This Privacy Statement applies to all of our operations in Canada or our operations in connection with Canada, unless we have provided you with a separate privacy statement for a particular product, service, or activity.

This Privacy Statement is current as of the “Last Updated” date which appears at the top of this document. We may amend this Privacy Statement from time to time, which will become immediately effective when published in a revised Privacy Statement posted on our website unless otherwise noted. We may also communicate the changes through our services or by other means.

This Privacy Statement does not apply to the extent we process Personal Information in the role of a processor or service provider on behalf of our customers, such as your employer or an academic institution (your “Organization”). It is that Organization’s privacy statement that applies; we conduct such activities strictly in accordance with your Organization’s instructions and pursuant to our contractual arrangements with your Organization. This Privacy Statement is intended to complement your Organization’s contract with us to provide the services and to supplement (not replace) your Organization’s own privacy practices. Where a conflict arises between this Privacy Statement and your Organization’s contract with us or your Organization’s privacy practices, your Organization’s agreements and practices will apply.

Your Organization’s administrator can:

• Control and administer our products and services including platform-level settings like creating and suspending user accounts, creating projects, and managing workspace virtual machines.

• Access and process your data including account information, uploaded and processed files, and your logged activities as you use our products and services.

If you are an end user or consumer with an existing relationship with your Organization, you should refer to the Organization’s website to understand their privacy practices and policies.

We are not responsible for your Organization’s privacy or security practices. If you have questions about privacy or wish to exercise your privacy rights, you should contact your Organization.

"Personal Information" means information about an identifiable individual as described under Canadian privacy laws.

In certain circumstances such as for purpose of collection and obtaining consent, Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work e-mail address. However, such information may be subject to individuals’ rights to access and rectify Personal Information depending on applicable Canadian privacy laws.

Personal Information also does not include information that has been anonymized or aggregated in such a way that it is, at all times, reasonably foreseeable in the circumstances that it irreversibly no longer allows identification of an individual, whether on its own or in combination with other information.

We collect, use, and disclose your Personal Information with your consent or as allowed or required by Canadian privacy laws. How we obtain your consent may be express or implied and will depend on the circumstances, as well as the sensitivity of the information collected. If you choose to provide Personal Information to us after we provided access to this Privacy Statement, we assume that you consent to the collection, use, and disclosure of that Personal Information as outlined in this Privacy Statement.

If you wish to withdraw your consent to our collection, use, or disclosure of your Personal Information, please contact us using the contact information in the “How to Contact Us” section below. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

5.1 Products and Services

We may collect information from you or from your use of our products and services, including Pilot. This may include:

• User account information: If your use of our products and services requires a user account, we collect information on behalf of your Organization in order to create your user account, such as your email address when your Organization creates your account, your first and last name and a username when you register your account.

• Your use of our products and services: When you use our products and services, your actions form an audit trail that helps you and your Organization to keep track of who did what and when. We may automatically collect technical and usage data that is identifiable to you when you use our products and services, including your internet protocol address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, mobile or platform device type and other technological information on the devices you may use to access and use our products and services. For example, when you upload a file, a log entry is created that associates your username with the filename and date and time of the upload. This feature is provided to you as a security measure for your data processing activities.

• Content you provide through our products and services: Information you upload, store, process, or create when using our products and services may include any information about you that you decide to include.

• Communications with us: Information you provide when you communicate with our support team, for example, to ask questions, provide feedback, or seek technical support when using our products and services.

We will aggregate and anonymize certain data collected in connection with your use of our products and services, for example, site analytics or usage data, which may be stored and used separately from the data and Personal Information referred to above.

5.2 Website

For individuals who visit our website located at https://www.indocsystems.com or any of our related websites (collectively, “our website”), we may collect information from you or from your activities on the website. Like most websites and other Internet services, we may collect certain technical and device information about your use of our website, which may include your Internet protocol (“IP”) address, information about your device, browser and operating system, and the date and time of your visit, as well as the region or general location where your device is accessing the internet, and other information about the usage of our website, including a history of the pages you view, articles you read, and other behaviours.

If you enter information in the “Contact Us” section of our website, we may collect your name, email address, phone number, Organization you represent and details of your inquiry to enable us to respond to a general/business inquiry made by you on behalf of your company.

5.3 Cookies

We use “cookies” that are technically necessary and ensure the proper functionality of our products and services. In addition to cookies, we may use web beacons, and similar technologies when you use our products and services for our business or analytical purposes, such as assessing traffic on our website and understanding how customers use our products and services.

What are cookies?

Cookies are small pieces of anonymous text stored in your browser to ensure the web-based features of our products and services work as expected. Cookies do not contain personally identifying information and do not give us access to change anything on your device. Data generated from cookies are not used to identify you and are never shared with third parties.

What types of Cookies do we use?

Our products and services use only “strictly necessary” cookies to allow them to function correctly. Examples include:

• Access token: An encoded token that is used to mark user identity and access to services.

• Refresh token: An encoded token that is used to refresh a user's session.

• Username: Username of the current user.

• Login status: Indicates whether or not a user is logged into their user account.

• Terms of Use Notification: Indicates whether or not a user has acknowledged the applicable Terms of Use and Privacy Policy notifications.

We do not use third-party cross-site tracking cookies in our products and services.

How to manage your cookie settings

If you do not wish to accept cookies, your web browser can be set so that you automatically deny the storage of cookies or are informed every time a website requests to be allowed to store a cookie. Previously stored cookies can also be deleted through the web browser. Please refer to your web browser’s help pages for more information. However, please be aware that some areas or features of our products and services rely on cookies and so may not work if you delete or decline cookies. For more information about cookies please visit www.allaboutcookies.org.

5.4 Other Interactions

For individuals who otherwise interact with us, whether in person, by phone or e-mail, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, who attend events hosted by us, or who respond to surveys and questionnaires, we may collect information that you provide to us during these interactions. This information may include your name, e-mail address, demographic information (such as your location, gender and age range), professional information (such as your professional designations and name of your employer), other information relevant and related to your use and interaction with our products and services, and any other information you may elect to provide to us during these interactions.

5.5 Information From Third-Party Companies

We may receive Personal Information or anonymous data about you from companies that offer their products and/or services for use in conjunction with our products and services or whose products and/or services may be linked with ours. For example, our customer service management service provider may provide us with information regarding your service tickets and inquiries. We may add this to the data we have already collected from or about you through other means set out in this section.

Our products and services are not directed at children under the age of thirteen (13), or the age specified by the law in their jurisdiction and we do not knowingly collect Personal Information from children under the age of thirteen (13). Children under the age of thirteen (13) should not use our products and services and should not provide us with Personal Information.

If you become aware that a child has provided us with Personal Information, please contact us at privacy@indocsystems.com.

We use your Personal Information only for the purpose(s) for which it was collected. We may use this information in a number of ways:

• to provide our products and services to you, including to determine your eligibility to register for a user account, providing the functionality of Pilot, and notifying you of changes to our policies or services.

• to communicate with you, including responding to your online support requests, communicating with you by email, responding to your inquiries, complaints, or requests, or providing notices of platform maintenance or outages.

• to protect the integrity and security of our products and services, including monitoring network traffic on our servers, detecting, and preventing errors and fraudulent or malicious usage of our products and services, and confirming your agreement to our Terms of Use. We analyze website usage data strictly for internal purposes.

• to improve our products and services, including to improve the effectiveness and efficiency of our operations, products, services, and programs.

• to comply with the law, if required by legal authorities, including to investigate legal claims and protect our rights, operations, or property.

• to generate de-identified data to conduct research and analysis related to our operations, products, and services.

• for such other purposes as you may consent to from time to time.

• as otherwise required or permitted by law.

We will collect, use, and disclose information received through our websites and products only to pursue our legitimate business interests in keeping you updated on our services and products, respond to your queries, establish communication with you and your company, and to enhance user experience by analyzing your use of our website.

8.1 Sale of Personal Information

We do not sell or rent your Personal Information.

8.2 Use of Third-Party products and Services

We use some tools, service providers, and apps to perform a variety of tasks related to our products and services. This includes third-party tools like helpdesk software, video conferencing software, technical support providers, data storage and processing providers, research and analytics service providers. If we transfer your Personal Information to a service provider, we require that they maintain the confidentiality of your Personal Information and keep it secure. We also require that our service providers comply with applicable privacy laws and process your Personal Information only for the purpose of performing services on our behalf, and that they are not permitted to use or disclose your Personal Information for any other purpose.

8.3 When Required by Law

Additionally, we may use and disclose your personal information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.

8.4 Access by Our Team

Access to Personal Information is restricted to authorized individuals employed or contracted by us who need access to the information in order to perform their job duties. Our employees and individuals hired under contract by us are required to abide by our Confidentiality Agreement and Privacy Policies.

8.5 In Event of Sale or Transfer of Business

If we engage in the sale or transfer of some or all of our business, we may disclose your Personal Information in connection with the transfer or sale but will require the acquiring organization to agree to protect the confidentiality of your Personal Information in a manner that is consistent with this Privacy Statement.

The Personal Information we collect from you is only stored for as long as necessary to fulfill the purpose for which it was collected, and as permitted or required by law.

We may transfer your Personal Information outside of Canada to fulfil the purpose for which we collected it, including for processing and storage by service providers. While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada. Those laws may require disclosure of your Personal Information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, contact us using the contact information in the “How to Contact Us” section below.

The information we collect from you is stored on secure infrastructure and is protected against loss, theft, unauthorized disclosure, copying and unauthorized use or modification through the use of contractual, technological, organizational, and physical controls in accordance with our information security policies and practices.

Despite these measures, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in risks such as phishing and identity theft. In such cases, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.

We may also require that you assist us in safeguarding your Personal Information. For example, if you create an account through our website or products, you should use a unique and strong password and not share your password with others.

If you have reason to believe that your Personal Information is no longer secure, please contact us immediately using the contact information in the “How to Contact Us” section below.

We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products or services from third parties with different privacy practices. Those other websites, products, or services are governed by the privacy statements and policies of the respective third party. This Privacy Statement does not extend to any websites, products, or services provided by third parties. We do not assume responsibility for the privacy practices of third parties and we encourage you to review all third-party privacy statements prior to using third-party websites, products, or services.

12.1 Updating Your Personal Information

We expect you to supply us with updates to your Personal Information, when required. We will not routinely update your Personal Information unless such a process is necessary.

12.2 Awareness and Access To Your Personal Information

You have the right to know if Personal Information about you is being stored, and if so, how it has been used and disclosed. You have the right to access a copy of your Personal Information or request an update or correction to your Personal Information. If you demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend your Personal Information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your Personal Information in our records without first providing you with an estimate of the approximate fees, if any.

Inquiries regarding the Personal Information your Organization holds about you should be directed to your Organization.

If you have questions about our products and services, please contact us at privacy@indocsystems.com. We may need to request more information from you to verify your identity. If we do collect such other information, we will only use it for the purpose of fulfilling your request.

12.3 Resolving Your Concerns

We will do our best to resolve any concerns you may have. If we are unable to resolve your concerns, you may have the right to make a complaint to the Privacy Commissioner of Canada or the applicable provincial privacy commissioner.

The contact information for the Office of the Privacy Commissioner of Canada is 30 Victoria Street, Gatineau, QC K1A 1H3 Canada, or Toll Free: 1-800-282-1376 or www.priv.gc.ca.

If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information in the “How to Contact Us” section below.

Please note that if you opt out from receiving marketing-related e-mails, we may still need to send you communications about your use of our products or services, or other matters.

For more information about our privacy practices, how we collect, use, or disclose your Personal Information, or to request access or corrections to your Personal Information, please contact us at: 

Privacy Officer, Indoc Systems, 1 Richmond Street West, Suite 401, Toronto, ON M5H 3W4, Canada, or by email: privacy@indocsystems.com.

If you have questions about our website or our products and services, please contact info@indocsystems.com.

Changes from June 30, 2024 version of the Pilot Privacy Policy and the July 1, 2023 version of the Indoc Website Privacy Policy

• We merged the Indoc Website Privacy Policy and the Pilot Privacy Policy into a single unified Indoc Systems Privacy Statement that applies to all Indoc Systems products and services.

• We added a Notice to End Users that applies to the processing of your personal information on behalf of another Organization, for example, a company you work for that has purchased a subscription to our products or services.

• We removed an outdated reference to the collection of personal information under the authority of the Ontario Freedom of Information and Protection of Privacy Act (FIPPA).

• We added more detail throughout the Privacy Statement, including a more thorough description of the personal information we collect and how we use and disclose it, and how you can access and update your personal information.