The following sets out the manner in which we collect, use and disclose Personal Information (as defined below), including through our website (the “Website”).
1. PERSONAL INFORMATION WE COLLECT
“Personal Information” is information about an identifiable individual. Personal Information that the Company may collect from you may include the following:
- your name, email address and phone number;
- information about your use of the products and services we provide to you;
- customer relationship information such as customer requests and feedback and other information you provide, such as report a problem with our Website or if you receive customer support; and
- information contained in any communication you send to us; such correspondence data may include the content of the communication and the metadata associated with the communication generated by our Website using our Website’s contact forms.
In order to recruit potential job candidates we may also collect:
- resume information, such as your employment history, clients lists, academic history and transcripts;
- cover letter information, such as your skills, personal life experience and work experience; and
- remuneration information, such as previous or expected salary, benefits and bonuses.
2. WHY DO WE COLLECT PERSONAL INFORMATION
We collect Personal Information to enable us to provide, manage and develop our business and operations, including:
- to establish, maintain and manage relations with you so that we may provide you with the products and services that have been requested (for example, we will use your Personal Information to determine your suitability for a position);
- to review the services we provide to you so that we may understand your requirements and improve our services;
- to inform you of services other than those you have specifically requested such as information promoting our other services;
- to comply with your requests (for example, if you prefer to be contacted at a business or residential phone number and advise us of your preference, we will use this information for that purpose);
- to protect us against error, fraud, theft and damage to our property and goods;
- to comply with applicable law or regulatory requirements; and
- as otherwise permitted by law.
3. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We use your Personal Information to:
- identify you;
- understand your qualifications, needs and preferences, in the case of a job applicant;
- process and respond to your application for current and future career opportunities;
- respond to your inquiries, comments or requests;
- in order to facilitate the operation or maintenance of our Website, our services, our operations and internal record keeping.
4. HOW WE PROTECT THE PERSONAL INFORMATION
The Company is committed to ensuring to maintain all reasonable physical, technical and procedural safeguards to protect your Personal Information against unauthorized access, use, modification and disclosure, whether electronically or on paper.
For example, our electronic files are protected by passwords and are accessible only to authorized employees who need it to carry out their respective duties. In addition, the information is kept safely in filing cabinets and protected against unauthorized access.
However, we cannot guarantee that our security measures can prevent third parties (“hackers”) from obtaining and accessing the Personal Information we keep.
5. HOW WE DISCLOSE THE PERSONAL INFORMATION
Further to the foregoing uses, your Personal Information may also be shared with the Company’ employees, agents, representatives and selected third-party service providers in Canada and the United States (“US”) who require this information to perform services on our behalf in connection with hosting or the operation of our Website, or to facilitate reporting of analytics. These parties will be under an obligation to the Company to use reasonable care to keep this information confidential and are prohibited from using your Personal Information for any purpose other than in connection with the service they provide to us.
The Company reserves the right to transfer your Personal Information to a third party in the event of a transfer of all or substantially all of its assets to a third party (including transfers made as part of insolvency or bankruptcy proceedings) or as part of a corporate reorganization or change in corporate control.
The Company and our Canadian and American service providers may disclose your Personal Information without your consent if compelled to do so by a court or body with jurisdiction to compel the production of information or by regulatory requirements, to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian or US law. We may also disclose Personal Information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons and property.
6. WEBSITE INFORMATION WE COLLECT
In general, you can visit our Website without telling us who you are or submitting any Personal Information. We may collect information that does not identify you personally, but is linked to your computer or device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of operating our Website. When you visit our Website to browse, read or download information, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We may also collect information about your mobile device such as the type and model, operating system (e.g. iOS or Android), carrier name, mobile browser (e.g. Chrome, Safari), applications using our Website, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID.
Location Information: We may also collect your location information, such as your zip code or the approximate geographic area provided by your Internet service provider (“ISP”) or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled. We use this information to help us understand our Website activity, and to monitor and improve our Website.
Tracer Tags & Web Beacons: Our Website may also use a technology called”tracer tags” or”Web beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.
7. YOUR RIGHTS
You have the right to access, update, object to our processing of your Personal Information, correct inaccuracies and request erasure of your Personal Information in our custody and control, subject to certain exceptions prescribed by law. You may object to our processing, request access, updating, corrections of inaccuracies or erasure of Personal Information we have in our custody or control by writing to us at the contact information set out below or sending an e-mail message to our Privacy Officer (see Section 12) explaining your request and provide any relevant confirmation or reference number. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.
You also have the legal right to file a complaint with a supervisory authority responsible for data protection if you consider that our processing of your Personal Information infringes data protection laws.
8. LINKS TO THIRD-PARTY WEBSITES
9. ACCEPTANCE AND CONSENT
Your consent is important to us. Depending on the sensitivity of the Personal Information, your consent may be express or implied. Express consent may be given orally, electronically, or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, if you submit a resume or Personal Information by email, fax or mail in response to an advertisement, we will assume your consent to the collection, use and disclosure of your Personal Information related to your recruitment and placement by the Company.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice by contacting the Company using the contact information below. In some circumstances, a change or withdrawal of consent may limit our ability to provide services to you.
10. WRITTEN DOCUMENT
You can keep this Policy for your records by printing the document. The most recent version will however at all times be posted on our Website.
The Company further undertakes to comply with the Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents Act and the Telecommunications Act (the “Canada Anti-Spam Act”) in providing its services to you.
12. CONTACT INFORMATION
C/O Privacy Officer, Legal Department
1470 Peel Street, Tower B, Suite 720
Montreal, Quebec H3A 1T1
Email : [email protected]