Privacy Notice

Overview

One of Rewind’s values is “Be Trustworthy”. Part of being trustworthy is offering the highest standards of privacy protection regardless of a customer’s location, citizenship, or the origin of their data. We aim to be honest, truthful and respectful about Rewind’s privacy practices and how we process the Personal Data entrusted to us. 

This Privacy Notice describes how we collect, receive, use, store and otherwise process your Personal Data, as well as your choices and rights with respect to your Personal Data. For the purposes of this Privacy Notice, “Personal Information or Personal Data” means any information relating to an identified individual or that can be used to identify an individual. Personal Data doesn’t include a business name, phone number, or address. If we use capitalized terms in this Privacy Notice that aren’t defined, they would have the same meaning as defined in our Terms of Service. 

The following table provides a summary of our privacy controls.

Collection and Use of Personal Data

We collect Personal Data about you when you use our products and services, visit our websites, or contact us for any reason. We process this Personal Data to fulfill our contract with you, and for our own legitimate business interests. This includes maintaining our business relationships, preventing risk and fraud, providing effective services to our customers, and improving our products and services.  

Personal Data is collected directly, indirectly or automatically. 

• Direct collection is when you provide us with information.
• Indirect collection may occur when we receive information from other companies. 
• Automatic collection occurs through the use of tracking technologies.

If you choose to provide us with a third party’s Personal Data (the person’s name, email and company) for any purpose, you represent that you have the third party’s permission to do so. 

Please note that we may record video conferencing calls in which you participate in order to analyze and improve our staff’s communication skills. If we do so, we will announce it at the beginning of the conference call as well as in the meeting invite and we will provide a link to this Privacy Notice in the meeting invites and on the registration page. 

In addition, we may collect Personal Data uploaded by you, your employer or other users of the Application that may be required to use Rewind services. We expect all users to follow their organization’s Privacy Notice and any applicable regulatory requirements when uploading to, or accessing and using Personal Data in our Application.

Sharing Personal Data

Service Providers

We use third parties to help us provide our products and services and to manage many of our operations. They may have access to your information as collected by the Website or the Application, as reasonably necessary to perform the tasks on our behalf. We assess third parties on their security and privacy practices to ensure that Personal Data is only used to deliver the contracted services to us, to prohibit them from selling it and not to disclose it without our knowledge and permission and we ensure that any data transfers are protected by appropriate data transfer mechanisms. 

A list of our core service providers can be found on our Sub-processors page.

Legal disclosures

It is possible that we may need to disclose Personal Data to comply with legal and regulatory requirements and legal processes including, for example, responding to lawful requests from public and governmental authorities and court order. 

We attempt to notify our clients about legal demands for their Personal Data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

Change in Control

We can also share your Personal Data as part of a sale, merger, amalgamation or change in control or in preparation for any of these events. 

Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Notice unless you agree otherwise.

International Data Transfers

Rewind is a company that operates globally. This means that we may transfer, store and/or process Personal Data in countries different from where you reside or do business. When a cross-border transfer of Personal Data occurs, it is always done so in accordance with applicable law.

We rely on legal mechanisms to transfer data such as adequacy decisions, when we cannot rely on adequacy decisions, we use contracts and standard contractual clauses as written commitments by both parties to provide appropriate data protection safeguards. 

Rewind complies with the Personal Data Protection and Electronic Documents Act (“PIPEDA”), which has been recognized by the European Commission as legislation that offers adequate protection to Personal Data.  You can learn more about this adequacy decision by reading the Commission decision available at http://data.europa.eu/eli/dec/2002/2(1)/oj

Security and Data Protection

We are committed to protecting the security of all of the Personal Data we collect and use. 

We use a variety of physical, administrative and technical safeguards designed to help protect it from [accidental loss and from] unauthorized access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data at rest and in transit. Please visit our Security at Rewind page to learn more about how we protect data. For detailed information including our SOC2 Report and policies, visit our Trust Portal at https://security.rewind.com for further information.

Your Privacy Rights

Rewind values your privacy and acknowledges the rights granted to individuals under relevant data protection laws. Your interactions with our services may entitle you to request access, correction, amendment, deletion, export, restriction or object to the processing of your Personal Data.  These rights may be subject to certain limitations and exceptions subject to the applicable law(s).  

To exercise any of these rights please contact us at privacy@rewind.com.

Please note that we will take reasonable steps to verify your identity and that you are authorized to make such a request. This may require additional Personal Data from you. 

We may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems or as permitted by law.

You also have the right to lodge a complaint with the local organizations in charge of enforcing the privacy legislation applicable in your territory if you are not satisfied with our response. 

Communications Preferences 

You may choose to receive or not receive marketing communications from us. To stop receiving marketing communications, please click the “Unsubscribe” link in the email we sent you. 

Even if you opt-out of receiving marketing communications, we may still communicate with you in connection with security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.

Retention of Personal Data

We retain Personal Data only for as long as it is necessary to fulfill the purpose for which we have collected it.  This may include providing services to our Customers or to fulfill our legitimate purpose for collection and use. 

When Personal Data is no longer needed, we will either delete, de-identify, or anonymize. This data may be aggregated with other non-Personal Data to provide insights which are commercially valuable to Rewind. 

We may also retain Personal Data to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our terms of service and take other actions permitted by law.

Contact Information

If you have any questions about this Privacy Notice or to exercise the privacy rights and choices we offer please contact us as follows:

• Reach out by email to privacy@rewind.com; 
• Via website: https://rewind.com/contact; or 
• You can mail us:

Attn: Data Protection and Privacy Specialist
Rewind, Inc.
333 Preston Street, Suite 200,
Ottawa, Ontario
K1S 5N4
Canada 

Supplemental Notice 

For individuals based in the European Union (EU), European Economic Area (EEA), the United Kingdom (UK) and Switzerland.

This section provides additional specific information for consumers based in the EU, EEA, UK and Switzerland. If you are based in one of these jurisdictions, Rewind is the controller of your Personal Data when we collect it for our own purposes as described above. We only process Personal Data if we have a lawful basis for doing so. The lawful bases applicable to our processing as controller are:

• Consent – We will ask for your express and informed consent every time we collect your Personal Data on this legal basis in accordance with Article 6(1)(a) GDPR
• Contractual basis – We process the Personal Data as necessary to fulfill our contractual terms with you or our Customers in accordance with Article 6(1)(b) GDPR
• Legitimate interest – We process the names, contact details, job titles, companies of our existing and prospective clients for our marketing purposes, including market research and sales leads generation in accordance with Article 6(1)(c) GDPR

Rewind is a processor of Personal Data contained within Customer Content. We only process this Personal Data on the instruction of our Customers, you can read more about this processing by viewing our Data Protection Addendum. 

If you would like to exercise your privacy rights, please follow the instructions provided in the “Your Rights” section. You may contact us at privacy@rewind.com and you may also lodge a complaint with your local supervisory authority, EU Data Protection Authorities (DPAs), UK Information Commissioner’s Office (ICO) or Swiss Federal Data Protection and Information Commissioner (FDPIC). See their contact details here.

For individuals based in the United States

This section provides additional details for consumers residing in certain US states such as California. 

Collection and Use of Personal Data

Rewind does not sell your Personal Data. We collect, use and disclose Personal Data as described in above in “Collection and Use of Personal Data” and “Sharing Personal Data”. This information may be categorized as follows: 

• Identifiers, such as your name, mailing address, email address, zip code, telephone number, or other similar identifiers.
• Personal Data such as listed in the California Customer Records (Cal. Civ. Code § 1798.80(e)), including username and password, company name, job title, business email address, and department.
• Internet/Network Information, such as your browsing history, log and analytics data, information about the device(s) used to access the Services and information regarding your interaction with our websites or Services and other usage data.
• Geolocation Data, such as information about your location (at country and city level) collected from your IP address.
• Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law.
• Profession/Employment Information that you include in your CV, cover letter and send to us when applying for a position.
• Other Personal Data, such as Personal Data you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our Application.

We collect Personal Data directly from you, from your browser or device when you visit our Websites, from third parties that you permit to share your information or from third parties that share public information about you and as stated above.

We share Personal Data with third parties as described above in “Sharing Personal Data”.  The categories of third parties to whom we disclose your Personal Data may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks.

Your Privacy Rights

Depending on where you live, how you use Rewind, and subject to certain exceptions, you may be able to exercise the following rights in relation to your Personal Data:

• The Right to Know any or all of the following information relating to your Personal Data we have collected and disclosed in the last 12 months, upon verification of your identity:
  • The specific pieces of Personal Data we have collected about you;
  • The categories of Personal Data we have collected about you;
  • The categories of sources of the Personal Data;
  • The categories of Personal Data that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of Personal Data we have sold and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the Personal Data.
• The Right to Request Deletion of Personal Data we have collected from you, subject to certain exceptions.
• The Right to Opt-Out of Personal Data sales to third parties now or in the future. However, we do not sell your Personal Data.

You also have the right to be free of discrimination for exercising these rights. 

Please note that if the exercise of these rights limits our ability to process Personal Data (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once a request has been submitted by an authorized agent, we may require additional information (i.e. written authorization from you) to confirm the authorized agent’s authority. 

If you would like to exercise your rights, please follow the instructions provided in the “Your Rights” section. 

If you are an employee/former employee of a Rewind Client that uses our application and services, please direct your requests and/or questions directly to your employer/former employer.

If you are a third party (auditor, business associate etc.), who was given access to the Rewind application by a Rewind Client, please direct your requests and/or questions directly to the Rewind Client that gave you access.

Other Important Information

As an Application End User, you consent to our collection of your Personal Data when you log in for the first time. However, your company/employer has control of the account and may upload and share additional Personal Data. It is your company’s/employer’s responsibility to ensure the collection, use and sharing of the Personal Data uploaded to the Application complies with all applicable legislation. 

This Privacy Notice applies only to Personal Data. Rewind collects Personal Data only as necessary to operate its business and to provide its products and services. Personal Data protected by this Privacy Notice is information about a natural person. If identifiers are removed from any Personal Data so that you can no longer be identified from that information, then that information has been anonymized and is not considered Personal Data. As such, anonymized information falls out of scope of this Privacy Notice.

Minors Under Age 16

Our application and services are intended for business use and we do not expect them to be of any interest to children under the age of 16. We do not intentionally collect any Personal Data of consumers below the age of 16 and will cancel the registration of any user account initiated by a child upon becoming aware of any such registration. We do not sell the Personal Data of California consumers for any commercial purpose other than for providing the services.

Updates to this Privacy Notice

This Privacy Notice may be updated periodically.  Any changes to our Privacy Notice will be posted here and we will indicate the date of our most recent review and update. 

If a change to our Privacy Notice impacts how we collect or process data, we will provide appropriate notice to our Customers. 

This Privacy Notice was last updated on April 2, 2024.