Date of Last
Update: April 8, 2021 By visiting,
viewing, accessing, browsing, surfing, registering, or using (collectively
the “Use”) our website www.lextodoc.ca including its sub-domains, website pages,
hyperlinks and mobile optimized version, if any (“Website”) or our Practice Management Software (CRM) (the “Software”)
as available at the Website. The Website
and the Software are owned by Fromtofor
Inc., a corporation incorporated under the laws
of Canada, having its registered address at 8108 Yonge Street, suite 210, Thornhill ON L4J
1W4(hereinafter
referred to as “we,” “us” or “our”). This Privacy
Policy also sets out how we may collect, use and disclose information in
relation to Legal Professionals, Assistants and Account Holders (“Users” or “You”)
of the Website. 1.Information We
Collect 1.1 Your privacy is important to us and we have taken steps to
ensure that we or our affiliated third-parties do not collect more information
from you than what is necessary for us in relation to your Use of the Website. 1.2 For visiting, viewing, accessing, browsing,
surfing, registering or using the Website, you may
be asked to submit the following types of personal data: 1.2.1 Personal Data: This may include
personal information relating to a Legal Professional or Assistant such Name, phone, fax, email, website address,
professional membership data, address, gender, practice area, languages, Services,
About and any payment gateway
details and such other information, data and materials as we may deem necessary
for provision of our services offered through the Website. We may use this
Personal Data to create and maintain Profiles and a database of Legal
Professionals on our Website. 1.2.2Communication Data: This may include data relating to any
communication that you send to us whether that be through the consultation/contact
form on the Website, through e-mail, instant messaging, chat or any other mode of communication that you
use to contact us. We process this data for the purposes of communicating with
you, for record keeping and for the establishment, pursuance or defence of potential
legal claims. Our lawful ground for this processing is our legitimate interests
which in this case are to reply to communications sent to us, to keep records
and to establish, pursue or defend potential legal claims. 1.2.3 Technical Data: This may include data about your use of the Website
and online services such as your IP address, your login data, details about
your browser, length of visit to pages on the Website, page views and
navigation paths, details about the number of times you use the Website, time
zone settings and other technology on the devices you use to access the Website.
The source of this data is from our analytics tracking system. We process this
data to analyse your use of the Website and other online services, to
administer and protect our business and the Website, to deliver relevant
website content and advertisements to you and to understand the effectiveness
of our advertising. Our lawful ground for this processing is our legitimate
interests which in this case are to enable us to properly administer the Website
and our business and to grow our business and to decide our marketing strategy. 1.2.4 Marketing Data: This may include data about your preferences in
receiving marketing material from us and our third parties and your
communication preferences. Our lawful ground for this processing is our
legitimate interests which in this case are to study how customers use our
services, to develop them, to grow our business and to decide our marketing
strategy. 1.3 We may use Personal Data, Communication Data,
Technical Data and Marketing Data (collectively the “Data”). 2. Name and
Address of the Data Controller 2.1 Data Controller for the purposes of the Personal Information and
Protection Electronic Documents Act (PIPEDA) and other provisions related to data
protection is:
Data
Controller: Rhyton Law PC Data
Protection Officer: Daniel Larijani, corporate counsel Address:8108 Yonge Street, suite 210, Thornhill ON L4J
1W4 Phone: 1-416-200-0131 Email: [email protected] 3. Consent and
its Withdrawal 3.1 When you visit, view, access, browse, surf, register or use our Website, you provide us with your consent to use your Data as per this Privacy Policy. In order for you
to Use the Website, it is necessary for us to collect all relevant and
necessary Data from you. In addition, by filling the forms available on the
Website, you give us your express consent and permission to use your Data. 3.2 We will process the Data only after taking
written instructions/consent from you mostly in electronic form in the form of clickable
button or a checkbox. 3.3 If you change your mind, you may withdraw your
consent for us to contact you, for the continued collection, use or disclosure
of your information, at any time, by contacting us at [email protected]. 4. How We Use and
Process the Data 4.1 The Data
collected by us from you may be used to better understand your needs in
relation to your Use of the Website, to correspond with you and reply to any of
your questions relating to any of our programs. 4.2 We will not
rent or sell your Data to others. We may store the Data in locations outside our
direct control (for instance, on servers or databases co-located with hosting
providers). 4.3 If you provide any Data to us, you are deemed
to have authorized us to collect, retain and use that data for the following
purposes: i. verifying your identity; ii.sending you a
welcome e-mail; iii. providing you with customer service and responding
to your queries, feedback or disputes; iv. conducting
marketing analysis, sending surveys or newsletters, contacting you about our
programs, activities, special events or offers from us and for other marketing,
information, product development and promotional purposes; v. making such disclosures as may be required for
any of the above purposes or as required by law, regulations and guidelines or
in respect of any investigations, claims or potential claims brought on or
against us; vi.sending you
notices (for example, in the form of e-mails, mailings and the like) regarding
products or services you are receiving and for billing and collection purposes; vii.provide and
maintain the Website; viii. notifying you
about changes to the Website; ix. sending you
information we think you may find useful or that you have requested from us; x.enhancing and
improve the Website such as through personalized features and content; xi.analysing the
use of the Website and the people visiting to improve our content and Website; xii.investigating,
preventing or taking action regarding illegal activities, suspected fraud,
situations involving potential threats to the physical safety of any person,
violations of our policies or as otherwise required by law; 4.4We shall ensure
that: i.The Data
collected and processed for and on our behalf by any party is collected and
processed in accordance with applicable data privacy laws; ii.You are
always made fully aware of the reasons for the collection of Data and are given
details of the purpose(s) for which the Data will be used;
iii.The Data is
only collected to the extent that is necessary to fulfil the purpose(s) for
which it is required; iv.No Data is
held for any longer than necessary in light of the purpose(s) for which it is
required. v.Whenever
cookies or similar technologies are used online by us, they shall be used
strictly in accordance with applicable laws; vi.You will be informed
if any Data submitted by you online cannot be fully deleted at your request
under normal circumstances and how to request deletion of any other copies of
that Data, where it is within your right to do so; vii.Appropriate
technical and organizational measures are taken to protect the Data; viii.Data is
transferred securely, whether it is transmitted electronically or in hard copy; ix.You can fully
exercise your rights with ease and without hindrance. 5.Disclosure of
Data 5.1 We shall not
be able to keep your Data private in response to legal process, i.e. a court
order or a subpoena or a law enforcement agency’s request. If, in our view, it
is deemed appropriate to investigate, prevent or take action regarding illegal
activities, suspected fraud, situations involving potential threats to the
physical safety of any person, violations of our terms of use or as otherwise
required by law, we may be compelled to disclose the Data. Moreover, in case of
takeover, merger or acquisition, we reserve a right to transfer your Data to
new platform. 5.2We may
disclose the Data in the good faith belief that such action is necessary to: i. comply with a
legal obligation; ii. protect and
defend our rights or property; iii. prevent or
investigate possible wrongdoing; iv.protect the
personal safety of users of the Website or the public; v. protect
against legal liability. 5.3When
necessary, we may also disclose and transfer your Data to our professional
advisors, law enforcement agencies, insurers, government and regulatory and
other organizations.
6. Data Storage 6.1 Your Data may
be stored and processed at the servers in United Kingdom or any other country
in which we or our subsidiaries, affiliates or service providers maintain
facilities. 6.2 We may
transfer your Data to affiliated entities or to other third parties across borders
and from your country or jurisdiction to other countries or jurisdictions
around the world. Your consent to this Privacy Policy followed by your
submission of such information represents your agreement to that transfer. 6.3 We will take
all steps reasonably necessary to ensure that your Data is treated securely and
in accordance with this Privacy Policy and no transfer of your Data will take
place to an organization or a country unless there are adequate controls in
place including the security of your Data. 6.4 We will only
retain your Data preferably for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any record retention
or reporting requirements under applicable laws. When deciding what the correct
time is to keep the Data, we look at its amount, nature and sensitivity,
potential risk of harm from unauthorised use or disclosure, the processing
purposes, if these can be achieved by other means and legal requirements.
7. How We
Protect Your Information 7.1We store all
the Data submitted by you through the Website at a secure database. 7.2We are
concerned with protecting your privacy and Data, but we cannot ensure or
warrant the security of any Data you transmit or guarantee that your Data may
not be accessed, disclosed, altered or destroyed by breach of any of our
industry standard physical, technical or managerial safeguards. 7.3 No method of
transmission over the Internet or method of electronic storage is 100% secure.
While we strive to use commercially acceptable means to protect your Data, we
cannot guarantee its absolute security. If you have any questions about
security of the Website, you can contact us at [email protected]. 7.4 Any Data
supplied by you will be retained by us and will be accessible by our employees,
any service providers engaged by us and third parties.
8.Compliance
with the GDPR 8.1For users
based in Canada, the Website shall make all reasonable efforts to ensure that
it complies with the Personal Information and
Protection Electronic Documents Act (PIPEDA) regarding the collection, use,
and retention of Data from the Users based in Canada. The Website
shall make all reasonable efforts to adhere to the requirements of notice,
choice, onward transfer, security, data integrity, access and enforcement.
8.2The Rights of Users: You may exercise certain rights regarding your
Data processed by us. In particular, users based in Canada may do the following: 8.3 Right of confirmation: You shall have the right granted by the Canadian legislator
to obtain from us the confirmation as to whether or not personal data
concerning you are being processed. 8.4 Right of Access: You shall have the right granted by the Canadian legislator
to obtain from us free information about your personal data stored at any time
and a copy of this information. Furthermore, the Canadian directives and regulations
grant you access to the following information: 8.4.1 the purposes of the processing; 8.4.2the categories of personal data concerned; 8.4.3the recipients or categories of recipients to
whom the personal data have been or will be disclosed, in particular recipients
in third countries or international organizations; 8.4.4 where possible, the envisaged period for
which the personal data will be stored, or, if not possible, the criteria used
to determine that period; 8.4.5the existence of the right to request from us
rectification or erasure of personal data or restriction of processing of
personal data concerning the data subject or to object to such processing; 8.4.6 the existence of the right to lodge a
complaint with a supervisory authority; 8.4.7 where the personal data are not collected
from you, any available information as to its source; 8.4.8the existence of automated decision-making,
including profiling, referred to in Article 22(1) and (4) of the GDPR and, at
least in those cases, meaningful information about the logic involved as well
as the significance and envisaged consequences of such processing for you. 8.5 Furthermore, you shall have a right to obtain
information as to whether personal data are transferred to a third country or
to an international organisation. Where this is the case, you shall have the
right to be informed of the appropriate safeguards relating to the transfer. 8.6 Right to rectification: You shall have the right granted by the Canadian legislator
to obtain from us without undue delay the rectification of inaccurate personal
data concerning you. Taking into account the purposes of the processing, you shall
have the right to have incomplete personal data completed, including by means
of providing a supplementary statement. 8.7Right to erasure (Right to be forgotten): You shall have the right granted by the Canadian legislator
to obtain from us the erasure of personal data concerning you without undue
delay and we shall have the obligation to erase personal data without undue
delay where one of the following grounds applies as long as the processing is
not necessary: 8.7.1 The personal data are no longer necessary in
relation to the purposes for which they were collected or otherwise processed. 8.7.2 You withdraw consent to which the processing
is based according to the relevant provisions of the Personal Information and
Protection Electronic Documents Act (PIPEDA) and where there is no other legal ground for the
processing.
8.7.3 You object to the processing pursuant to to the relevant provisions of the Personal Information and Protection Electronic Documents Act (PIPEDA) and there are no overriding legitimate grounds for
the processing or you object to the processing.
8.7.4The personal data have been unlawfully
processed. 8.7.5The personal data must be erased for
compliance with a legal obligation in Canadian law to which we are subject. 8.7.6The personal data have been collected in
relation to the offer of information society services referred to in Article
8(1) of the GDPR. 8.7.7Where we have made personal data public and are
obliged to erase the personal data, we, while taking
account of available technology and the cost of implementation, shall take
reasonable steps including technical measures to inform other controllers
processing the personal data that you have requested erasure by such
controllers of any links to, or copy or replication of, those personal data, as
far as processing is not required. We will arrange the necessary measures in
individual cases. 8.8Right of restriction of processing: You shall have the right granted by the Canadian legislator
to obtain from us restriction of processing where one of the following applies: 8.8.1The accuracy of the personal data is
contested by the data subject for a period enabling us to verify the accuracy
of the personal data. 8.8.2The processing is unlawful and the data
subject opposes the erasure of the personal data and requests instead the restriction
of their use instead. 8.8.3We no longer need the personal data for the
purposes of the processing but we are required by the data subject for the
establishment, exercise or defence of legal claims. 8.8.4You have objected to processing pending the verification whether our legitimate
grounds override those of yours. If one of the aforementioned conditions is
met and you wish to request the restriction of the processing of personal data
stored by us, you may at any time contact us. 8.9Right to data portability: You shall have the right granted by the Canadian legislator
to receive the personal data concerning you, which was provided to us, in a
structured, commonly used and machine-readable format. You shall have the right
to transmit those data to another data controller without hindrance from us to
which the personal data have been provided as long as the processing is based
on consent pursuant to the relevant provisions or on a contract and the processing is carried out by automated means as long as the
processing is not necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in us. 8.10Right to object: You shall have the right granted by the Canadian legislator
to object on grounds relating to your particular situation at any time to
processing of personal data concerning you, which is based on relevant provisions. This also applies to profiling based on these
provisions. 8.10.1We shall no longer process the personal data
in the event of the objection, unless we can demonstrate compelling legitimate
grounds for the processing which override the interests, rights and freedoms of
the data subject or for the establishment, exercise or defence of legal claims. 8.10.2If we process personal data for direct
marketing purposes, you shall have the right to object at any time to
processing of personal data concerning you for such marketing. This applies to
profiling to the extent that it is related to such direct marketing. If you
object to us to the processing for direct marketing purposes, we will no longer
process the personal data for these purposes. 8.10.3In addition, you have the right, on grounds
relating to your particular situation, to object to processing of personal data
concerning you by us for scientific or historical research purposes or for
statistical purposes, unless the
processing is necessary for the performance of a task carried out for reasons
of public interest. 8.11Automated individual decision-making,
including profiling: You shall
have the right granted by the Canadian legislator not to be subject to a decision
based solely on automated processing, including profiling, which produces legal
effects concerning you, or similarly significantly affects you, as long as the
decision (1) is not necessary for entering into, or the performance of, a
contract between you and us, or (2) is not authorised by Canadian law to which we are subject and which also lays down suitable measures to safeguard
your rights and freedoms and legitimate interests, or (3) is not based on your
explicit consent. If the decision (1) is necessary for entering
into, or the performance of, a contract between you and us, or (2) it is based
on your explicit consent, we shall implement suitable measures to safeguard your
rights and freedoms and legitimate interests, at least the right to obtain
human intervention on our part, to express your point of view and contest the
decision. 8.12 Right to withdraw data protection consent: You shall have the right granted by the Canadian legislator
to withdraw your consent to processing of your personal data at any time. You
may initiate request with us at[email protected]to exercise
any of the above-mentioned rights. We shall review your request and, in our own
discretion, honour your request, if deemed necessary by us, within reasonable
time.
9.Cookies 9.1 We use
technologies such as cookies to make better users experience, customise
content, to provide social media features and to analyse traffic to the
Website. Where applicable the Website uses a cookie control system allowing the
user on their first visit to the Website to allow or disallow the use of cookies
on their computer / device. 9.2 Cookies are
small files saved to the user's computers’ or mobile devices’ hard drive or
memory that track, save and store information about the user's interactions and
usage of the Website. This allows the Website, through its server to provide
the users with a tailored experience within the Website. 9.3 Users are
advised that if they wish to deny the use and saving of cookies from the Website
on to their computers hard drive they should take necessary steps within their
web browsers security settings to block all cookies from the Website and its
external serving vendors. 9.4 We may gather
certain information automatically and store it in log files. This information
includes Internet protocol (IP) addresses, browser type, Internet service
provider (ISP), referring/exit pages, operating system, date/time stamp, and
click stream data. We may use this information, which does not identify
individual users, to analyse trends, to administer the Website, to track users’
movements around the Website and to gather demographic information about our
user base as a whole. 9.5We may track
the referring URL (the web page you left before coming to the Website) and the
pages, links, and graphics of the Website you visited. We do so because it allows
us to evaluate the reputation and responsiveness of specific web pages and any
promotional programs we may be running. 9.6Managing Cookies: Many web browsers allow you to manage your
preferences. You can set your browser to refuse cookies or delete certain
cookies. You may be able to manage other technologies in the same way that you
manage cookies using your browser’s preferences. 9.7 Please note
that if you choose to block cookies, doing so may impair your Use of the Website
or prevent certain elements of it from functioning.
10.Third-Party Service
Providers 10.1 We may employ
third party companies and individuals to operate or manage the Website ("Third Party Service Providers"),
to provide the services listed on the Website on our behalf or to assist us in analysing
how the Website is used. 10.2 These third
parties have access to your Data only to perform these tasks on our behalf and
are obligated not to disclose or use it for any other purpose.
11.Changes to
this Privacy Statement 11.1We may modify
these this Privacy Policy from time to time and any such change shall be
reflected on the Website with the updated version of the Privacy Policy and you
agree to be bound to any changes to the updated version of Privacy Policy when
you use the Website. 11.2You
acknowledge and agree that it is your responsibility to review the Website and
this Privacy Policy periodically and to be aware of any modifications. Updates
to this Privacy Policy will be posted on this page. 11.3Occasionally
there may be information on the Website that contains typographical errors,
inaccuracies or omissions that may relate to service descriptions, pricing,
availability, and various other information, and we reserve the right to
correct any errors, inaccuracies or omissions and to change or update the
information at any time, without prior notice.
12. Contact US 12.1If you have questions about our Privacy Policy,
please contact us via email: [email protected].