Introduction
Fink Solutions Inc., (hereinafter called “We/we”, or “Us/us” or “Our/our”), a Corporation incorporated in the Province of Quebec, Canada doing business as “Pesabooks” through the Platform including the Website (https://pesabooks.com/) and the Web App (https://app.pesabooks.com/) is committed to protecting your privacy. When you access and use our Platform, you trust us with your data including personal data. In this Privacy Policy, we describe our practices with respect to your data. By reading the Privacy Policy, you will know what data we collect, how we use it, and what rights you have in relation to it. Please take some time to read through it carefully, as it is important. We request you to read Privacy Policy along with the “Terms of Use” posted on the Platform.
What personal data do we collect about you?
The personal data that we collect depends on the context of your interactions with us and the Platform. Briefly stating, we collect the personal data that you voluntarily provide to us including the Email Address. You cannot modify your email once you have signed up on the Platform.
For what purposes do we process, or utilize your data?
(i) To make it possible for you to register or signup on the Platform by creating a personal user account or personal user profile on the Platform;
(ii) To make it possible for you to sign in and use the Platform;
(iii) For email authentication, email transactions, and email marketing;
(iv) To personalize and customize your experience based on your interactions with us;
(v) To protect our Platform as part of our efforts to keep our Platform safe and secure, from any suspected activities;
(vi) To respond to legal requests and prevent harm to you or to us. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond; (vii) To attend and manage your requests to us; (viii) To otherwise interact with you for any other legitimate purpose or activities.
What is the legal basis for processing your personal data?
We may process personal data under the following conditions:
(i) You have given your consent for processing personal data for one or more specific purposes;
(ii) Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
(iii) Processing personal data is necessary for compliance with a legal obligation to which you are subject;
(iv) Processing personal data is necessary in order to protect your vital interests or of another natural person;
(v) Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested with us;
(vi) Processing personal data is necessary for the purposes of our legitimate interests pursued by us.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Will your data be shared with anyone?
We only share your data with your prior consent, to comply with laws, protect your rights, or fulfill our business obligations.
We may share or disclose your data where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). We may disclose your data where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
We may share or transfer your data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. This will be done with your prior written permission and requiring the other party to comply with this Privacy Policy. We may disclose your data for any other purpose with your prior consent.
Do we use Website analytics?
Yes, we use Google Analytics to monitor and analyze your use of the Platform.
How long do we retain your data?
The users may repeatedly use the Platform for any amount of time on an ongoing basis. Hence, we would retain your data on a continuing basis without deleting it. This is done for your convenience only. However, you may reach out to us at Support@pesabooks.com, if you do not want us to retain your data. If you request us to delete your data, we will do our best to delete most of your data. But please remember that it will not be possible for us to delete all of your data. Some data, for example, your interaction history, etc. will still be retained by us for record purposes or to comply with any legal obligations.
How do we secure and protect your data?
We take due care to protect your data. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal data. We take reasonable steps to help protect your data in an effort to prevent the loss, misuse, unauthorized access, disclosure alteration, and destruction. The data you provide to us is shared on our secure servers. We have implemented appropriate physical, technical, and organizational measures to secure your data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data on a need-to-know basis to those employees or third parties that have a legitimate business need for such access.
If you are concerned about your data, you have the right to request access to the personal data which we may hold or process about you. At any stage, you also have the right to ask us to stop using your personal data for direct marketing purposes. However, please also remember that we cannot guarantee that anything on the internet itself is completely secure. Although we will do our best to protect your data, the transmission of data to and from our Platform is at your own risk. You should only access the Platform within a secure environment.
How do we transfer your data?
Your data is processed at our operating offices in the Province of Quebec, Canada, and in any other places where the parties involved (third-party service providers) in the processing are located. It means this data may be transferred to and maintained on devices outside of your state, province, country, or other legal jurisdiction where the data protection laws may differ from those of your jurisdiction. Your consent to this Privacy Policy followed by your submission of such data represents your agreement to the transfer of your data across the borders of your legal jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data.
How should a minor or child access or use our Platform?
In case you are a minor or a child in the jurisdiction, country, or territory in which reside or are domiciled and you are about to access the Platform or are accessing the Platform, you agree and confirm that you have obtained the permission of your parents or guardians before accessing or using the Platform and shall continue to do so under the absolute supervision of your parents or guardians and we shall not be liable to verify your compliance in this regard.
Do Not Track
If you are a user from the State of California (USA), you must note that we currently do not recognize or respond to Do Not Track signals. “Do not Track” is a privacy preference that some users can set in certain web browsers.
If you are a citizen or resident of the European Union, what are your rights under the GDPR (General Data Protection Regulation)?
We respect the confidentiality of your personal data. We will provide you with complete support in exercising your rights. You have the right under this Privacy Policy, and by law, if you are within the European Union, to:
(i) The right to access, update or delete the data we have about you. Whenever made possible, you can access, update or request deletion of your personal data directly by contacting us. This also enables you to receive a copy of the personal data we hold about you;
(ii) You have the right to have corrected any incomplete or inaccurate data we hold about you;
(iii) This right exists where we rely on legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object to where we are processing your personal data for direct marketing purposes;
(iv) You have the right to ask us to delete or remove your personal data when there is no good reason for us to continue processing it;
(v) You have the right to withdraw your consent to use your personal data. If you withdraw your consent, you may not be able to use our Platform or we may not be able to provide you with access to the Platform.
How can you exercise your GDPR data protection rights?
You may exercise your rights of access, rectification, cancellation, and opposition by contacting us at Support@pesabooks.com. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
Do we make updates to this Privacy Policy?
We may update this Privacy Policy from time to time. The updated version will be indicated by the “Last Updated and Effective Date” displayed at the start of the Privacy Policy and the updated version will be effective as soon as it is posted on the Platform. If we make substantial changes to this Privacy Policy, we may notify you through email. We expect you to read the updated Privacy Policy carefully and only then proceed ahead to use our Platform.
How can you contact us?
If you have any questions regarding this Privacy Policy, please contact us at Support@pesabooks.com.