Privacy Policy

Translucent General Privacy Statement

Your Privacy Rights

Translucent Computing Inc. (“Translucent”) is governed by the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. The law gives you rights concerning the privacy of your personal information.

As a technology and business intelligence company that provides services for institutions, our customers may be subject to other legislation that protects personal information. Translucent complies with the privacy requirements of its customers upon notice of the relevant legislation and requirements. Translucent may have the role of a recipient of personal information or of an agent for its customers, depending on the circumstances.

Translucent is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this privacy statement, and trained our staff about our policies and practices.

The language used in this privacy statement is based on Canadian legal terms.  Personal information is defined in PIPEDA as “information about an identifiable individual”. 

Translucent respects that potentially identifiable information (i.e., that could be used with other information to identify an individual) may be protected under laws applicable to Translucent’s customers or users.

Why do we need personal information?

Translucent collects or has access to the following data that may include personal information:

User information – Translucent may collect personal contact information, such as name, physical or electronic address, and phone number. User information may include a unique identifier created to identify a user of a Translucent product, and any data entered by, related to or that may identify a user.

Financial information – Translucent may collect financial information such as billing name and address, credit card number, and the number of employees within a customer organization that will be using the services, apps or other products.

Employee information – Translucent collects personal information from job applicants and from its employees such as resumes, curriculum vitae, and information to manage its human resources.

Customer information – In providing services to its customers, Translucent may collect personal information or access personal information that its customers have collected as needed to develop an app or provide services.

Maintenance access to Customer information – In providing maintenance and improvements to a platform, app or other product, Translucent may have access to personal information collected by its customers or by their users.

Cookies and website management information – In managing its website, Translucent may use cookies that identify your browser.

How do we collect your personal information?

Our methods of collection of personal information and the specific information collected within an app are specified in each privacy policy addendum; each one named for a product that Translucent has made generally available.  For services and for applications or other products developed under a contract with a customer, the contract may contain such specifics and the requirements imposed by the customer.

Consent is typically requested in the application or, if part of a service agreement, through a consent process agreed-upon with the customer.

What will we use your information for?  Who in our organization will see or use your information?

Personal information is used as applicable to provide services, manage payments, or manage our human resources.  Certain aggregate information is used to develop better products.  Specific information and uses are more particularly described in the applicable privacy policy addendum, or if part of a service agreement, in the applicable service agreement.

Who else will see or use your personal information?

As more particularly described in each privacy policy addendum, where the data is hosted by another entity, that entity may have access to your personal information.  

Under certain circumstances, Translucent will disclose your personal information:

  • when we are required or authorized by law to do so, for example if a court issues a subpoena;
  • when you have consented to the disclosure;
  • when the services we are providing to you requires us give your information to third parties your consent will be implied, unless you tell us otherwise;
  • where it is necessary to establish or collect fees;
  • if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our Privacy Policy;
  • to the resulting entity, if we are involved in a merger or acquisition of our company and the third party has agreed to keep it confidential;
  • if the information is Publicly Available Personal Information, as it is defined under the Personal Information Protection and Electronic Documents Act.

Translucent does not otherwise provide your personal information to third parties without consent.

How can you update your information or ask us to update your information?  What about correcting errors?

You may ask for access to any personal information we hold about you.  If permitted under the law, we may charge reasonable fees for archive, retrieval and redacting costs.

If we hold information about you and you can establish that it is not accurate, complete and up-to-date, we will take reasonable steps to correct it.

Your rights to access your personal information are not absolute. We may deny access when:

  • it is required or authorized by law;
  • to do so would reveal confidential commercial information, and the personal information cannot be severed from the record;
  • to do so could reasonably be expected to threaten the life or security of another individual, and the personal information cannot be severed from the record; or
  • the information was generated in the course of a formal dispute resolution process.

If we deny your request for access to, or refuse a request to correct information, we will explain why. 

If you have any questions, or wish to access your personal information, please write to our Privacy Officer at, 1 Yonge Street, Suite 1801, Toronto, Ontario, M5E1W7

.

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at 112 Kent Street, Ottawa Ontario, K1A 1H3, 1.800.282.1376.

How will we store your information and keep personal information secure?

Translucent uses a variety of security safeguards in its products and services.  To maximize such security, users are encouraged to create strong passwords and to refrain from sharing passwords.  Further details about storage and security related to personal information is available in each privacy addendum.

When and how will we make changes to this privacy statement?

Translucent will update its website from time to time by adding a privacy addendum.  Translucent may change a privacy addendum or this privacy statement from time to time.  You are encouraged to check this privacy statement from time to time to ensure that you are aware of the most up to date version.