Last updated August 15, 2023
Effective Date: 03/13/2019
We are ContentFly Inc d/b/a Draft (“Draft”) a Canadian registered company with a registered address at 1 King Street West, Suite 4800 – 238, Toronto, Ontario, M5H 1A1, Canada provides a content generation service (“Service”) more fully described on the website Draft.co (“Website”).
Information you provide us
You may give us Personal Information by:
- Using our service as a Customer of ours. Where you are our Customer or are an employee of our Customer you may provide us with Personal Information. The type of information collected includes your name; company name; business address; email address; phone number; username; password; business tax number and basic site information i.e. URL/Channel/Impression Traffic etc.
- Corresponding with us by phone, e-mail or otherwise. We ask you to disclose only as much information as is necessary to provide you with our products or services or to submit a question/suggestion/comment in relation to our Website or our services or products.
- Applying to work with us. The type of information you may provide in your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive personal information (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.
- Supplying us with goods or services, whether as a Writer or otherwise. Suppliers such as Writers may provide us with information which may include a contact name; email address; business address; and telephone number.
Information we collect from your use of Draft Service
Draft may also collect certain information from visitors to and customers of the Website, such as Internet addresses. This information is logged to help diagnose technical problems, to administer our Website and in order to constantly improve the quality of the Services. We may also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
Our third-party partners also employ clear gifs (a.k.a. Web Beacons/Web Bugs), images, and scripts that help them better manage content on our Website. We do not tie the information gathered to our Customers' or End Users' Personal Information.
Cookies on the Website
When you interact with the Website we strive to make that experience easy and meaningful. When you come to our Website, our web server sends a cookie to your computer. Cookies are files that web browsers place on a computer's hard drive and are used to tell us whether customers and visitors have visited the Website previously. If you click on a link to a third-party Website, such third party may also transmit cookies to you.
Standing alone, cookies do not identify you personally. They merely recognize your browser. Unless you choose to identify yourself to Draft, either by responding to a promotional offer, opening an account, or registering for a free trial, you remain anonymous to Draft. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you've closed your browser or turned off your computer. They include such information as a unique identifier for your browser.
Draft uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Draft to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you've logged in and are required in order to use the Draft application. Draft uses persistent cookies that only Draft can read and use, to identify the fact that you are a Draft customer or prior Draft Website visitor (whatever the case may be). We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. Users who disable their web browsers ability to accept cookies will be able to browse our Website but will not be able to successfully use our Services. End Users may be able to limit cookies used by their browsers and third parties by updating settings at: http://www.aboutads.info/choices and http://www.youronlinechoices.eu .
How we use the information we collect
We collect the Personal Information described above in order to provide our Services to our Customers and their End Users, to market our products and services, to improve our Website and to recruit staff.
We will use the information we collect in the following ways:
- To fulfill our obligations arising from our contract with you i.e. to provide you with our Services;
- To set your company up as a customer on our systems.
- To liaise with you about projects that we are undertaking with you.
- To deliver information about our products and services, where you have subscribed to receive same.
- To ensure payment of our invoices.
- To administer and improve our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- As part of our efforts to keep our Website safe and secure.
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To make suggestions and recommendations to you and other users of our Website about services that may interest you or them;
Writers and Suppliers
- To fulfill our obligations arising from our contract with you, and to allow you to fulfil your contractual obligation to us, such as by accessing the Services as a Writer or Content Provider (as defined in our Terms of Service for Writers);
- To liaise with you about projects that you are undertaking for us.
- To manage your delivery of your services to us
Who we share your information with
We may share your Personal Information with our selected business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, these business partners may include our web hosting provider and our IT service providers.
We use a number of sub-processors and service providers to both assist us in providing the Website and Services and in addition, we may disclose your Personal Information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, in which case information held by us about our Customers and their End Users will be one of the transferred assets.
The data that we collect from you may be transferred to, and stored in, Canada which is outside the European Economic Area ("EEA") and for which there is an adequacy decision relating to the safeguards for personal data from the European Commission. The data that we collect from you may also be transferred to, and stored at, United States of America outside the European Economic Area ("EEA") for which there is an adequacy decision relating to the safeguards for personal data from the European Commission. For information about the adequate security safeguards that have been put in place for data based in the United States of America, you can reach out to firstname.lastname@example.org
The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.
Automated decision-making & profiling
We use automated decision-making/profiling in the administration of the employment or contractual relationship. Draft uses automated decision-making when deciding on the correct answer to serve based on a customer question. The exact logic of the automated decision may change based on the machine learning model employed.
Your data rights
You have the following rights in respect of your Personal Information:
- The right to access the Personal Information we hold about you.
- The right to require us to rectify any inaccurate Personal Information about you without undue delay.
As a customer of Draft, you have the following rights:
- The right to have us erase any Personal Information we hold about you in circumstances such as where it is no longer necessary for us to hold the Personal Information or, in some circumstances, if you have withdrawn your consent to the processing.
- The right to object to us processing Personal Information about you such as processing for profiling or direct marketing.
- The right to ask us to provide your Personal Information to you in a portable format or, where technically feasible, for us to port that Personal Information to another provider provided it does not result in a disclosure of Personal Information relating to other people.
- The right to request a restriction of the processing of your Personal Information.
- The right to address a challenge concerning the personal information handling policies and practices at Draft.
Where our processing of your Personal Information is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful. You may exercise any of the above rights by contacting email@example.com Where Draft is acting as the Data Processor, End Users should contact the Data Controller, i.e. the entity with which End User has a relationship, to exercise these rights.
If you are a resident of the European Union, you may also lodge a complaint with your local privacy commissioner or other Supervisory Authority with respect to our processing of your Personal Information. The local Supervisory Authority in each European country can be found here .
Our Data Protection Officer can be reached at firstname.lastname@example.org