, establishing or defending legal claims, and obtaining business contact data as described in section 3.4, provided those interests are not overridden by your rights and interests; or
Necessary for compliance with a legal obligation to which we are subject.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide our services to you.

6. How we use personal data

We use personal data:

To provide, maintain, secure and improve our services;
To create and administer accounts and workspaces;
To assess and respond to requests for access to the Private Beta;
To identify companies and individuals relevant to our customers’ businesses;
To provide AI Features, as described in section 8;
To communicate with you regarding our services, including service, security and administrative messages;
To provide marketing communications in accordance with section 7;
To respond to your enquiries, comments, complaints and support requests;
To detect, prevent and address fraud, abuse and security incidents;
To process payments, once our services are provided on a paid basis;
To generate anonymised or aggregated information that does not identify any individual, which we may use for any lawful purpose; and
To comply with applicable law and to establish, exercise or defend legal claims.

7. Marketing communications

Where you have requested information from us, used our services, or have not opted out of receiving marketing, we may send you marketing communications.

You may ask us to stop sending marketing communications at any time by following the opt out link in any such communication or by contacting us. Where you opt out, this does not apply to service, transactional, security or administrative communications relating to your account or your use of our services, which do not require consent.

Where you ask to be removed from our marketing lists, we will retain a record of your email address for the sole purpose of ensuring that we do not send you further marketing.

8. Artificial intelligence services

Certain features of our services use artificial intelligence to research companies and to assist in drafting communications (“AI Features”). Where you use an AI Feature, the relevant content is transmitted to our AI service provider for processing and the output is returned to you.

Our AI service provider is contractually prohibited from using content submitted through our services to train its models. We do not use customer content to train any model.

Output generated by AI Features may be inaccurate. The Terms of Private Beta set out the responsibilities that apply to your use of AI Features and any Output.

We may share your personal data with third parties in the following circumstances:

Service providers working on our behalf. We share personal data with service providers, sub-contractors and agents appointed to perform functions on our behalf and in accordance with our instructions, including hosting, database, authentication, email delivery, customer support, product analytics and payment providers. Such providers are bound by contractual obligations to process personal data only as instructed and to maintain appropriate safeguards.
AI service providers. We disclose content submitted through AI Features to our AI service provider for the purposes described in section 8.
Analytics partners. We use analytics services to collect and process usage data as described in section 3.2.
Services you connect. Where you connect a third party service, we transmit the information necessary to establish and maintain that connection.
Professional advisers. We share personal data with our professional advisers, including lawyers, accountants and auditors, where required in order to obtain advice or services.
Legal. We may disclose personal data where required to do so by law, or in the good faith belief that such action is necessary to comply with applicable law, respond to lawful requests from public authorities, take precautions against liability, protect against fraudulent, abusive or unlawful use of our services, investigate and defend against claims, protect the security or integrity of our services, or protect our rights, property or safety or those of others.
Merger or corporate event. We may disclose or transfer personal data to an acquirer, investor, successor or assignee as part of any merger, acquisition, financing, sale of assets or similar transaction, or in the event of insolvency or receivership.
With your consent. We may disclose personal data with your permission.

We do not sell personal data and we do not share personal data for advertising purposes.

10. Where we hold and process personal data

We are established in Canada. Some or all of your personal data may be stored or processed outside Canada, including in the United States and other jurisdictions in which our service providers operate. While personal data is located in another jurisdiction, it may be accessible to the courts, law enforcement and national security authorities of that jurisdiction.

Where personal data is transferred to a jurisdiction that does not provide an equivalent standard of protection, we put in place contractual and other measures intended to provide a comparable level of protection, including the transfer mechanisms recognised under applicable law. You may contact us at the address in section 16 for further information on the mechanism applicable to a particular transfer.

11. Security

We make reasonable efforts to protect personal data by means of appropriate technical and organisational measures designed to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Notwithstanding the above, you acknowledge that no system can be completely secure. Although we take these steps, we do not warrant that personal data will at all times remain secure.

Where a breach of security involving personal data creates a real risk of significant harm to an individual, we will notify the Office of the Information and Privacy Commissioner of Alberta and affected individuals without unreasonable delay, and will notify other authorities where applicable law requires.

12. Your rights

Subject to the exceptions and limitations provided by applicable law, you may:

Access. Request confirmation of whether we hold personal data about you, a copy of that data, and information about how it is processed.
Rectification. Request that inaccurate or incomplete personal data be corrected.
Deletion. Request that personal data be deleted or anonymised.
Restriction and objection. Request that we restrict processing of your personal data, or object to processing. Where you object to the use of your personal data for marketing purposes or to being contacted, we will cease such use.
Withdrawal of consent. Withdraw consent previously given, at any time and free of charge.
Portability. Request a copy of personal data you have provided to us in a portable form, or that it be transmitted to another provider.
Complaint. Lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.

You may exercise these rights by contacting us at the address set out in section 16. We may require confirmation of your identity before acting on a request. We do not charge a fee for responding to a request, and you will not be treated differently for making one.

Where we process personal data on a customer’s behalf, section 2 applies. You will need to contact that customer directly if you wish to exercise your rights in relation to that data. If you do contact us directly, we will notify that customer as soon as reasonably practicable and assist them in fulfilling their obligations to you.

If you have any complaint in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We will review and investigate your complaint and try to get back to you within a reasonable time. You may also contact the Office of the Information and Privacy Commissioner of Alberta, the Office of the Privacy Commissioner of Canada, or, if you are based elsewhere, your local data protection authority.

13. Retention of personal data

We will retain personal data in accordance with applicable law.

Where we hold personal data about you because you are a user of our services or an employee of a customer, we will retain that personal data until we no longer work with you or your employer, except where we are required to retain personal data for a particular period in order to comply with legal, statutory or accounting requirements.

Where we hold personal data because a customer has uploaded it to our services or connected a service through which we receive it, we will retain it in accordance with that customer’s instructions and the Terms of Private Beta.

In some circumstances you can ask us to delete your personal data. See “Your rights” above.

In some circumstances we will anonymise your personal data so that it can no longer be associated with you, in which case we may use that information indefinitely without further notice to you.

14. Children’s privacy

We do not knowingly collect, maintain or use personal data from children under 18 years of age, and no part of our services is directed to children. If you become aware that a child has provided personal data to us, you may notify us at the address in section 16 and we will delete it.

15. Third party platforms

Our services and our website may contain links to, or connections with, third party websites, platforms and applications. Enabling such links or connections may allow third parties to collect or share data about you. We do not control third party platforms and are not responsible for their privacy practices. We encourage you to read the privacy policy of every third party platform you use.

16. How to contact us

You may contact us with any questions or comments regarding your personal data, this Privacy Policy, or any other privacy related enquiry:

Multireach Technology Inc.
58 Carringsby Way NW, Calgary, Alberta T3P 1T4, Canada
infosec@multireach.co