1.About this policy
1.1Who we are. Chord33 is the business name under which Wisper Bird, a sole proprietor, carries on business in Edmonton, Alberta (“Chord33”, “we”, “us” or “our”).
1.2What it covers. This policy applies to personal information we collect through the website at chord33.ca, the contact form and our email, the client dashboard at my.chord33.ca, and our work for clients.
1.3What it does not cover. Websites we build for clients are operated by those clients, and their own privacy policies apply to them.
1.4Meaning of personal information. “Personal information” means information about an identifiable individual, as defined in the laws listed in section 3.
2.Privacy officer
2.1Wisper Bird is responsible for our compliance with this policy and with the law, and is the person who can answer questions about the collection, use, disclosure and storage of personal information, including by our service providers outside Canada. Contact: [email protected].
3.Laws that apply
3.1We handle personal information in accordance with Alberta’s Personal Information Protection Act (“PIPA”) and, where it applies, the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”).
4.What we collect
4.1When you visit chord33.ca.
- (a)No cookies. The website sets no cookies, so no cookie consent is requested. For the length of a visit only, your browser keeps one setting recording that the opening animation has already played. It contains no personal information and is not sent to us.
- (b)Visit statistics. We count visits with Cloudflare Web Analytics, which records the page viewed, the type of device, the country and the referring website. It sets no cookie, does not follow visitors to other websites, and does not identify anyone to us. We use no advertising or social media tracking code.
- (c)Technical logs. Cloudflare, which hosts the website, keeps short-lived technical records of requests, including network (IP) addresses, for security and to keep the service running. We do not use them to identify visitors.
- (d)Fonts. The website’s typefaces are served by Google Fonts. When a page loads, your browser requests the font files from Google, and that request includes your IP address in the ordinary way.
4.2When you contact us.
- (a)Contact form. The form collects your organization, your email address, the service you are interested in, the address of your current website and your message. We store those five items in our own database. We do not store your IP address, browser details or any other identifier with them.
- (b)Notification email. So that your message reaches us promptly, your browser also sends the same five items to Web3Forms, which emails them to us. Web3Forms adds your IP address to that email.
- (c)Email. If you write to [email protected], we receive your email address and whatever your message contains.
4.3When you use the client dashboard.
- (a)Signing in. Access is by a named work email address and a one-time code, provided by Cloudflare. We do not hold passwords. We keep the list of email addresses authorized to sign in.
- (b)Statistics. The visitor statistics shown for a client’s website are counted without cookies and do not identify any visitor, to the client or to us.
- (c)Assistant questions. Where a client’s website has an assistant, we keep the wording of questions visitors asked for 90 days. Email addresses, phone numbers and long numbers are removed before anything is stored, and we do not keep the answers or any record of who asked.
- (d)Records of use. Sign-ins are logged by Cloudflare. Each time we open a client’s dashboard, the time is recorded. A sign-in by a person not yet linked to a website is noted, with the address they used, and kept for one year so that we can correct it.
4.4In our work for clients. While building or supporting a client’s website we may see personal information the client holds, such as the names of its staff or information about the people it serves. We use that information only to carry out the work, on the client’s behalf and instructions, and keep it confidential.
4.5Billing. For clients, we keep the name, contact details and payment records needed to invoice and to keep our business records. Payments by Interac e-Transfer are processed by the financial institutions involved.
5.How we use it
5.1We use personal information only to:
- (a)respond to your enquiry and prepare a quote or written scope of work;
- (b)provide, support and invoice for our services;
- (c)operate and secure chord33.ca and the client dashboard; and
- (d)meet our legal and tax obligations.
5.2We do not use personal information for advertising, and we do not build profiles of visitors.
6.Consent
6.1By sending us information, you consent to our using it for the purposes described in section 5. Where we wish to use it for any other purpose, we will ask you first.
6.2You may withdraw your consent at any time on reasonable notice, subject to any legal or contractual requirement that we keep a record. We will tell you if withdrawing would affect our ability to provide a service.
7.Service providers and storage outside Canada
7.1We use the following service providers, which store or process personal information on our behalf:
- (a)Cloudflare, Inc. hosts chord33.ca and the client dashboard, provides visit statistics, sign-in and our database, and may store or process information in the United States and other countries.
- (b)Google LLC serves the website’s typefaces from the United States and other countries.
- (c)Web3Forms delivers contact form notifications by email and may process them outside Canada.
- (d)Zoho Corporation provides our email, which is stored in Zoho’s Canadian data centre.
7.2Information stored or processed outside Canada is subject to the laws of the country where it is held, and may be accessible to the courts and authorities of that country.
7.3You may obtain written information about our policies and practices for service providers outside Canada, or ask questions about the collection, use, disclosure or storage of personal information by them, from our privacy officer named in section 2.
8.Disclosure
8.1We disclose personal information only to the service providers listed in section 7, with your consent, or where the law requires or permits it.
8.2We never sell, rent or trade personal information.
9.Retention
9.1We keep personal information only for as long as it is needed for the purposes in section 5 or as the law requires. In particular:
- (a)contact form records are deleted when an enquiry ends without a project, or when the resulting project closes;
- (b)email, including form notifications, is kept as ordinary business correspondence for as long as it is needed;
- (c)assistant questions are deleted automatically after 90 days;
- (d)an email address is removed from the dashboard sign-in list when that person’s access ends; and
- (e)invoices and related records are kept for the period that Canadian tax law requires, generally six years.
10.Safeguards
10.1We protect personal information with reasonable security arrangements suited to its sensitivity, including encrypted connections, access limited to Chord33, sign-in to the client dashboard by one-time code, and collecting no more than we need.
10.2If an incident involving personal information we control presents a real risk of significant harm, we will notify the individuals affected and the Information and Privacy Commissioner of Alberta, as PIPA requires.
11.Your rights
11.1You may ask us:
- (a)what personal information we hold about you, how it has been used, and to whom it has been disclosed;
- (b)to correct personal information that is inaccurate or incomplete; and
- (c)to delete personal information, unless the law or a contract requires us to keep it, in which case we will tell you which.
11.2Send requests to our privacy officer at [email protected]. We may ask you to confirm your identity. We will respond within 30 days and charge no fee. If we cannot grant a request, we will explain why and how you may ask for a review.
12.Children
12.1chord33.ca is intended for organizations and the adults who act for them. We do not knowingly collect personal information from children.
13.Questions and complaints
13.1Please bring any question or concern to our privacy officer first, at [email protected].
13.2If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner of Alberta (oipc.ab.ca) or, where PIPEDA applies, the Office of the Privacy Commissioner of Canada (priv.gc.ca).
14.Changes to this policy
14.1We will update this policy when our practices change. The updated policy will be posted here with a new effective date.