Privacy Policy
(CAN:online)
1. Introduction
Direct Heroes Inc. ("Company", "we" or "us") respect your privacy and are committed to protecting it through our compliance with this policy.
This Privacy Policy (the "Policy") describes the types of information we may collect from you or that you may provide when you access and use the directheroes.com website (the "Website") and all related mobile apps, social media apps, desktop apps, and software services (collectively, the "Platform"). The Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account, to enable you to build social CRM and Direct Message Marketing Solutions and communicate with social CRM and Direct Message Marketing Solutions others have built, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.
Remember that your​ use of the Platform is at all times subject to the Terms of Use  which incorporates this Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use 

This Policy applies to information we collect:

     -through the Website or any other part of the Platform; and
     -in e-mail, text and other electronic messages between you and us.

It does not apply to information collected by:

     -us offline or through any other means, including on any other website operated by the Company (including our affiliates and subsidiaries) or any third party; or
     -any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Platform. By accessing or using any part of the Platform, you agree to this Policy. This Policy may change from time to time. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

PEOPLE UNDER THE MINIMUM AGE: As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 13 (the "Minimum Age"). If you are under 13, please do not attempt to register for the Platform or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe we might have any information from or about a person under the Minimum Age, please contact us—see Section 12 of this Policy.

2. Consent
When we collect, use or disclose your personal information we will generally obtain your consent. Most of the time, we will obtain your consent before or at the same time we collect your personal information. In some instances, however, we may seek your consent after we have collected your personal information if we wish to make an additional use or disclosure of your personal information where we do not already have your consent for that new use or disclosure.
Depending on the circumstances, your consent may be express or implied. Express consent would arise if you specifically consented to a particular use of your personal information. Express consent can be given orally, electronically or in writing. Implied consent can be inferred from the circumstances. For example, if we indicate that we may send certain correspondence to your home address and you provide us with your home address, we would not normally obtain your explicit consent to use your home address to send you that correspondence—your consent would be implied in those circumstances.
If you voluntarily provide your personal information for a particular purpose, you have given your consent to the collection, use or disclosure of the information for that purpose.
(a) Privacy Policy as a Means of Consent
In addition, certain collection, uses and disclosures of your personal information that we wish to make are specifically set out in this Policy. Be sure to review this Policy since by providing your personal information to us, you are consenting to the collection, use and disclosure of your personal information in accordance with the terms of this Policy.
(b) Opting In, Opting Out and Changing Consent
We may, from time to time, provide you with an opportunity to opt out of certain collection, uses and disclosures of your personal information. At the same time, an implied consent to collect, use or disclose your personal information would arise if you fail to indicate that you wish to opt out of the particular collection, use or disclosure when you are given an opportunity to do so.
As well, we may, from time to time, provide you with an opportunity to opt-in to certain collection, uses and disclosures of your personal information. In that case, if you do not opt-in, we will assume that you do not consent to your personal information being collected, used or disclosed in that particular manner.
We will generally use an opt-in method. We may use the opt-out method when a particular use or disclosure is not unusual, the information is not particularly sensitive or when the Company believes that most people would likely consent to the particular use or disclosure.
(c) Changing Consent
You may change or withdraw your consent at any time on reasonable notice to us, subject to pre-existing legal and contractual obligations, by contacting us as set out in Section 12. If you withdraw certain consents, it may limit the manner in which you can make use of the Platform and to otherwise interact with the Company or you may be required to delete your account. For clarity, your ability to change or withdraw consent is not absolute. The Company reserves the right to continue handling your personal information in those circumstances required or permitted by law despite a change or withdrawal of consent.

3. Information We Collect About You and How We Collect It
We collect several types of information from and about users of the Platform, including information:

     1. You Provide Directly to Us. We receive and store any information you knowingly provide to us. For example, if you create an account on our Platform to build a social CRM and Direct Message Marketing Solution, through the registration process and/or through your account settings, we may collect Personal Information such as, but not limited to, your name, email address, timezone, list of Facebook and Instagram Accounts you own. Or, if you are an individual who communicates with social CRM and Direct Message Marketing Solutions that have been created using our services, we may collect information such as, but not limited to, your name, gender, time zone, and avatar/picture. If you provide your Facebook or other third-party account credentials to, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, when you log in to our Platform using your Facebook Messenger account, we may receive your personal information associated with that account, such as your Facebook pages. Certain information may be required to register with us or to take advantage of some of our features.  

     1. Indirect Information You Provide to Us. You also may provide information to be published or displayed ("posted") on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. No security measures are perfect or impenetrable. Also, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

     1. Usage Details, IP Addresses and Other Technologies. Whenever you interact with our Platform, we automatically receive and record information on our server logs from your browser or device, which may include any social CRM and Direct Message Marketing Solutions you have created using the Platform, your conversation history with the social CRM and Direct Message Marketing Solutions(s), IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Platform, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Platform are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Platform, and those third parties may not honor “Do Not Track” requests you have set using your browser or device. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Platform or to help developers build better social CRM and Direct Message Marketing Solutions– for example, this data can tell us how often users use a particular feature of the Platform, or what kinds of questions users ask of certain social CRM and Direct Message Marketing Solutions, and we can use that knowledge to make the Platform and the social CRM and Direct Message Marketing Solutions created through the Platform interesting to as many users as possible. The information we collect automatically is statistical data. It helps us to improve the Platform and to deliver a better and more personalized service by enabling us to: Estimate our audience size and usage patterns; improve system responsiveness and performance; and recognize you when you return to the Platform.

4. Third Party Services
What information does Direct Heroes processes in connection with third party services? 
Depending on how you have configured our Platform, you may be able to use several functionalities provided by third parties. Certain of these functions need further information or personal data processed by us or the third party. Please note that you as our customer remain solely responsible under applicable data protection law for the processing of personal data under such functionality to your user and we remain the processor of such data. The fulfilment of obligations under applicable data protection law to your users is thus solely your responsibility. We will provide information on any of our products and services in this regard in the following: 
Transfer data with our Platform to Google sheets: Our Platform provides the functionality to send data to Google sheets provided by a messenger social CRM and Direct Message Marketing Solution you have built with our Platform. You can provide content to the Google sheets and share certain information, e.g., bot user’s email address. If you want to use this function, the processing of certain data is mandatory to provide the functionality and will be done on your behalf only. For this purpose, we collect and process personal data, in particular, the Google ID or email address. In addition, we collect technical data, such as access tokens, refresh tokens or spreadsheet IDs. All information we collect is processed solely to provide the functionality as described above. Except for bot admin’s email address, which could possibly be shared with other admins to the extent necessary to provide this function, none of the processed data is being shared with third parties other than elsewhere stated in this privacy policy. 
To comply with the data protection obligations, we recommend informing your users on the processing by adding the following wording to your privacy policy, without giving any warranty to be sufficient to comply with the legal obligations to which you are subject: 
“We collect or process personal data by the use of third-party tools, inter alia, we use the services of Direct Heroes Inc. d/b/a Direct Heroes (“DH”). DH is an online platform that allows us to easily build, host and manage social CRM and Direct Message Marketing Solutions. We use certain functionalities that enable us to send data to Google sheets provided by a messenger social CRM and Direct Message Marketing Solution we have built with DH’s services. Using this function, the processing of certain data by DH and Google is mandatory to provide the functionality. For this purpose, we may collect and process personal data, such as email addresses. In addition, we collect technical data, such as access tokens, refresh tokens or spreadsheet IDs. All information we collect is processed solely to provide the functionality as described above. None of the processed data is being shared with third parties other than already stated in this privacy policy.”

5. How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:

     -to present the Platform and its contents to you;
     -to provide you with information, products or services that you request from us;
     -to fulfill any other purpose for which you provide it (for example, if you send us an e-mail with a question or comment, we will use your e-mail address to respond to you. Further, we may store your e-mail and e-mail address and a copy of our response for future reference);
     -to provide you with notices about your account, including expiration and renewal notices;
     -to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
     -to notify you about changes to the Platform or any products or services we offer or provide though it;
     -to allow you to participate in interactive features on the Platform;
     -to allow you to access to patches, upgrades and enhancements to the Platform
     -to allow you to access to Platform customizations created for you, if applicable
     -in any other way we may describe when you provide the information; and
     -for any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data or on the registration form or adjust your user preferences in your account profile.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
The law permits or requires the collection, use and disclosure of personal information without the knowledge or consent of the individual in a number of circumstances. We reserve the rights to collect, use, and disclose your personal information in those circumstances without your knowledge or consent, as the law may permit.

6. Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this Policy:

     -to our subsidiaries and affiliates;
     -to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
     -to a buyer or other successor in the event of an amalgamation, a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about the Platform users is among the assets transferred;
     -to third parties to market their products or services to you if you have consented to these disclosures;
     -to fulfill the purpose for which you provide it (for example, if there is a feature of the Platform that allows you to send your contact information to another user through the Platform, when you use that feature, we will disclose your personal information to that other user);
     -for any other purpose disclosed by us when you provide the information; or
     -with your consent.

We may also disclose your personal information:

     -to comply with any court order, law or legal process, including responding to any government or regulatory request;
     -to enforce or apply our terms of use, viewable at https://www.directheroes.com/terms, and other agreements, including for billing and collection purposes; and
     -if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

7. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

     -Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Platform may then be inaccessible or not function properly.
     -Disclosure of Your Information for Third-Party Advertising. If you want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-in by checking the relevant box located on the form on which we collect your data or on the registration form or at any other time by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.
     -Promotional Offers from the Company. If you wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-in by checking the relevant box located on the form on which we collect your data or on the registration form or at any other time by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.
     -Targeted Advertising. If you want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-in by checking the relevant box located on the form on which we collect your data or on the registration form or at any other time by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.

8. Accessing and Correcting Your Information
You can review and change your personal information by logging into the Platform and visiting your account profile.
If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users. Proper access to and use of information provided on the Platform, including User Contributions, is governed by our terms of use, viewable at https://www.direct heroes.com/terms.
You may also send us an e-mail at privacy@directheroes.com to request access to, corrections to or the deletion of any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
An individual's ability to access his or her personal information under our control is not absolute. The Company reserves all rights to not disclose personal information in certain circumstances. For example, we may not disclose personal information where:
the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;

     -the disclosure would reveal personal information about another individual;
     -the disclosure of the information would reveal confidential commercial information; or
     -the personal information was collected by us for an investigation or legal proceeding.

9. Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

10. Retention and Destruction
For legal and business purposes we may retain your personal information for as long as it is reasonably needed. Upon expiry of the appropriate retention period, bearing in mind our reasonable legal and business requirements, your personal information will either be destroyed in a secure manner or made anonymous.

11. Changes to Our Privacy Policy
It is our policy to post any changes we make to this Policy on the following Website page: https://directheroes.com/privacy as well as a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by e-mail to the primary e-mail address specified in your account and through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active e-mail address for you at which you are able to receive messages from us, and for periodically visiting our Website and this Policy to check for any changes.
12. Contact Information
To ask questions or comment about this Policy and our privacy practices, contact us at: privacy@directheroes.com