We work in compliance with Canadian law (where our headquarters are located), including compliance with Canada's Anti-Spam Law (CASL) in our digital communications. Since Spring works globally, we also work in alignment with international privacy laws, such as General Data Protection Regulation (GDPR), which applies throughout the EU. We apply privacy best practices to all of our clients and others in our global community, regardless of where they are located.
2. Identifying Purposes
We collect, use and disclose Personal Information to provide you with the product or service you have requested and to offer you additional products and services we believe you might be interested in. The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address and payment information is provided as part of the order process.
Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law. Providing us with your Personal Information is always your choice. However, your decision not to provide certain information may limit our ability to provide you with our products or services. We will not require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except as required to be able to supply the product or service. Please note that some special offers are available as perks to those subscribed to our monthly newsletter. This will not prohibit you from acquiring Spring’s core products or services.
4. Limiting Collection
The Personal Information collected will be limited to those details necessary for the purposes identified by us. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, or the Internet.
5. Limiting Use, Disclosure and Retention
Personal Information may only be used or disclosed for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by law. Personal Information will only be retained for the period of time required to fulfill the purpose for which we collected it or as may be required by law. At times where Spring hosts products, services or events jointly with third parties, such as implementing partners (philanthropic or public foundations, non-governmental organizations or other clients or partners), we will not share information without your express consent, or the consent of the party that owns the domain of the email address we will communicate with you about (as in the case of a manager signing their team up for a training).
Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.
7. Safeguarding Customer Information
Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information. We take all reasonable precautions to protect your Personal Information from any loss or unauthorized use, access or disclosure, and will act swiftly should any such unauthorized use, access or disclosure be brought to our attention or discovered in routine monitoring.
We will make information available to you about our policies and practices with respect to the management of your Personal Information. You are entitled to access, correct, delete and limit processing of personal data, as well as to receive it so tthey can be used by another processor.
9. Customer Access
Upon request, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to it. You may verify the accuracy and completeness of your Personal Information, and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.
10. Handling Customer Complaints and Suggestions
You have the right to right to lodge a complaint with a supervisory authority.
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