Privacy Policy

PRIVACY POLICY AND PROTECTION OF PERSONAL INFORMATION OF SIGNEL SERVICES INC.
(the “Policy”)

1. INTRODUCTION

The respect of your privacy and the protection of your Personal Information are the utmost importance for SIGNEL SERVICES INC., its subsidiaries and management companies (“Signel”, “our”, “we”, “us”). Therefore, we have implemented this Policy that manages collection, use, disclosure, retention, and disposal of Personal Information, whether they were collected through technological means or not. This Policy also describes the way that we protect Personal Information and the established process to deal with complaints.

2. APPLICATION AND INTERPRETATIONS

This Policy applies to Signel, which particularly includes, its directors, employees, consultants, and any other person who formerly provided beneficial services from Signel.

It covers the Personal Information of clients (potential, current or formerly), people visiting the Site of Signel accessible through www.signel.ca (the “Site”) and any other physical person who would communicate personal information to Signel.

For the purpose hereof and as defined by the Act respecting the protection of personal information in the private sector (“Act”), a Personal Information is an information that concerns a physical person and allows, directly or indirectly, to identify them. For example, it could be a first and last name, mailing address, email address, phone number, gender, bank information, personal health information, ethnicity, language, information relative to the use of our website including technical information about the visits or any other information collected through cookies (“Cookies”) and any other Personal Information that you deem useful to provide us (“Personal Information”).

Not considered as Personal Information professional or business contact details of a person nor personal information of a public nature.

WHEN PROVIDING PERSONAL INFORMATION TO SIGNEL OR THEIR PROVIDERS, BY INTERMEDIARY OF OUR SITE, BY PHONE, BY EMAIL, IN PERSON OR ANY OTHER MEANS, YOU CONSENT THAT YOUR PERSONAL INFORMATION IS COLLECTED, USED, DISCLOSED, RETAINED, DISPOSED AS EXPECTED BY THE PRESENT POLICY.

3. CONSENT, COLLECTION, USE, AND DISCLOSURE

3.1. Consent

As a rule, Signel directly obtains Personal Information from you and with your consent, subject to exemptions according to the Law. Personal Information is only used for the purposes they were collected for unless your consent was given.

If you consent to it or when allowed by the law, Signel can also collect Personal Information from a third party.

Signel will not collect, use, or disclose Personal Information without your consent unless it was authorized or obligated to do it in accordance with the Law.

It should be noted that you have the right to refuse to communicate with us Personal information. You also have the right, with reservation of a reasonable advance notice and relevant legal restrictions, to withdraw your consent concerning the use of Personal Information that was already collected by communicating with the Privacy Policy Officer with the coordinates in clause 15. However, it is worth noting that refusing to disclose information or the withdrawal of your consent could prevent us from providing or continue to provide our services or information on them.

IMPORTANT: If you provide us Personal Information concerning another person, you are declaring that you have the authorization to do so and, when necessary, that you have the consent needed, and you recognized that this information can be used in accordance with this Policy.

3.2. Collection and Use

Without restricting the importance of what follows, Signel will collect and use Personal Information for the intended use determined at the time the information was collected in accordance with the Law. The collection will be limited to information that is necessary to the determined use. You will find below, a non exhaustive list of information that Signel can collect. Except for Personal Information of certain clients and those that can be collected by using our Site, most of the information collected by Signel is information of professional nature.

3.2.1. Use of Our Site or interaction with us by Email

When you navigate on our Site or interact with us via email, we can collect information about you as described below, some of which is collected automatically:

• When you make a request for information, we can collect information about you. Such as your first and last name, phone number, email, your specific request, and any other information or document you deem useful to convey.
• When you create an online client account, we can collect information concerning you. Such as your first and last name, phone number and the password to access your account. It should be noted that the creation of an account is mainly intended for enterprises, but it is still possible to create one for personal use.
• Connection data, which may include your IP address, the pages you visit on the Site, the date and time of your visit to the Site, the address of the web page you visited before using the Site, the URL that directed you to our Site, the type of setting of your browser, information about your device (such as brand, model, and operating system), browser configuration information, language preferences, unique identifiers, and cookies.
• Data usage and analysis that can include login frequency, the functions you used, the duration and the moment of use, as well as the different types of activities undertook by the user.
• If you wish to have additional information about our services, use our functions, signup for an event, a webinar or a contest, or download certain content, we can ask that you provide your coordinates. Such as your first and last name, phone number and email, as well as certain information about your needs or preferences.
• Customer support inquiries, general comments that you choose to provide.
• Any other Personal Information provided.

This information is collected to help us to know more about your needs, preferences and interactions with our Site and the services offered, make statistics, market research and performance to help us evaluate our Site and our services, measuring our performances and improve the experiences and services we offer. They also allow you to identify yourself to access your account when you create one.

3.2.2. Clients (Potential, Current, or former)

When you inquire for information about our products and services, request a submission and/or buy our products, we cam collect your information as described below:

• Your first and last name, postal address, phone number, email, bank information, language and any other information deemed relevant.

This information is collected to:

• Manage your file and communicate with you and maintain your client account.
• Process payment.
• Send information concerning various products and service or information that you have asked for or to answer your requests and questions.
• Communicate with you (by telephone, an alert, an email, mail or other) and present to you advertising materials and additional information about out services, products, surveys, contests, promotions, and special offers, along with our customer service.

Create statistics, market research and performance to help us evaluate our services, measure our performance, and improve the experiences and our services we offer.

3.2.3. Survey, events, and information marketing

If you choose to participate in our surveys, contests, events, and request information, we can collect your information in relation with the survey, contests, the information request, or event. Notably your first and last name, email, phone number and general information you choose to provide. We may also use your Personal Information for marketing needs.

3.2.4. Phone calls

If you communicate with us by telephone, we can record the call and request you provide us with your coordinates. Such as your first and last name, address, phone number and email. This information is used to identify you so we can serve you better.

3.2.5. Visits to our Office

If you visit our office, you may be asked to sign in as a visitor and provide your first and last name, email, phone number and the hour and date of your arrival and departure. This information is colligated for security reasons. So, we know the coming and going in our office.

3.3. Communication

Signel limits their communication and disclosure of your Personal Information for any other purposes other than those that were previously mentioned, but please note the following specification and exception:

3.3.1 In accordance with the law

We can share your Personal Information to answer demands in accordance with the law, orders from the court or any other legal procedure or if we judge that a disclosure is necessary for an investigation, prevention or answer to illegal activities, frauds, threat of physical assault or as required by any other applicable law or regulations and to the extent necessary to protect the property, interests and rights of Signel.

3.3.2 Archival service

We may share your Personal Information with a company engaged in document retentions for general information value.

3.3.3. Our employees and authorized service providers

Our employees can have access to your Personal Information with the goal to help us to provide you with our services. Authorized Personnel access and use this Personal Information in accordance with our instructions, only if they need to know such information, and under strict confidentiality and security obligations. Please be aware that we ensure that our employees handle this information with full discretion and diligence and comply with this Policy and applicable legal and regulatory requirements.

When you communicate Personal Information with Signel, you grant us permission to share your Personal Information with authorized service providers that we judged acceptable and will use this information to help us answer your demands and perform our services. Please note that we will only share the necessary Personal Information for the use of these third-party services, only with the goal to provide you with our services, and we ensure that these authorized providers accept to keep this information confidential and secure. The service providers retain the information they need to accomplish the functions for which they were nominated for, and we do not authorize these third parties to use or disclose your Personal Information for their own marketing or other purposes.

3.3.4. Business transaction

Signel could be involve (1) in a sale or lease of all or substantially all its business and/or assets that they own, (2) changes in its legal structure through merge or otherwise, (3) in a transaction to obtain a loan or any other form of finance and (4) any other similar transactions (individually or collectively the “Transaction”). In connection with this Transaction, we may assign or disclose your Personal Information to the current or potential contracting organization, but we will require this organization to agree to protect the confidentiality of your Personal Information in a manner consistent with this Policy.

3.3.5. Statistics and aggregated reports

We can use Personal Information in a depersonalize for. For example, for statistics purposes, analysis, calibration, management, and quality improvement in relation to the website and the services it offers, or for development or providing other products and services by Signel or for the benefice for all general users of the website.

3.3.6. Explicit consent

Signel may also disclose your Personal information if you request it or expressly consent to it.

4. YOUR PERSONAL INFORMATION AND THIRD-PARTY SITES

Our Site may reference links that lead to third-party sites. These third-party sites (“Third Party Sites”), which are only provided for your convenience, are not under our control and may be governed by their own privacy policies. Signel do not guarantee and is not responsible for the collection, use, retention, or disclosure of your Personal Information. Signel bears absolutely no responsibility regarding your use of these third-party sites or the access to these third-party sites by the intermediary of our Site, you exempt Signel of all responsibility regarding any actions, use or omissions of these third-party sites.

5. TRANSFER OF PERSONAL INFORMATION ABROAD

It may be possible that in the future, we hire third party service providers to process, manage and host Personal Information for our account that can be located abroad. Therefore, it is possible that certain of your Personal Information be transferred in another jurisdiction and they are submitted to the laws of that jurisdiction.

However, we ensure the protection of Personal Information in our care, including Personal Information entrusted to a service provider that are either located in Quebec or abroad. Our policy and practice in relation to the protection of Personal Information requires a written commitment signed by the service provider to respect their obligation to maintain de confidentiality and security of Personal Information entrusted to them. This notably includes to implement robust and efficient security measures, but also the prohibition to disclose, transfer or use your Personal Information to others in accordance with applicable legislation in the province of Quebec regarding the Protection of Personal Information.

6. PROTECTION OF PERSONAL INFORMATION

We take the appropriate measure to ensure the confidentiality of Personal information and to protect Personal Information against the loss, and non authorized access, disclosure, copy, use or modification, considering the sensitive information and the purpose they are meant for.

Signel uses physical, electronique procedures and commercially reasonable and appropriate management and the general standards accepted in the industrie to save and secure Personal information we collect.

Furthermore, Personal Information we possess is only accessible to individuals who are authorized to access and consult it, when necessary, in the performance of their duties.

For this purpose, we ensure that access to our offices and our computer equipment is restricted, to train our employees, and our agents and service providers with access to Personal Information to sign multiple agreements of confidentiality and to implement equivalent security measures.

However, please note that no mechanism offers a maximum security; particularly the use of the internet to transmit, create or host Personal Information always have a certain risk.

If you believe that your Personal information has been compromised, we invite you to contact our Privacy Policy Officer at the contact information in clause 15 of this Policy.

7. MINORS

Signel does not knowingly collect Personal information of people under the age of 18 years old.

If a minor under the age of 14 years old wishes to use our Site, our services or contact us, the collection of Personal Information of this minor can not occur without the consent of the holder of parental authority or legal guardian. If we learn that we unknowingly collected Personal Information of a person under the age of 14 years old, without obtaining the consent of parental authority or legal guardian, we will make sure the information is deleted from our files as quickly as possible. If you are the holder of parental authority or the legal guardian of a minor under the age of 14 and you are aware that your minor child provided Personal Information, we invite you to contact our Privacy Policy Officer at the contact information in clause 15 in this policy, so we can take the necessary actions.

8. RETENTION PERIOD

Except for non-identifiable and anonymized information, which we may retain indefinitely and in any reasonable location, Signel can host and retain your Personal Information for a necessary duration for the purposes set out in this Policy and to ensure compliance with our legal obligation and regulatory obligation.

If you wish to learn more about the benefits of the retention period of your Personal information, we invite you to contact Privacy Policy Officer at the contact information provided in clause 15 of this Policy.

9. ACCESS, CORRECTION, PERSONAL INFORMATION UPDATE AND WITHDRAWAL OF CONSENT

Your have the right to access your Personal Information and obtain copies. You are also entitled to update, correct any Personal Information that you deem inaccurate or incomplete. You can also demand a termination of the circulation of your Personal Information or de-index any hyperlink to your name that allows access for this Personal Information by technological means when the circulation infringes the law or court order. You can even request that the hyperlink to your Personal Information be reindexed, when certain conditions provided by the law is reunited.

To do so, please submit a written request for this purpose and send it to the Privacy Policy Officer contact information provided in clause 15 of this Policy, who will give you a written response within a period of 30 days from the reception date.

If you wish to obtain copies of your Personal information, it is possible we ask you to pay a minimum cost, which will be pre-emptively disclosed to you. This cost simply covers the transcription, the reproduction and/or the transmission.

Subject to legal restriction and contractual, if applicable, you can at any time withdraw your consent for the use or communication of your collected Personal information.

10. ELECTRONIC COMMUNICATION (EMAILS)

Your email address can be used to sometime send you messages or send you advertising material or documents about service, which could interest you. At any time, you may request us to stop sending you these messages by contacting our Privacy Policy Officer to the contact information provided in clause 15 of this Policy or follow the “unsubscribe” instructions located at the bottom of these communications, when applicable.

11. COOKIES AND OTHER TRACKING TECHNOLOGIES ON OUT SITE, THROUGH OUR SERVICES, AND IN EMAIL COMMUNICATION

We use common information collection tools, such as usage data, cookies (“cookies”), and similar technologies, to automatically collect information that may contain Persona Information from your computer or mobile phone when your browse our Site or interact with emails we have sent you.

By accessing and browsing our Site, you consent to the use of cookies in accordance with the terms of this Policy. You can control and manage cookies in various ways. Please note that deleting or blocking cookies may negatively impact your user experience, and certain parts of our Site may not longer be fully accessible. During your first visit to our Site, a window concerning the management of cookies will display itself and you will have options relative to the collection of these cookies. Afterwards, you will always have the possibility to change your initial choices through the settings of your browser, often found in the “Tools” or “Preferences” menu.

12. CHANGES TO THIS POLICY

Signel reserve the right to make changes to this Policy at any time. These changes will be posted on the Site and will take effect immediately upon posting. We will take reasonable steps, if necessary, to inform users of the Site and our services of any significant changes.

You can contact our Privacy Policy Officer at the contact information provided in clause 15 of this Policy to obtain an up-to-date copy of the Policy.

13. TERMS OF USE OF THE SITE AND SERVICES

The terms of use of the Site and Services contain important provisions that disclaim and exclude the liability of Signel and other persons regarding your use of the Site and Services, as well as provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute regarding your use of the Site and Services. Each of these provisions also applies to any dispute that may arise in connection with this Policy and the collection, use, storage, and disclosure of your Personal Information, and they have the same force and effects as if they had been reproduced verbatim in this Policy.

14. PROCESSING COMPLAINTS

14.1. Field of application

This process applies to Personal Information that Signel possess and all persons who handle this information.

14.2. Confidential processing of complaints

In the subject of processing these complaints, Signel commits to respecting the confidentiality and ensure the protection of Personal Information they possess for the entirety of its life cycle, from the collection all the way to its disposal.

All complaints are confidentially processed. Only the necessary information for the process of the complaint will only be shared among the staff of Signel who needs to be aware to be able to perform their duties.

14.3. Receipt of the complaint

All complains about the managed of Personal Information must be submitted in writing, addressed to the Privacy Policy Officer by email at confidentialité@signel.ca .

Any employee who receives a complaint must immediately inform the Privacy Policy Officer.

14.4. Admissibility of a complaint

For the complaint to be admissible, it must respect the following criteria:

• It was submitted by a physical person;
• It concerns a dissatisfaction in relation to a practice, action or inaction from Signel about the management of Personal Information they possess;
• It has the following elements:
  • Last name, first name and coordinates of the person concerned;
  • A description with sufficient precision of the problematic situation; and
  • One or more corrective measure desired, when applicable.

Complaints that are anonymous, improper, frivolous, defamatory, have hateful elements, without any foundation or does not have the necessary information about the complaint itself, can be rejected. However, a piece of justification must be provided to the person concerned.

14.5. Investigation and analysis of the complaint

A separate file will be created for each complaint received, when applicable. The file will have the complaint, the analysis and all documentation that support its evaluation, along with the answer sent to the concerned person.

The Privacy Policy Officer will conduct an extensive investigation by collecting proof, interrogating the concerned parties and gather all documentation.

The Privacy Policy Officer must be impartial and have the necessary authority to resolve the complaint.

14.6. Resolution of the complaint

14.6.1. Inadmissible complaint

The Privacy Policy Officer will inform in writing the person concerned when their complaint is inadmissible. The letter will precise why the complaint is inadmissible.

14.6.2. Determining the merits of a complaint

Once the complaint is admissible, the Privacy Policy Officer will process the complaint. After analyzing it and gather the relevant information, they will determine if the complaint is well-founded.

A complaint is unfounded when the Privacy Policy Officer concludes a mistake or a missing link with the laws, rules or policies concerning the management of the Protection of Personal Information by Signel.

If the complaint is well-founded, the Privacy Policy Officer will offer corrective measures or interventions that will be done as soon as possible.

A complaint made under this procedure does not entitle the person concerned to financial compensation.

14.7. Processing period of a complaint

Signel has a processing time of 30 days to analyse each complaint.

Signel commits to use all reasonable efforts to process each complaint within the 30 days time. However, if the complaint can not be processed within this period, the person concerned will be informed of the reason to extend the deadline, the status of your complaint and the reasonable time needed to be able to provide a definitive answer.

14.8. Messages with the person concerned

The Privacy Policy Officer regularly communicate with the person concerned to keep them informed of the progress of the investigation and resolution of the complaint.

All communication must be professional, empathetic, and respectful.

14.9. Closing of a complaint

Once the complaint is resolve, all information and documents related to the complaint must be retained in a confidential file where only the Privacy Policy Officer can access.

The Privacy Policy Officer must regularly maintain and update the complaints registry relating to the Protection of Personal Information.

You also have the possibility to place a written complaint to the Access to Information Commission – Surveillance department at the following address cai.communications@cai.gouv.qc.ca. However, we invite all interested parties to contact the Privacy Policy Officer beforehand and wait for the end of the process of the complaint by Signel.

15. QUESTIONS, COMMENTS, AND PRIVACY POLICY OFFICER

Signel is responsible for the Personal Information under its custody or control, and has designated and responsible to ensure compliance with this Policy and applicable privacy laws.

If you have any question, comments, concerns, or complaints about this Policy and Signel’s privacy practices, we invite you to contact our Privacy Policy Officer at the following coordinates:

M. Eric St-Denis
Privacy Policy Officer
700 Mnt Monette
Saint-Mathieu (Québec) J0L 2H0
confidentialite@signel.ca

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