Privacy Policy

ProgramCA ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website programca.net, use our services, or interact with us in any way.

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws. By using our services, you consent to the practices described in this policy.

1. Information We Collect

1.1 Personal Information You Provide

We collect information that you voluntarily provide to us, including:

• Contact Information: Name, email address, phone number, company name, and job title when you fill out forms or contact us
• Account Information: Login credentials and profile information if you create an account
• Communication Data: Content of emails, messages, and other communications you send to us
• Payment Information: Billing address and payment details (processed through secure third-party payment processors)
• Project Information: Business requirements, technical specifications, and other information related to your projects

1.2 Information Collected Automatically

When you visit our website, we automatically collect certain information:

• Device Information: Browser type, operating system, device type, and unique device identifiers
• Usage Data: Pages visited, time spent on pages, click patterns, and navigation paths
• Location Data: General geographic location based on IP address
• Cookies and Tracking: Information collected through cookies, web beacons, and similar technologies

1.3 Information from Third Parties

We may receive information about you from third parties, including:

• Business partners and referral sources
• Social media platforms (if you connect your accounts)
• Publicly available sources
• Analytics providers

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Service Delivery

• Providing, maintaining, and improving our software development services
• Processing transactions and managing your account
• Communicating with you about projects, updates, and support
• Customizing and personalizing your experience

2.2 Business Operations

• Analyzing usage patterns to improve our website and services
• Conducting research and development
• Managing our business relationships
• Complying with legal obligations

2.3 Marketing and Communications

• Sending newsletters, updates, and promotional materials (with your consent)
• Providing information about new services or features
• Conducting surveys and gathering feedback

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Service Providers

We work with trusted third-party companies that help us operate our business, including:

• Cloud hosting providers (data stored in Canada)
• Payment processors
• Analytics services
• Email service providers
• Customer support tools

3.2 Legal Requirements

We may disclose your information when required by law, including:

• In response to valid legal process (subpoenas, court orders)
• To protect our rights, privacy, safety, or property
• To investigate suspected fraud or security issues
• To comply with applicable laws and regulations

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

4. Data Security

We implement robust security measures to protect your information:

• Encryption: All data transmitted between your browser and our servers is encrypted using TLS/SSL
• Access Controls: Strict access controls limit who can access your data
• Security Audits: Regular security assessments and penetration testing
• SOC 2 Compliance: Our infrastructure is SOC 2 Type II certified
• Employee Training: All staff receive privacy and security training

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

5. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law. Factors affecting retention include:

• Duration of our business relationship
• Legal obligations and requirements
• Resolution of disputes
• Enforcement of agreements

When information is no longer needed, we securely delete or anonymize it.

6. Your Rights and Choices

Under Canadian privacy law, you have the following rights:

6.1 Access and Correction

You can request access to your personal information and ask us to correct any inaccuracies. Contact us to submit an access request.

6.2 Withdrawal of Consent

You can withdraw consent for certain processing activities at any time. Note that withdrawal may affect our ability to provide certain services.

6.3 Marketing Opt-Out

You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in our emails
• Contacting us directly
• Updating your communication preferences

6.4 Cookie Preferences

You can manage cookie preferences through your browser settings or our cookie consent tool.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

7.1 Types of Cookies

• Essential Cookies: Required for basic website functionality
• Analytics Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track effectiveness of our advertising (with consent)

7.2 Managing Cookies

You can control cookies through your browser settings. Disabling cookies may affect website functionality.

8. International Data Transfers

We primarily store and process data in Canada. If data is transferred outside Canada, we ensure appropriate safeguards are in place, including:

• Contractual protections with service providers
• Assessment of recipient country's privacy laws
• Technical and organizational security measures

9. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn we have collected information from a child, we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending email notification for significant changes

11. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer:

ProgramCA Privacy Office
150 King Street West, Suite 2100
Toronto, ON M5H 1J9, Canada
Email: [email protected]
Phone: +1 (416) 847-2953

We aim to respond to all privacy inquiries within 30 days.

12. Privacy Commissioner

If you are not satisfied with our response to a privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca