PRIVACY POLICY

Agnovi Corporation is a registered company at 15-1010 Polytek Street, Ottawa, Ontario, Canada, K1J 9H9, and owner of X-FIRE and REX, software solutions to help police, law enforcement and private sector companies gather, store, sort, access and analyze investigative information available as on-premise software (“Software”) and available through our cloud-computing software as a service application (accessible through a browser at agnovi-cloud.com or through our Desktop Client) (“Application”).  Agnovi Corporation also owns and operates www.agnovi.com (“Website”).

This Privacy Policy describes how Agnovi Corporation, its officers, directors, employees, subsidiaries, agents, assigns, and affiliates, (“Agnovi”, “we”, “us”, “our”) collects, uses, retains, stores, discloses, and protects your Personal or Sensitive Data, and how Agnovi processes Customer Data collected by police and law enforcement agencies, or similar organizations and entities (“you”, “yours”, “customer”).

As you read through this Privacy Policy, keep the following in mind:

“Consent” means the voluntary, unequivocal, expressed, informed, unambiguous, and meaningful indication from you stating that you wish to agree to the collection or processing of your Personal Data.

“Customer Data” means all electronic data or information

  1. uploaded by you on on-premise servers or to our Third-Party Platforms through our Application or Software, as the case may be;
  2. including Personal Data or Sensitive Data of persons lawfully collected by you;
  3. calculated, populated, or generated in any form(s) by the Application or Software;
  4. created as a result of additional inputs by you through the Application or Software;
  5. law enforcement data, or any data received from a law enforcement agency or agent, collected or generated by you;
  6. related to criminal records, offenses, claims or judgments against, any data subject, collected by you; and/or,
  7. generated by the Application or Software in the form of output data (i.e. reports, graphics, tables, etc.).

“Desktop Client” means our downloadable software that allows you to access our Application if you have signed up to use our cloud-computing software as a service.

“Master Subscription Agreement” means the services agreement between a customer and Agnovi, if you have entered into such an agreement.  If you have entered into a Master Subscription Agreement, the terms used in this Privacy Policy have the same meanings as in our Master Subscription Agreement.  Where there is a conflict of terms, the interpretation and definitions of the Master Subscription Agreement shall apply.

“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data does not include information that is anonymized or aggregated.

“Processing” means any work we do with data, including how we change data into non-personally identifiable information or aggregate information (i.e. pseudonymization).  This includes collecting, retaining, using, disclosing, storing, and destroying the information.

“Sensitive Data” means any Personal Data relating to health, finance, criminal records or information subject to specific regulation, and the disclosure of which would be reasonably detrimental to the data subject to whom it relates.  EXAMPLES: credit card numbers, income, salary, payment information, bank details, medical records, and criminal records.

“Third Party” means a person or organization that is authorized by agreement, contract or otherwise between the person or organization and Agnovi to access and process Personal Data or Sensitive Data.

“Third-Party Host” means the party that operates the Third-Party Platform.

“Third-Party Platform” means the online platform that hosts the Application and where Customer Data is stored when a customer has signed up for and uses the Application, operated and maintained by the Third-Party Host.

PERSONAL OR SENSITIVE DATA

WHAT DATA DO WE COLLECT?
We only collect information to provide the Software or Application and our services to you.  We do not collect or process Personal or Sensitive Data further than what we require for the basic functionalities of our Software, Application, and Website.

When you contact us through our Website, or contact us to sign up for our services, we collect Personal and Sensitive Data that includes your:

  • Your name;
  • Company information;
  • Email;
  • Telephone number;
  • Address (city, province, postal code); and
  • Payment information as required.

Agnovi does not collect information of any one individual except for your organization’s contact person(s) or person(s)-of-record under your service agreement with Agnovi.

We do not knowingly collect, process or retain any Personal Data or Sensitive Data from children under the age of majority in any jurisdiction.

HOW DO WE COLLECT PERSONAL OR SENSITIVE DATA?
In general, we collect Personal Data or Sensitive Data:

  • you provide to us when you use the form on our Website.
  • you provide when you contact us for business purposes.
  • when you contact us for customer support to investigate and address customers’ concerns and improve our Software and Application. Information gathered or produced during support of our customers is retained for as long as required to ensure that we address concerns in the best way possible.
  • we find available publicly.

Tracking Technologies on our Website

 Through our Website, we collect certain aggregate information using “cookies”.  A cookie is a small text file that the website sends to your browser, which then stores the cookie on your hard drive to save you time, provide you with a more meaningful visit, and measure website activity.  Different types of cookies include session cookies, persistent cookies, advertising cookies, and analytics cookies.  Cookies help us:

  • Identify return visitors;
  • Determine whether you are logged into the website and Software;
  • Prevent fraudulent use of login information;
  • Display advertisements that are relevant to you; and
  • Track the performance of our website and Software.

Cookies generally cannot be used to reveal your identity however Personal Data that we store may be linked to the information contained in and obtained from cookies.  Some of our third-party service providers likely use cookies as well (see How Do We Share Data?).

Agnovi uses different types of cookies including cookies for:

  • Functionality to recognize you on the Website;
  • Advertising to collect information about your visit to our Website, content viewed, links followed, browser information, device, and IP address.

Managing Cookies

You can set your browser not to accept cookies.  For instructions on how to disable cookies:

Agnovi will honour ‘do-not-track’ requests.

HOW WILL WE USE PERSONAL OR SENSITIVE DATA?
Agnovi collects Personal and Sensitive Data to provide you with our services, and to help us address ancillary issues involving security, authentication and billing.

From time to time, we also engage third-party services that collect information to:

  • Operate, support, maintain, improve and supply our Software and Application;
  • Optimize our Website, Software and Application;
  • Conduct security checks and verify identities;
  • Comply with audit and regulatory purposes;
  • Process payments;
  • Provide receipts and reports;
  • Resolve disputes;
  • Collect fees;
  • Comply with our legal obligations;
  • Correspond with you;
  • Troubleshoot problems; and,
  • Inform you of security breaches.

Wherever possible we will seek your Consent before collecting, using, or disclosing your Personal Data, unless otherwise permitted by law.

We will always get your Consent before collecting or processing any Sensitive Data.

We generally retain information throughout the relationship between you and Agnovi.  Once we no longer need the information for the purpose for which it was collected, we dispose of the information in a secure manner unless required by law.

HOW DO WE STORE PERSONAL OR SENSITIVE DATA?
We store your Personal and Sensitive Data on a secure server at our headquarters in Ontario, Canada.  Our servers have adequate technical, physical, and administrative protections.

HOW DO WE SHARE PERSONAL OR SENSITIVE DATA?
Agnovi generally does not share or disclose your Personal or Sensitive Data to others without notifying you unless required by law.

Agnovi shares Personal Data or Sensitive Data:

  • For legal reasons or in the event of a dispute. Agnovi shares your information if we believe it is required by applicable law, regulation, operation agreement, legal process or governmental request.  This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Standard Terms of Service or this Privacy Policy, customer agreements or other policies to protect our rights or property or the rights or property of others, or where there is a dispute relating to your use of our Software and Application; and
  • Although not anticipated in the near future, if Agnovi’s business activities are purchased, acquired, transferred, etc., partly or totally to any third-party, such third parties will have access to your Personal or Sensitive Data. Agnovi would notify you and allow your Personal or Sensitive Data to be transferred to the acquiring third-party.

We engage Third Parties, which would have limited access to Personal Data, including but not limited to:

Because our Third Party service providers process and store Personal Data, we encourage you to check out their privacy policies.

If you request that Personal or Sensitive Data be transferred to a third-party country, subject to the lawfulness of the transfer, Agnovi will ensure there are adequate safeguards available including data protection agreements, binding corporate rules, standard contractual clauses, certifications, or decisions of adequacy.

To the extent that you choose to share your data, or the data of others for which you have at law obtained the Consent, right and authority to provide, freely with any third party, and to the extent permitted by applicable law, Agnovi declines any liability for incidents arising from such sharing and voluntary disclosure on your part.  If at any time you or another person or entity made your Personal or Sensitive Data, or the data of others, for which the Consent, right and authority to make publicly available was legally obtained, you acknowledge that such Personal or Sensitive Data may already be publicly available.  We cannot prevent the use or misuse of such publicly available data by you or others.

WHAT RIGHTS DO YOU HAVE?

  • You have the right to access and review your Personal or Sensitive Data. Upon request, we will provide you with your data within a reasonable time unless otherwise required by law.  If we cannot provide the data to you, we will provide our reasons for denying the request.  Generally, we can provide you with one copy of your data free of charge, additional copies shall be subject to an administrative fee.
  • You have the right to rectify or correct your Personal or Sensitive Data. We endeavor to keep all our records accurate; if we become aware that Personal or Sensitive Data is inaccurate, incomplete or out of date, we will revise the information and we will use reasonable efforts to do so promptly.
  • You have the right to request that Agnovi erase your Personal or Sensitive Data, under certain conditions. We may need to keep some of your Personal or Sensitive Data for legal reasons but will otherwise try our best to remove your data from our systems.
  • You have the right to restrict Agnovi’s processing of your Personal or Sensitive Data. In all cases, Agnovi does not process your Personal or Sensitive Data beyond what is required to provide you with our services or requested information.
  • You have the right to object to Agnovi’s processing of your Personal or Sensitive Data. In all cases, Agnovi does not process your Personal or Sensitive Data beyond what is required to provide you with our services or requested information.
  • You have the right to request that Agnovi transfers your Personal or Sensitive Data we have collected or are processing to another organization or directly to you, under certain conditions. If there are legal reasons why Agnovi cannot fulfill your request, we will let you know.

You also have the rights to:

  • Withdraw your Consent. We will endeavor to comply with the request and adjust our practices regarding your Personal or Sensitive Data within a reasonable time.  Withdrawing Consent does not affect the legality of our collection, use, disclosure, and retention of the information before withdrawal.  In most cases, if Agnovi no longer requires your information for the purposes for which it was collected, then we will dispose of the information.
  • Notify the applicable authorities. If you feel that Agnovi has violated your rights, or if you wish to raise a concern with the data protection authorities, please contact the privacy authority in your jurisdiction.
  • Ask us not to contact you. If so requested, Agnovi will add your contact information to a ‘do not send’ list to comply with your no-contact request.  Note that if you request to be placed on a ‘do not send’ list, your name and limited contact information will be kept on that list.

To exercise any of your rights in this part, please contact us at info@agnovi.com.

Agnovi may request information from you when you contact Agnovi to verify your identity or to add you to a do-not-send or do-not-track list when completing a request under this part.

SECURITY FOR PERSONAL OR SENSITIVE DATA
We maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We also take reasonable steps to assure that third-party service providers to whom we transfer any data provide sufficient protection, and we restrict access to only authorized individuals.  In addition, we require that employee shaving access to personal or sensitive data undergo national security screening including criminal checks, and sign agreements regarding confidentiality and the security of Personal and Sensitive Data.  Only those officers and employees that require access to Personal or Sensitive Data have authority to do so. Our security processes include (varies for Website, Application or Software access):

  • Encryption of data at rest and in transit;
  • Advanced two factor authentication;
  • Strict filtering rules;
  • Brute force detection;
  • Secured and monitored facilities;
  • Authorization to access the Application is restricted to the development team by secure login;
  • Access to the back-end of the Application is restricted to only certain employees; and
  • Access to the Software is restricted to the Customer.

Despite our reasonable efforts to keep your data secure, no company can guarantee the complete security and privacy of its services, information and other data. Our Privacy Policy and procedures are “as is” and Agnovi makes no representations as to the fitness for a particular purpose or merchantability.

In the event of a security breach, or the unauthorized access or disclosure of Personal or Sensitive Data under our control, Agnovi will endeavor to notify you, and all relevant parties including the privacy authorities, as soon as feasible from the time we discover the breach.

CUSTOMER DATA

DO WE COLLECT, USE, DISCLOSE CUSTOMER DATA?
Agnovi does not collect, access, use, or disclose, or dispose of Customer Data in any way.  We have very limited access to Customer Data, which includes Personal Data or Sensitive Data of other people that you have collected, including information related to criminal records, and any other information uploaded by you through our Application to the Third-Party Platform.  We have no access to information uploaded by you through the Software to your on-premise servers.

Our Software and Application processes Customer Data.  Agnovi does not access your Customer Data in any way unless required for support reasons or as requested by you in writing.

In some cases, the domestic or international transfer of data related to criminal convictions or offences requires the control of an official public authority or other legal authority.  If you request us to transfer your Customer Data to a different jurisdiction, you acknowledge that you have at law obtained any necessary authority for the lawful transfer of such data if you have uploaded any such data through Agnovi Software, Application or systems.

You decide how long Customer Data is retained either on your on-premise server or on the Third-Party Platform.  Agnovi backs-up and protects data on Third-Party Platforms.  If requested by you in writing and agreed to under contract, Agnovi can implement automatic disposal of Customer Data on a regular basis.

You acknowledge that you have obtained the necessary Consent or authority required in your jurisdiction to collect, use, retain, disclose to us, and dispose of the Customer Data.  You acknowledge that you will be entirely accountable and liable for unlawfully handling Customer Data, and any costs, damages, claims, charges, or otherwise that arise from such unlawful activity.

HOW DO WE STORE CUSTOMER DATA?
Customer Data is stored one of two ways: