This Privacy Policy (the “Policy”) is designed to inform users of our website and on-line services, about how we gather and use information provided to, or collected by us and under what circumstances we will disclose such information.

Collection – What Information Do We Collect?

When using our online services, we collect the following information about you:

  • Contact Information, such as name, email address, and phone number
  • Company Identifier (employee number in some cases)
  • Credit card and payment information to process transactions with you/your company
  • Our Customers may add other fields such as date of birth or preferred language
Use – What Do We Use Your Information for?

Any of the information we collect from you may be used in the following ways:

  • Provide customer support and technical assistance, as required
  • Respond to questions and concerns
  • Respond to a request for a demonstration of our services
  • Engage in certain transactions with you
  • Send you product information and to personalize the experience of marketing communications (your information helps us to better respond to your individual needs). If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
Use of Information Collected and/or Provided by Customers
  • Our Customers use Firmwater services to assemble and deliver online training programs used by their employees, business affiliates & customers.
  • Firmwater does not control the content of these training programs or the types of information that our Customers may choose to collect or manage using our services. Such information belongs to the Customer and is used, disclosed, and protected by them according to the Customer Agreement.
  • Firmwater processes Customers’ information as they direct and in accordance with the Customer Agreement, and we store it on our service providers’ servers, but we do not have control over its collection or management.
  • Our Customer Agreements prohibit us from using that information, except as necessary to provide and improve the Services and for general business purposes, as permitted by this Privacy Policy Statement, and as required by law.
Agents and Service Providers:

Firmwater contracts with other companies and people to perform tasks on our behalf and may share your Personal Information with them to provide Services, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples may include hosting of the Firmwater applications, delivery of email to you from the Firmwater applications, and analyzing data.

When we share information in this way, we require the agent or service provider to maintain the privacy, confidentiality, and security of the Personal Information. These companies are authorized to use your Personal Information only as necessary to provide these services to us.

Your Consent

By using our Website and/or our Web Applications you explicitly consent to our collection and use of your Personal Information as described in this Privacy Policy. If you are a resident in a jurisdiction where transfer of your Personal Information to another jurisdiction requires your consent, then it is hereby understood that you provide us your express and unambiguous consent to such transfer.

Use of Cookies and other Tracking Technologies:

Firmwater and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

A cookie is a small file which asks permission to be placed on your computer’s hard drive or on the web browser of your mobile phone. Unless you disable this setting, the file is added and the cookie helps analyze web traffic or lets us know when you visit a particular site. Cookies allow Web Applications to respond to you as an individual. The Web Applications can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Firmwater and its partners & service providers use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our Website and Web Apps in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better Website and Web Apps, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer, mobile or any Personal Information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies, if you prefer. However, this may prevent you from taking full advantage of the Website and/or the Web Apps.

Third Party Tools & Aggregated Information

In the process of providing Services, we try to understand users’ behavior by tracking user movement, links clicked, content viewed, click/touch, scrolls and keystroke activities on our Site. In order to understand user behavior, we may use third party analytical tools, including but not limited to Google Analytics. These third parties are bound by their own privacy policy and may use cookies to provide their services.

If you do not want your behavior to be tracked, you have an option to opt-out of these analytics services. Opt-out options are available at and for users in European Union at

To enhance our Services and provide better user experience, we may use anonymized and aggregated statistical information, which may be based on extracts of your Personal Information and share such information with third parties.

We also use electronic images known as “clear GIFs” (sometimes called “transparent GIFs”, “Web bugs”, “pixel tags” or “beacons”) that allow us to track email delivery. Firmwater also automatically receives and records information from our servers and from your browser, including your IP address, the time, and information about the page you accessed.

Transfer of Data

Unless otherwise agreed to in a separate Customer Agreement, your information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our Services or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than those of your country or the country in which you were located when you initially provided the information.

Access to Your Data

Firmwater acknowledges that you have the right to access your Personal Information. As a Processor, we have no direct relationship with the individuals whose Personal Data we process. Individuals who seek access, or who seek to correct, amend, or delete inaccurate data should direct their query to the Customer (the Data Controller).

In most cases, changes can be made on-line. Should the Customer (Data Controller) request assistance in accessing, correcting, transferring or deleting individual’s Personal Data, we will provide assistance in making those changes. As a Controller, any Personal Information collected from our business customers, vendors, and suppliers can be accessed, reviewed, corrected or deleted by contacting [email protected]. We will respond to your inquiry within 30 days.

Security – How Do We Secure Personal Information?

Protecting our Customers’ information and their users’ privacy is extremely important to us. As a cloud-based company entrusted with some of our Customers’ most valuable data, we’ve set high standards for security. We always use industry-standard technologies when transferring and receiving consumer data we receive. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you in connection with our Services.

Retention – How long do we retain your Personal Information?

We will retain Personal Data that we process on behalf of our Customers for as long as needed to provide services to our Customers. We will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  • We may share your information with third parties who provide services on our behalf to help with our business activities.
  • We use other third parties such as an email service provider to send out emails on our behalf and a credit card processing provider to process payments for certain transactions. These companies are authorized to use your Personal Information only as necessary to provide these services to us. We obtain assurances they will safeguard the information consistently with this Privacy Policy.
  • We also reserve the right to disclose your Personal Information if we are required to do so by law, or in the good faith belief that disclosure of the information is reasonably necessary to comply with legal process, and to the extent permitted by applicable local law, to respond to claims, or to protect or advance the rights, property, safety, or well-being of our company, our employees, customers, or the public.
  • We will not use your Personal Data for automated-decision making.
  • We do not sell Personal Information to third-parties.
Changes to Our Privacy Policy

If we make changes to our privacy policy, we will post those changes on this page.

Further Information About Our Privacy Policy

Please contact [email protected] or write to us at

Firmwater Inc.
1655 Dupont Street, Suite 101
Toronto, ON, Canada
M6P 3T1

Last edited: February 28th, 2018