Last revised 4 March 2022
This Policy explains how the Company collects, uses, discloses, retains and protects the personal information of its Users in the course of its activities, including in connection with the use of the Company's website (collectively and individually the " Services ").
The Services are intended only for Users located in Canada.
By providing their personal information to the Company or using the Services, as the case may be, Users accept this Policy. The Company reserves the right to update its Policy at any time and such changes will be effective immediately, unless otherwise stated. Users are requested to check regularly if this Policy has been modified. Users are deemed to have accepted the changes to this Policy if they continue to provide personal information to the Company or use the Services after the changes are posted.
Types of Information Collected and Collection of Information
For the purposes of this Policy, " personal information " means all information about a natural person that can be used to identify him or her, such as name, date of birth, contact information, and information about his or her identity.
When a User uses the Services, the Company collects personal information about the User, as further described below:
- Personal Information Provided by the User: Personal information voluntarily provided by the User as part of the Services, in particular when the User uses one of the features of the Services. Depending on the functionality used, this could be the surname, first name, date of birth, telephone numbers and other contact details, the Interests of the User, the User's availability as well as any other personal information voluntarily provided by the User. The Company may also require the User to enable (i) location services so that the Company can collect information about the User's location, (ii) access to the User's contacts and calendar and/or (iii) access to other applications; by activating these features, the User will provide the information relating to them, but will be able to manage the permissions associated with these features in the settings of his device. In addition, certain features of the Services may direct the User to other websites, applications or services that are not operated or controlled by the Company; personal information that is provided using these third-party sites is not covered by the Policy.
- Location Data: Certain features and functionality of the Services require the User to provide their location data. If location data is enabled when the User uses the Services on his mobile device, the Company collects and uses the Geographical Coordinates (latitude and longitude) of the User to adapt the Services. The Company will only use this location data with the express permission of the User. If background location data is enabled on the User's mobile device, the Company will know the User's location even if the User is not using the Services. The User's location will not be disclosed to anyone, unless the User has given his consent or the Policy allows it. The Company uses various technologies to locate the User accurately, such as operating system and browser location services. If the User has agreed to communicate his location data in the background to the Company while the User is using the Services, the User may at any time withdraw his authorization by accessing the settings of his device and disabling the location data in the background.
- Aggregated Data: In order to better
understand and serve Users of the Services, the Company may research
users' demographics, interests, and behaviors based on personal
information and other types of information that are provided in the
Services. This data can be compiled and analyzed in aggregate form. The
Company may transmit such aggregated data, as well as anonymized and
aggregated statistical and usage data, and data related to the
functionality of the Services, to its affiliates, agents and service
providers, who may use and disclose it for their own purposes, to the
extent permitted by applicable laws, including to improve the Services, develop new products and services and
for marketing purposes (e.g., indicate the number of customers who use the
Services). This aggregated information does not identify the User
personally and cannot be reasonably associated with the User. ConsentThe
Company collects users' personal information for the purposes described
below. In addition to the purposes already set out in this Policy, the
Company will identify the purposes for which personal information is
collected at the time or before it is collected. If the Company seeks to
use the personal information that has been collected for purposes that
have not been previously identified, it will ask for your consent before
using it, unless otherwise required by law. Subject to legal or
contractual requirements, a User may at any time withdraw his or her
consent to the collection, use or communication of his or her personal
information in writing to the Company's Privacy Officer at the contact
information below, upon reasonable notice. However, the withdrawal of such
consent could limit the Company's ability to offer certain particular
Services to the User, prevent the Company from providing them or even
force the Company to stop offering them. In addition, even in the event of
withdrawal of such consent, under the law, the Company may nevertheless
have the right or obligation to retain, use or disclose personal
information about that User.Purposes for the collection and use of
personal informationIn addition to the aforementioned purposes, the
Company may collect and use personal information for the following
- Provide personalized Services or information requested by Users;
- Communicate with Users as part of the Company's activities, for internal quality assurance purposes or to manage the quality of the information provided;
- Detect and prevent fraud;
- For statistical and accounting purposes;
- Inform Users of news, updates, information and special offers regarding the Company's Services, in accordance with so-called anti-spam laws;
- If the Company has reasonable grounds to believe that they may be useful in the investigation of an offence under a federal, provincial or foreign law, or to ensure the protection or defence of a legal interest;
- As required or permitted by law.
Retention of Personal Information
The Company retains the personal information it collects for as long as it is necessary for the conduct of its business and for the fulfillment of the identified purposes, as long as it is reasonable to do so for customer service, legal or commercial purposes. The retention period depends on the Services and the nature of this information. Upon the expiration of this period, the information will be destroyed, deleted or anonymized.
Disclosure of Personal Information
The Company undertakes not to make public, sell, rent or share Users' personal information to anyone, except to the extent permitted by this Policy.
The Company will only communicate personal information about Users to third parties in the following cases:
- The User has expressly authorized the Company to communicate the information provided for a specific purpose;
- The third parties in question act on behalf of the Company as agents or service providers, and the information is disclosed to them solely for the purpose of assisting the Company in the provision of Services, it being understood that these third parties must comply with strict contractual conditions that require them to maintain the confidentiality of all information and to use it only for purposes related to the provision of the Services of the Society;
- If a person acts as a representative of the User or if the Company reasonably believes that the person is acting under an appropriate authorization (e.g. guardian, holder of parental authority, etc.) or if it is a person who holds a Service jointly with the User;
- In accordance with the conditions applicable to a Service of the Company, to facilitate the provision of the Service, in particular to meet legal requirements;
- If the Company is required to provide personal information in response to a proper court order, a subpoena to produce documents, an investigation by the authorities, or when otherwise required by law;
- the Company also reserves the right to report to law enforcement authorities any activity that the Company believes, in good faith, to be illegal;
- the Company may disclose certain personal information when it considers such disclosure reasonably necessary to protect the rights, property and safety of third parties as well as those of the Company or to ensure compliance with Users' obligations to the Company;
- If the Company ever sells its business or assets, in whole or in part, or merges, as required by such a transaction, as well as as part of due diligence.
Protection and Accuracy of Personal Information
The Company treats Users' personal information seriously.
Only authorized personnel of the Company have access to Users' personal information. These employees are informed by the Company of their obligation to maintain the confidentiality of this personal information. Employees of the Company who have access to personal information may only use it in accordance with the principles set out in this Policy and applicable laws and regulations.
The security and protection of personal information are important to the Company. The Company takes reasonable technical, contractual, administrative and physical measures to protect Users' personal information against unauthorized use or disclosure as well as loss or theft, including through secure exchange encryption, when required. While it is impossible to guarantee 100% protection, the Company has adopted rigorous methods that meet strict security standards to ensure the protection of personal information.
The Company also restricts access to Users' personal information to employees, contractors and agents whose work or duties so require.
Depending on the nature of the personal information, it may be stored at the Company's offices, in various computer systems of the Company or its service providers, or in the storage facilities of the Company or its service providers.
The Company will ensure that Users' personal information is as accurate, complete and up-to-date as possible for the purposes for which it is used. However, it is the User's responsibility to ensure that his/her personal information, such as contact information, is updated with the Company.
Access to And Changes to Personal Information
Users may have access to their own personal information in order to consult, update or rectify it by communicating in writing with the Company's Privacy Officer by email or by mail at the contact details below.
Any such request must contain sufficient details for the Company to process. The Company undertakes to respond to any such request within a reasonable time and, as far as possible, within a maximum period of thirty (30) days. However, the Company must first verify the identity of the person making such a request.
The Company may refuse in writing access to or modification of a User's personal information for serious reasons, such as the exorbitant cost of providing the information, the fact that the personal information contains information about other individuals, the existence of legal, security or commercial and proprietary reasons and the fact that the information is protected by professional secrecy or in the course of a judicial nature.
The Company may charge a fee for the transcription, reproduction or transmission of a User's personal information and will notify the User in advance.
Collection of Additional Personal Information Through the Services
In the course of operating its Online Services, the Company may collect additional personal information (the " Online Information ") about the use of the Services, and this Policy applies to such online information with necessary modifications. Aggregate information, such as demographic statistics about Users, the number of Users and the average time to use the Services is also considered online information.
The Company collects or obtains information online in connection with the operation of the Services. For example, when a User chooses to use a Service, the Service may automatically collect online information that is provided through analytical tools or digital markers. These analytical tools collect only a limited set of data, including the time and date a Service was used, as well as the IP address. A Service may also include analytical tools placed by partner advertisers or service providers to help the Company evaluate the effectiveness of the Services, including Google Analytics, Google Marketing Platform and Google Ad Manager.
Google Analytics is a web analytics service offered by Google that tracks and reports traffic on a website. Google uses the online information collected to track the use of the Services and to personalize ads. You may choose not to allow Google Analytics to use your online information, for example by installing the Google Analytics Opt-Out Browser Add-on available at: https://tools.google.com/dlpage/gaoptout. For more information about Google's privacy practices, visit https://policies.google.com/technologies/partner-sites
In addition to what is already provided for in this Policy with regard to personal information, the Company uses online information to track the use of the Services and improve their operation, personalize the user experience, in particular by offering personalized ads and offers, perform statistical analyses on all the characteristics and behaviors of Users, measure the demographic variables and interest of Users in specific services, describe its services to third parties and potential business partners, and determine how and where the allocation of the Company's resources can be most effective. No personal information is disclosed in connection with such activities.
This online information is necessary for the Company to collect the information required to count the number of Users, the features or aspects of the Services most used, the technology used by users of the Services, referencing sites and the location of Users.
Cookie records stored on a User's hard drive are harmless and can be read and deleted at any time. Thus, the User has absolute control over it. This information makes it possible to know the total number of visitors to each website as well as the duration of the visits. When a User visits the website, a cookie is created and stored on their computer, which allows the Company to "recognize" them each time they visit the website.
The Company processes and stores personal information using the servers of its service providers located in Canada.
If you are located outside of Canada, your personal information and other information that the Company collects may be transferred to Canada for the purposes described above. By accepting this Policy, using the Company's Services or providing your personal information to the Company, you agree to the transfer of such information to Canada.
Links to Third Party Websites, Third Party Mobile Applications and Third Party Social Media
The Company may use social media (e.g., Facebook and Twitter) in addition to operating the Services. Social media accounts are public and are not hosted by the Company. Users who decide to interact with the Company through these social media should therefore read the terms of service and privacy policies of these third-party service providers and the applications used to access them.
Personal information that is provided to the Company through social media accounts is collected in order to capture conversations (e.g. questions and answers, comments, "likes", shared tweets) between a User and the Company. They may be used to respond to requests, perform statistical evaluations as well as for reporting purposes and for all other purposes set out in this Policy.
Children under the age of 18
The Company takes special precautions to comply with applicable laws regarding children's privacy and advertising. The Services are intended for a general audience and not for children under the age of 18. The Company does not seek to collect personal information from children under the age of 18 without the verified consent of parental authority holders or otherwise as permitted by law. If, however, you believe that the Company is doing so, please let us know.
Questions, comments, suggestions or complaints
If you have any questions, comments or suggestions about this Policy or the Company's privacy practices that are not addressed in this Policy, you may contact the Company's Privacy Officer in writing by email or mail at the contact information below. You may file a complaint with the Company's Privacy Officer if you believe that the Company is not complying with its obligations to protect confidential information. The Company will investigate such a complaint and if warranted, will take appropriate steps to correct the situation. If you are not satisfied with this internal review of your complaint, you can contact the Commission d'accès à l'information du Québec or the Office of the Privacy Commissioner of Canada.
How to contact the Privacy Officer
The Company is responsible for the personal information under its control and has designated a Privacy Officer who is responsible for this Policy and for compliance with Canadian and other applicable privacy and data protection laws. If you have any questions about your personal information or the Company's privacy practices, please contact our Privacy Officer at the contact information below.
Users may contact us to ask us to delete their personal information from our systems or to request access to or correction of their personal information. We will endeavor to respond to such requests to the extent possible. If all of this information is deleted from our systems, your account may be deactivated. In any case, we may keep an archival copy of your records, in accordance with the law or for legitimate business purposes.
The Privacy Officer can be contacted at the following address:
Canada Inc. Attention: Privacy Officer 11908537 Canada Inc.
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