Last updated: May 8, 2020
Titus Inc., (“Titus”), owns and sells classification software focused on data security. Customers may be provided access to interactive websites, mobile applications and other services including but not limited to hosted environments for Titus software solutions, emails, newsletters, chat functionality, online forums and communities, (collectively called the “Services”).
This Policy covers information collected by Titus through various means of communication including but not limited to the following websites and mobile applications:
- Titus Customer Support Portal
- Titus Field Portal
- Titus SaaS EnvironmentCategories of Information
Categories of Information
We may have access to: your personal details (e.g., your name); your contact details (e.g., your physical address and your email address); purchase details; details of your employer; information about your interactions with our content, advertising or sales and customer support teams; and any views or opinions you provide to us.
We may also have access to information about you from your use of our Services (e.g., type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.
“Personal Information” means information about any individual, or from which any individual is directly or indirectly identifiable.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, including but not limited to collection, recording, organization, structuring, storage, retrieval, use, disclosure by transmission, erasure or destruction.
We may Process the following categories of Personal Information about you:
- Personal details: your name; username or log in details; password (where applicable).
- Demographic details: salutation; job title, company information, and language preferences.
- Contact details: mailing address(s); phone and/or mobile number(s); email address(s).
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g. email opt-in).
- Location information: location data that describes the geographic location of your device (“Location Data”).
- Employer details: where you interact with us as an employee of a company, the contact information of your employer (including name, address, telephone number and email address) to the extent applicable.
- Views and opinions: any views and opinions that you choose to send, or publicly post about Titus on social media platforms or in the Services, including on websites, forums, and communities.
We also collect other kinds of information from you or other sources, referred to as “Other Information” in this Policy, which may include but is not limited to:
Information about your use of the Services, such as usage data.
Information about the approximate physical location (for example, the city or postal code level) of a computer or device derived from the IP address of such computer or device.
- Internet Protocol (“IP”) address assigned to your device when the Internet is accessed.
- Log files, which may include IP addresses, browser details, ISP details, operating system, date/time indicators.
- Chat transcript data from live chat sessions.
- Mobile analytics of Titus mobile applications on your phone.
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.
How We Collect or Create Information
We may collect or obtain User Information about you: directly from you (e.g., if you contact us); in the course of our interactions with you (e.g., if you interact with customer support, sales or another team); when you make your Personal Information public (e.g., if you make a public post about us on social media); when you download or use any of our Services; or when you interact with any third party content on the Services. We may also receive User Information about you from third parties (e.g., social network sites). We may also create User Information about you, such as records of your interactions with us. Titus is not responsible for
Personal Information you volunteer about yourself in public areas of the Services.
This Policy does not cover the practices of third parties who may provide information about you to Titus.
Collection of User Information
We may collect User Information about you from the following sources:
Data you provide
We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, webinars or other communications; register any part of the Services; participate in surveys; contact us by any means; purchase a software license, subscription, maintenance or professional services; or when you provide us with your business information at tradeshows, etc.).
We may collect or obtain your Personal Information in the ordinary course of our interaction with you (e.g., if you interact with our customer support team, or via our chat functionality).
Data you make public
We may collect or obtain your Personal Information that you make public, including via social media (e.g., from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
We may collect or obtain your Personal Information when you visit, download, or use any part of our Service.
Content and advertising information
If you choose to interact with any third-party content on the Services, we may receive User Information about you from the relevant third party (e.g, mobile information).
Third party information
We may collect or obtain your Personal Information from third parties who provide it to us. This may include telephone or direct mail efforts; from customers, vendors, partners, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, hosting services, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites (e.g., Facebook, Twitter, LinkedIn, etc.). Please note that Titus is not responsible for the information you volunteer about yourself in the discussions in public areas of the Services, or information that you choose to make public where the Services allow users to upload or post content. Users should not post Personal Information in this fashion.
When applying for a job with Titus, information you provide is used to process, respond and assess your application for potential current or future career opportunities.
Creation of User Information
We may also create User Information about you, such as records of your interactions with us and details of your purchase history.
Purposes for Which We May Process Your Information
Processing User Information may include but is not limited to: providing Services to you; communicating with you; analyzing user engagement and purchase activity; marketing our products and services; conducting surveys; and maintaining compliance with applicable laws.
The purposes for which we may Process User Information, subject to applicable law, include:
Providing Services to You
Providing the Services including:
- Communicating and responding to requests and inquiries
- Delivering functionality and management on our sites
- Completing and processing purchase orders and transactions with customers, vendors and business partners
- Offering interactive chat areas, forums and communities
- Analyzing, developing and improving the use and performance of our sites, products and services
- Management of your account
- Professional services engagements
- Customer support
communicating with you for the purposes of obtaining feedback on your experience, products and Services.
Communicating with you via any means regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information; and obtaining and verifying opt-in consent where required.
Advertising and Marketing
providing advertising and marketing of products and Services for prospects and customers. You may unsubscribe for free or opt out of these marketing communications at any time by following the unsubscribe instructions included in each email or by sending your name and address to email@example.com. We may continue to contact you regarding the Services.
Titus reserves the right to access and disclose any information, data, graphics, video, sound, files and other content created by, provided by, or accessed by you (“Content”) in order to comply with applicable laws and lawful government requests.
Cookies and Similar Technologies
IP addresses of visitors, and other related information including browser type, operating system, requested pages, and time spent on our website may be Processed. We use this information to help us understand website activity, and to monitor and improve our website.
What Information We Disclose to Third Parties
We may disclose your User Information to: legal and regulatory authorities; external advisors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising or content used on the Services.
We may also engage third parties for the purpose of recognizing our users or delivering content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: collect information directly from your device, and collection information about your browser or operating system, and place or recognize a unique cookie on your browser.
International Transfers of Information
We may transfer your Personal Information to Titus locations in other countries. These countries may have different data protection laws and regulations. Titus will Process Personal Information when we receive your data in accordance with this Policy.
If you are a European individual with a privacy related complaint, concern or question about Titus’ privacy practices, please contact our Data Protection Officer at dpo@Titus.com , and we will respond within a reasonable time after receiving your request.
Titus has implemented security measures to protect your User Information.
Transmission of information via the internet is not completely secure. Titus cannot guarantee the security of your data transmitted to us using the internet. Any transmission of data is at your own risk and you are responsible for ensuring that Personal Information is sent securely.
We take reasonable steps to ensure that your User Information is accurate and, where necessary, kept up to date. We may contact you to ensure User Information is up to date and accurate.
We take reasonable steps to ensure that your User Information that we Process is limited to that reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or to access and use products and the Services.
Titus retains information for such periods as it believes it is useful, or as may be required for the duration of a service period contract or longer as required by applicable laws or regulations.
Information provided to Titus is stored within internal systems in Canada and the United States.
By providing services, information may be transferred to Titus employees operating outside of Canada who may be engaged in maintenance and support, and professional services including product demonstrations and deployment.
Titus has implemented appropriate technical, physical and organizational measures designed to protect information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access.
What Can I Do to Control My Information?
You can directly take steps to change your preferences for newsletters and online behavioral advertising as outlined in this section.
If you are an EU resident, you may have certain rights including but not limited to: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
You may directly take steps to change your preferences as follows:
At any time, you can opt out or unsubscribe to any marketing emails at any time by following the instructions on emails you receive. Please allow ten to fifteen business days for changes to take effect. If you opt out to receive marketing materials, you may still be contacted for other business purposes.
GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case some of the functionality of the Services may not be available. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, or erasure of your own information.
Requests regarding your information must be submitted by contacting us using the information below. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
If you have any questions or concerns regarding this Policy, you may contact us at the addresses set out below or by emailing Stephane Charbonneau, our Data Protection Officer at firstname.lastname@example.org.
Titus’ Corporate Headquarters are located at:
Attention: Legal Department
343 Preston Street, Suite 800
Ottawa, ON, K1S1N4
Our Data Protection Officer may be contacted at email@example.com.
If you are an EU resident, you may contact our Data Protection Officer directly firstname.lastname@example.org.
Changes to this Policy
Titus may change this Policy from time to time, to reflect changes to our data privacy policies and collection of personal information practices. The latest Privacy Statement will be posted on this Website. We strongly encourage you to check this Privacy Statement to ensure that you are aware of the most recent version.