Hello. We are Invoke Media (known by you as Incrowd). Here's how we protect your data and respect your privacy.
This is the privacy policy (“Policy”) of Invoke Media Inc., its subsidiaries and affiliates (collectively, “Invoke”). Invoke is committed to protecting your right to privacy when you provide us with personal information. This Policy sets out how we collect and manage personal information, whether that information is collected via our services, including our platforms, such as Incrowd (“Platforms”) or through our websites, including https://getincrowd.ai (“Sites”) . In this Policy, the terms "you", "user" and "your" refer to a user of our services through our Platforms and Sites (collectively, the “Services”) and the terms “we”, “us” and “our” refer to Invoke. Please read this Policy carefully before using our Services. We may also update or modify this Policy at any time by posting our revised policy to our Services. We include an “effective date” in the Policy displayed in our Platforms and Sites. We strongly encourage you to refer back to the Policy periodically to ensure that you stay up to date with our practices and procedures.By using our Services, you agree that you have read, understood and agree to be bound by this Policy, including any updates to the Policy, and approve of the collection and use by us of personal information according to its terms.
By submitting personal information to us or by otherwise using our Services, Platforms or Sites, you hereby consent to the collection, use and disclosure of personal information in accordance with this Policy. If you do not agree with some or all of this Policy, you must not use our Services, Platforms or Sites or submit personal information to us.
Invoke’s Privacy Officer is Wes DeBoer, Director of Technology. The Privacy Officer is generally responsible for ensuring compliance with applicable privacy legislation. The Privacy Officer must approve the policies and practices regulating the governance of personal information. More specifically, this person is responsible for implementing this Policy and ensuring that it is known, understood and applied. In the event of the absence or inability to act of the Privacy Officer Kiara Tchir, Senior Operations Manager will assume the duties of the Privacy Officer.
Invoke employees who have access to personal information or are otherwise involved in the management of such information must ensure its protection and comply with this Policy.
The roles and responsibilities of Invoke’s employees throughout the life cycle of personal information may be specified by any other Invoke policy in this regard, if applicable.
In the course of providing Services through our Platform, Sites, and off-line, we may collect your personal information and the personal information of persons depicted in images or video generated by the Platform (collectively, “Images”).
“personal information” means information that can identify an individual, and includes, for example, a person’s name, image, home address, home phone number, gender, date of birth, language preference, email address, credit card information, or account information. Personal information in Canada does not include information to enable an individual at a place of business to be contacted, such as their name, position name or title, business telephone number, business address, or business email address.
We will only collect personal information as permitted under the applicable privacy legislation. We may collect information in a variety of ways, including where you:
By submitting information to us, you consent to us collecting your information and the information of anyone captured in the Images. You covenant that you have obtained all required consents and provided all required notifications to use the Images and the personal information of all individuals depicted in the Images.
We may also collect aggregate information which tells us about users of our Platform and Sites. For example, we will collect information about the date, time and duration of visits as well as content preferences. The purpose of collecting this aggregate information is to help us administer and improve our Platform and Sites. We reserve the right to provide our analyses based on such aggregated data to third parties.
Personal information collected by us is used only for the purposes described in this Policy, or for other purposes which are disclosed to you and to which you consent.
We generally use your personal information or personal information that you provide to us to:
We will use the Images to as part of the operation of the Platform. The Images will be used to train object and scene detection models to improve the performance of the Platform. We will use your anonymized content preferences to train models to provide improved recommendations on the Platform.
The Sites also use Google Analytics to gather information about users’ usage of the Sites. We utilize this information to make educated metric-based decisions to improve the user experience of the Sites. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on.
We may disclose or share your personal information or personal information that you provide to us in the following circumstances:
It is important to us that we collect, use or disclose your personal information or the personal information of other parties only where we have your consent to do so or as provided in this Policy. Depending on the sensitivity of the personal information, your consent may be express, implied or deemed. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you use our Platform, Sites and other Services, we will assume your consent to the collection, use and disclosure of your personal information and personal information of individuals depicted in Images for purposes related to use of the Platform or for other purposes identified to you at the relevant time. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.
By submitting personal information to us or obtaining our Platform, Sites and Services, you consent to the collection, use and disclosure of personal information in the manner described in this Policy. Further, by using the Platform, Sites and Services, you covenant to us that you have all required consents from all individuals displayed in the Images. To the extent that we are required by applicable laws to obtain your explicit consent for the collection, use or disclosure of the personal information in accordance with this Policy, such consent will be requested at the appropriate time. Further, if we plan to use or disclose the personal information for a purpose not previously identified (either in this Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure. However, we may collect, use or disclose personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below. If an individual depicted in the Images withdraws consent or does not provide consent for use of the Image, it is your responsibility to inform us. In some circumstances, a change or withdrawal of consent may limit our ability to provide Services to you.
We assume, unless you advise us otherwise, that by receiving or having access to a copy of this Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of personal information as explained in this Policy.
Our Platform and Sites may contain links to the websites of other organizations which may be of interest to you. Similarly, you may be directed to the websites of other organizations to perform certain functions provided in our Platforms or Sites. Linked websites are operated by third parties who are responsible for their own privacy practices and you should check those websites for their respective privacy policies.
Please refer to our Terms of Use for further information in relation to links to third party websites. Where we recommend third parties for certain services or where use of third party solutions is required to use our Services, those parties will have their own privacy policy: we encourage you to be familiar with the privacy policies of such providers. For example, we use Auth0 to perform authentication to login into our Services and Stripe for payment processing. Invoke takes reasonable measures to ensure that service providers are compliant with applicable privacy laws. Where a third party is not a service provider, however, Invoke does not monitor privacy practices. We encourage you to be familiar with the privacy practices of third parties.
In order to improve our Sites on an ongoing basis, we use cookies to track your visit. The Sites also use cookies to provide users with certain features and preference settings.
A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the website that gave it to you. Cookies can also customize the site to your particular interests or store your personal information – like passwords or user IDs.
Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie – this gives you the chance to decide whether to accept it. To learn more about cookies and how to change your settings, please use the help function in your browser. The alerts will be quite frequent, however, and may eventually become annoying.
You can use the Sites without cookies, but you may have to re-enter information each time you visit. When you visit our Sites, Google Analytics adds a cookie to distinguish you from other users and track your behavior across our Sites. We use this information to improve the user experience of the Sites. The cookie lasts for up to 2 years. You can read about this in the Google Analytics Privacy Policy.
With your permission, the Sites utilize the Conversion Tracking Pixel service of Facebook Inc ("Facebook"). This tool allows us to follow the actions of users after they are redirected to a provider's website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remains anonymous. This means we cannot see the personal data of any individual user.
However, the collected data is saved and processed by Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook's Data Use Policy found under: https://www.facebook.com/about/privacy/.
Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside of Facebook. In addition, a cookie will be saved to your computer for these purposes.
Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/
Similarly, we may also collect information regarding the type of device, your operating system, the browser you use, your internet service provider, your domain name, your internet protocol (IP) address, the date and time that you accessed our service, the website that referred you to our Site, the web pages you requested, and the subject of the ads you click or scroll over. We may use such information to evaluate service performance and service quality and to optimize the user’s experience of our Site. To collect this information, we use cookies, web beacons and similar technologies.
We use reasonable and appropriate measures (including using TLS encrypted protocols and storing data encrypted in AWS cloud) to help secure personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with Invoke is prohibited and constitutes grounds for disciplinary action.
Unfortunately, no data transmission over the Internet can be guaranteed as completely secure. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us.
You are solely responsible for ensuring that you do not disclose personal information to third parties. This includes but is not limited to not disclosing login codes to anyone, ensuring that sufficient security software is installed and running on your computer, smartphone or tablet, that your network firewall is of sufficient quality and that your wireless connection is encrypted to a degree that will prevent third party access.
Personal information collected by Invoke referenced herein will be stored and processed in Canada. Personal Information collected by third parties referenced herein may be stored and processed in another country and by using the Sites, you consent to any such transfer of information outside of Canada. We will use reasonable measures to ensure all personal information is protected, but cannot ensure that the laws of other countries will offer the same level of protection as Canadian laws. By submitting your personal information to us, you hereby consent to the transmission, processing and/or storage of personal information outside of Canada.
We do not knowingly collect personal information from or offer Services to anyone under the age of 16, or who is otherwise under the age of majority in their place of residence. If you are under the age of majority, you may only provide personal information or use the Services with the permission and involvement of a parent or legal guardian.
We are committed to complying with Canada’s Anti-Spam Legislation. Where we have your consent or it is lawful to do so, we may provide you with direct marketing communications about us, or our Services which may be of interest to you. Such information may be sent to you by post, email, telephone or SMS.
If you have consented to receiving marketing materials from us, you can withdraw your consent to receiving those communications at any time by using the “unsubscribe” mechanism in our emails or contacting our Privacy Officer using the contact information provided below.
However, we reserve the right to send you transactional or informational emails such as customer service communications in connection with the Services, changes to the Platform or Sites, your account or our policies.
You have the right to know what personal information we have about you, which categories of Invoke personnel have access to it, how long it is retained and to correct any inaccuracies. Through the Platform, your personal information is available when you log in to your account and you may correct this information at any time. Otherwise, please direct any such requests by email to our Privacy Officer at privacy@invokemedia.com.
We may retain the personal information as long as is necessary in order to manage our relationship with you (or fulfill the purposes for which it was collected) or as otherwise permitted by law. We will destroy personal information when it is no longer required for the purposes for which it was collected or as required by applicable law.
Any person who wishes to make a complaint concerning the application of this Policy or, more generally, the protection of his or her personal information by Invoke, must do so in writing to our Privacy Officer at the e-mail address indicated in the following section.The individual must provide his or her name, contact information, including a telephone number, as well as the subject of the complaint and the reasons for the complaint, in sufficient detail to allow Invoke to evaluate the complaint. If the complaint is not specific enough, the Privacy Officer may request any additional information deemed necessary to assess the complaint.
Invoke undertakes to treat all complaints received as confidential. Within thirty (30) days following receipt of the complaint or of all additional information deemed necessary and required by Invoke’s Privacy Officer in order to process the complaint, the Privacy Officer shall evaluate the complaint and provide a written response. The purpose of this assessment will be to determine whether Invoke’s handling of personal information complies with this Policy, any other policies and practices in place within the organization, and applicable legislation or regulations.
Invoke shall maintain a separate file for each complaint received, each of them containing the complaint, the analysis and documentation supporting the assessment, as well as the response sent to the person who filed the complaint.It is also possible to file a complaint with the Commisson d’accès à l’information du Québec in Quebec or any other provincial privacy oversight body responsible for the applicable law. However, Invoke invites any interested party to first contact its Privacy Officer and wait for Invoke’s process to be completed.
Contacting Us. If you have any questions or comments about this Policy, your information, our third-party disclosure practices or your consent choices, please contact our Privacy Officer at privacy@invokemedia.com.
Effective Date: October 28, 2024