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CaseWare Cloud Privacy Policy

1.0 Overview

1.1 CaseWare Cloud Ltd. (“CWC”) has developed this “Cloud Privacy Policy” in order to demonstrate CWC’s firm commitment to your privacy.

1.2 This Cloud Privacy Policy describes how CWC will collect, use, disclose, retain and protect your Personal Information in order to provide you with access to the CaseWare Cloud Services.

1.3 This Cloud Privacy Policy supplements the general CaseWare Privacy Policy applicable to the Website and Desktop Programs. This Cloud Privacy Policy should be read in conjunction with the general Privacy Policy, CWC’s Terms of Use and where applicable, CWC’s CaseWare Cloud Services Agreement.

1.4 CWC uses and discloses the Personal Information only as described in this Cloud Privacy Policy, CWC’s Terms of Use and any applicable Cloud Services Agreement. By using the Website or CaseWare Cloud Services you consent and agree to such use and disclosure.

1.5 As used herein, the following terms shall have the following meanings:

  • “Affiliate” means a corporation that controls, is controlled by, or is under common control with, CWC.

  • “CaseWare Cloud Services” means those Cloud Services offered by CWC to Customers.

  • “Cloud Infrastructure” means those computing devices, including servers, networking equipment, data storage devices, and associated software used in the provision of the Cloud Services.

  • “Cloud Services” means computing resources provided by way of the Internet and may include the provision of storage, software, platform, computing services or other resources.

  • “Cloud Services Agreement” means an applicable agreement for the provision of CaseWare Cloud Services between a Customer and CWC.

  • “Customer” means a party who has entered into a CaseWare Cloud Services Agreement for the provision of CaseWare Cloud Services with CWC and who has ized you to access and use the CaseWare Cloud Services, so provided;

  • “Desktop Program” means computer software program or programs offered by Affiliates of CWC to Licensees for installation and execution on computing systems owned or operated by Licensee, but does not include the CaseWare Cloud Services.

  • “Licensee” means a party who has entered into a valid license agreement for a Desktop Program with an Affiliate of CWC and who is ized to use and access the Desktop Program.

  • “Personal Information” means information about an identifiable individual, and may include information such as a person’s name, email address, residential address, telephone number, bank account details, and in some cases, more sensitive information such as but not limited to gender, demographic information, family status, investment particulars, consumption preferences, business expenditures, credit score, accounting data, social security or social insurance numbers, bank account information, passports, drivers licenses and payment card information.

  • “Subscriber Data” means any content, information, and data input by you using the Cloud Services as provided for a Customer by CWC, and data derived therefrom.

  • “Website” means www.shheyixing.com, and any other website operated by CWC or its Affiliates in providing the CaseWare Cloud Services and includes all related webpages, and all related websites operated by Affiliates, but does not include any third-party websites which are linked to or may link from the Website whether or not such third-party websites are used in connection with the CaseWare Cloud Services, and does not include the access or use of the CaseWare Cloud Services themselves.

1.6 CWC has the following Affiliates:

  • CaseWare Europe Limited

  • CaseWare International Inc.

  • CaseWare LatinoAmerica, S.R.L.

  • CaseWare Asia Ptd. Ltd.

  • CaseWare IDEA Inc.

  • CaseWare IDEA B.V.

  • CaseWare Software Holding Limited

  • CaseWare UK Limited

  • CaseWare RCM Inc.

  • CaseWare Beijing Limited

  • CaseWare Hong Kong Limited

  • CaseWare Greater China Pte Ltd.

2.0 Questions or Complaints?

If you have any questions or complaints about this Cloud Privacy Policy, please contact us at:

CaseWare Cloud Ltd.

1 Toronto St, Suite 1400

Toronto ON M5C 2V6

Telephone: (416) 867-9504

Fax: (416) 867-1906

Email: privacy@shheyixing.com

3.0 Scope

3.1 In accessing or using the CaseWare Cloud Services you may provide CWC with, and CWC may collect, Personal Information such as:

  • last name, first name, address and date of birth;

  • communication data (e.g. telephone number, email, IP addresses, mac addresses);

  • contract master data;

  • billing and payment data;

  • IT usage data (e.g. user ID, passwords, roles, geolocation data, website usage, cookie related data, tracking and analytics data);

  • bank data (e.g. bank account details and credit card number);

  • and credit rating data (e.g. payment behavior and balance sheets).

3.2 CWC may also collect Personal Information about you from other sources including third parties from whom we have purchased business contact information and from publicly accessible websites, such as your company’s website, professional network services, or press releases.

3.3 CWC may, at its option, combine Personal Information you have provided to CWC with data collected from other sources as described above. CWC may process this data to update, expand, and analyze our existing marketing records; identify new customers; and send marketing emails, as permitted by law.

4.0 Accountability

4.1 CWC’s Security and Compliance Manager is responsible for the oversight and implementation of this Cloud Privacy Policy and procedures to protect Personal Information, for receiving your privacy-related questions, and for providing you with information about CWC’s privacy practices, by posting updated information on CWC’s Website.

4.2 You may send us your privacy-related questions or challenge CWC’s compliance with this Cloud Privacy Policy by submitting your concern to CWC’s Security and Compliance Manager:

Lynn Dookhran

Security & Compliance Manager

(416) 867-9504

privacy@shheyixing.com

5.0 Legal Bases

5.1 CWC’s legal grounds for collecting and using Personal Information as described in this Cloud Privacy Policy fall into the following four categories.

Consent: In some cases, CWC will ask you for your consent to process your personal data, such as when we need your consent for marketing purposes. You can withdraw your consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. If you would like to withdraw your consent, you can do so by emailing privacy@shheyixing.com.

Legitimate Interest: CWC processes certain data for the legitimate interests of CWC, its Affiliates, partners, or customers. These legitimate interests include, for example, contacting you to provide support or sending you marketing information (subject to applicable law); detecting, preventing, and investigating illegal activities and potential security issues; providing the CaseWare Cloud Services; and maintaining and improving the Website, the CaseWare Cloud Services and the CaseWare Desktop Programs. CWC will rely on our legitimate interests for processing Personal Information only after balancing our interests and rights against the impact of the processing on individuals.

Performance of a Contract: CWC processes Personal Information in order to provide the CaseWare Cloud Services, and to perform our obligations under an agreement with you or a Customer.

Other Legal Bases: In some cases, we may have a legal obligation to process your personal data, such as in response to an order of court of law or regulatory ity. We also may need to process your Personal Information to protect vital interests, or to exercise, establish, or defend legal claims.

5.2 CWC collects Personal Information directly from you and only obtains Personal Information from other organizations (e.g., your bank or other third-party service providers) when you provide CWC with the account numbers, passwords or other credentials required to retrieve the Personal Information and for the purpose of providing you with CaseWare Cloud Services.

5.3 To the extent Subscriber Data includes Personal Information about others (including any Personal Information of clients’ of a Customer or third parties), it is your or Customer’s responsibility to obtain, and you represent and warrant that all necessary consents to disclose such Personal Information to CWC have been obtained, and to allow CWC to process such Personal Information in accordance with this Cloud Privacy Policy.

5.4 You can opt out of any e-mail communication sent by CWC or its Affiliates. CWC’s e-mails will contain clear and obvious instructions describing how you can be removed from any mailing list. CWC will remove you at your request within a reasonable amount of time.

6.0 Identifying Purposes

CWC collects, uses and discloses Personal Information only for the purposes of providing CaseWare Cloud Services, the Website and in improving Cloud Services or Cloud Infrastructure, the Website and Desktop Programs, and for such other ancillary purposes consented to by you as set out herein or as required by law.

7.0 Limiting Collection

7.1 Use of CaseWare Cloud Services may require you to provide Subscriber Data. That Subscriber Data may include Personal Information.

7.2 CaseWare may collect Personal Information directly from you when you:

  • register to use the CaseWare Cloud Services;

  • use the CaseWare Cloud Services;

  • provide Subscriber Data; and

  • contact CWC for support.

7.3 CWC also uses common information-gathering technologies for indirectly collecting usage data, including cookies, web beacons and similar technologies to automatically collect information that may contain Personal Information from your computing or mobile device as you use the CaseWare Cloud Services. CaseWare may gather certain information automatically in connection with the use of the CaseWare Cloud Services by individual users. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage.

7.4 CWC may use cookies and similar technologies such as web beacons, tags and JavaScript, alone or in conjunction with cookies, to compile information about the usage of the Website and interaction with emails from CWC or its Affiliates.

7.5 You can always choose not to provide Personal Information to CWC, but it may mean that CWC is unable to provide you with CaseWare Cloud Services or access to the Website.

8.0 Limiting Use, Disclosure and Retention of Personal Information

8.1 CWC collects, uses and discloses information (which may include Personal Information) for the following purposes:

  • To verify your identity.

  • To provide you with the CaseWare Cloud Services. CWC may collect contact, billing or credit information including phone numbers, email addresses and physical addresses, or information related to your clients for billing purposes. CaseWare Cloud Services may, for example, require data related to you or your clients in order to the provide CaseWare Cloud Services, or to promote or offer you products, services and offers (including new and other Services which are offered by CWC and its Affiliates) that may be relevant to you. Collected Personal Information may also be used to review compliance with applicable Terms of Use and any applicable CaseWare Cloud Services Agreement

  • To contact you for the purposes of product information, service updates, billing notifications, or notifications relating to the CaseWare Cloud Services. In particular, CWC requires you to give us necessary contact information such as name and email address. We also ask for unique identifiers (log-in password names). CWC uses such contact information to send information about CWC’s or its Affiliates’ products and services.

  • To monitor and/or improve system usage, server and software performance. CWC may use Personal Information such as login information, and IP addresses of computers which access the Cloud Infrastructure to help diagnose any problems with the Cloud Infrastructure, to assess capacity requirements, and to administer the Website, to help identify you and to gather broad demographic information. CWC may use cookies or tracking technologies to monitor access to the Cloud Infrastructure, to save your password, or otherwise allow offering of the CaseWare Cloud Services.

  • To assist you with technical support issues.

  • To comply with any laws, regulations, court orders, subpoenas or other legal process or investigation and to protect CWC, its Affiliates and other individuals from harm.

  • To improve and enhance CWC Service offerings. CWC may use Personal Information provided by its users in an anonymous, and/or aggregated fashion to improve or enhance its Cloud Services and other service offerings. For example, the Personal Information may be used to analyze overall trends, to help us provide and improve our Website and CaseWare Cloud Services and to guarantee their security and continued proper functioning, to provide necessary functionality, to assess and improve Customer and user experience of the CaseWare Cloud Services, to identify future opportunities for development of the CaseWare Cloud Services, to identify customer opportunities.

8.2 By using the CaseWare Cloud Services, you consent to your Personal Information being collected, held and used in this way and for any other use you ize. CWC will only use your Personal Information for the purposes described in this Cloud Privacy Policy or with your express permission.

8.3 It is your responsibility to keep your password or other forms of authentication to the CaseWare Cloud Services safe. You agree to notify us as soon as possible if you become aware of any misuse of your password, and immediately change your password within the CaseWare Cloud Services.

9.0 Accuracy

9.1 CWC relies on you to ensure that the Personal Information you provide to us while using the CaseWare Cloud Services is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Upon request, CWC will provide you with information CWC holds about you. You are welcome to make changes, request deletions or corrections to this Personal Information at any time by contacting us at the contact information listed in this Cloud Privacy Policy. We will respond to your request within a reasonable timeframe. The foregoing, however, shall not apply to any Personal Information as it is contained in Subscriber Data. Such Personal Information can only be accessed through, and in such a manner as provided by, the CaseWare Cloud Services.

9.2 You are responsible for ensuring that the information you have provided is truthful, accurate, reliable and complete, and does not infringe the rights of others.

9.3 CWC will retain Subscriber Data provided by you or the Customer as long as the Customer remain(s) a subscriber of the CaseWare Cloud Services in good standing, in accordance with the CaseWare Cloud Services Agreement. CWC will retain and use your Personal Information as necessary to comply with CWC’s legal obligations, resolve disputes, and enforce agreements with CWC.

10.0 Where Your Personal Information is Stored

10.1 CWC uses third party data hosting providers (e.g. Amazon Web Services) to host its Cloud Services and Subscriber Data for Customers on servers located throughout the world. A complete list of third party hosting providers may be found on https://www.casewarecloud.com/security.html#security.

10.2 Upon subscribing to the CaseWare Cloud Services, CWC shall inform Customer of the preferred jurisdiction in which a server that has been allocated to host Customer’s Subscriber Data and Personal Information is located. Customer may consent to such allocation, or refuse a server so allocated. If Customer consents, Subscriber Data for Customer will be stored on a server in the preferred jurisdiction. If Customer refuses allocation of a server, CWC may not be able to provide Customer with CaseWare Cloud Services.

10.3 At present, CWC uses servers in the United States, Australia, Canada and Europe. For Customers of the CaseWare Cloud Services in the United States, CWC will attempt to allocate a server in the United States. For Customers of the CaseWare Cloud Services in Europe, CWC will attempt to allocate a server in Europe. For Customers of CaseWare Services in Canada, CWC will attempt to allocate to a server in Canada. For Customer to the CaseWare Cloud Services in Australia, CWC will attempt to allocate a server in Australia.

10.4 By entering personal information into the CaseWare Cloud Services, you consent to that Personal Information being hosted on servers where allocated. Each data hosting provider’s role is limited to providing a hosting and storage service to CWC, and CWC has taken reasonable measure to ensure that our data hosting providers will not access the data, and will use the necessary level of protection for, Personal Information. They do not control, and are not permitted to access or use your personal information, except for the limited purpose of storing the information. CWC may further access the Personal Information from its locations in Canada for the purposes described in Section 8.

10.5 If you do not want your Personal Information to be accessed or transferred to a server as described above, You should not provide CWC with Personal Information or use the CaseWare Cloud Service.

11.0 Safeguards

11.1 CWC is committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from unized access, modification and disclosure. CWC uses technical and organizational measures that provide a level of security appropriate to the risk of processing your Personal Information. For example, your Personal Information is stored on secure servers that are encrypted, and all data transferred between you and the CaseWare Cloud Services is encrypted.

11.2 However, the Internet is not in itself a secure environment and CWC cannot give an absolute assurance that your Personal Information will be secure at all times. Transmission of Personal Information over the Internet is at your own risk and you should only enter, or instruct the entering of, Personal Information to the CaseWare Cloud Services within a secure environment.

11.3 CWC will advise you at the first reasonable opportunity, and as required by law, upon discovering or being advised of an incident where your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by unized persons or in an unized manner.

12.0 Individual Access

CWC makes no claim to your Subscriber Data. Upon request, CWC will provide you with a list of the third-party service providers used to host your Subscriber Data, and the countries in which our servers are located.

13.0 Openness

CWC makes clear and transparent notice of its privacy practices publicly available through this Cloud Privacy Policy. CWC may change this Cloud Privacy Policy or the related general Privacy Policy at any time, and any amended Cloud Privacy Policy or general Privacy Policy is effective upon posting to the Website. CWC will make every effort to communicate any significant changes to you via email or notification via the CaseWare Cloud Services. Your continued use of the CaseWare Cloud Services will be deemed acceptance of any amended Cloud Privacy Policy and of any amended general Privacy Policy.

14.0 Challenging Compliance

You may send us your privacy-related questions or challenge our compliance with our Cloud Privacy Policy by submitting your concern to our Security & Compliance Manager:

Lynn Dookhran

Security & Compliance Manager

(416) 867-9504

privacy@shheyixing.com