Last modified April 2, 2021

Privacy Policy

Welcome!

Welcome to the Zivo website located at https://www.zivo.ca/ (the “Website”) which includes all subdomains and subpages present and future.  We are delighted that you have chosen to visit us. Zivo Financial Services Inc. (the company that owns and operates the Website) takes your privacy and security of Personal Information very seriously. We have provided and will continue to provide a secure environment and this strict Privacy Policy (the “Policy”) that describes the limited ways your information is used and the limited access to such information.

This Policy also covers Personal Information you submit through Zivo’s Client Portal located at https://www.encyro.com/zivo (the “Client Portal”).


Key Elements of this Policy

Here are the key elements of the Policy so you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your Personal Information. You can find the details in the rest of the Policy


About Us and Definitions

The Website is owned and operated by Zivo Financial Services., a company located in Ottawa, Canada at the address listed below. Where this Policy refers to “Zivo” it may refer to Zivo Inc. and / or its affiliates, and their respective shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to Zivo and / or its Representatives. In this Policy, a Website visitor or user may be referred to as “you” or “your”.

Additional definitions shall be made throughout this Policy, but they will be recognizable as they will be capitalized, bolded, and in quotation marks. Additional definitions may also be found in the Terms of Use, and will have the same meaning in this Policy as they do there. The definitions found in this Policy shall also apply to the Terms of Use.


Acceptance and Modifications

By visiting or using the Website you agree to be bound by the terms of the Policy. By submitting Personal Information to us on the Website or via other means, you consent to Zivo’s collection, use and disclosure of such Personal Information (as that term is defined hereinbelow) in accordance with this Policy (as amended from time to time) and as permitted or required by law.

Zivo reserves the right, at any time and without prior notice, to modify or replace any of the Policy. Any changes to the Policy can be found at this URL. It is your responsibility to check the Policy periodically for changes. Your use of the Website following the posting of any changes to the Policy constitutes acceptance of those changes. If there are any significant changes to the Policy that materially affect the way we treat your information, we will use commercially reasonable efforts to notify you by posting a prominent notice on the Website. You can always identify the most recent version of the Policy by the date at the top of this page.

The Policy should be read in conjunction with the Terms of Use, as both these documents govern your use of the Website.

If you have any questions about the Policy or if you wish to inquire about and / or access any Personal Information Zivo holds about you, please contact:


Zivo Privacy Officer

privacy@zivo.ca

or:

Zivo Privacy Officer
5-2164 Montreal Road
Suite #8171
Ottawa, ON K1J 1G4


What Does This Privacy Policy Cover?

This Policy covers the treatment of personally-identifiable information, i.e. any information that identifies an individual, or can be used in conjunction with other information to identify an individual (“Personal Information”) and other information gathered by Zivo when you are visiting or using the Website. This Policy also covers Zivo’s treatment of any Personal Information that Zivo may share with its business partners or other third parties under very limited circumstances.

This Policy does not apply to the general practices and treatment of information (whether Personal or not) by third parties that Zivo does not own or control, including but not limited to any third-party websites or services that you elect to access through the Website or via a link from the Website that are not owned by Zivo (“Third-Party Websites”), or to individuals that Zivo does not manage or employ. While we attempt to facilitate access or link only to those Third-Party Websites that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Websites. We encourage you to carefully review the privacy policies of any Third-Party Website you access.

Finally, this Policy does not cover any Personal Information you send to Zivo via any non-secured, non-encrypted mode of communications such as email, instant messenger or other messaging service, or Twitter or any other social media, as communications via these methods may be subject to interception, loss, or alteration. While we welcome your comments and suggestions sent to us in this manner, we encourage you to carefully examine what Personal Information you send to Zivo via these methods.


No Collection of Personal Information as a Matter of Course

Zivo does not, as a matter of course, gather any of your Personal Information while you visit or use the Website, unless you are asked to provide such information and voluntarily choose to do so, for example by filling in a contact form. Personal Information is only gathered with your informed consent. Where you have provided Personal Information, it will only be used for the stated purpose, as detailed more specifically in the next section.


Personal Information Collected and Its Uses

The following is an exhaustive list of Personal Information collected from you when you visit or use the Website or Client Portal and what we use it for. You acknowledge and agree that you are submitting this Personal Information with your informed consent.

  • “Contact Information”. When you fill in the contact form on the Website, we collect your name, company name, phone number and email address. We only use this to respond to your inquiry;
  • “Client Information”. When you use the Client Portal to upload documents, you will be required to include your email address and optionally your name. We use the information to receive documents uploaded, and to communicate with you about the documents.

In addition to the functions and uses just described, Zivo may also use your Personal Information you have submitted in order to perform any functions as otherwise explicitly described to you at the time of your submission of your Personal Information.


Security of Information

Zivo uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, Zivo uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website, and these third parties have been selected for their high standards of security, both electronic and physical.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where data protection laws require us to do so, and within the time frame required by the applicable data protection law.

All information, including Personal Information, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check Zivo’s valid SSL security certificate for the Website. All information (both documents and Personal Information) uploaded to the Client Portal is encrypted both in transit and at rest.


Non-disclosure of Personal Information to Third Parties

Except as provided in the next paragraph and specified in the next three sections of this Policy, Zivo does not divulge any Personal Information gathered via the Website or Client Portal to third parties. Moreover, Zivo does not sell, rent, trade or license any Personal Information regarding its Website visitors or users to third parties. Only the Representatives and subcontractors of Zivo are responsible for the management and development of the Website and Client Portal, and only these individuals have access to the information collected there. These Representatives and subcontractors all have been instructed to comply with the Policy, and are under contractual obligations of non-disclosure.

Notwithstanding anything in the Policy to the contrary, we may share any information we have collected about you or that you have submitted (whether Personal Information or not): (1) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims or demands; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the Terms of Use; (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Website generally); (4) to a parent company, subsidiaries, joint ventures, or other companies under common control with Zivo (in which case we will require such entities to honour this Policy); (5) if Zivo merges with another entity, is subject to a corporate reorganization, or sells or transfers all or part of its business, assets or shares (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).


Transfer of Personal Information to Third Parties

We routinely share some of your Personal Information with certain third parties in order to facilitate the functioning of the Website and Client Portal. These third parties are identified in the table below, along with what they do with the Personal Information transferred to them.

Links: Webflow  Amazon AWS  Hubspot  Encryo  Google Analytics


Zivo Advertising and Opting Out

Zivo is continuously evaluating and modifying our use of various advertising networks, which may change from time to time. In this section you will find all the advertising networks that Zivo may use and instructions for opting out of them. If you wish to inquire about what advertising networks are being used at any particular time by Zivo, please contact our Privacy Officer at the contact information above.

Zivo may use Google AdWords and Display Network and by visiting the Website you consent to this use. Specifically, Zivo uses the remarketing features of interest-based advertising of Google AdWords that delivers you advertisements that will be of particular interest to you, based on your browsing and activity history interacting with the Website. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these ads around the web. You may prevent this type of advertising by deleting the appropriate Google cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google advertising by adjusting your Google ad settings or using the WebChoices online opt-out tool.

Zivo may advertise using Facebook Custom Audience, to display advertisements to you on Facebook or in Facebook Messenger that will be of interest to you, and by visiting the Website you consent to this use. Facebook may collect or receive information from the Website and other applications and websites and use that information to provide measurement services and targeted ads. If you do not want to receive such Facebook advertisements, you can opt-out of such advertising by adjusting your Ad Preferences settings while logged in to Facebook.

Zivo may also advertise using LinkedIn Advertising , to display advertisements to you on LinkedIn that will be of interest to you, and by visiting the Website you consent to this use. LinkedIn may collect or receive information from our and use that information to provide measurement services and targeted ads. If you do not want to receive such LinkedIn advertisements, you can opt-out of such advertising by following LinkedIn's instructions or using the WebChoices online opt-out tool.


Limited Gathering of Information for Statistical, Analytical and Security Purposes

Zivo automatically collects certain information using third-party analytics program Google Analytics to help us understand how our users use the Website, but none of this information identifies you personally. For example, each time you visit the Website, we automatically collect (as applicable) your IP address, browser and computer or device type, access times, the web page from which you came, the web page(s) or content you access, and other related information. We use information collected in this manner only to better understand your needs and the needs of Website visitors and users in the aggregate. Zivo also makes use of information gathered for statistical purposes to keep track of the number of visits to the Website, the specific pages on the Website, and users with a view to introducing improvements to the Website.

Your IP address and other relevant information we collect using Google Analytics may be used in order to trace any fraudulent or criminal activity, or any activity in violation of the Terms of Use.


Tracking Technology ("Cookies") and Related Technologies

Zivo uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website and by visiting or using the Website you agree to their use. Cookies are small text files placed on your computer or device when you visit a website, in order to track use of the site and to improve the user experience by storing certain data on your computer.

Specifically, we use cookies and related technologies for the following functions:

  • to facilitate online advertising, as described above in this Policy;
  • to provide general internal and user analytics and to conduct research to improve the content of the Website using Google Analytics as described above in this Policy; and
  • to assist in identifying possible fraudulent activities.


Your browser can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:

Please note that deleting these cookies may reduce your user experience on the Website. Furthermore, deleting cookies may prevent certain functions from working at all. Zivo and its Representatives shall not be held responsible for any function that may not operate after you delete cookies, or any losses or damages (pecuniary or otherwise) arising from those functions not operating, or having reduced functionality.


Verification, Correction and Deletion of Personal Information

You have the right to: (i) verify what Personal Information Zivo holds about you; (ii) ask for your Personal Information to be corrected or updated; and (iii) to withdraw your consent to the use by Zivo of your Personal Information and have it deleted from our records. If you wish to inquire about and verify and / or correct Personal Information Zivo holds about you, or if you wish to have all your Personal Information permanently deleted from our records, please contact us using the contact information further up in this Policy. Please note that deletion of your Personal Information may make it impossible for you to use the Website or Client Portal, or certain portions thereof, and Zivo and its Representatives accepts no responsibility for any damages, pecuniary or otherwise, resulting therefrom. If you request deletion of your Personal Information, Zivo reserves the right to retain some of your Personal Information for a reasonable time in order to satisfy our legal obligations or under a legal procedure of any sort.


Risks Associated with the Internet and Wireless Data Transmission

Despite Zivo’s best efforts to ensure that third parties will not access or obtain your Personal Information through your use of the Website, complete confidentiality and security cannot currently be guaranteed on the Internet and / or where data is transferred via digital wireless technology of any type. Communication via the Internet or wireless data transmission is subject to interception, loss, or alteration. You acknowledge and agree that Zivo and its Representatives cannot be held responsible for damages resulting from the transmission of confidential information or Personal Information in this manner and that such communications are at your own risk.


Compliance with Privacy Laws

This Policy and Zivo’s practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”, S.C. 2000, c. 5). If you have any questions regarding this compliance, please contact us using the contact information further up in this Policy.


© Zivo Financial Services Inc. 2021