Privacy Policy

March 20th, 2020

1. Introduction

We are Chord Strategy Inc. (“Chord Strategy”), a Canadian registered company.  We provide those services (our “Services”) more fully described on our websites and (“Sites” or “Websites”) .

This Privacy Policy explains what personal information (“Personal Information”) Chord Strategy collects from visitors to our Websites and customers  who have subscribed for and use our Services including their employees, contractors or other authorised users (“Users”) and why, what we do with that information and how we share it. 

Our Privacy Officer may be contacted using the contact details set out at the bottom of this policy.

2. Choice

It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of the Services. We set out in detail below the information that we collect about Users. Chord Strategy does not collect on its own behalf things like protected health information, financial information, date of birth, social security or other government-issued identification number, and other sensitive personal information.

3. The Information We Collect About Users

Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).

We may collect, use, store and transfer different kinds of personal information about Users which we have grouped together follows:

  • Identity Data includes first name, last name or similar identifier.
  • Contact Data includes email address and telephone numbers.
  • Profile Data includes Users’ profile information saved through the Service.
  • Technical Data includes internet protocol (IP) address, browser type and version,   operating system and platform 
  • Usage Data includes information about how Users use our Services, such as browsing actions within the portal, the buttons, controls, Users click on, pages of our portal that Users visit, the time spent on those pages, User’s search queries, the dates and times of User’s visits, and workplace usage.

We also collect, use and share Non-personalized data called “Service Data” such as statistical or demographic data for any purpose. Service Data may be derived from User’s personal information but is not considered personal information in law as this information does not directly or indirectly reveal User’s identity. For example, we may aggregate User’s Usage Data to calculate the percentage of users accessing a specific Website feature.

We do not collect any Special Categories of Personal Data about Users (this includes details about User’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about User’s health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

4. How Is User’s Personal Information Collected

We use different methods to collect data from and about Users including through:

  • Direct interactions. Users may give us User’s Identity, Contact and Profile Data by registering for the Service and completing fields within the Service 
  • Automated technologies or interactions. As Users interact with our Service, we may automatically collect Technical and Usage Data about User’s equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive personal information about Users from various third parties and public sources as set out below:
    • Technical Data from the following parties:
  • analytics providers such as Google Analytics;
  • search information providers such as Google.

5. Purposes for Which We Will Users User’s Personal Information

We have set out below, in a table format, a description of all the ways we plan to use Users’ personal information. 

Purpose/ActivityType of Data
To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)
To register Users as a UserIdentityContact
To manage our relationship with User which will include notifying Users about changes to our terms or Privacy Policy
To administer and protect our business and this the Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)IdentityContactTechnical
To use data analytics to improve our services, customer relationships and experiences and to personalize Chord Strategy’s services 
To make suggestions and recommendations to User about services that may be of interest to Users and to provide Users with information, products or services they request
To improve our Services including:tracking email open rates, web page visits and form submissions)To inform Chord Strategy as to what content is effectiveTo provide follower updatesTo personalize Chord Strategy’s servicesIdentityContactProfileUsageTechnical

6. Disclosures

We may disclose Personal Information that we collect, or Users provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates where they are providing.
  • To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Chord Strategy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Chord Strategy about our Site or App users is among the assets transferred.
  • To fulfill the purpose for which Users provide it.
  • For any other purpose expressly disclosed by us when Users provide the information.
  • With User’s express consent to other uses not indicated in this Privacy Policy.

We may also disclose User’s Personal Information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Chord Strategy, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. Access

Upon request, Chord Strategy will provide Users with information about whether we hold any of User’s Personal Information. Chord Strategy enables customers and website visitors with the ability to access and correct Personal Information we have collected. If Users have any concerns or suspect unauthorized activities associated with User’s account, please contact us at security (@) We will respond to User’s request within a reasonable timeframe, and in any event within 30 days of receipt of request.

Chord Strategy acknowledges that Users have the right to access, update, revoke permission to process, or request the deletion of User’s Personal Information. Any such query can be directed to Chord Strategy’s Data Protection Officer at security (@) If requested to remove data under either scenario, we will respond within a reasonable timeframe.

8. Security and Enforcement

The security of User’s Personal Information is important to us. We use security safeguards appropriate to the sensitivity of the information to ensure that User’s Personal Information is stored and maintained in a secure environment. Chord Strategy exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our customers and website visitors. These safeguards include encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.

Chord Strategy monitors and reviews security safeguards and takes corrective action whenever we discover deviations from our Privacy Policy.

9. Retention of Data

Chord Strategy will keep User’s Personal Information for as long as it remains necessary for the identified purposes set out below or as required by law, which may extend beyond the termination of our relationship with User. Users acknowledge and agree that if they request that their name be removed from our databases, it may not be possible to completely delete all of their Personal Information due to legal constraints.

Data TypeRetention periodReason
Identity, Contact and Profile dataSubscription term and 3 months after account terminationTo provide the services to you during the subscription term.
Technical and Usage data3 years after account terminationTo provide the services to you during the subscription term and to protect against fraud.

** Chord Strategy is required to maintain records of consent and requests for correcting or deleting Personal Information for 6 years.

10. Managing the Online Collection of Additional Data

As Users navigate through and interact with our Website and Services, we may use automatic data collection technologies to collect certain information about User’s equipment, browsing actions and patterns, location, and workplace usage patterns, including:

  • Details of User’s visits to our Website or App and other communication data and the resources that User access and use on the Site or App.
  • Information about User’s computer and Internet connection, including User’s IP address, operating system, and browser type.
  • We also may use these technologies to collect information about User’s online activities over time and across third-party websites or other online services (behavioral tracking).
  • When User access and use the App, we may automatically collect certain details of User’s access to and use of the App, including traffic data, location data, and other communication data and the resources that Users access and use on or through the App.
  • We may collect information about User’s mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
  • Our App collects real-time information about the location of User’s device.

We and our third-party service providers may collect information about Users in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Service by informing us what content is effective.

10.1 Cookies

When Users visit our website or otherwise interact with the Service, we (or third-party data or ad networks we work with) may send one or more “cookies” to User’s computer or other devices. Cookies are alphanumeric identifiers stored on User’s computer through User’s web browser and are used by most websites to help personalize User’s web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third-party websites. Some features on this site will not function if Users do not allow cookies. We may link the information we store in cookies to any Personal Information Users submit while on our site.

We may use both session ID cookies and persistent cookies. A session ID cookie expires when Users close User’s browser. A persistent cookie remains on User’s hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site. If User does not want information collected through the use of cookies, there is a simple procedure in most browsers that allows User to automatically decline cookies, or be given the choice of declining or accepting the transfer to User’s computer of a particular cookie (or cookies) from a particular site. Users may also wish to refer to If Users reject cookies, Users may still use our site, but some features on the site will not function properly.

Functional cookies, persistent and session type, store information to enable core site functionality.

Analytics cookies allow us to count page visits and traffic sources, so we can measure and improve the performance of our site and our marketing campaigns.

10.2 Web Beacons

We (or third-party data or ad networks we work with) may use Web Beacons alone or in conjunction with cookies to compile information about our Service, or other information we or they have collected. Web Beacons are tiny graphic objects that are embedded in a web page or email and are usually invisible to the user but allow checking that a user has viewed the page or email. Web Beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by Web Beacons to our Users’ Personal Information. For example, we use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

10.3 Flash and HTML5 Storage

We use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website upon User’s web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

10.4 Do Not Track Signals

At this time, we do not respond to browser ‘do not track’ signals.

11. Transfers of Data

Chord Strategy’s headquarters in Canada is our primary location for business operations. 

In order to provide User with the information, products, or services User have requested, Personal Data may be transferred or shared with other companies within our family of companies, including those third-party vendors who act on our behalf, process Personal Data in accordance with the purposes for which the data was originally collected, or for purposes to which Data Subjects have subsequently consented. Our Privacy Policy, supported by model contract agreements and safeguards for data governance, are designed to provide equivalent data protection for all customers wherever they may reside.

For example, regarding normal business operations, Chord Strategy may engage a third-party to support our billing, support services, information technology, or mailings on our behalf.

We may also disclose User’s Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect User’s safety, or the safety of others, investigate fraud, or respond to a government request.

12. Outside Parties and Sites

Through us, User may be introduced to a variety of third-party vendors and/or websites. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that User may provide to any third-party, or the use of “cookie” technology by any third-party, will be governed by the privacy policy of the operator of the website that Users are visiting. If Users have any doubts about the privacy of the information Users are providing on another website, we recommend that Users contact that website directly for more information and review its privacy policy. To properly process online orders, Users may be directed to a third-party credit card processing or other payment processing website. The privacy policies of these third parties are not under our control and may differ from ours. If Users have any doubts about the privacy of the information Users are providing on another website, we recommend that Users contact that website directly for more information and review its privacy policy.

13. Additional Privacy Protections for Minors

We join the industry in recognizing that children, including young teens, may not be able to make informed choices about Personal Information requested online. Chord Strategy does not solicit or knowingly collect Personal Information of those under the age of sixteen. 


Chord Strategy generally processes Personal Information in order to fulfill contracts we have with our customers and end users and to pursue our legitimate business interests listed above. Otherwise, Chord Strategy will obtain consent from an individual with respect to the processing of Personal Information if required by law to do so.

Further, individuals located in the EU have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of User’s personal data. Individual end users, customers or prospective customers located in the EU who wish to exercise these rights, should contact Chord Strategy using the contact information below in Section 17. If we are processing User’s information on behalf of a third party then Users should contact that party directly because Chord Strategy serves as a data processor on behalf of third party in that instance and can only forward User’s request to the buyer to allow them to respond. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.

15. Changes to this Privacy Policy

Chord Strategy may make changes to this Privacy Policy from time to time for any reason. Users of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes or changes in the way we use information, we will notify customers via e-mail or by posting an announcement on the Website prior to the change becoming effective. Website users are bound by any changes to the Privacy Policy after such changes have been posted.

In the event that Chord Strategy is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any Personal Information and give affected users notice before Personal Information is transferred or becomes subject to a different privacy policy. Account holders will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of User’s information, as well as any choices Users may have regarding User’s information.

16. Contact information. 

C/O Privacy OfficerChord Strategy Inc.
8623 Granville St., Suite 264
Vancouver, BC V6P 5A2
security (@)