Last updated on January 7, 2025
At CODEVISION, protecting privacy is a key priority. The purpose of this document is to set out how CODEVISION Inc. and its affiliates (“us,” “our,” or “we”) collect, use, store, or otherwise process personal information about customers and other individuals (collectively “you”) who access or use our websites, including CODEVISION.ca, our mobile applications, our web client or professional client, and/or any of our other websites, products, or services that link to this Privacy Notice (the “Services”). By using our Services, you understand that we will collect and use your personal information as described in this Privacy Notice.
In some cases, we may process your personal information pursuant to an agreement with a third-party organization. In those cases, the terms of that agreement may govern how we process your personal information. If you believe a third-party organization has asked us to process your personal information on their behalf, please consult with them in the first instance, as they will be responsible for how we process your information. This Privacy Notice (“Notice”) does not apply to any third-party websites and apps that you may use, including those to which we link in our Services. You should review the terms and policies for third-party websites and apps before clicking on any links.
CODEVISION’s core product and Services help users create, complete, and show the validity of digital or electronic transactions, such as electronically signing a contract for mobile phone services or placing a digital App on a loan application. As part of our Services, users want us to collect and record information that helps the parties prove the validity of the transactions, such as the names of the persons who are involved in the transactions and the devices those persons use.
We recommend that you read this Notice in full to ensure you are fully informed about the way we collect, use, store, or otherwise process your personal information as well as your privacy rights.
You have choices about whether you visit our websites, install our apps, or provide personal information to us. However, if you do not provide us with certain personal information, you may not be able to use some functionalities of our Services. For example, if you do not adopt an electronic App, then you will not be able to sign certain electronic documents on our Service. For choices and rights you may have, please see Sections 5 and 8 of this Notice.
Personal Information We Collect from You. You provide us with personal information about yourself when you:
You also provide us with personal information about others when you use parts of our Services, such as when you:
Your main choice for this type of personal information is simply not providing it, such as by not creating a profile or not leaving a comment in a blog. For other choices you may have, please see Section 5 of this Privacy Notice.
Examples of the categories of personal information you may provide are:
Personal Information We Collect Automatically. We may automatically collect personal information from you and your devices when you use our Services, including when you visit our websites or apps without logging in. For choices you may have on what information we automatically collect, please see Section 5 of this Privacy Notice.
We collect personal information about how you use our Services and the devices (e.g., computers, mobile phones, tablets) you use to access our Services. This may include, but is not limited to, the following:
Some of the information we collect automatically is captured using cookies, which are text files containing small amounts of information that are downloaded on your device or related technologies, such as web beacons, local shared objects, and tracking pixels, to collect and/or store information. For additional information about cookies and related technologies, including details of how to opt-out, please read our Cookies Notice below and “Your Privacy Rights and Choices” below.
Personal Information We Collect from Other Sources. Subject to applicable law, we may collect personal information about you from others, such as:
Personal Information We Collect & Process on Behalf of Customers. When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For example, in the context of the PDF-VISION App, when a customer uploads contracts or other documents for review or App, we act as a data processor and process the documents on the customer's behalf and in accordance with their instructions. In those instances, the customer is the data controller and is responsible for most aspects of the processing of the personal information. We may act as a processor and as a controller in certain circumstances (e.g., retention of transactional data to comply with CODEVISION’s legal obligations). If you have any questions or concerns about how personal information is processed in these cases, including how to exercise your rights as a data subject, you should contact the customer (either your employer or the individual or entity requesting your App). If we receive any rights requests concerning instances where we act as a data processor, we will forward your query on to the relevant customer.
In general, and subject to applicable law, we will use your personal information to provide, maintain, and improve our Services, develop new Services, and market our CODEVISION products and Services. Please see the section below entitled “Further Information on the Personal Information We Process and Our Purposes,” which provides more specific information on these purposes, examples of the types of information processed for these purposes, and the lawful bases (i.e., legal grounds) on which we rely to process it.
Lawful Basis for Processing Your Personal Information. If applicable data protection law requires a lawful basis for processing, and where CODEVISION acts as a data controller, our lawful basis for collecting and using the personal information described in this Notice will depend on the type of personal information concerned and the specific context in which we collect or use it.
We normally collect or use personal information only where we need the personal information to perform a contract with you or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or may need the personal information to protect your vital interests or those of another person. In certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal data.
If we process sensitive personal information about you, as well as ensuring that one of the lawful bases referenced above applies, we will make sure that one or more of the grounds for processing sensitive personal information applies.
Note that in situations where CODEVISION acts as a processor, it is our customer who determines the appropriate legal basis associated with processing activities, and queries about the applicable lawful basis should be directed to them.
Further Information on the Personal Information We Process and Our Purposes
The table below provides more specific information on our purposes, the types of information that may be processed, and the legal bases on which we process it. The examples provided in the table cannot, of course, be exhaustive.
Depending on the jurisdiction in which you live, there may be other applicable lawful bases for processing your personal information that are not listed here. If you have questions about our lawful bases or need further information, please contact us using the contact details provided in Section 11 of this Notice.
| Purpose | Examples of personal information that may be processed | Lawful basis for processing |
|---|---|---|
| Provide you with and collect payment for the products and Services you request | Identifiers and Contact Information Commercial Information Account Data Contact and Image Data Customer Service and Communications Information Transactional Data Device Data Location Data | Contract Consent (in the case of processing of Location Data) |
| Create your account and manage your relationship with us (e.g., communicating with you, providing you with requested information) | Identifiers and Contact Information Account Data Contact and Image Data Customer Service and Communications Information Location Data | Contract Legitimate interests (to operate, provide and improve the Services; or to communicate with you, where our communications are not necessary to perform or enter into a contract with you). Consent (in the case of processing of Location Data) |
| Record details about transactions involving electronic documents (e.g., who initiated, viewed, or signed the documents; signers’ IP addresses; timestamps) | Identifiers and Contact Information Account Data Contact and Image Data Customer Service and Communications Information Location Data | Contract Legitimate interests (to operate, provide and improve the Services) |
| Gather and record data associated with the use of a digital certificate or digital App | Identifiers and Contact Information (specifically, your electronic App) Transactional Data | Contract Legal obligation |
| Maintain and improve the security of the Services | Account Data Device Data Usage Data Transactional Data Location Data | Legitimate interests (to operate, provide and improve the Services; to detect or prevent illegal activities; and to manage the security of our IT infrastructure and the Services, and the safety and security of our employees, customers and vendors). |
| Troubleshoot the Services, including answering support questions, customer education and training, and resolving disputes | Identifiers and Contact Information Account Data Customer Service and Communications Information Device Data Usage Data Transactional Data | Legitimate interests (to operate, provide and improve the Services; and to communicate with you). |
| Prevent, investigate, and respond to fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior | Identifiers and Contact Information Account Data Device Data Usage Data Transactional Data Location Data | Contract Legitimate interests (to operate, provide and improve the Services; to detect or prevent illegal activities; and/or to manage the security of our IT infrastructure and the Services, and the security of our employees, customers, and vendors). |
| Analyze, improve, and enhance the Services and research and develop new features and products | Customer Service and Communications Information (more specifically, any product feedback you provide via surveys) Device Data Usage Data Transactional Data Location Data | Consent (where required by applicable law) Legitimate interests (to operate, provide and improve the Services; and use insights to research and develop new products and services). |
| Building, training and maintaining our artificial intelligence models through machine learning that power certain of our Services using de-identified Customer Data (with customer consent) | Customer Data (as defined in CODEVISION Master Services Agreement or CODEVISION Sites & Services Terms and Conditions (as applicable)) Usage Data Transactional Data | Consent (where required under applicable law) Consent (in the case of processing Location Data) |
| Choose and deliver content and tailored advertising, support the marketing and advertising of our Services and measure the effectiveness of our campaigns | Account Data Usage Data Marketing and Advertising Data | Consent (where required under applicable law) Legitimate interests (to improve our business; to promote our products and services; and to use the insights to improve or develop our marketing activities). |
| Send you information about new features, products, or special events by email or phone or send you marketing communications about third-party products and services we think may be of interest to you | Identifiers and Contact Information Marketing and Advertising Data | Consent (where required under applicable law) Legitimate interests (to improve our business; to promote our products and services; and to develop marketing activities) |
| Run surveys sweepstakes, contests, and refer-a-friend programs | Identifiers and Contact Information Your Account Data Other Contact Data Customer Service and Communications Information | Legitimate interests (to drive customer engagement; to promote our products and services; and to collect user feedback) |
| Comply with legal and regulatory obligations to which we are subject | Identifiers and Contact Information Account Data Commercial Information Transactional Data Location Data Customer Service and Communications Information | Legal obligation |
| Protect our legal rights, for example to establish, exercise, or defend our rights in legal claims | Any information relevant or potentially relevant to a dispute or legal proceeding affecting us. | Legitimate interests (to protect our business interests) |
Other Uses. We may aggregate the personal information we collect, or insights generated or derived from the use of our Services or remove pieces of personal information (“de-identify”) to limit or prevent identification of any particular user or device to help with goals like marketing, research and product development (including training our artificial intelligence models that power certain of our Services). Where such information has been aggregated and anonymized so that it is no longer considered personal information under applicable data protection law, this Notice does not apply.
AI Model Training. AI models must be trained to perform accurately. Through training, an AI model learns to recognize patterns and make predictions. CODEVISION has implemented role-based access controls and technical and organizational security measures to help minimize the privacy impact to individuals when we train our AI models. We intentionally design our systems with functionality to avoid training models using personal information that customers may enter our Services (except when we have consent from a customer to do so).
Subject to applicable law, including to the extent applicable law requires us to obtain consent, we may disclose personal information as follows:
Your personal information may also be disclosed as described below:
User-Generated Content When you comment on our blogs or in our community forums, this information may also be read, collected, and used by others.
Profile Information When you create a CODEVISION profile, other CODEVISION users can view your profile information. If you would like to make this information private, please visit your account settings.
We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our data retention policy and information handling standards. Generally, this means we retain your personal information to comply with any retention compliance obligations or statutory requirements or for purposes of performing a contract with you. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it through implementing appropriate organizational technical and security measures.
This section describes many of the actions you can take to change or limit the collection, use, storage, or other processing of your personal information.
Rights Regarding Your Personal Information. You may have certain rights related to your personal information, subject to local data protection laws, as described in more detail below. To exercise any of these rights, please contact us via: info@codevision.ca. If you are a California resident, you can find more information about your rights with respect to your personal information in Section 8 (“Notice to California Residents”) below.
If you make a request to exercise the rights referenced above, we will require you to provide certain information for identity verification purposes. If you have an account with us, we may verify you through your login of your account. If you do not have an account with us, we may require you to provide additional information from which we can confirm your identity. You may authorize an agent to make a request to us on your behalf and we will verify the identity of your agent or authorized legal representative by either seeking confirmation from you or documents that establish the agent’s authorization to act on your behalf.
Certain personal information may be exempt from such requests under applicable law. We need certain types of personal information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services.
If you wish to exercise these rights, please contact us via: info@codevision.ca.
Right to Opt-Out of Sales of Personal Information and Processing of Personal Information for Targeted Advertising Purposes. Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “processing of your information for targeted advertising purposes.”
As explained in Section 3 (“Disclosure of Your Personal Information”) above, we sometimes disclose information to third-party partners that help us market our products and services to you across platforms. This disclosure of information may be considered a “sale” or “processing of your personal information for targeted advertising purposes” under applicable laws.
If you would like to opt out of such “sales” or “processing” for targeted advertising purposes through cookies and similar online technologies, please click on the “Your Privacy Choices” link in our website footer. To opt out of these activities that are not based on cookies, please email us at: info@codevision.ca. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.
Please note that if you have a legally recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
Our Services are not designed for and are not marketed to people under the age of 18 or such other age designated by applicable law (“minors”). We do not knowingly collect or ask for personal information from minors. We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or send us your personal information. We delete personal information that we learn is collected from a minor without verified parental consent. Please contact us if you believe we might have personal information from or about a minor that should be removed from our system.
In addition to the other information and rights described in this Privacy Notice, California residents are also entitled to certain additional information and have certain additional rights under the California Consumer Privacy Act (“CCPA”) with respect to their personal information. If you are a resident of California (a “Consumer” as defined by the CCPA), this section of the Privacy Notice applies to you. If you are not a Consumer, this section does not apply to you and you should not rely on it.
A. Information We Collect and How We Use and Disclose It
Below is a summary of the categories of personal information – including sensitive personal information – that we have collected in the past 12 months leading up to the effective date of this Notice, as well as the purposes for which we use the information and the categories of third parties to whom we disclose or “sell/share” the information.
| Categories of Personal Information Collected | Purpose of Use | Categories of Third Parties to Which Information is Disclosed for Business Purposes | Categories of Third Parties to Which Information is Sold/Shared |
|---|---|---|---|
| Identifiers (e.g., name, email address, physical address, phone number, electronic App, device identifiers) | Provide and collect payments for the Services. Communicate with you. Market our or third parties’ features, products, or special events that may be of interest to you. Run sweepstakes, contests, and refer-a-friend programs. Choose and deliver tailored content and advertising. Analyze and improve the Services and develop new features and products. Troubleshoot the Services, including answering support questions and resolving disputes. Manage the Services platform, including support systems and security. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Comply with legal obligations. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Payment processors Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent | Advertising and marketing partners |
| Commercial information, including financial or payment information and transaction information | Provide and collect payments for the Services. Analyze and improve the Services and develop new features and products. Troubleshoot the Services, including answering support questions and resolving disputes. Manage the Services platform, including support systems and security. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Comply with legal obligations. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Payment processors Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Other parties to the transaction (transaction history information only) | N/A – we do not sell/share this information |
| Customer service information (e.g., questions and other messages you address to us directly through online forms, by email, over the phone, or by post) | Provide the Services. Communicate with you. Analyze and improve the Services and develop new features and products. Troubleshoot the Services, including answering support questions and resolving disputes. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Comply with legal obligations. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent | N/A – we do not sell/share this information |
| Internet or other electronic network activity information (e.g., IP address, device identifiers, and device attributes, cookie IDs, data about how you interact with the Services) | Provide the Services. Market our or third parties’ features, products, or special events that may be of interest to you. Choose and deliver tailored content and advertising. Analyze and improve the Services and develop new features and products. Troubleshoot the Services, including answering support questions and resolving disputes. Manage the Services platform, including support systems and security. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Comply with legal obligations. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent | Advertising and marketing partners |
| Geolocation data, including your approximate location based on IP address or wifi triangulation or precise GPS location with your consent and consistent with your device settings | Provide the Services. Market our or third parties’ features, products, or special events that may be of interest to you. Choose and deliver tailored content and advertising. Analyze and improve the Services and develop new features and products. Troubleshoot the Services, including answering support questions and resolving disputes. Manage the Services platform, including support systems and security. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Comply with legal obligations. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent | Advertising and marketing partners |
| Information about others, such as if you submit information about other parties to a transaction or for a refer-a-friend program | Provide the Services. Market our or third parties’ features, products, or special events that may be of interest to you. Run sweepstakes, contests, and refer-a-friend programs. Analyze and improve the Services and develop new features and products. Troubleshoot the Services, including answering support questions and resolving disputes. Manage the Services platform, including support systems and security. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Comply with legal obligations. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent | N/A – we do not sell/share this information |
| Inferences drawn from the above information | Provide the Services. Market our or third parties’ features, products, or special events that may be of interest to you. Choose and deliver tailored content and advertising. Analyze and improve the Services and develop new features and products. Troubleshoot the Services, including answering support questions and resolving disputes. Manage the Services platform, including support systems and security. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Affiliates Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent | Advertising and marketing partners |
| Sensitive personal information including username/password and credit card or financial account number | Provide the Services. Manage the Services platform, including support systems and security. Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior. Comply with legal obligations. Meet legal retention periods. Establish, exercise, or defend our rights in legal claims. | Service providers Payment processors (credit card and financial account number only) Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent | N/A – we do not sell or share this information |
B. The Right to Opt-Out of Sales/Sharing of Personal Information
Consumers have the right to opt out of “sales” of their personal information or “sharing” of their personal information for cross-context behavioral advertising purposes under the CCPA. As explained in our Privacy Notice above, we may allow third-party advertising and marketing technologies and parties that support our advertising and marketing efforts (e.g., ad networks, ad measurement services, advertising analytics providers, remarketing providers, etc.) on our Services that use cookies and similar technologies to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use. This type of information collection and disclosure can be considered to be a “sale” or “sharing” for cross-context behavioral advertising purposes under the CCPA.
Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.
If you would like to opt out of such “sales” or “processing” for targeted advertising purposes through cookies and similar online technologies, please click on the “Your Privacy Choices” link in our website footer. To opt out of these activities that are not based on cookies, please email us at info@codevision.ca. If you have a legally recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
C. Information Rights
Consumers have other rights with respect to their Personal Information under the CCPA. This includes the right to request that we:
You may have the right to receive information about the financial incentives that we offer to you (if any). You have the right not to be discriminated against for exercising your CCPA rights. We will not deny, charge different prices for, or provide a different level of quality of goods or services with respect to Consumers who choose to exercise their CCPA rights.
Consumers may submit requests to access, delete, or correct their personal information using any of the following methods:
For security purposes, we will attempt to verify your identity prior to fulfilling your request. If you have an account with us, we may verify your identity through your login to your account. If you do not have an account with us, we may need to respond to your request or otherwise contact you to request additional information from you to verify your identity (including, but not limited to your name, email address, or telephone number).
If we can verify your identity, we will respond to your request to the extent we are able to and as required by law. If we cannot verify your identity, we may request additional information from you or we may deny your request. If we are unable to fulfill your request in its entirety, we will provide further information to you about the reasons that we could not comply with your request.
Certain personal information may be exempt from such requests under applicable law. In addition, we need certain types of personal information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services.
D. Authorized Agents
Consumers may designate an agent to make CCPA requests on their behalf. For Consumers who do so, we will take steps to verify both the identity of the consumer seeking to exercise their rights as described above, and to verify that the consumer’s agent has been authorized by them to make a request on their behalf by requesting a signed written authorization or a copy of a power of attorney.
E. “Shine the Light”
California residents may ask for a list of third parties that have received your personal information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information shared. We provide this list at no cost. If you are a California resident and would like to request this information, please contact us via: info@codevision.ca.
We have implemented appropriate technical, physical, and organizational measures to protect your personal information from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access, as well as all other forms of unlawful processing. To achieve this, we have developed and implemented an Information Security Management System and other sub-policies and guidelines relating to the protection of your personal information. For example, our staff is permitted to access customer personal information only to the extent necessary to fulfill the applicable business purpose(s) and to perform their job, subject to confidentiality obligations.
We may amend this Notice to reflect changes in the law, our companies, our Services, our data processing practices, or advances in technology. Our use of the personal information we collect is subject to the Privacy Notice in effect at the time such personal information is used. Depending on the type of change, we may notify you of the change by posting on this page.
For questions or complaints regarding our use of your personal information or this Notice, please contact us via: info@codevision.ca.
If you reside in one of the following countries, the below Privacy Notice also applies to the processing of your personal information. To the extent there is a conflict between the country-specific language below and the provisions above, the below provisions control to the extent of that conflict.
Canada