Code of Conduct
Our code of conduct defines how the company and employee act on a day-to-day basis. It reflects the organization's daily operations, core values and overall company culture.
Sapper Labs Cyber Solutions is committed to ensuring the privacy of individuals. We are fully compliant to all privacy laws including the Personal Information Protection and Electronic Documents Act (PIPEDA) and General Data Protection Regulation (GDPR). We do not target, monitor, collect or store any Personally Identifiable Information (PII) of Canadians. Client data and information related to criminal or civil investigations is securely stored in a privacy data bank in accordance with Canadian Privacy Laws and best practices.
The team at Sapper Labs Cyber Solutions are trusted individuals having undergone extensive security and reliability vetting. The company has a culture of security. We treat the customers confidentiality seriously and with the utmost of discretion.
We maintain the highest degree of integrity in our work. We always demonstrate a consistent and uncompromising adherence to strong moral and ethical principles and values. We champion honesty and truthfulness or accuracy in all actions, principled in everything we do, dedicated to the health, safety, and security of Canada.
We support the Universal Declaration of Human Rights (UDHR) which that enshrines the rights and freedoms of all human beings and work to ensure freedom and shared values like dignity, fairness, equality, respect, and independence. We work actively to safeguards human rights globally and particularly in contested and denied environments.
We always conduct our services honestly and honourably. We protection and enhance the moral standing and reputation of our clients, partners, and competitors. Ethical principles govern all decisions and behaviour at a company.
DUTY OF CARE
Our products and services, advice and guidance always abide by legislation, regulation, standards, and best practices. Do no harm.
CONFLICT OF INTEREST
We always conduct ourselves in a manner free of perceived or real conflict of interest.
INTELLECTUAL PROPERTY AND MORAL RIGHTS
We respect, handle, protect and defend the moral and intellectual property vested in our clients’ data.
We maintain the highest-quality and best-practices to exceed international and government standards. Our quality management program is focused on providing high confidence that client requirements are fulfilled.
We conduct all our activities professionally and in accordance with the highest principles of discretion, honesty, truth, integrity, and ethics. We provide objective advice in the best interests of our clients and Canadians.
We always strive to be fair, impartial, and objective. We are committed to treating all people equally and nurturing great talent. We are champions of equality, language, gender, orientation, race, creed, colour, age, or disability.
INTERPRETATION AND DEFINITIONS
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- Account means a unique account created for You to access our Service or parts of our Service
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Sapper Labs Group Inc., 4575 Whispering Willow Drive Navan K4B 0K6 ON CA
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses
- Country refers to: Ontario, Canada
- Device means any device that can access the Service such as a computer, a cell phone or a digital tablet
- Personal Data is any information that relates to an identified or identifiable individual
- Service refers to the Website
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit)
- You refers to the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
In carrying out our business under we collect personal information as defined by section 3 of the Privacy Act. We are committed to respecting the privacy rights of everyone whose personal information we have collected. Sapper Labs Group is fully compliant with Personal Information Protection and Electronic Documents Act (PIPEDA) and the principles of natural justice.
Why we collect personal information?
We collect basic personal information for the purposes of interacting with clients and partners. Predominately, contact information.
We may also collect personal information for administrative reasons such as providing individuals with publications, blogs, e-mail or other information that they ask for.
We can only use your personal information for the purpose for which it was obtained or for a use consistent with that purpose, or for a purpose listed in PIPEDA.
What personal information do we collect?
We only collect personal information that is directly related to our stated business. Wherever possible, such information will be collected directly from the individual about whom it pertains. The amount and the type of the information collected will be limited to that which is needed to fulfil the identified purpose(s). We only collect what we need.
We may for example, collect your name, contact information, or views or comments in connection with one of our reports, publications, or posts. We may also collect your IP address if you visit our website.
We strongly encourage you not to provide us with information beyond that which is necessary.
We may also collect personal information from other sources, as appropriate, including witnesses, employers, government, or corporate files and records.
Personal information banks (PIBs) are descriptions of personal information under the control of a government institution. The personal information described in a PIB has been used, is being used or is available for an administrative purpose or is organized in such way to make it more efficient to retrieve it. It could be organized by the name of an individual or by an identifying number or symbol. The PIB describes how personal information is collected, used, disclosed, retained and/or disposed of in the administration of a government institution's program or activity.
Who sees your personal information?
We will not disclose your personal information without your consent unless it is allowed under PIPEDA. In this case, we will aim to disclose only the specific information that is needed under the circumstances and, wherever possible, will inform you about the disclosure.
Access to personal information within the Sapper Labs will be restricted to those staff members who need the information in order to carry out their job duties. Those employees will maintain the information in the strictest of confidence and will not provide access to the information to anyone who is not authorized. The level of staff access to personal information will be granted on a need-to-know basis.
All individuals we hire under contract or other means to conduct business on our behalf will be required to respect the provisions of PIPEDA as well as this Policy and related internal procedures. Violations of any part of the contractual agreement may result in termination of the contract.
How we protect your personal information
In any organization, failure to protect personal information can increase the risk of a privacy breach. These privacy breaches can lead to things such as reputational harm, fraud or identity theft.
We will protect personal information from loss or theft, unauthorized access, use or disclosure, modification or destruction through appropriate administrative, technical and physical security measures and safeguards.
The level of safeguards used to protect personal information will depend on the:
- sensitivity of the personal information;
- amount, distribution and format of the information;
- method of storage.
We follow best practices and standards for information technology security received from the relevant federal agencies.
Additional information about our methods of protection:
Wherever possible, we seek a person’s consent before we collect their personal information. The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied, and can be provided directly by the individual or by an authorized representative.
Express consent is preferred. Express consent can be given orally, electronically or in writing. Implied consent may be reasonably inferred from a person’s action or inaction. For example, providing a name and address to receive a publication or providing a name and telephone number to receive a response to a question. When determining the appropriate form of consent, we take into account the sensitivity of the personal information, the reasons we are collecting it, and the reasonable expectations of the person. When using personal information for a new purpose, we will document that new purpose and ask for consent again.
During our investigations, it may not always be possible to obtain a person’s consent to collect, use, or disclose their personal information. PIPEDA allow for the disclosure of personal information during the course of an investigation if it is necessary to carry out that investigation.
We will not use your personal information without your consent unless it is either:
- for the same purpose for which the information was originally collected or compiled,
- consistent with that purpose,
- for a purpose that may be disclosed under PIPEDA
How we use your personal data (clients under contract and blog site)
We may use your personal data to provide and maintain services to clients.
- to provide and maintain our Service, including to monitor the usage of our Service
- to manage Your Account: to manage Your registration as a subscriber to the Service, the Personal Data (email) You provide can give You access to receiving email updates.
- for the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service
- to contact You: to contact You by email, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation
- to provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already subscribed, purchased or enquired about unless You have opted not to receive such information
- to manage Your requests: to attend and manage Your requests to Us
- for business transfers: we may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred
- For other purposes: we may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience
We may share Your personal information in the following situations:
- with Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You
- for business transfers: we may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company - all of which You would be informed about beforehand
- with business partners: we may share Your information with Our business partners to offer You certain products, services or promotions
- with other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- with Your consent: We may disclose Your personal information for any other purpose with Your consent
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If we need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Retention and destruction of personal information
We are responsible for ensuring that all personal information is managed within a set life cycle. We will retain personal information in accordance with the maximum retention periods set out under the PIPEDA.
The retention, disposition and destruction of personal information is made in strict accordance with the Government of Canada’s Directive on Privacy Practices.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
TRANSFER OF YOUR PERSONAL DATA
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction.
PERSONAL DATA DELETION
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service, such as unsubscribing from Our emails.
You may update, amend, or delete Your information at any time by contacting Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
DISCLOSURE OF YOUR PERSONAL DATA
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other Legal Requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- comply with a legal obligation
- protect and defend the rights or property of the Company
- prevent or investigate possible wrongdoing in connection with the Service
- protect the personal safety of Users of the Service or the public
- protect against legal liability
Access or corrections to personal information
Individuals do not always need to use Privacy Law to access to or correct their personal information (e.g. informal request). However, they do have the right to formally request access or corrections to their personal.
We make every effort to ensure that information we use to make a decision that directly affects someone is as accurate, up-to-date and complete as possible.
Additional information about access and correction of personal information:
Our roles and responsibilities
We are responsible for the personal information that we collect, retain, use, disclose, and destroy in the course of fulfilling our business. We will continue to develop policies and practices to ensure that personal information is handled in strict accordance with the Canadian Privacy Law. Our Chief Privacy Officer is responsible for overseeing the implementation of those policies and practices, including:
- ensuring open, full and timely communication with employees and individuals about our policies, practices and expectations with respect to the handling of personal information;
- establishing standards for designating the sensitivity of personal information, to determine the appropriate level of security and privacy required for the information;
- working with the Company Security Officer to ensure that personal information is safeguarded from improper access, loss, use, disclosure or destruction through;
- the implementation of systems to ensure that only our staff whose responsibilities require access to personal information, are granted access to that information;
- the inclusion of specific provisions in contracts or other arrangements with third parties, that require adherence to the Privacy Act as well as to this Policy and other internal procedures;
- ensuring procedures are in place under which individuals may request access to their personal information, request correction of their personal information, and file complaints concerning the management of their personal information;
- ensuring procedures are in place under which individuals are notified of an improper collection, retention, use, disclosure or destruction of their personal information; and
- monitoring the degree of compliance with this Policy and, where required, initiating action to correct any issues.
Employees – staff that collect personal information on our behalf will be required to explain the purpose(s) for which the information is being collected. If unable to do so, they will be required to refer the individual to someone within our office who is able to explain the purpose(s). It is every employee’s duty to inform themselves of their obligations under this Policy and PIPEDA. Employees must report any and all violations of the Policy to their manager or to the company Privacy Officer.
Managers and Supervisors – along with the responsibilities noted above, managers and supervisors must instruct their staff to respect the Policy and PIPEDA. They must also examine and/or make inquiries into any issues brought to their attention concerning this Policy and the Act. When appropriate, managers and supervisors must notify, work with, or refer certain matters to the Director of HR and the Company Security Officer.
Company Privacy Officer – the company privacy will provide advice and guidance to Senior Management, managers, supervisors and employees of Sapper Labs with respect to the treatment of personal information within our company. The company privacy officer will also act as the main point of contact for individuals seeking information or who have concerns about our handling of their personal information.
Violation of this Policy through intent or neglect may result in disciplinary action up to and including termination of employment. Legal sanctions may also be pursued if appropriate.
Monitoring and evaluation
Measuring compliance with this policy is part of our internal audit program. We conduct periodic audits within all of our programs and services. The results of internal audits will be reported to the CEO.
The following laws, policies and guidelines should be read along with this Policy:
The Personal Information Protection and Electronic Documents Act (PIPEDA)
- Privacy Act and Privacy Regulations
- Access to Information Act and Regulations
- Library and Archives of Canada Act
- Policy on Privacy Protection
- Policy on Government Security
- Directive on Privacy Practices
- Directive on Personal Information Requests and Correction of Personal Information
- Directive on Privacy Practices - Appendix E: Standard on Privacy and Web Analytics
- Directive on Privacy Practices - Appendix B: Mandatory Procedures for Privacy Breaches
- OPC Access to Information and Privacy Process and Compliance Manual
Questions or Complaints
If you have any questions about this policy or about how we manage personal information, you may also contact:
Company Privacy Officer
Where an individual is not satisfied with the actions we may have taken to rectify a matter, or with the explanations given, they will be informed of their right to file a complaint, and will be given direction as to how to do so.
WEBSITE TERMS AND CONDITIONS OF USE
Your privacy and our website
What personal information do we collect?
Web servers automatically collect certain information about a visit to a website, including the visitor's Internet Protocol (IP) address. IP addresses are unique numbers assigned by Internet Service Providers (ISP) to all devices used to access the Internet. Web servers automatically log the IP addresses of visitors to their sites. The IP address, on its own, may not identify an individual. However, in certain circumstances, it could be used to identify an individual using the site. For this reason, we consider the IP address to be personal information, particularly when combined with other data automatically collected when a visitor requests a web page. This information can include the name of the page you visited and the date and time of your visit.
Unless otherwise noted, we do not automatically gather any specific personal information from you. The only way we would get this information is if you give it to us, for example, should you communicate directly with us. We have forms on our site to help you interact with our office – for example, signing up for a newsletter or to send us a message. We only ask for the information that we need to address your request.
TYPES OF DATA COLLECTED
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email Address
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Form Block Submissions
This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:
- information about your browser, network and device
- web pages you visited prior to coming to this website
- web pages you view while on this website
- your IP address
Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyzes the data in a depersonalized form.
This website collects personal data to power our site analytics, including:
- information about your browser, network, and device
- web pages you visited prior to coming to this website
- your IP address
This information may also include details about your use of this website, including:
- internal links
- pages visited
We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.
We may send you marketing emails, which you can unsubscribe from by clicking the link at the bottom of the email. We share your contact information with Squarespace, our email marketing provider, so they can send these emails on our behalf.
TRACKING TECHNOLOGIES AND COOKIES
These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.
These analytics and performance cookies are used on this website, as described below, only when you acknowledge our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.
- Web Beacons: certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
- Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
This website serves font files from and renders fonts using Google Fonts and Adobe Fonts. To properly display this site to you, these third parties may receive personal information about you, including:
- Information about your browser, network, or device
- Information about this site and the page you’re viewing on it
- Your IP address
Why we collect your personal information
In the course of providing online services through our website, we collect personal information for certain purposes. We use digital markers and web analytics to improve our site. We offer a number of online tools, such as forms for enquiries, to deliver our services. We also use certain software to ensure the security of our website. These uses are described in more detail in the sections below.
If you send us an email or complete an online form, we may use your personal information to respond to you. In most cases, we will delete any personal information that we did not ask for.
Personal information from emails or completed forms is collected according to PIPEDA. Such information is used to provide our services.
Digital markers (including cookies)
A digital marker is a small file placed on your computer by a web site that you visit. They are stored there so that the web server can remember certain pieces of information about you. This information is used by the web server during the same or another visit to the website. Examples of digital markers are "cookies" or HTML5 web storage. They are often used in the collection of web analytics, to store your preferences (for example: language or location), and to manage your session if you are logged in.
More information about what digital markers can do and how we use them:
Web analytics is the collection, analysis, measurement, and reporting of data about web traffic and visits. This data is used to improve our website and deliver on our services. It also helps us complete administrative tasks such as:
- communications and information technology statistics,
- audit and evaluation,
- research, and
More information about how we use web analytics to improve our web site:
Protecting the security of our website
We use software programs to monitor network traffic and identify unauthorized attempts to change information, or damage our systems. This software receives and records the IP address of the computer that has contacted our website, the date and time of the visit and the pages visited.
More information about how we handle the information that we collect while securing our website:
Who sees your personal information
We do not disclose the information to anyone. We do not use your personal information to create individual profiles. Any further disclosure of your personal information is done with your consent and in accordance with the Privacy Law and Policy.
In cases where services are provided by third parties such as social media platforms or mobile applications, IP addresses may be recorded by their web servers.
How we protect your personal information
Emails and other electronic methods used to communicate with us are not secure unless it specifically says so. It is not recommended that you send sensitive personal information through non-secure electronic means.
Inquiring about our privacy practices
Any questions, comments, concerns or complaints you may have about the administration of privacy law and policy concerning our web presence may be directed to our Company Privacy Officer.
Our use of social media serves as an extension of our web presence. Social media accounts are public and are not hosted on our servers. Users who choose to interact with us via social media should read the terms of service and privacy policies of these third-party service providers and those of any applications you use to access them. We use Twitter, and LinkedIn.
Comments left by individuals on social media can be read by anyone. Therefore, we strongly advise you not to post any personal information – whether it is yours or not. We reserve the right to remove any comments that violate our Comment Policy or contain personal information.
Personal information that you provide us via social media is collected to capture conversations (e.g. questions and answers, comments) between us. It may be used to respond to inquiries, or for statistical, evaluation and reporting purposes. The personal information that you provide directly to us falls under Personal Information Bank.
Linking to company websites
Links to websites not under our control are provided for the convenience of our visitors. We are not responsible for the accuracy or reliability of the content. We do not offer any guarantee and are not responsible for the information found through these links. We also do not endorse these sites or their content.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Who can I contact if I have any questions about this website?
Questions about our website may be directed to our webmaster. They will either answer your question or put you in touch with the correct staff member.