Privacy Policy

Cuemill Corporation (“Cuemill”, “us”, “we”, “our”) owns and operates the website located at https://cuemill.com the Loop web application (“Web Platform”), the Loop mobile app (“App”) and provides the services described on the Website and on the Platform and App (collectively with the Website, Web Platform, and App, the “Platform”).

This privacy policy (“Privacy Policy”) describes how we collect, store, use, and distribute your Personal Information when you use the Platform. For the purposes of this Privacy Policy, "Personal Information" means any personally identifying information about an individual. Please read the following carefully to understand our practices regarding Personal Information of users who access and browse the Website and Cuemill customers who use the Platform (“Users”, “you”, “your”).

We may change this Privacy Policy from time to time at our sole discretion. We encourage you to review this Privacy Policy each time you use the Platform to see if the Privacy Policy have been changed, as indicated by the “Last Updated” date set out above. Cuemill may require you to provide consent to the updated Privacy Policy before further use of the Platform is permitted.

1. Consent. By using the Platform, you consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be collected, used, or disclosed for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing of such Personal Information in a way that specifically identifies an individual. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using all or part of the Platform.

2. Information You Provide Us. You may disclose Personal Information to us as follows:

a. By Submitting Information via the Website. When you use the Website (for example, when you use the “Contact us” form, send us a request to become a business partner, or subscribe to receive early bird promotions), the information we may collect includes your name, email address, and any other Personal Information you choose to submit to us. We ask that you do not disclose sensitive Personal Information (including, without limitation, medical information) in your contact form.

b. By Making Purchases or Using the Platform. When you purchase hardware from us or use any part of the Platform, the information we collect may include your name, email, OAuth login identifiers, date of birth, preferred pronouns, interests, phone number, address, hardware device and or browser description, location, social media profile identifiers, IP addresses, profile photos or images, and billing information.

c. By Submitting Content via the Platform. Users may submit and make available content via the Platform (“Content”). Any Personal Information contained in Content will be subject to the terms of this Privacy Policy.

d. Through Third-Party Integrations. Cuemill may rely on certain third-party applications to provide the Platform to you (“Third-Party Integrations”). Any Personal Information Users submit to us via Third-Party Integrations that we can access will be subject to this Privacy Policy, but please note that your Personal Information will also be subject to the terms of the applicable Third-Party Integration.

e. By Contacting us through our Social Media Accounts. We provide links to our social media accounts on our Website, and you may choose to contact us via our social media accounts. Any Personal Information you submit to us via our social media accounts will be processed in accordance with this Privacy Policy, but please note that the applicable social media platform may have access to your Personal Information. Please consult the relevant social media platform’s privacy policy to see how they process your Personal Information.

f. By Applying to Work with Us. If you would like to work with us and submit hiring materials to us, we collect any Personal Information in your hiring materials, such as your resume, cover letter, transcripts, or certifications. If you submit hiring materials to us, we ask you to only include information relevant to the position you’re applying for, and your employment history and education (including, without limitation, certifications and/or degrees obtained, previous work experience, relevant awards, etc.).

‍3. Information We Collect When You Use the Platform.

a. Analytics. When you use the Platform, Cuemill may collect analytical information about your use of the Platform and combine it with analytical information from other Users’ use of the Platform to generate aggregate statistics about Platform usage, such as how long Users spend using the Platform, and what parts or pages of the Platform are viewed most often. This information is used to improve the content and operation of the Platform.

b. Cookies. When you use the Platform, Cuemill may collect certain information through technologies such as cookies and other automatic data collection technologies (“Cookies”). We may use Cookies for authenticating Users on the Platform, to identify you when you interact with Users through Cuemill hardware, and to compile analytics. We may also use cookies to prevent malicious entities from forging requests and injecting undesirable content. You may opt out of Cookies or prevent third-party websites from accessing our Cookies by adjusting your privacy settings on your browser. However, opting out of Cookies may disable some features of the Platform and may prevent us from providing you with the information and services you have requested.

c. Device and Location Information. When you use the Platform, Cuemill may collect information about your device (“Device Information”). Some Device Information, such as unique device identifiers, may constitute Personal Information. The Personal Information we collect from Device Information can depend on the individual settings of your device and software that you use to access the Platform. We recommend checking the policies of your device manufacturer or software provider to learn what Device Information may be shared with Cuemill. Furthermore, certain aspects of the Platform may require you to share Personal Information such as your geo-location data. You may disable the sharing of Device Information or geo-location, but doing so may disable some features of the Platform and may prevent us from providing you with the information and services you have requested. Cuemill may also monitor and record IP address of some or all requests made to its servers.

4. How We Use Information We Collect. We use Personal Information in the following ways:

a. To authenticate and onboard Users and provide access to the Platform;

b. To provide, maintain, improve, and enhance the Platform;

c. To develop new products, features, and services;

d. To communicate with you, provide you with updates and other information relating to the Platform, provide information that you request, respond to comments and questions, and otherwise provide customer support;

e. For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you, where you have subscribed to receive them;

f. To find and prevent fraud, and respond to trust and safety issues that may arise;

g. For compliance purposes, as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

h. For other purposes for which we provide notice at the time the information is collected.

5. Who We Share Your Information With. In connection with our provision of the Platform, your Personal Information may be shared with third party service providers for the purpose of enabling them to provide their services, including IT, web hosting, cloud service, database, notifications, debug and error logging, maps, weather, analytics, and OAuth service providers, because of how these services work. We may share your Personal Information with selected business partners, agents, contractors, affiliates, and related entities while performing our contractual obligations.

We have put in place contractual and other organizational safeguards with such third parties to protect your Personal Information from unauthorized uses and disclosures. Such third parties have limited access to Personal Information solely for the purposes described herein, and they will be subject to contractual restrictions prohibiting them from using such Personal Information for any other purpose.  

In addition, we may disclose your Personal Information to third parties:

a. In connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or shares, including any due diligence exercise carried out in relation to the same, provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the Personal Information;

b. If we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; or

c. If we believe in good faith that such disclosure is required by and in accordance with the law.

Our servers and those of third parties who may receive your Personal Information may be located outside of Canada. Accordingly, your Personal Information may be available to foreign governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

6. Third Parties. The Platform may contain links to third-party websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to the collection, storage, use, and sharing of your Personal Information by such third parties.

7. Data Retention and Deletion. We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. All retained Personal Information will remain subject to the terms of this Privacy Policy. You have the right to ask us to remove your Personal Information from our databases, and we will do so to the best of our ability, but it may not be possible to completely delete all of your Personal Information due to technological and legal constraints (for example, when your Personal Information pertains to another User).

‍8. Access and Accuracy. You may access the Personal Information we hold about you to verify accuracy of your Personal Information, to have a general account of our uses of your Personal Information, and to correct your Personal Information as appropriate. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you (for example, where that Personal Information also pertains to another User). In such circumstances, we will provide reasons for the denial to you upon request. We will make every reasonable effort to keep your Personal Information accurate, and to respond to your request in a timely manner.

9. Security. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff and third parties as reasonably necessary to carry out the stated purposes we have communicated to you.

10. Children’s Privacy. Cuemill will not knowingly request or collect Personal Information from any child under the age of 13. If a child under 13 submits Personal Information to Cuemill and we learn that such information is of a child under 13, we will delete the information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at support@cuemill.com.

11. Additional Disclosures for Residents of the EEU and California.

a. General Data Protection Regulation (GDPR) Compliance (EEA). If you are a resident of the EEA, you have certain additional data protection rights mandated by the laws of your jurisdiction. Cuemill takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed of what Personal Information we hold about you and if you want it to be removed from our systems, please contact us at support@cuemill.com. Note that where we act as the data processor on behalf of our Users, you will be required to contact the data controller directly to exercise your rights.

In certain circumstances, where we act as a data controller, you have the following data protection rights:

• Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you where we are the data controller and to check that we are lawfully processing it.

• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA. You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights).  

b. California Compliance (US). This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the CCPA).

For more details about the Personal Information Cuemill has collected over the last 12 months, please see Section 2 and 3 above. We collect this Personal Information for commercial purposes described in Section 4 above. Cuemill will only share this information when you make a User support query to another organization, which is a customer of Cuemill and which uses the Platform to assist their User support function. Cuemill does not sell (as that term is defined in the CCPA) the Personal Information we collect.  

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at support@cuemill.com. We will verify your request using the information associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

12. Contact Us. If you want to enforce any of your rights under this Privacy Policy or if you have any questions regarding this Privacy Policy or your Personal Information, please contact our Data Protection Officer per the information below:

a. Via email: Email us at support@cuemill.com using the subject line “Re Privacy Policy”.

b. Via mail: Mail us correspondence to 601 – 5343 Dundas Street West, Toronto, ON M9B 6K5 Canada.