Privacy Policy

PING CANADA CORPORATION (“PING,” “us,” or “we”) is committed to protecting your privacy. PING has prepared this Privacy Policy to describe to you, or if you represent an entity or other organization, that entity or organization, (in either case, “You” or “User”) our practices regarding the personal information that PING collects, uses, and shares regarding our online informational platform (the “Platform”) accessed through the website located at https://ca.ping.com/ and any other websites operated by PING or by PING, Inc. (each, a “Site”) or using mobile applications provided by and on behalf of PING or by PING, Inc. (each, an “Application,” and each Site and Application treated as a part of the “Platform” for purposes of this Privacy Policy). Capitalized terms not defined in this Privacy Policy, shall have the meanings as defined in the Terms of Use, located at: https://ca.ping.com/legal/terms-of-use.

PING reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that You keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.

Please read this Privacy Policy carefully to understand PING’s views and practices regarding Your personal information and how we will treat it. By visiting this Platform, You are freely accepting and consenting to the practices in this Privacy Policy. You may withdraw Your consent at any time and for any reason with effect to future data processing by contacting us at the address listed below in the Section titled “Communications”. Without Your consent, PING will use personal information, only insofar as such processing is permitted by applicable law (e.g., for the performance of a contract or agreement between PING and You) or where such processing is necessary for compliance with a legal obligation to which PING is subject.

1. COLLECTION OF PERSONAL INFORMATION.

Personal information refers to information that is connected to You, and may include things such as Your email address, mailing address, mobile number, demographic information, billing and payment preferences, Product Comments, and photographs.

PING collects personal information when Users voluntarily submit it to us. For example, we may collect or receive information from You when You create an Account, submit Your Content or Product Comments, use or access Service or Content, or otherwise interact with us or other Users of the Platform.

In addition to personal information that we may receive from You, PING may collect other information from Users using the following technologies:

Cookies. "Cookies" are small bits of information that the Platform places on the hard drive of Your computer. Cookies remember information about Your activities on the Platform to make Your visits to the Platform more enjoyable and valuable to You by providing a customized experience and recognizing Your preferences when You visit the Platform. If You've chosen to disable cookies on Your browser, some of the functionality of the Platform may be lost. Certain Services provided by PING, require that cookies be enabled in Your browser and cannot be used when You have disabled cookies in Your browser.

Flash cookies (also called Local Shared Objects or “LSOs”). Flash cookies are data files similar to cookies, except that they can store more complex data. Flash cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services.

Web beacons or clear pixels. Web beacons are small graphic images on a web page or in an email that can be used for such things as recording the pages and advertisements that You select, or tracking the performance of email marketing campaigns.

Web Server Logs. Web server logs are records of activity created by the computer that delivers the webpages You request to Your browser. For example, a web server log may record the search term You entered or the link You clicked to bring You to a webpage. The web server log also may record information about Your browser, such as Your IP address and the cookies set on Your browser by the server.

Social Networking Sites. If You log into Your Account through sign-in services (e.g., Facebook Connect), You provide PING with permission to access certain information about You from that social networking site, such as Your Facebook User ID, user profile, friends list, and profile picture.

Device Information. We may collect information about the mobile device or computer You use to access the Platform, including without limitation the hardware model, operating system and version, browser type, unique device identifiers, and mobile network information.

Physical Activity Trackers. PING may collect information about Your physical activity while You are using the Application, or a peripheral device connected to the Application, such as Your step count, heart rate, or calorie count. When You install the Application You will be reminded by the Application of the relevant physical activity related information that the Application collects, and asked to provide Your consent.

Geo-location Information. We may collect information about the geo-location of Your device if You provide Your consent. When You install the Application You will be reminded by the Application of that the device may be tracking Your geo-location, and asked to provide Your consent.

2. USE OF PERSONAL INFORMATION.

PING’s primary purpose in collecting personal information is to provide You with Content, Services, and PING’s products that match Your interests. PING may also use personal information about You for various purposes, including without limitation to:

• To help You track Your activity levels. If we gather information from the Apple HealthKit we will not use that information for general advertising purposes, unless permitted to do so by Apple’s terms of use. That information may be used, however, to provide You with information that will help improve Your health or to conduct health-related research.

• To conduct research and analysis.

• To help diagnose problems with the Platform, to administer the Platform, and to enhance the Platform for optimal User experience.

• To monitor the usage and performance of the Platform, and to determine aggregate information about our Users and usage patterns.

• To customize Content and Services that may be of interest to our Users.

• To provide You with information about our products.

• To facilitate Orders, product transactions, and process payments.

• To send Users materials, updates, and information regarding the Platform.

• To send You information about special events and promotions that we offer.

• To provide maintenance, support, and customer service for the Platform.

• To contact Users for information verification purposes.

We may also participate in behavioral-based advertising. This means that a third party may use technology, such as a cookie or a web beacon, to identify You on the Platform so that they can provide advertising about products and services tailored to Your interest. That advertising may appear either on the Platform, or on other web sites.

3. SHARING OF PERSONAL INFORMATION.

PING may share Your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with PING). We do not share Your information with third parties to directly market to You, but we may market to You on behalf of such third parties that would like to send You information about their products and services. For example, PING may offer a promotion in conjunction with a co-sponsor that may have special offers or services that might be of interest to our Users. We may also extend to You special offers from the co-sponsor that may be of interest to You.

PING may disclose personal information to service providers for the purposes of operating our business, delivering, improving, and customizing our Content, Services, or products, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law. For example, PING may share information about Your physical activity with Apple HealthKit and Health App, and as a result information observed by PING may be stored by Apple. If we gather information from the Apple HealthKit, we will not share HealthKit data with any third party other than Apple. Additionally, PING contracts with payment processing providers which may process sales and Orders that Users make through the Platform. Personal information handled by service providers is subject to their terms and privacy policies. Please review the service provider’s terms and privacy policies to better understand how they manage Your personal information.

There may also be instances when PING may disclose Your personal information without providing You with a choice in order to protect the legal rights of PING, other affiliated companies or their employees, agents, and contractors; to honor a request that You have made through the Platform; to protect the safety and security of other Users; to protect against fraud or for risk management purposes; or to comply with the law or legal process. In addition, if PING sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, PING may transfer Your personal information to a third party as part of that transaction.

The Platform may offer You the ability to share Your personal information through a social networking site (e.g., Facebook, Twitter, LinkedIn), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables You to share personal information about Yourself with other individuals or the public, depending on the settings that You have established with such social networking site. By making personal information available on the Platform, You “opt in” to allow PING to provide such personal information to a social networking site without Your further consent. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.

PING gives you the opportunity to opt-out prior to disclosing personal information or using personal information for a purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized by you. Additionally, PING gives you the opportunity to affirmatively opt-in prior to any additional disclosures of sensitive personal information to a third party not described in this Privacy Policy or to use of sensitive personal information for a purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized by such individual. Exceptions to these requirements may apply where the disclosure of personal information is necessary for PING to carry out its legal obligations, or for other reasons as permitted by applicable law. The exercise of these options by you must be communicated to PING in writing.

4. DATA INTEGRITY AND PURPOSE LIMITATION.

PING limits the use of personal information to ways that are compatible and relevant to the purposes for which the personal information was collected or subsequently authorized or for which consent was obtained or implied. PING will take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current.

5. RETENTION.

PING will retain Your personal information as needed to fulfill the purposes for which it was collected, or until You withdraw Your consent. PING will retain and use Your personal information as necessary to comply with PING’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

6. SECURITY.

PING employs reasonable and appropriate physical, administrative, and technical safeguards to protect personal information from becoming disclosed to individuals who are not described in this Privacy Policy. While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to ensure the safety of Your personal information.

7. ACCESS & CHOICE.

PING has implemented the following procedure that You may use to access, correct, or delete Your personal information, or choose how Your information is used:

• If You would like to know whether PING has collected personal information about You please send us the activities and services that You participated in on the Platform that requested personal information. After reviewing the relevant databases, PING will confirm whether PING has collected such information about You and provide a list of Your personal information that we have on file.

• If Your personal information is incorrect, You may correct the personal information by sending a written request for correction to PING Compliance at the address below. Your request must include: (a) all of the incorrect personal information that You wish to change, (b) the corrected personal information, and (c) Your signature authorizing such changes. PING will then correct the personal information in our database and send a written confirmation to You.

• If You wish to stop receiving email marketing communications from PING, please contact us at the address listed below or use the unsubscribe link at the bottom of any email marketing communication. If You opt out, we may still send You non-promotional communications, such as those about Your Account or to facilitate Orders You have made.

• If You would like to opt-out of behavioral advertising based on your use of the Platform, You can do so by visiting the Network Advertising Initiative or the Digital Advertising Alliance.

• Some web browsers and devices permit You to broadcast a preference that You not be “tracked” online. At this time PING does not modify Your experience based upon whether such a signal is broadcast.

8. INTERNATIONAL DATA TRANSFERS.

PING is a member of a global operation with business processes, management structures, and technical systems that cross borders. The personal information that we collect from You may be transferred to, and stored at, a destination outside of the country in which it was originally collected. This may include transfers outside of Canada. It may also be processed by personnel working outside of the Canada who work for us or for one of our providers. Such personnel may be engaged in, among other things, the fulfilment of Your Order, the processing of Your payment details and the provision of Services or Content. By submitting Your personal information, You agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this Privacy Policy and applicable law.

9. OTHER WEBSITES.

This Privacy Policy does not apply to web sites or applications offered by other organizations or individuals that may be displayed as content in a search on the Platform. PING encourages You to read the privacy policy of any third party web site or applications before transmitting personal information.

10. COMMUNICATIONS.

If You have any additional questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:

PING CANADA CORPORATION
2790 Brighton Road Oakville,
Ontario L6H 5T4
ca.ping.com

If PING needs, or is required, to contact You concerning any event that involves information about You, we may do so by email, telephone, or mail.

Effective as of June 1, 2018.