Privacy Policy

1. Introduction

This Privacy Policy applies to all the products, services, websites and apps offered by Avatar Brand Management Inc., Do Better Marketing (a division of Avatar Brand Management Inc., SimpleLeads™™, GreenTexts™, go.4more.ca and their affiliates (collectively Avatar Brand Management Inc.) except where otherwise noted. We refer to those products, services, websites and apps collectively as the “services” in this policy. Unless otherwise noted, our services are provided by Avatar Brand Management Inc.

References to "data" in this Privacy Policy will refer to whatever data you use our services to collect, whether it be survey responses, data collected in a form, or data inserted on a site hosted by us – it’s all your data! Reference to personal information or just information, means information about you personally that we collect or for which we act as custodian.

If you want to identify your data controller please see the “Who is my data controller” section below.

2. Information we collect

2.1 Who are “you”?

We refer to “you” a lot in this Privacy Policy. To better understand what information is most relevant to you, see the following useful definitions.

Creators

You hold an account with SimpleLeads™™ or GreenTexts™ and you either directly create surveys, forms, applications, or questionnaires or you are collaborating on, commenting on, or reviewing surveys, forms, applications, or questionnaires within an account.

Respondents

You have received a survey, form, application, or questionnaire powered by an Avatar Brand Management Inc. service.

Website Visitor

You are just visiting one of our websites because you are Curious!

2.2 Information we collect about you.

  • Contact Information (for example an email address). You might provide us with your contact information, whether through use of our services, a form on our website, or an interaction with our sales or customer support team.
  • Usage information. We collect usage information about you whenever you interact with our websites and services. This includes which webpages you visit, what you click on, when you perform those actions, what language preference you have, and so on.
  • Device and browser data. We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, system and performance information, and browser type. If you are on a mobile device we also collect the UUID for that device.
  • Information from page tags. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes usage and user statistics. Emails sent by Avatar Brand Management Inc. or by users through our services include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies below and in our Cookies Policy.
  • Log Data. Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.
  • Referral information. If you arrive at an Avatar Brand Management Inc. website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
  • Information from third parties and integration partners. We collect your personal information or data from third parties if you give permission to those third parties to share your information with us or where you have made that information publicly available online.

If you are a Creator we will also collect:

Use of some of our services will also result in us collecting the following data on your behalf:

  • Address book information. We allow you to import email addresses into an Address Book so you can easily invite people to fill in your form via email. We don’t use these email addresses for our own purposes or email them except at your direction.
  • Survey/form/application data. We store your survey/form/application data (questions and responses) for you and provide analysis tools for you to use with respect to this data.
  • Profile data. When you sign up for our services you are asked to provide us with information about yourself and to give us more detailed insights into who you are.

3. How we use the information we collect

3.1 Creator

We process personal data about you either with your consent or in order to:

  • Fulfill our contractual responsibility to deliver the services to you;
  • To pursue the legitimate interests of Avatar Brand Management Inc:
  • to improve service experience; and
  • develop new products and service features.

In each of the instances where we describe how we use your data in this privacy policy, we have identified which of these grounds for processing we are relying upon.

You have consented to us using certain types of cookies on our websites. In particular we use:

  • Page tags and web beacons.

We collect information from page tags and web beacons to allow us to determine the success of our advertising campaigns. We also use page tags to allow the email sender (for a survey or form for example) to measure the performance of their email messaging and to learn how to improve email deliverability and open rates.

More details: We use this data to personalize online marketing campaigns to be relevant to you and your use of our services. By clearing your cookies in your browser settings you will no longer see personalized messages in this way but you continue to see ads over the internet that are not based on information you provided to Avatar Brand Management Inc. For more information please read our Cookies Policy.

We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this privacy policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.

  • Contact Information.

We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (for as long as you do not opt-out).

More details: We use your email address to send you marketing (newsletters), unless you indicate a preference to opt-out and for general updates on your account. You can opt out of marketing communications at any time by clicking on the “unsubscribe” link in them, or changing the relevant setting on your My Account page.

  • How you use our services.

We use information about how you use our services to improve our services for you and all users.

More details: We collect information about the types of surveys/forms/applications you create (e.g. HR surveys) to build a profile about you so as to help direct you to other relevant features and services we offer and help you in using our services, for example by making recommendations for you to optimize use of our services.

  • Device data.

We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address.

More details: Device and browser data: We collect this to help us improve your service experience through a specific device/browser by optimizing how the website looks in a particular browser, how your screen brightness affects your experience and to ensure the service operates optimally and as it should on different devices and browsers.

  • Log data.

We use log data for many different business purposes to include:

  • To monitor abuse and troubleshoot.
  • To create new services, features, content or make recommendations.
  • To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services.
  • To fix bugs and troubleshoot product functionality.

More details: Your IP address is used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).

  • Referral information.

We use referral information to track the success of our integrations and referral processes.

  • Third parties and integrations.

We will collect and use information from third parties and integration partners to:

  • Ensure you can sign-up to our service from a third party integration like Facebook/LinkedIn/Microsoft/Google/SSO;
  • To personalize our services for you; and
  • Ensure you can use our service in conjunction with other services.
  • Log data.

We use log data for many different business purposes to include:

  • To monitor abuse and troubleshoot.
  • To create new services, features, content or make recommendations.
  • To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services.
  • To fix bugs and troubleshoot product functionality.

More details: Your IP address is used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).

  • Service and Marketing uses.
  • Profiling. We combine information about you from third party sources with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve your service experience.
  • Machine learning. We use machine learning techniques on certain data in order to provide users with useful statistics and more relevant insights from the data they have collected using our services and to optimize our marketing campaigns. By way of example, if you have used open text questions in a survey, our machine learning may provide you with useful insights into the trends in responses to that question in our Analyze survey tool.
  • To manage our services we will also internally use your information and data, for the following limited purposes:
  • To enforce our agreements where applicable.
  • To prevent potentially illegal activities.
  • To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
  • Legal uses.

To respond to legal requests or prevent fraud, we may need to use and disclose information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

We collect and use the following data on the basis that we have to use this information in order to fulfill our contract with you:

  • Your Account Information.

We need to use your account data to run your account, provide you with services, bill you for our services, provide you with customer support, and contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You cannot opt out of these communications since they are required to provide our services to you.

  • Your Profile.

We process other aspects of your account information (like the personal information you provide about your job, your job title, and your marketing preferences) for legitimate interests like providing you with a personalized experience and relevant and useful marketing information as well as to make other product, feature and service recommendations to you to optimize your use of the services we offer.

You can object to us using your data as described above but our ability to fully and properly provide our services to you may be impacted if you do not want us to collect or use the above data.

In relation to Survey Data

  • Your Data.

We also use survey questions and responses on an aggregated and anonymized basis as described in this Privacy Policy, but we will never sell individual response data or identify / contact individual respondents except on your request or where required by law. Feature descriptions will identify where this is feature linked. In some cases you can avoid the use of your survey/ responses in this way by simply choosing not to use a feature or by indicating your preferences in your account. See our “Respondent” section.

3.2 Respondent

We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this privacy policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.

  • Cookies (to include page tags).

We collect information using cookies when you take a survey or fill out a form. These cookies are used to ensure that the full functionality of our service is operational, to ensure the survey operates appropriately and optimally. For more information please read our Cookies section below and our Respondent Cookies Policy. After completion of a form, in most cases, you will be re-directed to a page and treated as a website visitor where other cookies may be used so you should read our Website Visitor section if this is of interest to you.

Examples

We use page tags to allow the email sender (for a survey or form for example) to measure the performance of email messaging and to learn how to improve email deliverability and open rates. We also use cookies to ensure a respondent can only take a survey once (where the Creator has set this function) and to track completion rates of surveys.

  • Contact Information.

As a Respondent, we only use contact information to respond to an inquiry which you submit to us.

Examples

Our customer support team use your email address to communicate with you if you have contacted us about a survey, form, application or questionnaire you received, but we will not send marketing to you unless you have otherwise opted-in to marketing.

  • How you use our services (applicable to survey Respondents only).

We use information about how you use our services to improve our services for you and all users.

Examples

We collect information about the types of questions you answer. This data will be aggregated and anonymized so we can examine patterns in terms of respondent preferences when submitting responses (see further below in Information for Survey Respondent section). We collect and use all this data for our legitimate interests like helping us improve the experience for respondents (so that questions are easier to answer), to understand industry trends in and to help improve the completion rates on surveys/forms.

We will also use usage information such as the type of survey, form, questionnaire or application that you answered to personalize products we show you on completion of a survey when you are re-directed to our website.

  • Device and browser data.

We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address.

Other Examples

We collect this to ensure that service experience works well across all possible devices and to infer geographic location to produce aggregated data around Respondent location trends. We also want to use this information to provide an additional data layer to Creators so that they can filter responses by e.g. inferred geographic location. Note however, that we do not collect precise GPS co-ordinate location. We just infer location from IP address. Finally, we will use this information to compare and look at trends on how our service operates and how you interact with surveys, on different browsers and devices.

  • Log data.

We use log data for many different business purposes to include:

  • To monitor abuse and troubleshoot.
  • To create new services, features, content or make recommendations.
  • To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services.
  • To fix bugs and troubleshoot product functionality.

Examples

Your IP address is used to ensure that you do not complete the same survey, form, application or questionnaire twice if the creator has included settings to avoid this (ballot stuffing), for abuse monitoring purposes (so we can identify a Respondent who abused the survey taking experience in a manner contrary to our usage policies or to facilitate the Creator in complying with their own legal obligations. We also collect log data to collate aggregated data and metrics on activity at a non-identifying level and so that we can identify trends in survey taking over time.

  • Third parties and integrations.

We will collect and use information from third parties and integration partners to facilitate Creators in sending surveys/forms/applications/questionnaires to you.

  • Machine learning.

We will use machine learning techniques on response data, metadata (as described above) and cookie data, in order to provide Creators with useful and relevant insights from the data they have collected using our services, to build features, improve our services and to develop aggregated data products. You can read more about this in relation to surveys below.

  • To manage our services we will also internally use your information and data, for the following limited purposes:
  • To enforce our agreements where applicable.
  • To prevent potentially illegal activities.
  • To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
  • Legal uses.

To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

3.3 Visitor

We process personal data about you where:

  • You have consented or;
  • Avatar Brand Management Inc. has legitimate interests of:
  • improving service experience; and
  • developing new products and service features.

In each of the instances where we describe how we use your data in this privacy policy, we have identified which of these grounds for processing we are relying upon.

When you have consented we collect and use the following information about you:

  • Contact Information.

We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (as long as you have agreed to this at the point of providing your information and for as long as you do not opt-out).

Examples

We provide your email address to a member of our sales team who will contact you if you submitted an inquiry through one of the online forms on our site. You will also receive marketing communications from us if you have consented to this at the point where you provided your information. We will always provide you with the means to opt-out of this marketing at any time.

  • Cookies - page tags and web beacons.

We collect information from page tags and web beacons to allow us to determine the success of our advertising campaigns. We also use page tags to allow the email sender (for a survey or form for example) to measure the performance of their email messaging and to learn how to improve email deliverability and open rates.

  • How you use our services.

We use information about how you have interacted with our websites to improve our website services for you and all users. Some examples relevant to you:

Examples

We collect information about the webpages you have visited and your activity on our sites. We collect this information so that we can track the most visited and most useful parts of our website to identify what are our most popular services.

As a result of the above data we collect, we also carry out the following:

  • Profiling.

We combine information about you from third party sources with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve our marketing campaigns and website experience.

  • Machine learning.

We use machine learning techniques on certain data in order to optimize our marketing campaigns.

We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this privacy policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.

  • Device data.

We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address. Some examples relevant to you:

Examples

We collect device and browser information from you to troubleshoot website functionality issues and to fix bugs.

  • Log data.

We use log data for many different business purposes to include:

  • To monitor abuse and troubleshoot.
  • To track your preferences and create new services, features, content or make recommendations personalized for you.
  • To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services.
  • To fix bugs and troubleshoot product functionality.

Examples

Your browser type to determine how we can present our website best within that browser environment.

  • Referral information.

We use referral information to track the success of our integrations and referral processes.

Examples

If you clicked on an advertisement for Avatar Brand Management Inc., presented by one of our partners on the web, which brought you to one of our websites, we will record this information to help us track the success of advertising campaigns

  • To manage our services we will also internally use your information and data, for the following limited purposes:
  • To enforce our agreements where applicable.
  • To prevent potentially illegal activities.
  • To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
  • Legal uses.

To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

4. Information you share

Many of our services let you share information with others. Remember that when you share information publicly, it can be indexable by search engines. Our services provide you with different options on sharing and deleting your content but we cannot delete content from search engines so you need to be careful about information you make public.

5. Information we share: Partners and Integrations

We do not share your information or data with third parties outside Avatar Brand Management Inc. except in the following limited circumstances:

  • If you are a Creator that is part of an Enterprise team using Avatar Brand Management Inc.  your account information and data will be shared with the primary administrator(s) and your survey data may also be visible to other members in your team with whom you share your surveys or with whom you collaborate.
  • To help us provide certain aspects of our services we use our affiliates and trusted key partners – in particular, we engage third parties to:
  • facilitate our email collectors for sending surveys by email to Respondents.
  • facilitate customers in making credit card payments.
  • deliver and help us track our marketing and advertising content.
  • help us track website conversion success metrics.
  • manage our sales and customer support services to you.

We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.

  • On your instructions, we share your information or data if you choose to use an integration in conjunction with Avatar Brand Management Inc.  services, to the extent necessary to facilitate that use.
  • We also have to share information or data in order to:
  • meet any applicable law, regulation, legal process or enforceable governmental request.
  • enforce applicable policies, including investigation of potential violations.
  • detect, prevent, or otherwise address fraud, security or technical issues.
  • protect against harm to the rights, property or safety of our users, the public or to Avatar Brand Management Inc.  and/or as required or permitted by law.

6. Cookies

We and our partners use cookies and similar technologies on our websites.

We use certain cookies, as described in our Cookies Policy and here in our Privacy Policy, that you agree to when you use our sites and, in the case of some cookies, for legitimate interests of delivering and optimizing our services (where the cookie delivers essential functionality). Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:

  • To make our site easier to use. Creators if you use the “Remember me” feature when you sign into your account, we store your username in a cookie to make it quicker for you to sign in whenever you return to Avatar Brand Management Inc.
  • For security reasons. We use cookies to authenticate your identity and confirm whether you are currently logged into Avatar Brand Management Inc.  or determine if an incident impacts you.
  • To provide you with personalized content. We store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can personalize the content you see.
  • To improve our services. We use cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services (it helps us focus on the parts of the service you seem most interested in) and optimize the content we display to you (which may include marketing content).
  • Google Analytics. In addition to the above, we have implemented on our websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.

You can choose to remove or disable cookies via your browser settings.

7. Data Retention

If you hold an account with Avatar Brand Management Inc.  we do not delete the data in your account – you are responsible for and control the time periods for which you retain this dataThere are controls in your account where you can delete data at the account level (all data in your account) and at the response level. If you are a Respondent, you will need to ask the Creator how long your responses will be stored in Avatar Brand Management Inc.  services.

8. Safety of Minors

Our services are not intended for and may not be used by minors. “Minors” are individuals under the age of 13 (or under a higher age if permitted by the laws of their residence). Avatar Brand Management Inc.  does not knowingly collect personal data from Minors or allow them to register. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.

9. Changes to our privacy policy

We can make changes to this Privacy Policy from time to time. We will identify the changes we have made on this page. In circumstances where a change will materially change the way in which we collect or use your personal information or data, we will send a notice of this change to all of our account holders.

10. Personalized marketing

You can opt-out from direct marketing in your account and we provide opt-out options in all direct marketing emails. Finally, if you do not wish to see personalized marketing content on the web related to our service you can clear the cookies in your browser settings.

11. Who is my data controller?

As mentioned above – all response data at an individual level is controlled by the Creator and Avatar Brand Management Inc. Data on the Respondent and the Visitor Level is processed by Active Campaign LLC (privacy policy here), Avenue 81 (privacy policy here) and controlled by Avatar Brand Management Inc.

12. Your rights

Some of you (in particular, European users and those whose information we receive under the EU-U.S. Privacy Shield) have certain legal rights to obtain information about whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).

Rights which you are entitled to are:

  • Data access rights
  • Right to restrict processing
  • Right of Rectification
  • Right to Erasure (Right to be Forgotten)
  • Right to object to processing
  • Right to withdraw consent; and
  • Data portability rights

13. Exercising your rights

Our Contact Information for Privacy Inquiries

Avatar Brand Management Inc., Edmonton, AB, Canada, T6A 2Y7

privacy@dobettermarketing.com