Divigo Inc. (operating as “Divigo”) is committed to ensuring that your privacy is protected while we provide our clients, customers, and vendors with exceptional service. Protecting personal information is one of our highest priorities.
Divigo abides by the Canadian federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), which sets out the ground rules for how businesses may collect, use, disclose, and dispose of personal information. We follow the privacy principles required by PIPEDA when handling your personal information. Should we ask you to provide information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this Privacy Policy (the “Policy”).
We will inform our clients, customers, and vendors of why and how we collect, use, disclose, and dispose of their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Our privacy commitment includes allowing our clients, customers, and vendors to request access to, and correction of, their personal information.
Divigo may change this Policy from time to time by updating this page. If you are registered on this website, we will send you an email to notify you when material changes occur.
Unless indicated otherwise, this Policy applies to all of our websites, domains, apps, products, services, and features.
Definitions
“Business contact information” means information that would enable an individual to be contacted at a place of business, including name, position name or title, business telephone number, business address, business email, or business fax number. It is not covered by this Policy or by Part 1 of PIPEDA.
“Personal Information” means information about an identifiable individual. It does not include business contact information (described above).
“Privacy Officer” means the individual designated with responsibility for ensuring that Divigo complies with this Policy and with Part 1 of PIPEDA.
“Divigo,” “we,” “our,” or “us” means Divigo Inc., operating as Divigo.
What is Divigo?
Divigo supports organizations in assessing their diversity status quo through means such as surveys, staff engagements, and reviewing internal documents. We help organizations develop solutions and strategies to become more inclusive. We may collect personal information that includes, but is not limited to:
- Name
- Contact information, including email address
- Demographic information such as postal code, preferences, and interests
- Raw data that may or may not identify individuals by name, but which could be used to identify the individual as the source of the input provided
- Other information relevant to surveys and engagements
What We Do With the Information We Gather
We require this information to understand your needs and provide you with better service and tools, such as reports and resources that meet your inclusion needs. We may also use the information gathered to improve our products and services.
Policy 1. Collecting Personal Information
Unless the purposes for collecting personal information are obvious and the client, customer, or vendor has voluntarily provided personal information for those purposes, we will seek permission either orally or in writing, before or at the time of collection.
We will only collect information that is necessary to fulfill the following purposes, including but not limited to:
- Verifying identity
- Identifying preferences
- Understanding needs
- Delivering requested products and services
- Enrolling the client in a program
- Sending out information
- Ensuring a high standard of service
- Meeting regulatory requirements
- Collecting and processing payments
Policy 2. Consent
We will obtain consent to collect, use, or disclose personal information.
Consent can be provided electronically through an authorized representative, or it may be implied where the purpose for collecting, using, or disclosing the personal information would be considered obvious.
Consent may also be implied where a client, customer, or vendor is given notice and a reasonable opportunity to opt out of having their personal information used.
Policy 3. Using and Disclosing Personal Information
We will only use or disclose personal information where necessary to fulfill the purposes identified at the time of collection, or for consistent purposes.
We will not use or disclose personal information for any additional purpose unless we obtain consent to do so.
We will never sell client, customer, or vendor lists or personal information to other parties.
Policy 4. Retaining Personal Information
We will retain client, customer, and vendor personal information only as long as necessary to fulfill the identified purposes for which it was collected.
We will retain that personal information for at least one (1) year after use, and as long as necessary to fulfill the identified purpose, so that the client, customer, or vendor has a reasonable opportunity to request access to it. Please refer to our retention schedule as a guideline.
Policy 5. Ensuring Accuracy of Personal Information
We will make reasonable efforts to ensure that personal information is accurate and complete where it may be used to make a decision about the client, customer, or vendor.
Clients, customers, and vendors may request a correction to their personal information to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
Policy 6. Securing Personal Information
We are committed to protecting personal information from unauthorized access, collection, use, disclosure, or disposal. We use the following measures to ensure that personal information is appropriately protected:
- Physically securing offices and any locations where personal information is held
- The use of user IDs, passwords, encryption, and firewalls
- Restricting employee access to personal information as appropriate
- Contractually requiring any service providers to provide comparable security measures
We will use appropriate security measures when destroying client, customer, and vendor personal information, such as securely shredding physical documents and permanently deleting electronically stored information.
We will continually review and update our security policies and controls as technology changes to ensure ongoing security. All of our employees receive annual information privacy training.
Policy 7. Providing Access to Personal Information
Clients, customers, and vendors have a right to access their personal information, subject to limited exceptions such as information that is subject to solicitor-client or litigation privilege, information that is prohibitively costly to provide, information that contains references to other individuals, or information that cannot be disclosed for security or commercial proprietary reasons.
A request to access personal information must be made in writing, with sufficient detail to identify the personal information being sought. Upon request, we will also tell a client, customer, or vendor how we use their personal information and to whom it has been disclosed, if applicable.
We will make the requested information available within thirty (30) days of receiving the request, or provide written notice where additional time is required to fulfill the request. A minimal fee may be charged for providing access, in which case we will inform the client, customer, or vendor of the cost and request direction on whether to proceed.
If a request is refused in full or in part, we will notify the client, customer, or vendor in writing, providing the reasons for refusal and the recourse available to them.
Policy 8. Questions and Complaints
Clients, customers, and vendors should direct any complaints, concerns, or questions to the Privacy Officer at [email protected].
If the Privacy Officer is unable to resolve the concern, the client, customer, or vendor may also write to the Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3.
Updated June 23, 2026
