Privacy Policy (this "Privacy Policy" or this "privacy policy")
Last revised and effective as of December 15, 2020.
GroupBy, Inc. and its affiliates, including, without limitation, GroupBy USA, Inc., (collectively referred to
herein as “GroupBy”, “the Company”, “us”) is a software-as-a-service
(“SaaS”) company with offices in Toronto, Ontario, Canada, Austin, Texas, United States of
America. GroupBy provides its customers a data-driven e-commerce platform utilizing personal relevance. Our
Data Protection Officer is Mark Alder, and he can be reached using the contact details provided at the bottom
of this privacy policy. Except as otherwise provided in this privacy policy (including as described in Part
2), under the General Data Protection Regulation 2016/679 (the “GDPR”), to the extent
applicable, GroupBy shall be a controller (as defined in the GDPR) with respect to Personal Information
collected under this privacy policy.
At GroupBy, we care about your privacy, and take matters seriously. This privacy policy is an outline of the
ways in which we collect and use the Personal Information you provide and describes the choices available to
you and the rights that you have regarding our use of your Personal Information and how you can access and
update this Personal Information. “Personal Information” refers to information that can be used on
its own or with other information to identify, contact, or locate a single person, or to identify an
individual in context. For example, contact information, such as your name, e-mail address, phone number, or
mailing address, is Personal Information.
If you have any questions or concerns about our use of your Personal Information, then please contact us
using the contact details provided at the bottom of this privacy policy.
This privacy policy is divided into several parts:
Part 1 applies to information about visitors to our website, www.groupbyinc.com. In this
privacy policy, www.groupbyinc.com (together with any subdomains thereof, but excluding
support.groupbyinc.com) is referred to as the “Website” and visitors to the website are referred
to as “Website Users”.
Part 2 describes information GroupBy processes on behalf of Customers of our platform and related services.
In this privacy policy, the platform and services (including support.groupbyinc.com) will be referred to as
“Services” and our business customers will be referred to as “Customers”.
Part 3 is our cookie policy.
Part 4 applies to international residents.
Part 5 provides general information relating to this privacy policy.
PART 1: THE WEBSITE
What information does GroupBy collect, including on its Website, and from which sources?
When you browse our Website, we receive information that helps us learn about your browser and operating
system. There are ways to control your browser settings to indicate when we have set a cookie in your browser,
and you have the ability to control our use of cookies and third-party analytics with respect to your use of
Website (please see the section on cookies below). Please note that disabling certain cookies may prevent the
Website from functioning properly. Your device may also have controls that determine the information
collected. Browser and operating system information, if provided by you, helps us analyze trends in the
aggregate and improve and administer our Website. If you consent to our use of cookies and third-party
analytics, this information may include your IP address, your browser type, your internet service provider,
the pages you viewed, your searches, your operating system and system configuration information, and date/time
stamps associated with your usage.
Any information you choose to provide on our Website will be stored. For example, if you register on our
Website via the “Contact Us” form, we will use the Personal Information you provide (first name,
last name, email, company name, phone number, etc.) in order to contact you for business purposes – for
example, to contact you regarding our Services or (unless you opt out (to the extent permitted by applicable
law)) promotions regarding our Services, respond to your request, question or concern, (unless you opt out (to
the extent permitted by applicable law)) to send you newsletters and marketing emails in accordance with your
marketing and communication preferences, and/or to improve our web site and marketing efforts.
The Personal Information that you provide directly to us through the Website will be apparent from the
context in which you provide the data. For example, our “Contact Us” includes a check box for you
to consent to receive emails and other marketing information from us. And, we may directly collect
Personal Information (including publicly viewable information in social media profiles as well as corporate
biography pages) about you that is publicly available from sources such as LinkedIn and other publicly
available websites.
For the avoidance of doubt, this privacy policy also applies to any access to the Website via a mobile device
or any other device.
How do you use information collected via the Website?
We use the information we collect to help our Website create a better experience for you. We use the
analytics information that we collect for such purposes as: counting and recognizing visitors to the Website;
analyzing how visitors use the Website; improving the Website; enhancing users’ experiences with the
Website; enabling additional website analytics and research concerning the Website; and managing our business,
and to comply with legal and/or regulatory requirements.
Unless you opt out (to the extent permitted by applicable law), we may send you emails and newsletters about
our Website. These emails may include other updates, promotions and GroupBy advertisements.
We may link non-personal information gathered using cookies with Personal Information, but we will treat the
combined information as Personal Information.
How do you get my consent?
To the extent not prohibited by applicable law, by using the Website (as clearly described on the Website and
in this Privacy Policy) you consent to our collection and use of your Personal Information as described
herein, consistent with applicable data protection laws.
To the extent permitted by applicable law, you provide your consent to our using specific information in
accordance with this privacy policy when you enter your Personal Information into various fields. There is an
indicator on each page that collects this information notifying you that the information will be used in
accordance with this privacy policy.
How do I modify information or withdraw my consent?
You are responsible for providing us with accurate information, if you choose to provide it. Please be sure
to update your information with us should it change. For example, if you wish to be on our email mailing list,
and your email address changes, please let us know.
If you do not wish for us to continue to collect your Personal Information in the future, you may stop using
the Website at any time. Please note, however, that the Personal Information we may have previously collected
will be retained in accordance with this privacy policy (including as described in Part 5).
You may unsubscribe from our email mailing list by using the “unsubscribe” feature located at the
bottom of the email you received from us.
You may block cookies in accordance with the Cookie Policy set forth in Part 3 (please note this may prevent
the website from functioning properly).
Google Analytics
The Website uses Google Analytics (including its data reporting features) to help collect and analyze certain
information for the purposes discussed above. Google Analytics may set and/or access a cookie and/or web
beacon. For information on opting out of Google Analytics, we encourage you to visit Google’s
website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout. Google’s
privacy policy is located here https://policies.google.com/privacy and information
about how Google uses partner information is located here: https://policies.google.com/privacy/partners.
HubSpot Inc.
HubSpot uses cookies to track Website visitors and contacts. When permitted, HubSpot leaves behind a cookie
on your browser that helps HubSpot identify them on future visits.
Social Media
The Website may link to third-party websites that incorporate comment and social media features, including,
without limitation: Facebook, LinkedIn, Twitter, and Instagram. The Website may also contain a Facebook
“like” button and a Facebook “share” button, A LinkedIn “share” button,
and a Twitter “tweet” and “follow” button. This may include providing you with the
ability to automatically post updates on Facebook, LinkedIn, Twitter, and Instagram.
These features may collect information including your IP address, which pages you visit on our Website, and
may set a cookie to enable the feature to function properly. If you choose to use these features, you may
disclose your information not just to those third-party websites and services, but also to their users and the
public more generally. Because these third-party websites and services are not operated by GroupBy, GroupBy is
not responsible for the content or practices of those websites or services. The collection, use, and
disclosure of your personal and non-personal information will be subject to the privacy policies of the
third-party websites or services, and not GroupBy’s policies. We advise you to please read the
third-party privacy policies.
Links to 3rd party sites
Our Website may include links to other websites whose privacy practices may differ from those of GroupBy. If
you submit Personal Information to any of those websites, your information is governed by the applicable
privacy policy for that website (and not GroupBy’s policies). We encourage you to carefully read the
privacy policy of any website you visit.
Cookies
For more information on how we use cookies, web beacons, and other tracking technology on our Website, please
see our Cookie Policy in Part 3.
Children's Data
Neither our Website nor our Services are directed at children. We do not collect Personal Information
from any person we actually know is under the age of 13. If a person under 13 submits information through
any part of the Website and we learn the person submitting the information is under 13, we will attempt to
delete this information as soon as possible. If you are aware of a user under the age of 13, please contact us
at: [email protected]
PART 2: THE SERVICES
What are the Services?
Our SaaS eCommerce platform offers several different solutions designed to help our customers. These
solutions include: Searchandiser, Enrich, SEO Enhancer and GroupBy Analytics.
Our Searchandiser solution provides highly relevant personalized search using machine learning and
merchandising controls.
Our Enrich solution automates product attribution across every retail vertical with our comprehensive
taxonomy.
Our SEO Enhancer solution helps maximize site traffic with URL beautification, orphan page elimination,
multi-site management and more.
Our analytics tool provides interactive dashboards, real-time monitoring, and regular health checks to allow
you to manage your business with real performance data.
What information does GroupBy collect via the Services and how is this information used?
If you use our Services as a representative of one of our Customers or interact with our Services as a
visitor to one of our Customers' website, we will not collect or use information except as set forth in our
agreement with the applicable Customer. If you have any questions about how we collect or use information in
the provision of our Services, please contact the applicable Customer.
What information does GroupBy collect about Customers using the Services and how do you use
it?
If you use our Services as a representative of one of our Customers, we will not collect or use information
except as set forth in our agreement with the applicable Customer.
Use of or interaction with the Services
To the extent our Services collect or process Personal Information on behalf of a Customer, such Personal
Information will be processed in accordance with our agreement with that Customer.
Please note that we do not control the content or type of data that our Customers use with the Services,
except as set forth in our agreement with each Customer. The data provided by a Customer or by visitors to
Customer's website belongs to the Customer, and is used, disclosed and protected by them according to their
privacy policy, and in no event according to this privacy policy. The data provided by a Customer or by
visitors to Customer's website is used by us on such Customer's behalf in accordance with our agreement with
such Customer, and in no event according to this privacy policy. Without limitation of the foregoing, under
the GDPR (to the extent applicable), the applicable Customer will be the controller (as defined in the GDPR)
with respect to such data and GroupBy shall not be a controller with respect to such data but instead will be
a processor (as defined in the GDPR) on behalf of such Customer with respect to such data. We process
information on behalf of our Customers as directed by each such Customer, and in accordance with our agreement
with the particular Customer.
We acknowledge that individuals may have a right to access their Personal Information in accordance with
applicable laws. Please note that if data is provided by a Customer for use with our Services, that Customer
controls the data. If you make a request to us to remove this data, we will notify our Customer, as the
Customer is responsible for removing this data. We will also respond to you within a reasonable timeframe, to
acknowledge your request. You should also contact the Customer directly. Please note that we are not
responsible for how our Customers use the data they store within the Services.
Third Party Service Providers
We may transfer information inputted into our Services to companies that help us provide our Services. Such
transfers are addressed in our agreements with our Customers. These service providers are authorized to use
information only as necessary to provide the requested services to us, and only as set forth in our agreements
with our Customers.
Social Media Login
If you choose to access the certain portions of the Services using the Facebook Login feature, you may be
providing us with access to all information, attributes, and data in your Facebook public profile. We
may freely store and use such information in accordance with this Privacy Policy. Such information may
be stored by us and may be used in connection with providing the Services or to contact you.
If you choose to access the certain portions of the Services using the Twitter Login feature, you may be
providing us with access to all information, attributes, and data in your Twitter public profile. We may
freely store and use such information in accordance with this Privacy Policy. Such information may be
stored by us and may be used in connection with providing the Services or to contact you.
If you choose to access the certain portions of the Services using the Google Login feature, you may be
providing us with access to all information, attributes, and data in your Google public profile. We may
freely store and use such information in accordance with this Privacy Policy. Such information may be
stored by us and may be used in connection with providing the Services or to contact you.
Cookies
Any use of cookies, web beacons, and similar tracking technologies in the Services is addressed in our
agreements with our Customers. If you are a Customer, your agreement with us may contain additional
information regarding cookies, web beacons and other tracking technology in our Services.
Data Retention Specific to the Services
With respect to information used to perform Services for our Customers, GroupBy will retain such information
only as set forth in our agreement with the applicable Customer, for at least as long as needed to provide
Services to the applicable Customer.
If you provide information to a Customer of ours as part of their use of the Services, that Customer decides
how long to retain that Personal Information. If the Customer terminates their access to our Services, they
may receive access to Personal Information stored within the Services pursuant to our agreement with them.
PART 3: COOKIE POLICY
This cookie policy explains how GroupBy uses cookies, web beacons, and similar tracking technologies on our
Website. This policy also tells you what your rights are with respect to our use of such cookies, web beacons
and tracking technologies on the Website. Any use of cookies, web beacons, and similar tracking technologies
in the Services is addressed in our agreements with our Customers.
Cookies
A cookie is a small file that is placed on your browser or device when you visit a particular website or
software application. Cookies can remember you and provide you with the information you’re most likely
to need.
For example, site navigational information provided by a cookie may include standard information from your
web browser (such as browser type and browser language), your IP address, and the actions you take on our Site
(such as pages viewed, and links clicked).
There are both session cookies and persistent cookies.
A session cookie expires when you close your browser. Simply exiting your browser will remove all session
cookies.
A persistent cookie remains on your hard drive for an extended period of time. For instance, when you return
to our Site, cookies identify you and prompt the site to provide your username (not your password), so you can
sign in more quickly. You can remove persistent cookies by following directions provided in your Internet
browser’s “help” directory.
Some cookies are set by the website owner. Other cookies are set by third parties. These third-party cookies
may enable third party features or functionality to be enabled through the website and provide information
about your computer to the third party.
Use of Cookies
We use cookies to help provide a better experience for you on our Website. The types of cookies we use
include:
• Required Cookies. Required Cookies needed in order to make the Website actually work. These cookies
are essential, and the Website would not function properly without them.
• User Experience Cookies. User Experience Cookies tailor the Website experience for you, the user (for
example, auto-populating certain fields). These are not required, but they may make your use of the Website
more enjoyable.
• Analytics Cookies – Analytics Cookies help us compile statistical information about use of our
Website, such as the time users spend at the site and the pages they visit most often. This information helps
us analyze trends in the aggregate and improve and administer our Website.
If you would like to understand the specific cookies that GroupBy uses, please click here: https://www.groupbyinc.com/compliance/cookies-policy
Control of Cookies
There are ways to control your browser settings to indicate when we have set a cookie in your browser, and
you have the ability to control our use of cookies and third-party analytics with respect to your use of
Website. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to
turn off all cookies. You do this through your browser settings. Your device may also have controls that
determine the information collected. Each browser is a little different, so look at your browser’s
“Help” menu to learn the correct way to modify your cookies. Please note that if you turn cookies
off, some features will be disabled that make your Website experience more efficient, and some of our Website
features may not function properly.
Web Beacons
A web beacon or tracking pixel is a small file that is placed on your browser or device when you visit a
particular website, email or software application. Web beacons are used to track whether or not you have
accessed certain content.
For example, web beacons may provide information about how many times a web page is accessed, along with the
times it was accessed and the IP address of users who accessed it.
Some web beacons are set by the website owner. Other web beacons are set by third parties. These third-party
web beacons may enable third party features or functionality to be enabled through the website and provide
information about your computer to the third party.
We use web beacons to help provide a better experience for you on our Website.
You have the ability to control our use of cookies and third-party analytics with respect to your use of
Website via your browser settings. Your device may also have controls that determine the information
collected. Each browser is a little different, so look at your browser’s “Help” menu to
learn the correct way to modify your settings. Please note that if you turn web beacons off, some features
will be disabled that make your Website experience more efficient, and some of our Website features may not
function properly.
By using cookies and web beacons together, we are able to gain valuable information to improve the Website
and measure the effectiveness of our marketing campaigns. Information collected from cookies (including
cookies placed by third-party vendors, such as Google and its partners) may be used to deliver advertisements
to Website Users when such Website Users are visiting other websites, including Facebook, LinkedIn, and
YouTube. You may opt out of a third-party vendor's use of cookies for personalized advertising by
visiting www.aboutads.info.
PART 4: INTERNATIONAL RESIDENTS
IMPORTANT NOTICE: Although our Website can be viewed internationally, many of our computer systems are
currently based in the United States and Canada. Therefore, please note that all Personal Information may be
processed by us in the United States and/or Canada.
Please also note that our Customers may have executed data processing addendums with us governing the
processing of certain types of data via our Services.
For more details regarding how we collect, use, process, and disclose Personal Information from European
Economic Area (EEA) visitors or where our processing of Personal Information is otherwise regulated by the
GDPR, and the additional rights are available to visitors under the GDPR (to the extent applicable) in respect
of this Personal Information, see below:
Under the GDPR, to the extent applicable, and under certain circumstances, you may have the following rights:
• If you wish to correct or update your Personal Information, you can do so at any time by contacting us
using the contact details provided under the Contact Us heading below.
• In addition, you can object to processing of your Personal Information, ask us to restrict processing
of your Personal Information or request portability of your Personal Information. Again, you can exercise
these rights by contacting us using the contact details provided under the Contact Us heading below.
• Similarly, if we have collected and process your Personal Information with your consent, then you can
withdraw your consent at any time, by emailing [email protected] . Withdrawing your consent will not
affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing
of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your
Personal Information. For more information, please contact your local data protection authority.
• We respond to all requests we receive from individuals wishing to exercise their data protection
rights within a reasonable timeframe and in accordance with applicable data protection laws.
Legal Basis for Processing Personal Information under the GDPR
Under the GDPR, to the extent applicable, our legal basis for collecting and using the Personal Information
described in this privacy policy will depend on the Personal Information concerned and the specific context in
which we collect it.
However, we will normally collect Personal Information from you only where we have your consent to do so,
where we need the Personal Information to perform a contract with you, or where the processing is in our
legitimate interests (as further described below) and such processing is not overridden by your data
protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to
process your Personal Information.
If we ask you to provide Personal Information to comply with a legal requirement or to perform under an
agreement we have in place with you, we will make this clear at the relevant time and advise you whether the
provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do
not provide your Personal Information (for example, if you do not provide your email address, you will not be
added to our email list).
Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those
of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Here are some examples:
• We process your Personal Information with your consent when you register on our Website; and when you
agree to receive online direct marketing from us (via email by signing up on our Website via the Contact Us
page).
• We process your Personal Information as required by applicable law. Applicable law may require us to
process your information: for tax purposes, to prevent/detect fraud, and in disclosures to law enforcement and
other regulatory or government agencies as required by law.
• We also process your Personal Information when it is in our legitimate interest to do so, and the
legitimate interest is not overridden by your data protection rights. Here are some examples of our legitimate
business interests:
– Developing and maintaining relationships with our customers and partners;
– Understanding how our visitors use our Website;
– Improving our Website;
– Understanding and responding to customer feedback;
– Researching and analyzing the products and services our customers want; and
– Securing our business and services.
If you have questions about or need further information concerning the legal basis on which we collect and
use your Personal Information, or regarding our legitimate interests, please contact us using the contact
details provided under the Contact Us heading below.
Personal Information collected under this privacy policy may be transferred from time to time to our offices
or personnel, or to third parties, located throughout the world, and the Website may be viewed and hosted
anywhere in the world, including countries that may not have laws of general applicability regulating the use
and transfer of such Personal Information. Where applicable law requires us to ensure that an
international data transfer is governed by a data transfer mechanism, we use one or more of the following
mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA (as permitted by GDPR), or
we will ask your consent. Please note that if you are a representative of a Customer, we may have agreed to a
specific data transfer mechanism in our agreement with the applicable Customer.
GDPR Rights
Under the GDPR, to the extent applicable, and under certain circumstances, you may have the right to:
• Ask us for a copy of your Personal Information
• Correct Personal Information, erase Personal Information or to transfer it to other organizations
(when technically feasible) at your request.
• Object to some processing and, where we have asked for your consent to process your Personal
Information, to withdraw this consent.
• Object to some processing where we have a legitimate interest in processing (as explained in the Legal
Basis for Processing Personal Information under the GDPR section above)
• To restrict processing in certain circumstances (for example, where we can demonstrate that we have a
legal requirement to process your Personal Information, it is possible that we may continue to do so).
• Lodge a complaint with the relevant supervisory authority (as defined in the GDPR). If you have any
complaints about the way we process your Personal Information, please do contact us using the contact details
provided under the Contact Us heading below. Alternatively, you may lodge a complaint with the supervisory
authority which is established in your country.
We may ask you to verify your identity and to provide other details to help us to respond to your request.
If you would like to: access, correct, amend or delete any Personal Information we have about you, register a
complaint, or simply want more information, please contact our Privacy Compliance Officer using the contact
details provided under the Contact Us heading below.
PART 5: GENERAL
What if I have questions about consent or your use of my information?
To the extent required by applicable law, upon request and upon reasonable verification of your identity in
accordance with applicable law, GroupBy will provide you with information about whether we hold any of your
Personal Information. Please note that we cannot provide details or information regarding whether any of our
Customers hold any of your Personal Information. You will need to seek this information directly from our
Customers.
If you would like us to delete, update, or modify any of your Personal Information that we currently hold, or
if you have questions at any time regarding the continued collection, use, storage or disclosure of your
Personal Information, please contact us using the details provided under the Contact Us heading below.
Prior Consent
Where the processing of your Personal Information is based on your previously given consent, you have the
right to withdraw your consent at any time. You may also have the right to object to the processing of your
Personal Information on grounds relating to your particular situation.
Disclosures to Third Parties
We may disclose your Personal Information:
• in response to lawful requests by public authorities, including to meet national security or law
enforcement requirements or as required by law, such as to comply with a subpoena, or similar legal process;
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety
or the safety of others, to protect our rights and property, or the legal rights or property of others,
investigate fraud, or respond to a government request;
• to a third party in connection with a sale, merger or other transfer of all or substantially all
of the assets of GroupBy or any of its Corporate Affiliates (as defined below), or any portion of GroupBy or
any of its Corporate Affiliates, or in connection with a strategic investment by a third party in GroupBy, or
in the event that we discontinue our business or file a petition or have filed against us a petition in
bankruptcy, reorganization or similar proceeding;
• to our Corporate Affiliates. For purposes of this Privacy Policy: "Corporate Affiliate" means any
person or entity which directly or indirectly controls, is controlled by or is under common control with
GroupBy, Inc., whether by ownership or otherwise; and “control” means possessing, directly or
indirectly, the power to direct or cause the direction of the management, policies or operations of an entity,
whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise;
• to independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide
specific services and products, such as hosting and maintaining the Website and developing applications. In
the course of providing products or services to us, these Outside Contractors may have access to information
collected under this privacy policy, including your Personal Information. We use reasonable efforts to
ensure that these Outside Contractors are capable of protecting the security of your Personal Information; or
• when it would potentially mitigate our liability in an actual or potential lawsuit.
In addition to the above, when individuals use our Website, third-party analytics service providers may
directly collect Personal Information and non-personal information about our users’ online activities
over time and across different websites.
Data Retention
We retain Personal Information where we have an ongoing legitimate business need to do so (for example, to
provide you the Website, to respond to questions you may have, to enforce our agreements, and to resolve
disputes). We will stop using the Personal Information when we no longer have a legitimate business need to do
so. If you request that we remove your Personal Information at an earlier date, to the extent required by
applicable law and upon reasonable verification of your identity in accordance with applicable law, we will do
so provided we do not have a separate legal obligation to keep it (for example, a lawsuit involving the
information).
If you have consented to receiving marketing communications (emails, etc.) from us, we will retain your
Personal Information for a reasonable period of time from the date you last provided consent, unless you
request that we remove it.
If we receive information derived from cookies or other tracking technologies, we will retain that
information for a reasonable period of time from the date it was collected.
When we have no longer have legitimate business need to process your Personal Information, we will either
delete or anonymize it or, if this is not possible (for example, because your Personal Information has been
stored in backup archives), then we will securely store your Personal Information and isolate it from any
further processing until deletion is possible.
Security
We take the security of information that we collect very seriously and therefore implement commercially
reasonable technical and organizational measures designed to protect it. Your Personal Information is
contained behind secured networks and is only accessible by a limited number of persons who have special
access rights to such systems. We follow commercially reasonable standards designed to protect the Personal
Information submitted to us. No method of transmission over the Internet, or method of electronic storage, is
100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about
security on our Web site, you can contact us at [email protected].
Changes to this Privacy Policy
We reserve the right to modify this privacy policy at any time, so please review it frequently. If we make
material changes to this policy, we will notify you on our Website that it has been updated, so that you are
aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or
disclose it. If we make changes to this privacy policy that materially change the way we use your
previously-collected Personal Information, we will communicate with you via a prominent posting on the
Website, as applicable.
DO NOT TRACK
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that
websites refrain from tracking the user. We take no action in response to automated Do Not Track requests.
However, if you wish to stop such tracking, please contact us with your request, using our contact details
provided below.
CONTACT US
Any questions, complaints or general comments should be directed to [email protected].
You may also reach us at:
Phone: +1 (855) 210-6513
Mailing address: GroupBy 250 The Esplanade, Suite 500 Toronto, Ontario M5A 4J5 Canada
ATTN: Privacy Officer
