Privacy Policy

Overview

Townfolio Inc. (“Refinery Labs”, “us”, “we”, “our” or “Townfolio”) operates the https://townfolio.co and https://refinery-labs.com website (the “Service”).

Personal Information Collection, Use, Disclosure and Consent

Personal Information may include your name, picture, email address and phone number.

We are committed to providing our clients, customers, members (“you”, “your” or “them”) with exceptional service. Providing exceptional service may involve the collection, use and, at times, the disclosure of your Personal Information to other users. Protecting your Personal Information is one of our highest priorities. While we have always respected your privacy and safeguarded all Personal Information, we have strengthened our commitment to this goal. This is to continue to provide exceptional service to you and to comply with all applicable laws regarding the collection, use and disclosure of Personal Information. We will inform you of why and how we collect, use and disclose Personal Information; obtain your consent, as required; and handle Personal Information according to applicable law, including the The Freedom of Information and Protection of Privacy Act (Saskatchewan) (“FIPPA”). Our privacy commitment includes ensuring the accuracy, confidentiality, and security of your Personal Information and allowing you to request access to, and correction of, your personal information.

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.

We will not use or share your information with anyone except as described in this Privacy Policy.

We will only collect Personal Information that is necessary to fulfill the following purposes:

To verify identity;
To identify your preferences;
To open and manage an account;
To operate the social aspects of this service;
To facilitate user to user communication;
To ensure you receive a high standard of service;
To meet regulatory requirements;
Other legal reasons as apply to the services requested.

We will obtain your consent to collect, use or disclose Personal Information. In some cases, we can do so without your consent (see below). You can provide consent orally, in writing, electronically or through an authorized representative.

You provide implied consent where our purpose for collecting using or disclosing your Personal Information would be considered obvious or reasonable in the circumstances and you voluntarily provide your Personal Information for that purpose. The social sharing of personal data is outlined in our Data Sharing Policy document. Consent may also be implied where you have notice and a reasonable opportunity to opt-out of having your Personal Information used for mail-outs, marketing or fundraising and you do not opt-out.

We may collect, use or disclose Personal Information without your consent:

When permitted or required by law;
In an emergency that threatens an individual’s life, health, or personal security;
When the Personal Information is available from a public source;
When we require legal advice from a lawyer;
For the purposes of collecting a debt or protection from fraud;
Other circumstances permitted by applicable law.

We will not sell your Personal Information to other parties unless consent has been provided or implied. We retain your Personal Information for the time necessary to fulfill the identified purposes or a legal or business purpose where we have used their Personal Information to make a decision that affects you, we will retain the Personal Information for at least one (1) year so you have a reasonable opportunity to request access to it. We will make reasonable efforts to ensure that your Personal Information is accurate and complete. You may request correction to your Personal Information to ensure its accuracy and completeness. A request must be in writing and provide sufficient detail to identify your Personal Information and the correction being sought.

We are committed to ensuring the security of your Personal Information and may use passwords, encryption, firewalls, restricted employee access or other methods, in our discretion. We will use appropriate security measures when destroying your Personal Information such as shredding documents or deleting electronically stored information, in our discretion.

We will continually review and update our security policies and controls as technology changes to ensure the ongoing security of your Personal Information.

Log Data

We may collect information that your web browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Service’s functionality. These third party service providers have their own privacy policies addressing how they use such information.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

We only use “cookies” to maintain your logged in state, no tracking or data collection is performed via cookies. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you do not instruct your browser to refuse all cookies or to indicate when a cookie is being sent, your consent to our use of your Personal Information may be implied.

Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. It is also possible to opt out of communications during sign up as well as the ‘Settings & Privacy’ area of the web application.

Compliance With Laws

As set out above, and for clarity, we will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. More details about our technology and security measures can be found in our Security Description document.

International Transfer

Your information, including Personal Information, may be transferred to — and maintained on – computers located outside of your province, but within Canada.

Information in the form of photos, videos, uploaded documents and other media for the purpose of sharing with others may be transferred to and maintained on computers located outside of your province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. These items have no personally identifiable information linking them back to your person or location, beyond content intentionally and explicitly embedded in the images, documents or media themselves by the creator.

If you are located outside Canada and choose to provide information to us, please note that we transfer the information, including Personal Information, to Canada and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address, and is not intended for use by, anyone under the age of 13 (“Minor”).

We do not knowingly collect personally identifiable information from Minors. If you are a parent or guardian and you are aware that your Minor has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Minors without verification of parental consent, we take steps to remove that information from our servers.

Providing You With Access To Your Personal Information

You have a right to access your personal information.

A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer identified below.

Upon request, we will also tell you how we use your personal information and to whom it has been disclosed, if applicable.

We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform you of the cost and request further direction from you on whether or not we should proceed with the request.

If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal and the recourse available to you.

Questions and Complaints: The Role of the Privacy Officer

The Privacy Officer is responsible for ensuring Townfolio’s compliance with this policy and

You should direct any complaints, concerns or questions regarding Townfolio’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, you may also write to the Information and Privacy Commissioner of Saskatchewan.

We may designate another individual other than the Privacy Officer as the person to contact for any requests related to this Privacy Policy by updating the contact information above.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.