Sharegate Group Inc. (“Sharegate”) offers tools and platforms commercialized as “Sharegate” (“Sharegate Product”) and “Sharegate Online” (“SGO Product”) which allow for a more straightforward management of SharePoint & Office 365. Sharegate understands the importance of protecting personal information. For this reason, Sharegate strives to have business procedures and security safeguards in place to protect personal information under its control.

Application and Scope

This Privacy Policy (“Policy”) is intended to establish responsible and transparent practices for the management of personal information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Sharegate in respect of any personal information collected, accessed or processed by Sharegate in the course of its business operations and specifies the obligations of Sharegate that arise from the End user license, maintenance and support agreement (the “EULA”) governing the use of Sharegate Product and from the Terms of Service (the “Terms”) governing the use of SGO Product, entered into between Sharegate and its corporate customers (each, a “Customer”), whereby Sharegate might handle or have access to personal information.

This Policy also governs personal information collected about Sharegate’s website users and explains how Sharegate uses and discloses personal information collected from people who visit its website and otherwise interact with Sharegate through https://en.share-gate.com (the “website”). It also explains how Sharegate uses cookies and similar technologies.

International Compliance

Sharegate complies with: (i) data protection laws applicable to Sharegate; and (ii) applicable industry standards concerning data protection, confidentiality or information security. Sharegate has global operations and therefore, in some cases, information managed by Sharegate may be transferred, processed and stored in other countries, although at all times, Sharegate will ensure that personal information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Sharegate itself.

Sharegate complies with this Policy as well as applicable Canadian private sector data protection laws such as the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and substantially similar provincial laws pertaining to the collection, use and disclosure of personal information. PIPEDA provides for an adequate protection of personal information according to the European Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and the Council.

Definition of Personal Information

Personal information is defined as “any information about an identifiable individual”. This may include, for example, email addresses and contact details and any similar information provided to Sharegate in the course of its business operations, or which Sharegate may receive from business inquiries. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.

Collection and Use of Personal Information through the Products and Services

When providing products and services, Sharegate only processes personal information in accordance with the EULA, the Terms and applicable laws. Sharegate generally uses personal information from or about its Customers or which is received from Customers and belongs to their own customers or end users (hereinafter referred to as “Customer’s Personal Information”) for the following purposes:

  • to create, establish and administer Customer’s subscription to Sharegate’s products and services, to respond to Customer inquiries related to its subscription and to contact Customer about Sharegate’s products and services or subscription -related matters;
  • to provide products, including to provide Customer with Sharegate Product and customer support related to Sharegate Product;
  • to provide services, including to provide Customer with access and use of the SGO Product and customer support related to SGO Product;
  • to measure and analyze user behavior in order to, among others, monitor, maintain and improve Sharegate’s products, services or features and to create new products, services or features;
  • to meet legal and regulatory requirements and to allow Sharegate to meet contractual requirements relating to the products and services provided to Customer;
  • to conduct surveys on the quality of Sharegate’s products and services or to collect feedbacks on the products and services; and
  • to provide Customer with offers for additional products and services that Sharegate believes may be of interest to Customer.

Unless required or authorized by law, when providing products and services, Sharegate will not use personal information for any other or new purpose without obtaining its Customers’ consent.

Collection and Use of Personal Information through the Website

Sharegate generally collects and uses personal information from or about its website users as follows:

  • Information provided by users. In many cases, Sharegate collects personal information directly from users when they visit or use the website. For instance, Sharegate may collect the following types of information:

    • Inquiries. Sharegate may collect users’ name, contact information, e-mail address and any information provided when users make an inquiry or contact Sharegate through the website, download documentation or gated content from the website, sign up for a webinar through the website and/or sign up to receive Sharegate’s newsletter. Sharegate will only use this information to process and answer users’ request or to manage Sharegate everyday business needs in connection with such request.
    • Requests for a Trial and/or Product and/or Service. Sharegate may collect users’ name, contact information, e-mail address and any other information provided to Sharegate when users submit a request or an order for a Sharegate trial and/or product and/or service. Sharegate will only use this information to process and answer users’ request or to manage Sharegate everyday business needs in connection with such request.
    • Personalization of Website. When users visit the website, they may, from time to time, be invited to provide information such as user’s title and company size to help Sharegate personalise or customise the users experience when using the website.
  • Technical information. When users visit the website, Sharegate may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including IP address of the users’ computer and which browser was used to view the website, the users’ operating system, resolution of screen, location, language settings in browsers, the site the user came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc.  This data is used to measure and improve the effectiveness of the website or enhance the experience for users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, Sharegate will treat this information as personal information. Sharegate may also, without limitations, collect and use the following type of information when users visit and/or interact with Sharegate on the website:

    • Google Analytics: Sharegate uses Google Analytics which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Sharegate’s use of Google Analytics by visiting the Google Analytics opt-out page.
    • Marketo: Sharegate uses Marketo which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. However, this information is not depersonalized and users may not opt-out of Sharegate’s use of Marketo.
    • Google AdWords: Sharegate uses Google AdWords Remarketing to advertise Sharegate across the Internet and to advertise on third party websites (including Google) to previous visitors to the website. AdWords remarketing will display ads to users based on what parts of the Sharegate website they have viewed by placing a cookie on the users’ web browser. It could mean that Sharegate advertises to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the user or give access to the users’ computer or mobile device. The cookie is only used to indicate to other websites that the user has visited a particular page on the website, so that they may show the user ads relating to that page. If users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.
    • Interest-based Advertising. Sharegate may also allow a limited number of trusted third parties to install cookies on users’ hard drive from the website. The website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about users, such as page views on the website, information requests or purchases on the website. Sharegate does not provide any personal information to advertisers or to third party sites that display interest-based ads on the website. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content displayed on the website are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the website directly to users’ browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. Sharegate does not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Policy. Please contact them directly for more information about their privacy practices. Users can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Digital Advertising Alliance of Canada. Please visit the DAAC opt-out page for more information.
  • Choice with Cookies. Users can block the use of cookies by activating the settings in their browser. The “Help” feature on most browsers will tell users how to prevent their browser from accepting new cookies, how to have the browser notify the users when they receive a new cookie, or how to disable cookies altogether. If users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
  • Privacy Policies of other Websites. This Policy only addresses the use and disclosure of information by Sharegate. Other websites that may be accessible through the website have their own privacy policies and data collection, use and disclosure practices.
  • Personal Information from other Sources. Sharegate may obtain from third parties additional personal information about a website user if such user gave permission to those third parties to share its information.

Sharing of Personal Information

Sharegate will not sell, rent or trade personal information to any third party. However, Sharegate may share personal information when authorized and/or required by law or as follows:

  • Service providers. Sharegate may grant access to personal information to third party services providers in connection with the performance or the improvement of its website, services and products. Before sharing any personal information with any of its third party service providers, Sharegate will ensure that the third party maintains reasonable data management practices for maintaining the confidentiality and security of personal information and preventing unauthorized access.
  • As permitted or required by law. Sharegate may disclose personal information as required by applicable law or by proper legal or governmental authority. Sharegate may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Sharegate may also release certain personal information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and itself, in accordance with or as authorized by law. In the event Sharegate receives a governmental or other regulatory request for any Customer’s Personal Information, it agrees to immediately notify Customer in order that Customer shall have the option to defend such action. Sharegate shall reasonably cooperate with Customer in such defense.
  • Business transaction. Sharegate may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, personal information will remain protected by applicable data protection laws. In the event the transaction is not completed, Sharegate will require the other party not to use or disclose the personal information received in any manner whatsoever and to delete such information.

Security of Personal Information

Sharegate will store and process the personal information in a manner consistent with industry security standards. Sharegate has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of personal information and to mitigate the risk of unauthorized access to or use of personal information, including (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the personal information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit or at rest; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with up-to-date virus definitions and security patches so as to avoid any adverse impact to the personal information that it manages; appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; permitting only authorized users access to systems and applications; and (iv) all persons with authorized access to personal information must have a genuine business need-to-know prior to access (“Security Program”).

Training and Supervision

Sharegate maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. Sharegate shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the personal information it manages.

Data Incidents involving Customer’s Personal Information

Sharegate shall immediately notify Customer of any reasonably suspected or actual loss of data or breach or compromise of its Security Program which has or may result in the loss or unauthorized access, disclosure, use or acquisition of Customer’s Personal Information (including hard copy records) or otherwise presents a potential threat to such information (“Data Incident”). While the initial notice may be in summary form, a comprehensive written notice shall be given within 48 hours to Customer. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action already taken or to be taken by Sharegate. Sharegate shall promptly take all necessary and advisable corrective actions, and shall cooperate fully with Customer in all reasonable efforts to mitigate the adverse effects of Data Incident and to prevent its recurrence.

How to Contact Us

Any questions or complaints regarding this Policy or Sharegate handling of personal information can be addressed by sending an email to: legal@share-gate.com.

Change of Privacy Policy

Sharegate will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. This Policy may therefore change from time to time.

This Policy was last updated on July 10th, 2017.