2. COLLECTION AND USE OF PERSONAL INFORMATION
2.1 Staello Information
To use our Services, Users must have a valid Staello account (“Account”). When you register for an Account, Staello provides you with your account username and password. This information is used to authenticate your account access and provide you with access to the Services. To register for an Account, you must provide your business name, the name and contact details (telephone number and email) of a contact person within your business, your business telephone number and address, billing information, and the email address to be associated with the account which requires verification before logging in. This Personal Information is used for the following purposes:
- Creating User account(s);
- Verifying User email addresses;
- Billing our Users; and
- Contacting our Users about relevant information related to the Services.
Staello will collect and store the above data for both your own and Staello’ records. This information will not be made public.
Staello Users must collect and share with Staello certain Personal Information of their customers, such as customer telephone numbers and/or email addresses. Staello only uses this Personal Information to send electronic communications to the customers of Staello Users for the purpose of providing the Services.
2.2 Third-Party Data
Staello collects publicly available Personal Information from third party sites such as Google and Facebook. This information includes usernames, user statistics, and reviews posted by users of these third-party sites. In some instances, reviews may include Personal Information relating to certain individuals such as a business’ customers or employees.  Staello uses this information to allow Customers to keep track of employee reviews.
2.3 Platform Activity
Users use the Website and Services, Staello collects information about the User’s activity to improve upon the Services and monitor compliance with our Terms of Service. In particular, Staello keeps track of messages sent through Staello’ messaging service, including the date, time and location of sent messages. 
2.4 Marketing Communications
Staello will use the contact information provided to notify Users of important information that is relevant to the Services and for marketing communications if the User chooses to opt in. Despite your indicated e-mail preferences, we may send you relevant notices where permitted by law.
2.5 Usage Data
Staello may also collect certain information from Users of the Website and Services, such as Internet addresses, time spent logged into the Services and other usage data (“Usage Data”). This Usage Data is logged to help diagnose technical problems, and to administer our Website and Services and improve their quality.
2.6 Mobile Data
When you use certain features of our Services, in particular our App we may receive, store and process different types of information about your location, including general information (e.g., IP address, postal code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services or specific features of the platform). If you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details .
2.7 Payment Information
If you subscribe to our services, we will collect your credit card information and/or other payment information, including your billing and shipping address to process payments. 
Technologies such as cookies, beacons, scripts and tags are used by us and our third-party partners. These technologies are used in analyzing trends, administering the website, tracking Users’ movements around the website, and gathering demographic information about our User base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.
Standing alone, cookies do not identify you personally. They merely recognize your browser. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you’ve closed your browser or turned off your computer.
Staello uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Staello to process online matches and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the Service.
Staello uses persistent cookies that only Staello can read and use, to identify the fact that you are a Staello User. We are especially careful about the security and confidentiality of the information stored in persistent cookies.  Users who disable their web browser’s ability to accept cookies will be able to browse our Website but may not be able to use all features of our Services.
3. SECURITY AND STORAGE
3.1 Storage Location
Staello stores its data, including Personal Information, on Amazon Web Services servers located in Canada and the United States . By submitting any Personal Information or using the Services, you agree to the transfer, storing and processing of your Personal Information in Canada and the United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.
The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or password for the Services to third parties.
4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1 Disclosure to our Service Providers
We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our products and services, including the provision of maintenance services, database management, customer relationship management, web analytics and general improvement of the Services, and businesses who engage our Services (to the extent provided for above).
4.2 Business Transfers
If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
4.3 With Your Consent
4.4 As required by law
We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:
- satisfy any applicable law, regulation, legal process or governmental request;
- enforce our contracts or user agreement (Terms of Service), including investigation of potential violations hereof; and
- detect, prevent, or otherwise address fraud, security or technical issues.
6. ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another User. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. Where appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
8. ADDITIONAL INFORMATION
Last Updated: October 26th 2019