This Odeumate User Privacy Policy (this "Privacy Policy") describes how Broken Leg Software Inc., doing business as Odeumate, and its affiliates (collectively "Odeumate", "we", "us", and/or "our") collects and processes your personal information for our own purposes when you interact with Odeumate and our websites, services, content, and any related software, mobile applications, and other applications (collectively, "Services").
When you access or use our Services, you acknowledge that you have read this Privacy Policy and understand its contents.
Applicable Law
We are a British Columbia corporation subject to the Personal Information Protection Act, SBC 2003, c. 63 ("PIPA"), which is BC's primary private-sector privacy law. The federal Personal Information Protection and Electronic Documents Act (PIPEDA) applies where PIPA does not, principally to personal information that crosses provincial or national borders in the course of commercial activity and to federally regulated activities. Depending on where you live, other laws may also apply, including Alberta's Personal Information Protection Act and Quebec's Act respecting the protection of personal information in the private sector.
What This Privacy Policy Covers
This Privacy Policy applies when you:
- visit, interact with, or use any Odeumate Services or websites that link to this Privacy Policy;
- create or administer your Odeumate account;
- receive communications from, or otherwise interact with us;
- complete a questionnaire, support ticket, or other information request forms;
- engage in a contracting process with Odeumate;
- register or take part in our marketing, learning, or training events; and
- offer or integrate your application, content, product, or services on or through Odeumate Services.
This Privacy Policy does not apply to personal information we collect as an employer, or to third-party products and services.
Personal Information We Collect
Information You Provide To Us
- Account information: email address, password, authentication credentials.
- Contact and professional information: name, address, phone number, company name, job title, department, industry.
- Payment information: credit card and bank account information, GST/HST, VAT or other tax identifiers.
- Communications information: feedback, queries, chat/email/call history.
- Financial information: bank routing and account information for regulatory clearance.
- Audio and video recordings: event or meeting recordings (with notice and consent where required).
- Contractor or vendor information: TIN, invoices, contracts, financial information.
- Advertising and marketing information: interests and communication preferences.
Information We Collect Automatically
- Usage and interaction information: URL clickstream, content viewed, page response times, download errors, page interaction data.
- Log data and device information: IP address, device/browser type, operating system, time zone, access dates and times.
- Inferred location information: based on IP address lookup.
- Location information: GPS, wireless, or Bluetooth technology (when permission is granted).
- Cookies and similar tracking technologies: as described in our Cookie Notice.
Product Analytics and Session Replay
We use third-party analytics providers, including Google Analytics (a service of Google LLC) and Microsoft Clarity (a service of Microsoft Corporation), to understand how visitors and users interact with the Services. This includes aggregate usage analytics and session-replay and heatmap technology, which records interactions such as mouse movement, clicks, scrolling, page navigation, and device and browser information, so that we can identify confusing steps and improve the product.
Masking. Session recordings are configured to mask content by default. Text shown on the page, information typed into forms, and uploaded images and files are obscured in the recording before any data leaves your browser, so the recording does not capture the personal information of your members, contacts, or other individuals displayed on screen. Passwords are never recorded.
Consent. We enable session replay and analytics only after you accept analytics cookies. You can decline or withdraw consent at any time through the cookie banner or your browser settings; declining stops this collection.
Service provider. Google and Microsoft process this information on our behalf as service providers and may store and process it outside Canada, including in the United States. We do not sell this information, and it is used only to operate and improve the Services. For their own practices, see the Google Privacy Policy and the Microsoft Privacy Statement.
Advertising Measurement (Meta Pixel and Google Ads)
Our marketing website (odeumate.com) uses the Meta Pixel, a service of Meta Platforms, Inc., and Google Ads conversion tracking, a service of Google LLC, to measure the effectiveness of our advertising and to help us reach people who may be interested in Odeumate. When enabled, these tools collect information such as the pages you visit on our marketing website, your device and browser information, and whether you completed a sign-up, and disclose it to Meta or Google. If you sign up, we also pass your sign-up email address to Google in a hashed (unreadable) form to improve conversion matching ("enhanced conversions"). Meta and Google may use this information for their own purposes, including advertising personalization, as described in the Meta Privacy Policy and the Google Privacy Policy.
These advertising tools load only after you accept cookies through our cookie banner. You can decline or withdraw consent at any time through the cookie banner or your browser settings; declining stops this collection. These tools are used only on our marketing website. They are not present inside the Odeumate application, and we never disclose Customer Data from within the application to advertising services.
Information We Collect from Other Sources
- Other Odeumate users: contact information via referrals or our referral programs.
- Third-party service providers: identity verification, risk management, fraud prevention data.
- Public and third-party sources: social profiles, marketing data from aggregators, events, and social media.
How We Use Your Personal Information
- User Account: register, create, and administrate your account.
- Process Transactions: payments, registrations, memberships, and purchases.
- Providing Services: deliver and assess eligibility for our Services.
- Communications: service updates, security alerts, support messages, and responding to inquiries.
- Improvement: measure, troubleshoot, develop, and improve our Services.
- Personalization: recommend Services and personalize your experience.
- Marketing: send promotional messages and personalize advertising. Where required by Canada's Anti-Spam Legislation (CASL) or other applicable law, we obtain your express or implied consent before sending commercial electronic messages, and include an unsubscribe mechanism in each message.
- Security: prevent and investigate security and fraud issues.
- Legal Compliance: comply with legal and regulatory obligations.
How We Disclose Your Personal Information
- Within your organization: in accordance with your account settings and preferences.
- Third-party transactions: for services available through our platform.
- Service providers: cloud computing, payments, analytics, customer support, etc.
- Business advisors: lawyers, bankers, auditors, and insurers.
- Authorized representatives, vendors, and contractors of Odeumate customers.
- Advertising measurement services: with your consent, our marketing website discloses website interaction information to Meta (via the Meta Pixel) and Google (via Google Ads conversion tracking, including a hashed sign-up email address) to measure advertising effectiveness and reach interested audiences, as described under "Advertising Measurement (Meta Pixel and Google Ads)" above. We do not disclose Customer Data from within the Odeumate application to advertising services.
- Legal protection: to comply with law, enforce our terms, and protect rights and safety.
- Affiliates: within the Odeumate corporate group.
- Business transfers: mergers, acquisitions, or sale of assets.
- With your consent.
How Long We Keep Your Personal Information
We keep your personal information for as long as required to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. After expiry, your personal information will be deleted, anonymized, or irreversibly destroyed in accordance with applicable laws.
International Transfers
Personal information may be stored and processed in your region, in Canada, in the United States, or in any other country where we or our service providers maintain facilities. We maintain primary data centers in Canada. While your personal information is stored or processed outside Canada, it is subject to the laws of that jurisdiction and may be accessible to the courts, law enforcement, and national security authorities of that jurisdiction in accordance with those laws. When transferring personal information from jurisdictions restricting such exports, we adopt appropriate data transfer tools such as standard contractual clauses or consent. For questions about our policies and practices regarding service providers outside Canada, contact our Privacy Officer at privacy@odeumate.com.
Cookies
We use cookies and similar technologies to recognize your browser, provide our Services, and improve your experience. The types of cookies we use include:
- Essential cookies: required for the Services to function, including authentication, session management, and security. These cannot be disabled.
- Preference cookies: store your settings and preferences to personalize your experience.
- Analytics cookies: help us understand how the Services are used so we can improve them, including Google Analytics (which sets cookies such as
_ga) and session-replay and heatmap analytics provided by Microsoft Clarity (which sets first-party cookies such as_clckand_clsk, and may set related identifiers). These are only set with your consent. - Advertising cookies: on our marketing website, the Meta Pixel and Google Ads set cookies (such as
_fbpand_gcl_au) to measure advertising effectiveness, as described under "Advertising Measurement (Meta Pixel and Google Ads)" above. These are only set with your consent.
You can control non-essential cookies through your browser settings. Disabling certain cookies may affect your ability to use some features of the Services.
Security
We design our systems with your security and privacy in mind. We maintain compliance programs, use industry-standard encryption for data in transit, and implement technical, physical, and organizational safeguards. However, no security measure is 100% secure. You are responsible for protecting your password, limiting device access, and signing out after sessions.
Your Rights and Choices
Depending on your location, you may have the right to:
- Ask whether we hold personal information about you, and request copies.
- Request correction of inaccurate personal information.
- Request deletion of your personal information.
- Request restriction of processing.
- Object to certain processing.
- Request portability of personal information.
- Withdraw your consent at any time.
- Opt out of disclosure for targeted advertising.
- Unsubscribe from promotional communications.
- Submit a complaint to a data protection authority.
We will respond to access and correction requests within 30 days of receipt, as required by PIPA (section 29). In limited cases we may extend this period by up to an additional 30 days as permitted by PIPA (section 31); if so, we will notify you of the extension, the reason for it, and the date by which we will respond.
To exercise any of these rights, please contact our Privacy Officer at privacy@odeumate.com.
Withdrawing Consent
You may withdraw consent to the collection or use of your personal information at any time by contacting our Privacy Officer at privacy@odeumate.com. Withdrawal of consent does not affect the lawfulness of any collection or use that occurred prior to withdrawal. Please note that if you withdraw consent for certain uses (such as providing the Services), we may be unable to continue providing those Services.
Children's Personal Information
The Services are not directed to children. Users must meet the minimum ages set out in the User Terms of Service (16 in Canada, the European Economic Area, and other jurisdictions where applicable law requires a higher minimum age; 13 in the United States and other territories where no higher minimum applies). We do not knowingly collect personal information from children below those minimum ages. If you learn that a child has provided us with personal information, please contact us and we will take steps to delete it.
Complaints
If you have concerns about how we handle your personal information and are not satisfied with our response, you have the right to make a complaint to the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC):
- Website: oipc.bc.ca
- Phone: 250-387-5629
- Toll-free: 1-800-663-7867
For matters governed by PIPEDA, you may also make a complaint to the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca or 1-800-282-1376. Quebec residents may make a complaint to the Commission d'accès à l'information du Québec (CAI) at cai.gouv.qc.ca.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will post a notice and seek consent when required by applicable laws.
Privacy Officer
Broken Leg Software Inc. d/b/a Odeumate has designated a Privacy Officer responsible for ensuring compliance with this Privacy Policy and with applicable privacy law. To reach our Privacy Officer with questions, concerns, or requests:
- Email: privacy@odeumate.com
- Mail: Broken Leg Software Inc., Attn: Privacy Officer, 201-45619 Yale Rd, Chilliwack, BC V2P 0B1, Canada
Additional Information for EEA and UK Users
If you are in the European Economic Area or the United Kingdom, the EU General Data Protection Regulation or UK GDPR applies to our processing of your personal information, and Broken Leg Software Inc. is the controller of the personal information described in this Privacy Policy (our customers are the controllers of Customer Data processed within the Services, which is governed by our Data Processing Addendum).
We rely on the following legal bases:
- Performance of a contract: to create and administer your account, process transactions, and provide the Services.
- Legitimate interests: to secure the Services, prevent fraud, improve and develop the Services, and communicate with business contacts, where those interests are not overridden by your rights and interests.
- Consent: for analytics and advertising cookies (including session replay, the Meta Pixel, and Google Ads conversion tracking), optional location information, and marketing communications where consent is required. You may withdraw consent at any time.
- Legal obligation: to comply with laws that apply to us, such as tax, accounting, and lawful disclosure requirements.
You have the rights described under "Your Rights and Choices" above, including access, rectification, erasure, restriction, portability, objection, and the right to withdraw consent. Transfers of your personal information outside the EEA or UK (including to Canada and the United States) are protected by appropriate safeguards, such as adequacy decisions (Canada holds an EU adequacy decision for PIPEDA-governed processing) and the Standard Contractual Clauses or UK Addendum described in our Data Processing Addendum. You also have the right to lodge a complaint with the data protection supervisory authority in your country of residence, place of work, or place of the alleged infringement (in the UK, the Information Commissioner's Office).
Additional Information for Quebec Residents
If you reside in Quebec, the Act respecting the protection of personal information in the private sector, CQLR c. P-39.1 (as amended by Law 25), applies to our handling of your personal information. In addition to the rights described above:
- Our Privacy Officer serves as the person in charge of the protection of personal information and can be reached at privacy@odeumate.com.
- Your personal information may be communicated outside Quebec, including to service providers in the rest of Canada and the United States, as described under "International Transfers" above. Before communicating personal information outside Quebec, we assess the privacy protections that will apply to it.
- You have the right to request that we cease disseminating your personal information, or de-index or re-index it, in the circumstances provided by the Act.
- We do not use personal information to render decisions based exclusively on automated processing. If that changes, we will inform you as required by the Act.
- If you are not satisfied with our response to a privacy request or complaint, you may contact the Commission d'accès à l'information du Québec.
Additional Information for US State Residents
Residents of US states with applicable privacy laws, including Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Nevada, and others, may have rights similar to those described in this Privacy Policy. Depending on your state and our relationship with you, these rights may include:
- The right to confirm whether we process your personal information and to access it.
- The right to correct inaccurate personal information.
- The right to delete personal information we hold about you.
- The right to data portability: to obtain a copy of your personal information in a portable format.
- The right to opt out of the sale or sharing of your personal information and targeted advertising.
- The right to opt out of profiling that produces legal or similarly significant effects.
- The right to appeal a decision we make in response to a privacy rights request.
We do not sell personal information for monetary consideration. Our use of the Meta Pixel and Google Ads conversion tracking on our marketing website may constitute "sharing" of personal information for targeted advertising (or a "sale" as broadly defined) under some state laws. You can opt out of this at any time by declining or withdrawing cookie consent through our cookie banner, which stops these tools, or by contacting us at privacy@odeumate.com. We do not engage in profiling that produces legal or similarly significant effects without consent. To exercise any of these rights, contact us at privacy@odeumate.com. We will respond within the timeframe required by your state's applicable law.
Additional Information for California Residents
The following additional disclosures are required by the California Consumer Privacy Act and the California Privacy Rights Act (together, the "CCPA").
Categories of Personal Information
Categories we have collected and disclosed in the preceding twelve months include: identifiers, personal information per Section 1798.80(e), characteristics of protected classifications, commercial information, internet/electronic network activity, geolocation data, audio/visual/electronic information, professional/employment information, inference data, and sensitive personal information.
Your CCPA Rights
You may ask us to provide descriptions of personal information we hold, provide access and portability, update or correct your information, delete certain information, and opt out of "sale" and "sharing." We will not discriminate against any consumer for exercising their CCPA rights.
We do not sell personal information for monetary consideration. Our use of the Meta Pixel and Google Ads conversion tracking on our marketing website may constitute "sharing" for cross-context behavioral advertising under the CCPA. You can opt out at any time by declining or withdrawing cookie consent through our cookie banner (which stops these tools) or by contacting us at privacy@odeumate.com.
To exercise your rights, contact us at privacy@odeumate.com.