At P2P Group Ltd. (“P2P Group”), we are committed to providing our clients, customers and members with exceptional service. As providing our services (“Services”) involves the collection, use and disclosure of some personal information about our clients, customers and members, protecting their personal information is one of our highest priorities.
While we have always respected our clients, customers and members privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s (“B.C.”) Personal Information Protection Act (“PIPA”). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses may collect, use and disclose personal information.
We will inform our clients, customers and members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Privacy Policy (“Policy”), in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’, customers’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’ and members’ personal information and allowing our clients, customers and members to request access to, and correction of, their personal information.
This Privacy Policy applies to P2P Group on its own behalf and its affiliates and/or wholly owned subsidiaries (collectively “P2P Group” “we” “us” or “our”).
This Policy also applies to any service providers collecting, using or disclosing personal information on behalf of P2P Group.
This Policy applies to visitors of the following publicly available website(s): https://www.inturai.com/ and all the publicly available associated domains and mobile applications owned and operated by P2P Group (collectively, the "Websites"). For the purposes of this Disclaimer, "you" and "your" means you as the visitor of the Websites.
This Policy describes the types of Personal Information we collect from visitors of our public Websites and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us.
Personal Information –means information about an identifiable individual that we collect through your use of the Websites may include IP Address, Device ID, and online identifier. We may use that Personal Information and link it to Internet or other electronic network activity information, and we may draw inferences about you from the information we collect. We may also collect your name, title, business contact information, phone number, date of birth, state, country, zip code, your health plan, email address or login identification information only if you provide such information directly to us when you begin registration to use our services or complete a web form seeking more information. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that P2P Group complies with this policy and PIPA.
1.1 Unless the purposes for collecting personal information are obvious and the client, customer and member voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client, customer and member information that is necessary to fulfill the following purposes:
2.1 We may collect Personal Information using the following methods:
"Cookies" are small files that a website stores on a user's computer or device. The Websites may use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Websites and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (see below). As required under applicable laws, we will obtain your consent necessary for utilizing cookies or similar tracking technologies.
2.2 Our Websites may use Google Analytics, a vendor's service that uses cookies, web beacons, web pixels and/or similar technology to collect and store information about you. You can learn more about Google Analytics' privacy policy and ways to opt out from Google Analytics tracking by visiting Google Analytics' website.
2.3 Our Websites may use Adobe's analytics and on-site personalization services, which use cookies, web beacons, web pixels and/or similar technology to collect and store information about you or your device or browser. You can learn more about how Adobe may handle information collected through our use of its services, and your options for controlling this activity, by visiting Adobe's website.
3.1 We will obtain client, customer and member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
3.2 Consent can be provided electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer and member voluntarily provides personal information for that purpose.
3.3 Consent may also be implied where a client, customer and member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer and member does not opt-out.
3.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, customers and members can withhold or withdraw their consent for P2P Group to use their personal information in certain ways. A client’s, customer’s and member’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client, customer and member in making the decision.
3.5 We may collect, use or disclose personal information without the client’s, customer’s and member’s knowledge or consent in the following limited circumstances:
We will only use or disclose client, customer and member personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
4.2 We will not use or disclose client, customer and member personal information for any additional purpose unless we obtain consent to do so.
4.3 Personal information collected by P2P Group may be stored or accessed outside Canada. When transferring data internationally, we ensure that it is subject to protections equivalent to those required by Canadian privacy laws, using contractual agreements and secure technology to safeguard the data.
5.1 Certain features of the Websites permit you to initiate interactions between the Websites and third-party services or platforms, such as social networks ("Social Features"). Social Features include features that allow you to click and access P2P Group's pages on certain third-party platforms, such as Facebook, Twitter and LinkedIn as applicable, and from there to "like" or "share" our content on those platforms. Use of Social Features may entail a third party's collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both P2P Group and the third party may have access to information about you and your use of both the Websites and the third-party service. P2P Group has no control over and is not responsible for the privacy practices of such third parties. This Privacy Policy does not apply to the extent P2P Group does not own or control any linked websites or features you visit or use. We recommend that you familiarize yourself with the privacy practices of those third parties.
6.1 Our Websites may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook, LinkedIn or Twitter) may also be viewable by other users of the Websites and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Websites. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.
7.1 As discussed above, on our Websites we may collect and disclose Personal Information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy Policy provides details and explains how to exercise your choices. You may see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons (also known as pixels). The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the webpages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.
7.2 You may disable or delete browser cookies through your browser settings. Cookies generally are easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts or functionality of our Websites may not work properly.
7.3 Each type of web browser offers ways to restrict and delete cookies. For more information on how to manage cookies visit the appropriate link at individual web browser.
We generally retain records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature, and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements. Because we maintain our Websites to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.
8.2 Subject to policy 8.1, we will retain client, customer and member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose. We securely dispose of personal information when it is no longer necessary using appropriate destruction methods.
We will make reasonable efforts to ensure that client, customer and member personal information is accurate and complete where it may be used to make a decision about the client, customer and member or disclosed to another organization.
9.2 Clients, Customers and Members may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. You have the right to access and correct your personal information held by P2P Group. To request access or correction, please submit a written request to our Privacy Officer. We will respond to your request within 30 business days, or provide a timeline if an extension is needed.
9.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’, customers’, members’ correction request in the file.
10.1 We are committed to ensuring the security of client, customer and member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
10.2 We take steps to secure Personal Information through administrative, technical, and physical safeguards designed to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. The following security measures will be followed to ensure that client, customer and member personal information is appropriately protected:
10.3 We will use appropriate security measures when destroying client’s, customer’s and member’s personal information such as deleting electronically stored information.
10.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
11.1 Clients, Customers and Members have a right to access their personal information, subject to limited exceptions for example solicitor-client privilege, disclosure would reveal personal information about another individual or health and safety concerns.
11.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
11.3 Upon request, we will also tell clients, customers and members how we use their personal information and to whom it has been disclosed if applicable.
11.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
11.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client, customer and member of the cost and request further direction from the client, customer and member on whether or not we should proceed with the request.
12.1 This Policy may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Policy from time to time to view any such changes.
13.1 The Privacy Officer or Legal Counsel is responsible for ensuring P2P Group’s compliance with this policy and the Personal Information Protection Act.
13.2 If you have concerns about our handling of your personal information, please contact our Privacy Officer. We aim to respond to complaints within 30 days. If we cannot resolve your complaint, you may contact the Information and Privacy Commissioner of British Columbia for further assistance.
Contact information for P2P Group’s Privacy Officer or Legal Counsel:
P2P Group Ltd.
Suite 650, 1231 Pacific Blvd.,
Vancouver, British Columbia,
V6Z 0E2, Canada.
Attention : Privacy Officer / Legal Counsel
Email : Privacy@p2p-group.com
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