Puter Technologies Inc. (“Puter” “us”, “we”, the “Company”) recognizes the importance of protecting the privacy of any personal information we collect. We appreciate that you trust us with your information and want to make sure you understand what information we collect, why we collect it and how it is used.
Privacy Policy
Capitalized terms used and not defined in this Privacy Policy have the meanings ascribed to such terms in Puter’s Terms of Use (“Terms”)
1. Where This Privacy Policy Applies
This Privacy Policy describes how we collect, use and handle your personal data when you use our Services. By using the Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms.
For the purposes of the Privacy Policy, “personal data” or “personal information” means any identifiable information about an individual, including but not limited to an individual’s name, home address, telephone number, email address, except any other information otherwise exempted by the applicable laws of Canada and other jurisdictions. For example, in Canada, personal information does not include any business contact information that is processed solely to communicate with that person about his or her employment or profession.
2. Information We Collect
Account Information. You are not required to create a Permanent Account to use the Services. If you do create a Permanent Account with us, you will provide us with at least your login credentials, as well as some other basic details necessary for our account-based services to work, which includes your email address. Following the creation of your Account, you may also choose to add additional information to your user profile, such as your name, home address, phone number. This information is voluntarily submitted by you and collected by us.
Billing. When you subscribe to a paid service or make a purchase directly from us, you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
Cookies. We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). We use this information to authenticate you, remember your preferences and settings, analyze site traffic and trends, and allow you to use other features. You can set your browser to not accept cookies, however doing so may limit aspects of the Services.
Usage Information. We collect information about your activity on our Services, for instance when you use the Services (e.g., date and time you logged in) or the features you use.
Device information. We collect information from and about the device(s) you use to access our Services, including hardware and software information such as IP address, device ID and type, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser.
We do not collect any personal information that is contained in your User Data, as that term is defined in the Terms.
3. How we share information
We may share information as follows:
Puter Users. If you use our Services and collaborate with other Puter users and third parties, those users may see some of your basic information, like your name, profile picture, device, email address and usage information.
Other Service Providers. We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We share your personal information with other service providers for them to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
Business Purposes. We may also share your personal information with other companies for the purposes of conducting corporate audits, analysis and consolidated reporting as well as our compliance with applicable law.
Business Transactions. We may disclose and transfer your personal information to an acquirer or investor if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
Compliance with Laws. We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
Non-Personal Information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, aggregated demographics, aggregated behavioral data, aggregated geolocation data in de-identified form), as well as personal information that has been de-identified or anonymized, under any of the above circumstances. We may also share this information with other third parties (notably advertisers) to develop and deliver targeted advertising on our Services and on websites or applications of third parties, and to analyze and report on advertising you see.
4. How We Use Information
We use your information (whether collected directly from you or from our other users or service providers) in the following ways:
To administer your Account and provide our Services to you
Create and manage your Account
Provide you with user support and respond to your requests
Process refunds
Communicate with you about our Services, including billing
To ensure a consistent experience across your devices
Link the various devices you use so that you can enjoy a consistent experience of our Services on all of them. We do this by linking devices and browser data, such as when you log into your Account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
To serve you relevant offers and ads
Administer sweepstakes, contests, discounts or other offers
Develop, display and track content and advertising tailored to your interests on our Services and other sites
Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
To improve our Services and develop new ones
Administer focus groups and surveys
Conduct research and analysis of users’ behavior to improve our Services and content
Develop new features and services
To prevent, detect and fight fraud or other illegal or unauthorized activities
Address ongoing or alleged misbehavior on and off-platform
Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights
To process your information as described above, we rely on the following legal bases:
Consent: We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable law. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. By using our Services or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Privacy Policy and as may be further identified when the personal information is collected. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.
If you do not consent to the processing of your personal information in accordance with this Privacy Policy, please do not access or continue to use any aspect of our Services or otherwise provide any personal information to us.
You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Services, where applicable, (ii) deleting your Account and stopping use of our Services, (iii) opting out of the use of your personal information by contacting our Privacy Officer. However, if you withdraw or change your consent, we may not be able to provide you with our Services.
Other Legal Bases. Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable law.
5. Cross-Border Data Transfers
To provide you with the Services, we may store, process and transmit data in Canada and locations around the world – including those outside your country. Data may also be stored locally on the devices you use to access the Services.
6. Your Rights
We want you to be aware of your privacy rights. Here are a few key points to remember:
Applicable privacy laws may give you the right to review the personal information we keep about you or to request that we explain how we have collected used, and shared your personal information (depending on the jurisdiction, this may be called right of access or variations of this term). You can request a copy of your personal information by contacting our Privacy Officer.
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and you want to request its rectification, deletion or object to its processing, you can contact our Privacy Officer.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can provide you with a copy of your personal information or rectify your personal information.
We may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user.
If you wish to receive information relating to another user, the other user will have to provide us with their written consent before the information is released. Notwithstanding the foregoing, we reserve the right, in our sole discretion, to reject any request for information about another user.
We may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
You may delete your Account at any time, from which time we will not collect any additional information about you through that Account. If you continue to use our Services without an Account, we will still continue to collect information about you as set out in this policy.
In certain countries, including Canada, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information.
7. How We Protect Your Information
We implement physical, organizational, and technological measures to protect your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that your Account or information is no longer secure, please notify our Privacy Officer immediately.
8. How Long We Retain Your Information
We keep your personal information for as long as we need it to provide the Services and as permitted or required by applicable law. If you delete your Account, we will remove information associated with your Account, unless:
we must keep it to comply with applicable law;
we must keep it to evidence our compliance with applicable law;
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security.
9. Children's Privacy
Our Services are restricted to users who are 13 years of age or older. We do not knowingly collect personal information from anyone under the age of 13. If we discover that a user is under the age of 13, we may delete the Account of such user.
10. Privacy Policy Changes
Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
11. How to Contact Us
If you have questions about this Privacy Policy, you can reach our Privacy Officer:
If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.