Privacy Policy

Latest revision: June 1, 2019

KEY ELEMENTS OF THIS PRIVACY POLICY
For information about:                                                                    See:
•a general overview of, and the differences between, our              section 1
website and our software platform section
• the information we collect                                                             section 2
• the purposes for which we collect, use and                                 section 3
disclose information
• how we disclose and share information                                        section 6
• how we keep Personal Information secure                                   section 7
• risk of harm and other consequences                                           section 8
• how long we keep Personal Information                                       section 9

1. OVERVIEW

1.1 General Overview

Quantify Labs Inc. (“Street Contxt”, “we”, “us”) provides a content and analytics platform and builds software for institutional trading desks (the “Platform”). Through our website located at www.streetcontxt.com (the “Site”) we provide information about our company, our products and services and this Privacy Policy describes how we collect, store, use and distribute information via the Platform and the Site. This Privacy Policy does not extend to our customer’s use of information which is governed by their own privacy policies. By using the Platform or the Site, you consent to the collection and use by us and our agents of your Personal Information as described in this Privacy Policy.
This Privacy Policy applies to our collection, use and disclosure of personal information. It does not impose any limits on our collection, use or disclosure of business contact information or certain publicly-available information.

In this Privacy Policy, “Personal Information” means personally identifiable information (for example, name, personal email address, date of birth) and “Non-Personal Information” means information that is not about an identifiable individual, including anonymous information and aggregated information.

1.2 Overview of Privacy Practices on the Platform

If you are a Street Contxt Platform customer, you can use our system on a licensed basis, subject to a separate agreement with Street Contxt, to create distribution lists, send emails and obtain analytics and insights on those activities. To the extent we have access to your customer or user information through the use of our Platform subscription services, we will employ the security and privacy measures indicated in this Privacy Policy and the data policies set out in our customer contract. Please send an email to privacy@streetcontxt.com to request additional information.

1.3 Overview of Privacy Practices on the Site

Street Contxt does not collect any Personal Information through the Site, unless you voluntarily choose to provide it to us (e.g., inquiring about or requesting products or services, forwarding an employment inquiry or a copy of your resume). If you do not want your Personal Information collected, please do not submit it to us. If you provide us with contact information, we will maintain the confidentiality of your contact information and use it only for the purposes for which we have collected it, as described below, unless you agree that we may disclose it to other third parties (subject to the exclusions we have listed below).

2. COLLECTION OF INFORMATION

We collect Personal Information and Non-Personal Information through the Site and the Platform as follows:

2.1 Personal Information–Site

We collect Personal Information through the Site that you provide directly to us, which may include name, address, e-mail address, date of birth, employment and education history, survey responses, etc. We may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that their use of the Personal Information conforms to applicable privacy laws.


2.2 Personal Information-Platform
We collect the following Personal Information through the Platform:
•first and last name
•business contact information: business title and business email address and street address
•identity of your employer

•survey responses

2.3 Non-Personal Information

We collect or derive Non-Personal Information in the course of operating the Site and the Platform such as the domain used to access the Site or Platform, and the type and version of browser or operating system being used.

Cookies

In order to use certain areas of the Site or the Platform, we store some information on your computer in the form of a “Cookie”. A Cookie is assigned to you when you access the Site or Platform and is placed on your computer for programming purposes only. We use cookies to help compile aggregate statistics about usage of the Site and the Platform, such as how many users visit the Site and Platform, how long users spend viewing the Site and Platform, and what pages are viewed most often. This is a temporary or session Cookie that uniquely identifies you as you move from page to page. We need this information in order to operate our services, but we do not share it with any third parties.

We also collect aggregate information, including demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, average time spent on the Site or the Platform.

With respect to the Platform only, we collect aggregate information from Platform users with respect to their e-mail, including what Platform content is opened, replied to, forwarded, deleted and otherwise engaged with by users.

Third-Party Analytics

We may use automated devices and applications, such as Google Analytics, to

evaluate usage of the Site and the Platform. We also may use other analytic means to evaluate our services. We use these tools to help us improve our services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. You may opt-out of Google Analytics by downloading and installing the Google Analytics Opt-Out Add-on for your web browser.

Location Data

We may determine the approximate location of your computer or device from your IP address. We collect and use this information to, for example, calculate how many people visit the Site or the Platform from certain geographic regions.

3. PURPOSES

We collect, use and disclose your Personal Information for the following purposes:

•to provide and administer products and services you request, and to disclose the
information for any purpose related to the provision of requested products and services;
•to respond to your inquiries or requests for information about our products and services;
•to better understand your business needs and how we can improve our products and services;
•to generate statistics and aggregate reports for internal use that do not personally identify any individuals and which may be shared with third parties;
•if you opt-in to receive communications from us, we (or a third party on our behalf) may use Personal Information to contact you about Street Contxt products or services that may be of interest to you. You may unsubscribe from receiving such communications from us at any time by following the opt-out instructions provided in our email communication;
•to authenticate your identity;
•to manage or transfer our assets or liabilities, for example, in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products or services;
•to maintain accurate customer records;
•to protect us, yourself and others from fraud and error and to safeguard our business interests;
•to collect debts owed to us; and

•to comply with legal and regulatory requirements.

Persons interested in employment opportunities with Street Contxt may make inquiries through the Site or forward to us their resumes or Personal Information about their interest, skills and experience, and we may use this information to assess and evaluate potential job applicants. We ask that such persons immediately contact us should they wish us to remove this information from our records. All such records are maintained by our Chief of Staff and are kept in a secure location.

We do not sell, rent or otherwise market Personal Information to third parties. We limit the collection, use, retention and disclosure of your Personal Information to that which is reasonably necessary for the purposes identified above.

4. CONSENT

We will obtain your consent to collect, use or disclose Personal Information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose Personal Information without your knowledge or consent where: the information is publicly available, as defined by statute or regulation; we are obtaining legal advice; or we reasonably expect that obtaining consent would compromise an investigation or proceeding. Other exceptions may apply.

Your consent can be express, implied or given through an authorized representative.

Consent may be provided orally, in writing, electronically, through inaction (such as when you do not notify us that you do not wish your personal information collected/used/disclosed for various purposes after you ave received notice of those purposes) or otherwise.

You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of your withdrawal of consent. If you notify us that you withdraw consent, we will inform you of the likely consequences of that withdrawal , which may include our inability to provide certain services for which that information is necessary.

5. LIMITS ON COLLECTION USE AND DISCLOSURE OF PERSONAL INFORMATION

We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We may also collect personal information as authorized by law.

Your Personal Information will only be used or disclosed for the purposes set out above and as authorized by law.

6. DISCLOSURE OF INFORM ATION; SERVICE PROVIDERS

6.1 Disclosure and Sharing

Street Contxt will not share the Personal Information we collect from you with any third party, except as indicated in this Privacy Policy.

From time to time we may engage third parties to help us improve our site and to provide various services (e.g. hosting, analytics, CRM, marketing automation, lead capture, email marketing, database management, maintenance, etc.). These third parties may have limited access to Personal Information solely for the purpose of helping us to provide such services. If we require a service provider to deal with your Personal Information, we will take reasonable steps to ensure that the service provider adheres to privacy procedures and will keep your Personal Information confidential. We will not provide more information than is necessary to the service provider and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.

6.2 Important Exceptions

We may disclose your Personal Information to a third party without your consent if we have reason to believe that disclosing this 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 site users or anyone else that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We may also disclose your Personal Information, in accordance with applicable law, 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 provided that the information disclosed continues to be used solely for the purposes permitted by this privacy policy by the entity acquiring the information.

6.3 Service Providers, Hosting and Servers

Our service providers may be located outside of the country in which you are located, and our servers are currently located in the United States of America. You therefore acknowledge that your Personal Information may be processed and stored in foreign jurisdictions and that governments, courts, law enforcement or government or regulatory agencies in the USA, Canada and elsewhere may be able to access or obtain disclosure of your Personal Information under a lawful order or otherwise through the laws of the foreign jurisdiction, irrespective of the safeguards we have put in place for the protection of your Personal Information.

6.4 Third Parties and Sites

Through Street Contxt, you may be introduced to a variety of third parties and websites. The privacy practices and policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third party, or the use of “cookie” technology by any third party, will be governed by the privacy policy of the operator of the website that you are visiting. If you have any doubts about the privacy of the information you are providing on another website, we recommend that you contact that website directly for more information and review its privacy policy.

7. SECURITY

Street Contxt uses commercially reasonable physical, technical, managerial, organizational and electronic efforts to ensure that your Personal Information is stored and maintained in a secure environment. We will take reasonable measures, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our safeguards.

8. RETENTION

Street Contxt will keep your Personal Information for as long as necessary in connection with the purposes identified in Section 3 or as required by law, which may extend beyond the termination of our relationship with you. You must notify Street Contxt if you no longer want us to retain your information.

We will destroy, erase or make anonymous documents or other records containing Personal Information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose. We will take due care when destroying Personal Information so as to prevent unauthorized access to the information.

9. ACCESS AND ACCURACY

We will make a reasonable effort to ensure that Personal Information we are using or disclosing is accurate and complete. If you demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. If a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, we will annotate the Personal Information under our control with a note that the correction was requested but not made.

You can access the Personal Information we hold about you by sending us an e-mail at privacy@streetcontxt.com. We will advise you in advance of any charges for copies of your file. We may be unable to provide you with some information in certain circumstances, such as if the information also refers to other individuals, is subject to legal privilege, contains confidential information, cannot be retrieved using your name or account number, or as otherwise permitted or restricted by law. We will notify in writing if we refuse an access request, and will document the reasons for refusal and outline further steps that are available to you.

If you wish to notify us of any changes to your Personal Information, if you would like to access your information, if you find any errors in our information about you, or if you have any questions, comments, or suggestions about this privacy policy or Street Contxt’s privacy practices that were not answered here, please contact us by email at: privacy@streetcontxt.com.

10. AMENDMENT OF THIS POLICY

Street Contxt reserves the right to modify or supplement this privacy policy at any time, which will be reflected by the “last modified” date below. Any changes to this privacy policy will apply to information collected from the date of the posting of the revised privacy policy and to existing information held by Street Contxt. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this privacy policy for your reference and revisit this policy from time to time to ensure that you are aware of any changes. Your continued use of the Site and/or Services signifies your acceptance of any changes to this policy.

11. CONTACT US

To find out about Street Contxt’s information-handling practices, or if you have any inquiries, complaints or questions regarding this policy or our information-handling practices, please send an email to privacy@streetcontxt.com or a letter addressed to “Privacy Officer” at 154 Pearl St., Third Floor, Toronto, ON, M5H 1L3.