A. Changes to this Privacy Notice
- If we are making a change to this Privacy Notice related to the disclosure of your personal information to additional third parties or to allow for additional uses by us of your personal information we will ask you for your explicit consent for such change.
B. A Brief Comment on Global Privacy Laws and What Law You Are Agreeing to Use
- Just as different individuals have different views over their personal information, what they are concerned about, how they protect it, and who they share it with, so have different governments enacted a variety of laws that touch on personal information and how it should be managed by entities other than yourself. Naturally these laws are different, inconsistent, and have varying degrees of applicability to your use of our Website. They also do not easily adapt to the reality of a global internet where you may live in any country in the world, My CV Creator is based in Nigeria, and we may host our actual application and store your personal information in Nigeria, the United States, a member of the European Union, or some other country using third parties to provide various services to us to provide the Website and its functionality.
- To make easier for both of us to understand our obligations and rights, by agreeing to this Privacy Notice you are agreeing that we both are adopting the Canadian laws in the Province of British Columbia that are applicable to My CV Creator to govern this Privacy Notice and your rights related to the policies and practices that are described in it, regardless of what country you live in or what country My CV Creator, or any third party providing services to My CV Creator, uses to store, process, gather, host, or any of the other actions taken related to your personal information My CV Creator obtains as a result of your use of the Website. If you are a resident in the EU then you also have additional rights under EU law, which are set out in more detail below.
- By using our service you are explicitly agreeing to the transfer of your personal information from your home country to a third country or countries which may include the United States and Canada.
- By using our service you are agreeing that My CV Creator may process your information using third party sub-processors located in any country so long as My CV Creator ensures that those third party sub-processors abide by our commitment to you and My CV Creator is responsible to you if they break their obligations in this Privacy Notice.
- You should be aware that when your information is located or stored in a particular jurisdiction (for example the United States), the laws of that jurisdiction will apply to the ability of that government and law enforcement to access your personal information without your consent. The laws of that jurisdiction and the protections related to your personal information may not be as rigorous as the laws in the country you live in.
C. What Does Canadian Law Require My CV Creator to Do?
- Canadian law governs the collection, use and disclosure of personal information in a manner that recognizes a individuals' right of privacy with respect to their personal information.
- Canada has two levels of government, Federal and Provincial. Federal privacy law applies unless a Province has enacted equivalent privacy law. My CV Creator is based in British Columbia which has enacted the Personal Information Privacy Act (PIPA) which sets out rules and principles for the management of personal information by commercial organizations. Because My CV Creator is based in British Columbia, PIPA will apply to this Privacy Notice.
- PIPA provides certain fundamental principles that apply to the collection, use and disclosure of personal information. One of the most significant, is that your personal information generally cannot be collected, used or disclosed without your consent. It also allows you to find out why your personal information is being collected, how it is being used, where it's being stored and to whom it's disclosed. It requires the use of appropriate safeguards to secure your personal information. It also grants you access to your personal information and provides mechanisms for ensuring compliance. It also provides for the circumstances where your information may be disclosed without your consent (things like law enforcement, to complete a contractual request, or to protect life).
- My CV Creator does not collect, use or disclose your personal information without your consent except where required or allowed by law.
D. What Information Does My CV Creator Collect?
- We collect two types of information when you interact with the Website: personal information (Personal Information) and everything else. Personal Information is information that relates to an identifiable person and includes information which can be used by itself or in combination with other information to identify you. Some Personal Information is obvious such as your government identification number, however other information that is Personal Information is somewhat subtle. As you add information together you can create a package of information that will identify someone and so together would be considered Personal Information. For example the following information: Law Degree, 2001, Yale, employed at Seyfarth Shaw, born in Cleveland, and works in Chicago, may not individually be Personal Information, but certainly taken as a whole would identify someone and therefore would be Personal Information. Because of this we treat all of your resume information as Personal Information.
- The information that is not Personal Information (everything else) is information that is not associated with any individual and mostly consists of aggregated usage information, anonymized data about web site pages visited, technical information like the internet browser used, os version used, screen resolution etc. that we use to operate and improve the Website.
- If you are paying us for use of certain features of the Website, we will use a third party payment processor (Payment Service) to collect the payments. When making a payment you will be directed to a web page hosted and controlled by the Payment Service. Any Personal Information you provide the Payment Service is being provided to the Payment Service and not My CV Creator and would be subject to the Privacy Notice of the Payment Service alone.
- You can visit this site without telling us who you are and without providing us with any information about yourself. However, certain anonymous information may be collected automatically as you navigate through the site or use our services, including usage details, sites visited prior to visiting our site, IP addresses and information collected through cookies Pixel Tags, and other tracking technologies. Some of this information would become your Personal Information were you to subsequently register with us.
- We and our service providers may also use so-called pixel tags, web beacons, clear GIFs or similar means (collectively, Pixel Tags) in connection with some Website pages and HTML-formatted email messages to, among other things, compile aggregate statistics about Website usage and response rates and to facilitate our advertising of our services at other websites you may visit. A Pixel Tag is an electronic image, often a single pixel (11), that is ordinarily not visible to a Website visitor and may be associated with Cookies on the visitor's computer. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, to help determine the effectiveness of promotional or advertising campaigns, and to show you targeted advertising related to our services when you visit other websites. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.
F. How Does My CV Creator Use Information?
- We use the information you provide to: 1.1 Fulfil the purpose for which you provided the information to us. For example: to complete your purchase, build your profile, have your credentials certified, have your resume reviewed by a career management professional, or publish your resume online. This type of use also covers your instructions to us to provide your information to a third party you identify to us. 1.2. We may select your public resume (which you have chosen to make public) as an example resume to show to other users of our Website for educational purposes. 1.3. To facilitate our communications either through the Website or by email to the email address you provide us. Note that (unless you are an EU Resident) by providing us with your email address you have explicitly consented to the receipt of email messages from us, related to your use of the Website and marketing offers we may make to you. While you can unsubscribe to marketing emails, you cannot opt out of receiving emails related to your use of the Website. 1.4. If you choose to do so, you may receive messages from other Website users relating to areas of interest that you select. We do not provide your Personal Information to such other users rather, the message from the user is sent to a group of people, including you, based on demographic information and the areas of interest you and the others in the group have selected, and you can decide whether to respond to the message or delete it. 1.5. To send targeted advertising to you related to our services when you visit other websites. Note that we may not know who you are when we advertise as you may have only visited our website and not registered on it. 1.6. To operate our business. This means such items as data analysis, audits, order fulfilment tracking, enhancing our web site, improving our services and identifying usage trends.
- The above sets out the lawful basis on which we process your personal information.
G. How is Your Personal Information Disclosed?
- We Don't Commercialize your Information. We do not sell, trade, rent, or license the personal information you provide us, whether to marketing list makers, advertisers, or anyone else.
- To Our Third Party Service Providers. We work with third parties to provide the various services and features of the Website and the other services that we provide. This includes: hosting, data processing, data analysis, order fulfilment, career management, and other services of an administrative nature. We provide your Personal Information with such third parties in order to provide the Website and services. As mentioned above, those third parties may exist or provide the services in any country and we have no restriction on what country we transfer your information to for the processing, recognizing that we are responsible for our third party service providers we transfer information to comply with this Privacy Notice.
- To Third Parties on Your Request. You can instruct us to transfer your information to a third party or make it available to third parties because of the settings you have chosen in your use of the Website, for example publishing your resume as a webpage, either public or private where you selectively share the URL. Note that the default account settings maintain your information as a private webpage. If you publish your resume freely on the web we cannot restrict what third parties will have access to it. It also may be cached in various online services even if you change or delete it. We have no control over how third parties (i) you instruct us to transfer information to, or (ii) who access your information because of your account settings, deal with your information. Once the information in in the hands of such third parties this Privacy Notice no longer applies and we are not responsible for the actions of such third parties.
- To Third Parties Related to Our Business. We can transfer your information to any third party in the event of a reorganization, merger, sales, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. The third party that we transfer the information to will be responsible to you to process your information in accordance with this Privacy Notice once that transfer is made. We can also disclose your information to any third party advisors (accountants, auditors, lawyers, investment bankers, lenders, etc.) related to such actions or who are engaged to assist us in the usual operation of our business. We are responsible to ensure that third party advisors act consistently with this Privacy Notice.
- To Third Parties in Accordance with Laws and Rights. We can transfer your information to a third party (a) as authorized in applicable law; (b) to comply with legal process; (c) to respond to a government or regulatory request; (d) to enforce the Terms of Service of our Website; (e) to protect our operations; (f) to protect the rights, privacy, safety, or property of us, you, or others; and (g) to permit us to pursue legal remedies or limit the damages we may sustain.
H. Links to Third Party sites
- Our Website may provide you with hyper-links to third party sites. These third party sites are not under our control. We are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on our Website does not imply endorsement of the linked site by us. If you provide any of your personal information to such third party website that information will be collected and controlled by the privacy notice of that third party and not by this Privacy Notice.
- One of our obligations to you under Canadian Law is to provide reasonable security over your Personal Information we process. We have put in place an information security program to manage how we secure your information. This program covers such areas as: 1.1. How we design our Website for security; 1.2. How we test our Website to discover security flaws; 1.3. How we host our product to limit vulnerabilities including: processes and procedures, server hardening, and operating system patching; 1.4. How we hire and train our staff, contractually impose confidentiality obligations on them, and restrict their access to your information to only what is necessary as part of their job; 1.5. How we interact with third parties who are providing services to us including the terms of the contracts we have with them; 1.6. How our administrative processes are set up for such things as password resets and verifying who we are communicating with; 1.7. How we respond to suspicious events and manage an incident should one happen; and 1.8. How we plan for disasters and how we continue to operate should one occur.
- Unfortunately, no information security program can absolutely guarantee that an unauthorized person will not obtain access to your information. Our sole obligation to you is to perform our information security program and update it in accordance with good industry practice. v3. Remember that the main way that unauthorized third parties obtain access to personal information is by obtaining access credentials. So please use a unique, strong password for your account on the Website. Also, be aware that phishing emails often install software to enable the obtaining of your user name and passwords to the various sites you use, including our Website. You need to be aware when you use the internet. We will never ask you to confirm your user id and password by email or send you an embedded link to our Website. If you receive such an email, we ask that you contact our Privacy Officer so we are informed and we can take appropriate actions to inform all of our users.
- Emails should not be considered secure so keep this in consideration when sending us email.
- Should we discover an unauthorized third party obtain access to any of your personal information we will inform you once we confirm that this has occurred.
J. Accessing and Changing Your Information
- We will take reasonable steps to ensure that your Personal Information is as accurate, complete and up-to-date as is appropriate for its purposes.
- You have full control over accessing and changing most of your Personal Information directly through the Website. For your Personal Information that is not directly accessible by you (mostly related to your account administration) you may contact us by contacting our Privacy Officer as described below. Upon request made in writing, we will inform you of the existence, use and disclosure of your Personal Information, at minimal or no cost to you, in accordance with processes and procedures that we have put in place for such requests. If you are unsure whether we have a record containing your information and would like to confirm what Information we have, please contact our Privacy Officer as set forth below, identifying all email addresses which you may have given us. If there is a cost involved at all, we will inform you at that time. We will provide access to the executor of your estate should you die upon proof of both your death and the appointment (and identity) of the executor which is reasonable to us.
- We may require additional information from you in order to verify your identity following an access request. Such personal information will only be used for the purpose of identity verification and will itself be subject to protection under the terms of this Privacy Notice. We will respond to all requests for access within 30 days of receipt or as otherwise required or permitted by law.
- In some circumstances, we may not be able to provide access to all of the Information that we hold about you. We may not provide access to Information if doing so would likely reveal Information about a third party, could be expected to threaten the life or security of an individual, reveal confidential commercial information, if the Information is protected by a legally recognized privilege, if it was created as part of a settlement or dispute resolution process, or if it was collected in relation to the investigation of a breach of an agreement or a contravention of law. We will provide reasons to you if it refuses an access request.
K. Retention of Your Information
- You may choose to delete your information from your account at any time. When you do this we will retain your information solely to enable you to change your mind and restore your account. None of your information will be accessible by you or the public. Deleting your information will not remove information we use to administer your account which we will retain until we delete it in accordance with our internal record keeping policy. We will also delete your information in accordance with our policies related to inactive accounts.
- When we delete your information we will do so in a secure manner in accordance with good industry practices.
L. Your legal rights
- Under certain circumstances, you have rights under data protection laws in relation to your personal information. You may have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
- If you wish to exercise any of the rights set out above, please contact us using the details set out below.
- You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
M. Contacting Us
- If you have a question or concern about this Privacy Notice or how your personal information is being handled by My CV Creator please contact us using the details below. Please make any communication to the attention of Privacy Officer and we will acknowledge, record, investigate, and respond to you in accordance with applicable law and this Privacy Notice.
- Remember that email is not secure so you should be thoughtful about including any Personal Information in your emails to us.
- Our Privacy Officer's address is: Privacy Officer My CV Creator Inc. #200 - 13799 Commerce Parkway Vancouver, BC V6V 2N9 Canada Email: [email protected]