This Privacy Policy was last updated May 2019 (V. 2.0).

BriteSky Technologies Inc. (“BriteSky”, “we” or “our”) understands the value of your personal information and we respect your right to privacy. We are committed to maintaining your confidence and trust. This commitment includes protecting the personal information that we obtain from you.

This Policy describes the practices that BriteSky follows with respect to the collection, processing, use and disclosure of personal information provided to us both on-line and off-line by website users, employees, contractors, agents and existing/prospective customers. In this Policy, the individuals described in the previous sentence are referred to as “you” or “your”.

Websites accessed from www.britesky.ca via hyperlinks or links to other sites may be governed by privacy policies and practices that differ from this Policy. The information practices of other third party websites linked to www.britesky.ca are not covered by this Policy. You are encouraged to become familiar with the privacy policies and practices of every website you visit prior to disclosing any personal information.

By using www.britesky.ca, you signify your acceptance of this Policy, as amended from time to time in accordance with Section 10 below. If you do not agree with the terms and conditions contained in this Policy, please do not use this website.

1. Accountability

BriteSky is responsible for maintaining and protecting the personal information under its control. Our Privacy Officer is responsible for analyzing all personal information handling practices at BriteSky and ensuring that this Policy is up-to-date at all times. On occasion, specific Policy responsibilities may be assigned by our Privacy Officer to other BriteSky staff members.

Our Privacy Officer may be contacted via email at privacy@britesky.ca.

2. Identifying Purposes – Why We Collect Personal Information

In general, we use your personal information in several ways:

    • To fulfill your requests and process your transactions.
    • To respond to your email messages.
    • To support your customer relationship with BriteSky. For example, if you provide us with an e-mail or postal address, you may receive mailings from BriteSky with marketing material and/or sales information concerning special events or offers, new services or products. You can unsubscribe to mailings from us at any time. Please refer to Section 5 of this Policy for details on the “opt-out” process.
    • To process responses to employment opportunities posted on www.britesky.ca. For example, if you submit a resume to us electronically, the information that you provide will be forwarded to the BriteSky representative(s) responsible for filling the relevant position. The personal information that is contained in your resume will not be used for any other purpose.
    • To help recognize visitors who have previously registered on our website.

We may combine the personal information that we collect from you on our website with other information that you provide to us in connection with your use of our other products and services.

More specifically:

Email From You: You may email messages to us that will contain your screen name and email address along with any additional information you may wish to include in the text of your message.

Third Parties: We may receive personally identifiable information from select third parties in order to fulfill orders for products, to facilitate your receipt of one of our newsletters or brochures, or to communicate with us concerning your participation in a webinar.

We occasionally hire other companies to provide limited services on behalf of BriteSky, including delivering purchases, administering surveys and processing event registration. We will only provide such companies with the personally identifiable information that they need to deliver the service that we have requested of them. They are prohibited from using the personally identifiable information that we provide to them for any other purpose and we make reasonable efforts to ensure that all third parties with whom we share personally identifiable information undertake to adhere to this Policy. We do not otherwise share your personally identifiable information with third parties, unless you have granted us permission to do so.

Resumes: We use www.britesky.ca as a recruiting tool to provide those seeking employment with BriteSky the ability to submit resumes or other personally identifiable information.

Surveys: Occasionally, we conduct online surveys (either for BriteSky or select third parties) on a specific topic. Our surveys are entirely voluntary and you may easily decline to participate.

Discussion and Other Public Forums: Information posted to discussion forums, bulletin boards, chat rooms and other public forums may be displayed publicly. Please consider this before posting.

3. Consent

Unless you provide information voluntarily, we will not collect any personal information about you when you visit www.britesky.ca. If we ask you to provide information that personally identifies you, our request to do so will occur at the time of collection or in advance and it will be specific. Before we decide what form of consent is appropriate (i.e. direct vs. implied, written, verbal, electronic, etc.), we will consider the type of personally identifiable information that we require, the reason for its use and the type of contact with you that is involved. The choice to provide us with personally identifiable information is always yours.

For example, if you register to receive our newsletters or brochures, participate in our seminars or request a quote, we will ask for personally identifiable information such as your name, e-mail address, postal address or phone number.

If we want you to provide additional information, we will explain why we need the additional information and how it will be used at the time of our request.

Upon request, we will explain your options of refusing or withdrawing consent to the collection, processing, use and release of your personally identifiable information and we will record and respect your written choices (subject to any overriding legal requirements or commitments). Note, however, that your decision to withhold consent may limit the services we are able to offer you. For example, if you refuse to provide certain information when you request marketing material and/or sales information, we may not be able to properly identify you as a current customer or prospect and be forced to decline your request. Similarly, if you request the deletion of your name from our prospect or customer list, you will no longer receive e-mail or other notices regarding BriteSky events, news or product updates.

Consent is not required when it is impossible or impractical to seek it, such as for legal, medical or security reasons. We may disclose or use your personally identifiable information when we, in good faith, believe that either the law requires us to do so or such action is necessary to protect or defend BriteSky’s rights or property.

4. Limiting Collection

We collect and process information by fair and lawful means. We only collect and process personally identifiable information for one or more specific, limited purpose(s), in accordance with this Policy.

Cookies: Our website, like many other commercial websites, uses a standard technology called a “cookie” to collect information about how our website is used. A cookie is a small text file containing a unique identifier that is placed on your computer’s hard drive when you visit a website. We use session-based and persistent first-party cookies to improve your access and ease of use of our website. When you browse our website, we may use a cookie to help us provide you with better customer service by (i) identifying your browser as one that has visited our website before; and (ii) saving and remembering any preferences that you may have set during previous visits to our website. We also use cookies as data collection devices on our forms to help recognize visitors who have previously registered on our website. The non-personally identifiable information collected from our use of first-party cookies is not linked to your personally identifiable information. Cookies cannot retrieve any other data from your hard drive or obtain your e-mail address. Only BriteSky is able to use our cookies to determine your identity. Cookies do not damage your system or files in any way.

Most browsers now recognize when a cookie is offered and permits users to control how and when they will be accepted. If you are not sure whether your browser has this capability, you should consult the documentation that accompanied your browser or check with your Internet Service Provider (ISP). If you choose to decline cookies, you may not be able to fully experience the interactive features of the BriteSky services and websites that you visit.

Website Usage Information: Our web server automatically collects and aggregates information about your visit to www.britesky.ca, including your IP address, service provider, browser type, domain names of referring websites, operating system, pages accessed on our website, and the date and time of your access. This information is not personally identifiable. We analyze this aggregated information in an effort to optimize your experience and enhance your time spent with us online.

5. Limiting Use, Disclosure and Retention

Identified Purpose: We will only use your personally identifiable information for the identified purpose(s) (subject to any overriding legal requirements or commitments). If we propose to use your personally identifiable information for a purpose not previously identified, we will identify the new purpose to you prior to our use and confirm your consent in respect of the new purpose.

Third Party Disclosure: Under no circumstances do we sell customer lists or other personally identifiable information to third parties; however, there are some unavoidable types of disclosures of your personally identifiable information which may occasionally occur as part of us conducting business in the ordinary course, including for example, to our partners, consultants and suppliers (collectively, our “service providers”), but only: (i) if they agree to abide by this Policy; and, (ii) to the extent necessary to allow them to provide business services or support to BriteSky. Additionally, BriteSky may disclose and/or transfer your personally identifiable information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of BriteSky or its divisions, or of any of the business or assets or shares of BriteSky in order for you to continue to receive the same services from the third party as you do from BriteSky. In the event of any transfer of your personally identifiable information to a third party, we will require such third party to refrain from using or disclosing your personally identifiable information for any purpose except purpose(s) for which BriteSky uses or discloses your personally identifiable information, except upon notice to you or in accordance with applicable privacy laws. By submitting personally identifiable information, you agree to the transfer of information to third parties in these circumstances.

Contests and Surveys: Periodically, we may encourage you to participate in contests and surveys via our website. The information that we collect from these contests and surveys may be associated with individual customer accounts and used by us to improve your overall customer experience. This type of information will only be shared with our service providers in aggregate.

Opting Out: Unless you opt-out, if you have voluntarily provided your personally identifiable information to us, you hereby agree to us sending you mail or e-mail regarding products and services that we believe are of interest to you in accordance with all applicable legislation. If you do not want to receive such mailings from us, at any time you may simply “opt-out” by following the “unsubscribe” instructions contained within the communication or notifying our Privacy Officer (see Section 1 above).

Legal Obligations: We may be required or compelled by law to disclose personally identifiable information which we hold about you to certain authorities. In these circumstances we may not be able to advise you that personally identifiable information has been disclosed, the nature of the information disclosed or when the disclosure took place.

Retention: BriteSky will make reasonable efforts to ensure that your personally identifiable information is not retained beyond the length of time that it takes to fulfill the purpose for which such personally identifiable information was collected, unless otherwise agreed to by you, or required or permitted by law. In the event that you wish BriteSky to delete your personally identifiable information currently in its possession, please make such request to  our Privacy Officer (see Section 1 above).  Upon request, we will make reasonable efforts to ensure your personally identifiable information is deleted.

If at any time in the future we decide to use your personally identifiable information for a purpose not currently stated in this Policy, we will modify the Policy to disclose such usage in accordance with Section 10 below.

6. Accuracy

We provide reasonable and practical access for you to identify inaccuracies in your personally identifiable information. If you provide us with personally identifiable information through the BriteSky website, you have the right to access this data. To the extent that updated personally identifiable information is relevant to the purpose(s) for which it was originally collected, we will make reasonable efforts to keep your personally identifiable information accurate and up-to-date based on the information you provide.

To request an update, modification, or deletion of any personally identifiable information maintained by BriteSky, you can contact us at privacy@britesky.ca. We will, upon request, update or delete your personally identifiable information; however, we will not be able to update or delete data that has been archived as part of our normal business operations.

We keep the personally identifiable information collected through our website as long as it is required to service your request, or until you request its deletion. We reserve the right to indefinitely retain aggregated information collected about your visit to our website (i.e., browser type, domain name, pages visited) for review and analysis purposes.

We do not add third-party data to your personally identifiable information and maintain your personally identifiable information in a merged or supplemented format.

7. Safeguards

We store your personally identifiable information in a secure location that is accessible only by designated staff. We make reasonable efforts to protect your personally identifiable information from loss, misuse, unauthorized access or disclosure, alteration or destruction. We use security safeguards appropriate to the sensitivity and nature of the personally identifiable information being protected to guard against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Generally, our measures of protection include:

    • physical measures, for example, locking filing cabinets and restricting access to offices;
    • organizational measures, for example, security passes and limiting access to personally identifiable information on a “need-to-know” basis;
    • o technological measures, for example, the use of firewalls, intrusion detection, passwords and encryption; and
    • control measures, for example, the shredding of sensitive personally identifiable information.

The personally identifiable information that we collect from you may be transferred to, and stored at, a destination outside the United States or Canada. It may also be processed by staff operating outside the United States or Canada who work for us or for one of our suppliers or service providers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting personally identifiable information, you agree to this transfer, storing or processing.

When we provide personally identifiable information to service providers acting on our behalf, we will make good faith and commercially reasonable efforts to have such organizations or individuals agree to abide by this Policy. We will give them only the information necessary to perform the services for which they are engaged. We will take commercially reasonable efforts to ensure that they comply with this Policy; however, we have no liability to you if such service providers fail to do so.

If you send us an e-mail message that includes personally identifiable information (such as your name in the “address”), we will use that information to respond to your inquiry. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Unless your e-mail is encrypted or your browser indicates that the access to our website(s) is secure, you may want to refrain from sending sensitive personally identifiable information to us electronically.

If you use passwords, ID numbers or other special access features on our website, it is your responsibility to safeguard them.

8. Openness

We are committed to being open about our policies and practices with respect to the handling of personally identifiable information. This Policy is available via hard copy from our Privacy Officer (see Section 1 above) and in electronic form at www.britesky.ca.

9. Individual Access

You may request a copy of your personally identifiable information in our possession by submitting a written request, satisfactory identification and proof of entitlement to our Privacy Officer (see Section 1 above). You have the right to know how we collected your personally identifiable information, how we are using it, and, to whom it may have been disclosed (with the exception of disclosures to government bodies or our service providers in connection with the conduct of our business in the ordinary course).

If you find any errors in your personally identifiable information, please contact our Privacy Officer (see Section 1 above) as soon as possible and we will make the appropriate corrections.

On occasion, we may decline your request for access to personally identifiable information within our possession or control. For example, this may occur if providing access to you would be likely to reveal personally identifiable information about a third party and the information cannot be segregated or consent cannot be obtained from the third party to such a disclosure and it would be unreasonable for us to comply with the request in the circumstances. Further, a request may be declined if the information has been collected during the investigation of a legal matter or cannot be disclosed for other legal reasons, such as a non-disclosure agreement. If we deny your request for access, we will advise you in writing of the reason for our refusal so that you may decide whether you wish to challenge our decision.

10. Data Privacy in the Cloud

BriteSky provides the highest level of flexibility to configure custom public, private, and hybrid cloud environments. Complete customization is enabled by our modular cloud architecture. This architecture is built on five functional layers that are optimized for enterprise cloud applications: Virtual storage, Virtual networking, Compute, Virtualization (virtual data center), and Security (virtual firewall).
BriteSky provides a secure cloud infrastructure environment that functions like a private cloud and reduces the risk of security breaches. The Customer is then responsible for ensuring their own data security controls are in place. BriteSky can enhance the Customer’s security posture by providing subscription-based services for firewalls, encryption, backup and security incident management upon request.

11. Challenging Compliance and Policy Changes

Challenging Compliance: Please contact our Privacy Officer (see Section 1 above) with any questions or concerns you may have about your privacy or our compliance with this Policy. We will investigate and provide you with a timely response to your concerns. Please ensure to include your name, address, preferred method of communication, nature of your concern and relevant details, including any past communications with us. If our response to your concerns does not meet with your satisfaction, we will provide you with information regarding other compliancy procedures that may be available to you.

If you have thoughts, questions or suggestions about this Policy or any other aspect of your relationship with BriteSky, please contact us via email at e-mail info@britesky.ca or regular mail at:

Privacy Officer
BriteSky Technologies Inc.
101 – 118 Iber Road
Ottawa, Ontario
K2S 1E9

Policy Changes: We may modify or amend this Policy from time to time. In an effort to keep you informed of changes to this Policy, we will indicate the effective date of the currently posted policy at the top of the Policy. Changes to this Policy will not affect our use of previously provided personally identifiable information. No personally identifiable information provided by you under the terms of this Policy (or any prior version of this Policy) will be used in a manner that is materially inconsistent with it, without your prior written permission.