This privacy policy provides information regarding Ulula’s management and protection of personal data collected through

  • its website,
  • its platform and
  • its services,

or personal information processed on behalf of Ulula’s customers under service agreements.

This policy also provides information regarding the process to obtain access to one’s personal data held by Ulula and rectify it as appropriate.

Personal information refers to any information relating to an identifiable individual.

How we collect information from the website

Ulula’s website uses cookies to identify the user’s computer and track access to the server to support user access to the website. It also helps Ulula better understand how visitors use its site so that it can be improved.

Information collected through cookies, such as IP addresses or pages visited, is only used to assist the user to navigate the website and to capture visit trends that help Ulula improve its website. Visitors are informed, up front, that they can opt out of the cookies via their browser’s privacy settings.

Ulula collects information users provide when they post comments on Ulula’s blog site or when contacting Ulula through the website contact form. The information collected includes the name and email address of individuals interacting with the website Individuals can have the information removed at any time by emailing privacy@ulula.com.

Children

Ulula’s website is intended for a general audience and we do not knowingly collect personal information from anyone under the age of 13.

How we collect information from Ulula services

Information collected through the platform

In the course of its business activities and with the user’s express consent, Ulula collects data through online surveys, messaging subscription and digital feedback, complaint and grievance from individuals responding to an inquiry commissioned by Ulula’s clients and customers. Individuals provide survey responses and other personal information with express consent. Individuals providing the responses are consenting to their responses being shared with Ulula’s clients in a non-identified, anonymous form.

Ulula’s services, including surveys, broadcast, and grievance management, collect personal information via SMS, voice, social media, messenger applications or any other means of communication chosen by individuals to interact with Ulula. Personal information includes, as applicable, name, email address, username, and password, Internet Protocol addresses, location data, use of the Services as well as payment information, usage data in relation to the Services and other information relevant for the purpose of providing the Services, specifically to:

  • Process transactions with Ulula;
  • Send emails about Ulula services or respond to inquiries;
  • Send emails and updates about Ulula services, including newsletters;
  • Provide support for Ulula services;
  • Enhance or improve Ulula services;
  • Monitor data and user activity to ensure compliance with contractual requirements;
  • Perform any other function reasonably necessary to protect the security or proper functioning of Ulula services.
  • Deliver Ulula services through surveys

With express consent from the individual, Ulula compiles the responses collected and makes it available to its clients in an anonymized form through the platform.

With express consent from clients, Ulula may post personal testimonials of clients in addition to other endorsements. If you are a registered user of the Services and have supplied your email address, Ulula may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up-to-date with what’s going on with Ulula and its products and services.

Sharing personal information

Whether it was collected through the website, the platform or Ulula Services, personal information is never sold or disclosed without consent except in the rare cases where it is required by law.

In the course of business, Ulula may hire third party individuals and organizations that may have access to information and data collected by Ulula. These third parties include the web host provider, other SaaS providers, such as an email hosting service, payment processors or outside contractors hired to perform maintenance or assist in securing our website. Ulula may also hire third parties to operate, maintain, repair, or otherwise improve or preserve files or systems.

In those cases, third parties process personal information collected by Ulula on Ulula’s behalf, under written instructions and with specific contractual clauses that ensure security of the personal information shared with them. The third parties are subject to this Privacy Policy and to compliance monitoring in that regard.

Where Ulula is required by law to disclose personal information, it is always upon demonstrated lawful authority to do so and on the basis of legal advice.

As permitted by law, Ulula provides access or discloses personal information when it is reasonable to believe that such disclosure is necessary to (i) enforce applicable terms of service, including investigation of potential violations; (ii) detect, prevent, or otherwise address fraud, security or technical issues; or (iii) protect the rights, property or safety of users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Right to access, edit, and remove user’s information

Individuals may contact Ulula at privacy@ulula.com to request access to their personal information in order to edit or to remove it from Ulula’s database. Individuals with login privileges can access, edit, and remove their personal information.

Individuals’ right to access their personal information held by Ulula includes:

  • Assurance by Ulula that their personal information is accurate and correction will be made as requested and necessary;
  • Deletion by Ulula of any inaccurate personal information and personal information for which consent has been withdrawn.

An access request cannot be accepted if it puts at risk the privacy of others.

Where the request requires disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), or would be extremely impractical (for instance, requests concerning information residing on backup systems), Ulula will charge a fee corresponding to administrative costs and provide justification. Otherwise, access, correction and deletion are provided for free.

If the access request relates to personal information stored by a client of Ulula, the request is redirected to that client to respond because the client is the data controller in that case.

While Ulula will seek to address any request and resolve any complaint regarding this policy, other complaint mechanisms exist. Ulula is subject to the investigatory and enforcement powers of the Offices of the Privacy Commissioner of Canada in Canada and the national data protection authorities in Europe. Ulula informs individuals of those recourses as relevant.

Security measures for all personal information

Ulula applies all necessary physical, technological and administrative measures to protect personal information at the level appropriate to its sensitivity. This includes:

  • Entry-exit registration of visitors;
  • Secure areas for the protection of servers and devices;
  • Use of SSL Certificates to protect users against unauthorized access;
  • Policies governing the management and protection of personal information, made easily accessible and distributed to staff for implementation;
  • Risk management plans, identifying threats and mitigation measures.

Ulula stores and processes personal information on computers located in Canada and/or the United States. This means Canadian and US privacy laws apply according to where the information is stored. Wherever it stores personal information, Ulula ensures, through contractual clauses, that the information will be protected with a comparable and adequate level of safeguards.

Changes

This Privacy Policy is updated as necessary to reflect Ulula’s activities that may entail collection and use of personal information as well as the measures developed to protect it.

Addressing questions or concerns

Ulula addresses questions and concerns through its Operations Department. All queries regarding privacy at Ulula Services are directed to privacy@ulula.com or via postal mail at:

185 Spadina Ave
Toronto, Ontario
M5T 2C6

Ulula makes every effort to respond in a timely and satisfactory manner.

Effective date

This Privacy Policy became effective on July 12, 2018.