Key Elements of this Policy
Here are the key elements of this 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 data. By submitting any personal data to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy.
|Personal data we collect from you but only with your consent||What we do with it||Third parties we share it with|
|Contact Information||Communicate with you and manage our relationship, depending on your relationship with us||Companies that provide our communications services, such as MailChimp and Google|
|User Information||Manage your account, and enable logging in to the Subscription Services||Companies that provide the infrastructure for the Subscription Services, specifically Amazon Web Services (AWS)|
|Customer Information||Manage your account and communicate with you about the Subscription Services||Companies that provide the infrastructure to store and manage Customer Information, specifically Copper|
Before we get started with the details, here are a few terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. These include: (1) the “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (2) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada; and (3) the California Consumer Privacy Act (“CCPA”) which applies to our activities in the United States in certain circumstances. Paladin AI is committed to adhering to all these applicable Data Protection laws.
“Personal data” – this is information we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA and the CCPA, the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.
About Us and Contacting Us
Paladin AI Inc. (“Paladin AI”) is a duly federally-incorporated company in the Province of Quebec, Canada. Where this Policy refers to “Paladin AI”, it may refer to Paladin AI Inc. and / or its shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns, depending on the context.
Under the GDPR, Paladin AI is a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can email or mail the Privacy Officer at:
Paladin AI Privacy Officer
2881 Place du Lievre
J7T 2M4 Canada
You have the following rights regarding your personal data held by Paladin AI, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting the price you pay for any of the Services. Notwithstanding that, exercising certain of these rights may affect your ability to use some or all of the Services.
- The right to withdraw at any time your consent for Paladin AI to process your personal data;
- The right to have your personal data erased from Paladin AI’s records;
- The right to access your personal data and any relevant information around its processing and use;
- The right to have a copy of your personal data given to you in an easy to read format so that you can transfer it to any data processor;
- The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
- The right to opt out of marketing communications we send you, at any time;
- The right to know whether Paladin AI sells or shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications;
- The right to demand that Paladin AI not sell your personal data;
- The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law; and
- The right to refuse any marketing or advertising targeted at you by Paladin AI.
If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above, or refer to certain relevant sections further in this Policy.
Personal Data Collected from You and What We Use It For
In the table below, please find all the personal data we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA, the legal basis is your informed consent, and by submitting this personal data you acknowledge having granted this consent to Paladin AI.
|Personal data category||Personal data processed||What we use it for (the “purpose” of processing)||Legal basis for processing under the GDPR|
|Contact information||Your name, company and email address||To communicate with you in reply to your inquiry||Your consent in giving us this information|
|User information||Name and email address, and the Customer of Paladin AI you work for||To create an account for you, to communicate with you, and to provide you with access to the Subscription Services||Your consent|
|Customer Information||Name, email address, business address, and phone number||To communicate with you and manage your subscription to the Subscription Services||Your consent and performance of a contract|
Where you have provided personal data further to the contract between you and us, if you fail to provide such data or withdraw your consent to use such data, we will no longer be able to provide certain Services to you.
Personal Data Collected About You from Third Parties and What We Use It For
Sometimes we get personal data about you from third parties. This table explains the details about this personal data – what it is, where it came from, what we do with it, and legal basis for us having and processing this personal data under the GDPR. Under PIPEDA, the legal basis is your informed consent.
|Personal data category||Personal data processed||Who we get the data from||What we use it for (the “purpose” of processing)||Legal basis for processing under the GDPR|
|User Information||Name and email address||The Customer of Paladin AI you work for who has signed an agreement with us||To create an account for you, to communicate with you, and to provide you with access to the Subscription Services||Your consent and performance of a contract|
Sensitive Personal Data
We do not collect any of what the GDPR considers sensitive personal data from you, unless you voluntarily submit it to us via email or other method, which we encourage you not to do.
Who We Transfer Your Personal Data To
We routinely share some of your personal data with certain types of third parties who are identified in the table below along with what they do with it. Some of those third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area — please see the “Transfer of Your Personal Data Outside of the European Economic Area” further down in this Policy for more information including on how we safeguard your personal data when this occurs.
We will share personal data with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (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 any Paladin AI contract that governs your relationship with us; or (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming or denial of service attacks).
We will never share your personal data with other third parties except under these circumstances. We do not sell or rent your personal data to any third party for direct marketing purposes or any other purpose.
|Personal data category||Who we transfer it to||What they do with it|
|Contact information||Companies that provide email services such as MailChimp, and as detailed more fully in the Email Communications section below||Send you emails|
|User Information||Companies providing technical infrastructure for the Subscription Services, specifically Amazon Web Services (AWS)||Control your logging in to the Subscription Services so they can be provided to you, and record-keeping|
|Customer Information||Companies that store our Customer Information, specifically Copper||Store and organize the information|
|Analytics identifiers||Companies that provide data analytics for the Website, such as Google Analytics||Provide us with analytics as to how the Website is used|
|Analytics identifiers and related information including IP address||Companies that provide data analytics and crash reporting for the Subscription Services, specifically Bugsnag and Datadog||Report errors and crashes of the Subscription Services to us so that we can diagnose and fix them|
Email Communications and Compliance with Anti-Spam Laws
You may unsubscribe from Paladin AI’s mailing list at any time, by following the link at the bottom of those Paladin AI emails. Other types of emails, such as relational and emails related to the Services will not have an opt-out option as they are necessary for the use of the Subscription Services.
Paladin AI’s practices in regard to its email are designed to be compliant with anti-spam laws, including but not limited to the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23). If you believe you have received email in violation of these laws, please contact us using the contact information further up in this Policy.
How We Protect Your Personal Data
We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way. All personal data is pseudonymized so that individuals and their related personal data are not identifiable to Paladin AI personnel.
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 the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.
Paladin AI uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Paladin AI uses Amazon Web Services (AWS), a recognized leader in secure data, for hosting of the Services and related data, and storage of data including personal data.
Finally, all information, including personal data, 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 Paladin AI’s valid SSL security certificate on the Website.
Transfer of Your Personal Data Outside of the European Economic Area (EEA)
For our European users, we endeavour to keep your personal data inside the EEA. Please note that if you are in Europe, the Subscription Services provided to you are hosted on AWS servers located in Europe (Frankfurt, Germany). Notwithstanding that, certain of our data processors (and Paladin AI) are in other countries where your personal data may be transferred. However, these countries are limited to countries with particular circumstances that protect your personal data, specifically:
- It has been determined that Canada has an “adequate level of protection” for your personal data under European data protection law.
- The United States. Your personal data is only transferred to companies in the United States that: (1) have signed agreements with us or have informed us that they are GDPR-compliant; and (2) have concluded the Standard Contractual Clauses for the transfer of personal data outside the EEA.
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA. Please contact our Privacy Officer to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Services.
Supervisory Authorities and Complaints
If you are in the EEA, under the GDPR you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Officer, or if you would like to make a complaint directly about Paladin AI’s data practises, we invite you to contact the supervisory authority in your country. For example, if you are in the U.K., you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF). If you are in France, you should contact the Commission Nationale de l’Informatique et des Libertés who is the supervisory authority there. Their contact information can be found here.
The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here.
If you are in Canada and you are not satisfied with the response received or the actions taken by our Privacy Officer, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website.
Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will only retain your User Information for as long as you have an account with us to use the Subscription Services.
Paladin AI uses certain automated decision-making processes in providing the Subscription Services. These automated processes are integral to the functioning of the Subscription Services, and are used to help train pilots and student pilots. None of the automated decision-making is attached to any particular data subject that could be identified by Paladin AI.
Children’s Privacy Statement
The Services are not intended for children under the age of 16. We do not knowingly collect any personal data from a child under 16. If we become aware that we have inadvertently received personal data from a person under the age of 16 through the Services, we will delete such information from our records.
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on the Website if we make significant changes. If you have a Paladin AI account or are our Customer, we will also email you to tell you the Policy has been updated, and what the important changes are.