Cairn — Privacy Policy

TwentyTwoStudios

Website: https://hliwudnew.github.io/

1.Introduction

1.1We are committed to safeguarding the privacy of our website visitors and service users.

1.2This policy covers the Cairn desktop application, the online licence service it uses to activate and check licences, and our website. Our payment processor may collect information of its own, and its own policy describes it.

1.3Your estate information never leaves your computer. We never receive it, and Cairn sends no analytics, usage statistics or crash reports.

1.4In this policy, “we”, “us” and “our” refer to TwentyTwoStudios, an individual trading as TwentyTwoStudios, in Ontario, Canada.

2.What personal data we collect

2.1Everything you enter into Cairn — estates, assets, accounts, contacts, beneficiaries, bills, debts, distributions, funeral wishes, checklists and attached files — is stored only on your computer, in Cairn’s own folder. So are saved account passwords (encrypted, if you set up password protection), Cairn’s automatic restore points and its error log. We cannot see any of it, and no feature of Cairn sends it to us.

2.2Our licence service holds only the following:

1. (a)Account data — your email address, and, if you sign in on our website through another service such as Google, the name of that service and the account identifier it gives us;
2. (b)Licence data — whether your licence is perpetual or a subscription, its status, your estate slots, and a scrambled (hashed) copy of your licence key. We never store the key itself;
3. (c)Device data — for each computer you activate, a code derived from the computer’s name (never the name itself), when it was activated, when it last checked in, whether it is active, and a record of moves from one computer to another;
4. (d)Estate slot data — for each estate given a perpetual estate slot, that estate’s random identifier and when the slot was given. Never the estate’s name or anything in it;
5. (e)Session data — website sign-in sessions, stored in hashed form, which stop working when they expire;
6. (f)Technical data — your internet protocol (IP) address, the time and the address requested, recorded in our server logs with each request;
7. (g)Correspondence data — the content of any emails you send us, including any diagnostic report you choose to include.

2.3We do not collect payment card details. Payments are handled entirely by our payment processor; we receive confirmation of payment and the email address it was made with.

3.How we use your personal data

3.1We process your personal data for the following purposes:

1. (a)activating, renewing and checking your licence, and managing your estate slots;
2. (b)keeping a licence active on one computer at a time, and preventing misuse;
3. (c)creating, maintaining and managing your account;
4. (d)keeping our service secure and fixing problems with it;
5. (e)responding to your enquiries, complaints and support requests;
6. (f)complying with legal obligations, such as keeping payment records.

3.2We do not sell your personal data, use it for advertising or marketing, or build profiles from it.

4.Legal basis for processing

4.1We will only process your personal data where we have a lawful basis for doing so. The legal bases we rely on include:

1. (a)Consent — you have given us clear consent to process your personal data for a specific purpose. You have the right to withdraw your consent at any time by contacting us using the details set out below.
2. (b)Legal obligation — the processing is necessary for us to comply with the law.
3. (c)Legitimate interests — the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

5.Sharing your personal data

5.1We disclose your personal data only to the following categories of third parties:

1. (a)our payment processor, for the purpose of processing transactions securely;
2. (b)our email provider, for the purpose of sending you emails about your account and licence;
3. (c)our cloud hosting provider, for the purpose of hosting our licence service and securely storing data;
4. (d)law enforcement agencies, regulatory bodies, and other authorities where we are legally required to do so.

5.2We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.International data transfers

6.1Our licence service runs with a cloud hosting provider, so your personal data may be stored and processed outside your province or country, where it is subject to the laws of that place.

6.2You may request further information about where your personal data is stored by contacting us using the details set out below.

7.Data retention

7.1We keep account, licence, device, estate slot and session data for as long as your account exists, because they are what keep your licence working and record what you have bought. We delete them within 30 days of a request to close your account, except records the law requires us to keep, such as payment records for tax purposes.

7.2We keep server logs for up to 30 days.

7.3We keep correspondence for as long as we need it to help you, and delete it if you ask.

7.4Closing your account ends your licence, and Cairn becomes read-only on your computers. Your estate information is not affected — it was never with us.

8.Your rights

8.1You have a number of rights in relation to your personal data. These include the right to:

1. (a)Access — request a copy of the personal data we hold about you.
2. (b)Rectification — request correction of any incomplete or inaccurate personal data we hold about you.
3. (c)Erasure — request deletion of your personal data where there is no good reason for us to keep it.
4. (d)Objection — object to processing of your personal data where we are relying on a legitimate interest.

8.2If you wish to exercise any of the rights set out above, please contact us using the contact details provided below. We will reply within 30 days.

8.3You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

9.Cookies

9.1Cairn itself uses no cookies.

9.2Our website uses no analytics or advertising cookies. It may use cookies that are strictly necessary to keep you signed in.

10.Children’s privacy

10.1Cairn and our services are intended for people aged 18 or over, and we do not knowingly collect personal data from anyone younger.

10.2If we learn that we have collected personal data from someone under 18, we will take steps to delete that information as quickly as possible.

11.Third-party links

11.1Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

11.2We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

12.Security

12.1We store licence keys and sign-in sessions only in hashed form, and every licence we issue is digitally signed so it cannot be forged.

12.2Your estate information is protected by your own computer — its sign-in and any disk encryption you use — and saved account passwords can be encrypted with a passphrase only you know.

13.Changes to this policy

13.1We may update this privacy policy from time to time. We will update the date above when we do.

13.2We will tell you about significant changes in Cairn or by email before they take effect.

14.How to contact us

14.1If you have any questions about this privacy policy or our treatment of your personal data, please contact us:

14.2by email: [email protected]

14.3Our Data Protection Officer is Gabriel Henderson, who can be contacted at [email protected].

15.Supervisory authority

15.1You have the right to make a complaint at any time to the Office of the Privacy Commissioner of Canada.

15.2The Office of the Privacy Commissioner’s contact details are available at: https://www.priv.gc.ca/.

15.3We would, however, appreciate the chance to deal with your concerns before you approach the Office of the Privacy Commissioner, so please contact us in the first instance.

This document was created using a free template from SEQ Legal.