Last modified: February 8, 2024
1. Introduction
Cradle, Inc. and our affiliates and subsidiaries ("Cradle" or "We") respect your privacy and are committed to protecting it by complying with this policy. We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.
This policy describes how we collect, use, disclose, and protect the personal information of our customers and website users ("you") and the types of information we may collect from you or that you may provide when you visit the website www.cradleaccounting.com ("Website").
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
2. Information we collect about you
We collect and use several types of information from and about you, including:
· Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, social insurance number, payment data, financial information and any other identifier we may use to contact you ("personal information").
· Business-related information, namely information that related to your business duties, including, title, duties, business address, business email address; and business telephone number.
· Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
· Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
· Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
3. How we collect information about you
We use different methods to collect your information, including through:
· Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
· Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, beacons, and other tracking technologies.
· Third parties or publicly available sources, for example, our business partners.
Information You Provide to Us
The information we collect directly from you on or through our Website may include:
· Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, uploading material, and requesting further services. We may also ask you for information when you report a problem with our Website.
· Records and copies of your correspondence (including email addresses), if you contact us.
· Details of transactions you carry out through our Website. You may be required to provide financial information before placing an order through our Website.
When you submit the personal information of your customers or employees to us, you are responsible for informing such customers and employees about Cradle, and for obtaining any necessary consent or authority from them, including informing them that Cradle operates within Canada and globally and utilizes service providers within the United States. In addition, your personal information will be accessed by Cradle personnel outside of Canada and the United States for business purposes.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
· Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
· Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
· Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Cradle, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
4. Legal basis for processing
Our legal basis for processing personal information is our legitimate interests to conduct our business and the proper management of our customer relationships.
5. Retention
We will retain personal information for as long as we have a business relationship. After that we may retain your personal information for a maximum of 36 months, following the end of our business relationship.
6. How we use your information
We use information that we collect about you or that you provide to us, including any personal information:
· To present our Website and its contents to you.
· To provide you with information, products, or services that you request from us.
· To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
· To provide you with notices about your subscription, including expiration and renewal notices.
· To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
· To notify you about changes to our Website or any products or services we offer or provide though it.
· To improve our Website, products or services, marketing, or customer relationships and experiences.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
7. Disclosure of your information
We may disclose personal information that we collect or you provide as described in this privacy policy:
· To our subsidiaries and affiliates.
· In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cradle Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cradle, Inc. about our customers and users is among the assets transferred.
· To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
· To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
· To enforce or apply our terms and conditions (https://www.cradleaccounting.com/legal/terms-and-conditions) and other agreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cradle Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
8. Transferring your personal information
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
9. Choices about how we use and disclose your information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.
10. Your GDPR Privacy Rights
You have a number of rights in connection with the processing of your personal data, subject to certain conditions set out in the GDPR, US state and federal laws and local data protection laws, including the right to:
· Request access to your personal information (“data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
· Request the rectification of the personal information that we process about you. This enables you to have incomplete or inaccurate data we hold about you corrected.
· Request the deletion of your personal information. This enables you to ask us to delete or remove personal data where there is no overriding reason for us to retain it.
· Ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your personal data to another party.
If you have given your consent for processing of your personal information and that consent has served as a legal basis for processing, you can withdraw this consent at any time with future effect by contacting us.
11. Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
· Confirm whether we process their personal information.
· Access and delete certain personal information.
· Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
· Data portability.
· Opt-out of personal data processing for:
· targeted advertising (excluding Iowa);
· sales; or
· profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
· Either limit (opt-out of) or require consent to process sensitive personal data.
The exact scope of these rights may vary by state. To exercise any of these rights please contact us.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to us. However, please know we do not currently sell data triggering that statute's opt-out requirements.
12. Data security
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not completely secure. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
13. Data retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
14. Children under the age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
15. Accessing and correcting your personal information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
You can review and change your personal information by logging into the Website and visiting your account profile page.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.
If you are concerned about our response or would like to correct the information provided, you may contact us at [email protected]
16. Withdrawing your consent
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [email protected]. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
17. Changes to our privacy policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you [by email to the primary email address specified in your account.
We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
18. Contact information and challenging compliance
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at [email protected].
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above.