CORACTIVE HIGH-TECH INC. NOTICE REGARDING THE PROTECTION OF PERSONAL INFORMATION

3. PRIVACY OFFICER AND CONTROL AUTHORITIES

3.1          Responsibility
Coractive is responsible for the Personal Information it deals with and has appointed a Personal Information Privacy Officer the (“PIPO”) who will ensure that Coractive will comply with protection of privacy legislation.

3.1.1      Coractive Privacy Officer Contact Information:
Coractive High-Tech Inc.

C/O Gisèle Chouinard
4680 Michelet Street
Québec City, Québec G1P 0B5

Phone.: 418 845-2466
Email: confidentialite@coractive.com

3.1.2   Privacy Officer Contact Information:
Gisèle Chouinard 
4680 Michelet Street
Québec City, Québec G1P 0B5

Phone.: 418 845-2466
Email: confidentialite@coractive.com

3.2   Control Authorities
You may file a complaint at any time with a Control Authority:

In Canada:

a)   In certain circumstances if you submit your Personal Information when you are located in Quebec: to the Commission d’accès à l’information du Québec (https://www.cai.gouv.qc.ca); [Acces to Information Commission]
b)   In certain circumstances if you submit your Personal Information when you are located in Alberta: Office of the Information and Privacy Commissioner, (https://www.oipc.ab.ca/);
c)    In certain circumstances if you submit your Personal Information when you are located in British Columbia: Office of the Information and Privacy Commissioner (https://www.oipc.bc.ca/);
d)    If you submit your Personal Information when you are located elsewhere in Canada: to the: Commission d’accès à l’information (www.cai.gouv.qc.ca) or to the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca/), depending on the applicable circumstances;

Other Jurisdictions:
a)  If you submit your Personal Information when you are located in the European Economic Area, (EEA): to a Control Authority in this area such as the CNIL (www.cnil.fr) or to the Data Protection Commission of Ireland (www.dataprotection.ie), for example;
b)  If you submit your Personal Information when you are located in Switzerland: by a judicial procedure pursuant to articles 28, 28a and 28I of the Swiss Civil Code;
c)   If you submit your personal Information when you are located in the United Kingdom: to the Information Commissioner’s Office (https://ici.org.uk/); et
d)  If you submit your personal information when you are elsewhere in the world and if the control authority in that area does not have jurisdiction: to the  Commission d’accès à l’information (www.cai.gouv.qc.ca).

We do appreciate however having a chance to answer your questions or to discuss your problem before you contact such a control authority. We would appreciate it if you would first contact us.

4.  PERSONAL INFORMATION COLLECTED BY CORACTIVE OR WHICH YOU SUPPLY TO US

We limit our collection of Personal Information to the information required to allow you to access and use the Website as well as for the purposes described in more detail in section 6 herein.

Coractive gathers and handles the following Personal Information:

4.1 Identity and contact information. Your first name, family name and email address with which you want to contact us through our website, or to subscribe to our information bulletins and in some cases, your organization’s name, your title, city, telephone number and country.
4.2 Commercial Information.
Personal Information supplied in a contract relationship or in the client relationship between you and Coractive.

4.3 User Information.
 Information about how you use the Website, including the display language, the services you consulted or searched for, the page answer time, downloading errors, duration of visits and information concerning interaction with pages (namely scrolling, clicks and mouse action), which are all dealt with by using cookies. For more information about our use of cookies or similar technology, please read our Notice Concerning Cookies).

4.4 Technical Information.
 Information collected during your visits of our Website. This information includes your Internet Protocol Address (IP), your location data, your connection data and web journals, referred Internet addresses, other communication data, research conducted, pages visited, the time and date when you logged on, your linguistic preferences, the browsers you use and their versions, the types and additional browser modules, type of device, time zone parameters, operating system and the platforms your devices use when you browse or connect and use the Website. In addition, to facilitate your use of the Website or for future communications, Coractive or its service suppliers may use cookies to gather information regarding the Internet connection and how and when you visit the Website. For more information about our use of cookies or similar technology, please read our Notice Concerning Cookies). 

4.5 Marketing Information.
 Your preferences for receiving marketing emails or other marketing tools sent through the Website, third party marketing tools and your communication preferences. This information may be linked to your personal identity.

4.6 Special Sensitive Personal Information.
 We usually do not deal with any Personal Information concerning your racial or ethnic origin, your political opinions, religious beliefs, trade union activities, your physical or mental health, your sex life and your sexual orientation or details concerning criminal offences, genetic or biometric data, but if you do mention such information on our Website, we will deal with it pursuant to this Notice.

5. THIRD PARTY INFORMATION, NON-PERSONAL INFORMATION AND THIRD PARTY LINKS;

Coractive would like to notify you about the following:

5.1 Third Party Personal Information.
 If you disclose to us Personal Information about any other physical persons, you must ensure that they understand the use that will be made of their Personal Information and that they authorized you to disclose such to us and to allow our suppliers to use it.  Before disclosing this information to us, you must, pursuant to this Notice, obtain the free and informed consent of each person regarding the disclosure of his/her Personal Information and the future use Coractive may make of that Personal Information, unless permitted otherwise by law.

5.2 Non-Personal Information.
 Some information mentioned in section 4 is not Personal Information when it does not allow you to be identified directly or together with other information. As a precautionary measure, Coractive may deal with this information as it if was Personal Information, but it shall have the right not to do so.

5.3 Third Party Links.
 The Website may contain links to other websites, plugins and third party applications. By clicking on these links or by authorizing these connections, you may allow third parties to collect or share Personal Information about you. We have no control over this and we are not responsible for the third party protection of privacy notices or policies. When you leave the Website to use these features, we encourage you to read the notices or policies regarding the protection of Personal Information governing them.

6. USE MADE OF PERSONAL INFORMATION

In general, we collect your Personal Information to give access to the Website and to inform you about our business, products and services. Coractive will collect, use communicate or otherwise deal with this information only to the extent required for these purposes. If Coractive were to use, communicate or otherwise deal with the Personal Information of a Person Concerned, for purposes other than those mentioned in this Notice, we will obtain your consent before using, communicating or otherwise dealing with this information, except in circumstances mentioned in section 10 of the Notice.

More specifically, Coractive will collect Personal Information as permitted by law, to:

Coractive will give you only marketing information if you have, when required by law, chosen to receive this type of communication or if you may choose at any time to no longer receive this type of information.

Coractive shall not use your Personal Information to make automated decisions concerning you.

Coractive shall not use your Personal Information for purposes other than for what they were gathered, except if the Person Concerned has consented thereto, unless:

a)    consent cannot be obtained for legal, medical or security considerations; or
b)    Coractive is authorized or required to do so under applicable legislation.

7. CIRCUMSTANCES IN WHICH PERSONAL INFORMATION MAY BE COLLECTED

The circumstances in which Coractive may collect Personal Information about you include the following:

7.1 Direct interactions.
 You may give us your Personal Information such as that regarding your identity, contacts and invoicing when you or your business:

a)   use the Website;
b)   fill out a form, make a request, interact or browse on the Website; and  
c)   contact us by phone, email or other electronic means or in writing or when you directly give us other information, namely in conversations with any member of the Coractive team when using the Website.
7.2 Automated interactions or technologies.
 While you browse on the Website or use any other part of the Website, we automatically collate your Technical Information and some of your User Information.

8. CONSEQUENCES OF A REFUSAL TO SUPPLY PERSONAL INFORMATION

When we must collate Personal Information by law or pursuant to the Conditions of Use of the Website and if you refuse to give us some of your Personal Information, it is possible that we will not be able to give you access to the complete Website or part of it. In such a case, we may have to cancel our commitment to you. You will however be advised if this situation should arise.

9. COLLECTING PERSONAL INFORMATION FROM THIRD PARTIES

Coractive will collect your Personal Information from third parties only after having obtained your consent or to the extent authorized by law.

The following are the names of our suppliers from whom we collect your Personal Information, and the type of Personal Information collected:

Supplier : Google Analytics

Types of Personal Information : Technical information, user information

Supplier : LinkedIn

Types of Personal Information : Technical information, user information

10. DISCLOSURE OF YOUR PERSONAL INFORMATION

10.1 Recipients.
Coractive may disclose your Personal Information:

a)  to the entities that are members of our group when we deliver services to you;

b)  to our service suppliers in the United States, who act as sub-contractors, who we specifically rely on concerning our Website:
     1) Zoho Corporation Pvt. Ltd. (https://zoho/privary.html);
     2) Microsoft Corporation (Office 365) (https://privacy.microsoft.com); and
     3)  Google LLC (Google Analytics) (https://policies.google.com/privacy?gl=CA&hl=fr)
    4) LinkedIn Corporation (https://fr.linkedin.com/legal/privacy-policy?)
b)  to courts, law enforcement authorities, regulatory authorities, public servants or attorneys or any other party when that is reasonably necessary to undertake, institute, or contest legal procedures, or for the purpose of an alternative dispute resolution process;
c)  for the purposes of a bankruptcy, an amalgamation, a sale, or for the transfer of some or all of Coractive’s assets, for an acquisition or for a similar transaction. If your Personal Information must be transferred to a third party for the purposes of such a transaction, we shall use reasonable efforts to notify you thereof. For example, we shall publish a notice of the transfer of Personal Information on the Website, and if we have your email address, we will send you a notice of the transfer of Personal Information to that address. In addition, we will require from the third party receiving your Personal Information in such a situation, that it agrees to protect the confidentiality of your Personal Information in compliance with this Notice and that it respect protection of privacy legislation. The third party shall deal with your Personal Information in compliance with this Notice, unless giving you prior notice, and when required by law, by obtaining your prior consent. In cases in which we deal with your Personal Information on the basis of your consent, you may withdraw your consent to prevent that third party from dealing with it; and
d)  if we consider in good faith that this measure is appropriate or necessary to avoid an infringement of our Conditions of Use of the Website or of any other agreement to which you are a party; to protect ourselves from a claim; to protect our rights, property, security, or those of a partner, of a person or of the general public; to maintain and ensure the security and integrity of the Website or of our infrastructures in connection with an abusive or illegal use. 

10.2 Restricted Authorization.
We require from any third party with whom we do business and who has access to your Personal Information, that it respect the security of your Personal Information and deal with it pursuant to law. By contract, we will allow only our service providers to deal with your Personal Information for specific uses and according to our instructions.

10.3 Application of law and communication pursuant to law.
We may disclose your Personal Information if we consider in good faith that this measure is required for the purposes of court proceedings, a warrant or any other judicial or administrative decision rendered by law.

11. COLLECTION, USE, DISCLOSURE AND ARCHIVING OUTSIDE OF QUEBEC OR CANADA

11.1 International transfers.
Coractive, its service suppliers or other third parties to whom Coractive discloses or transfers Personal Information pursuant to this Notice, may have activities outside of Canada. Any Personal Information regarding a Person Concerned that is used, archived, or consulted in foreign countries or in provinces other than Quebec may be subject to the laws of those countries or other provinces (for example, when a service supplier pursues activities on a global scale). Accordingly, Personal Information may be disclosed following valid demands or requirements of government authorities, courts or law enforcement authorities in other provinces or in foreign countries.

11.2 Requirements regarding servers.
We demand that our service suppliers and any third parties to whom we disclose your Personal Information deal with such only in Canada, except for the following Personal Information which is dealt with in the United States by the following service providers:

a)  Google LLC (Google Analytics);
b)  Microsoft Corporation (Office 365); 
c)  Zoho Corporation Pvt. Ltd; and
d) LinkedIn Corporation.

11.3 First location of processing.
Some of our service providers are based outside of Quebec, Canada and the EEA-U. Accordingly, their processing or your Personal Information will be done outside of those jurisdictions. Nevertheless, such processing is not a transfer of your Personal Information within the meaning of the GDPR and the GDPR-UK of the EEA-UK to this other location outside of the EEA-UK, as the first processing (collection) of your Personal Information was done in Canada.  

11.4 Security measures.
 In all cases of a transfer of your Personal Information in a jurisdiction other than Quebec, Canada or the EEA-UK, we ensure that your Personal Information will be dealt with safely and in compliance with this Notice and that no transfer of your Personal Information will be made to an organization or a country unless appropriate or adapted guarantees are provided , including the security of your Personal Information, such as standard contract clauses, except if not required under privacy legislation. These standard contract clauses or other appropriate or adapted guarantees for this transfer outside of Canada may be obtained on request from the Coractive Privacy Officer, whose contact information is given in paragraph 3.1.2.

11.5 Other information on request.
 For any question about the collection, use, disclosure or storage of Personal Information outside of Canada, please contact the Coractive Privacy Officer whose contact information is given in paragraph 3.1.2.

12. ARCHIVING

12.1 For how long will you archive my Personal Information?
Coractive will archive Personal Information only during a period of time reasonably necessary to satisfy the purposes for which it was gathered, including respecting legal, accounting and disclosure requirements and to enforce or defend its rights.

To determine the appropriate duration for archiving your Personal Information, we will consider the number, the nature and the sensitivity of the Personal Information, the potential risk level and the seriousness of unauthorized use or disclosure of your Personal Information and if we can use it by other means, including legal, regulatory, tax, accounting and other applicable means.

The precise duration of the archiving of your Personal Information is shown below according to its category:

12.2 Right to delete.
 In certain situations, you may request that we delete your Personal Information as provided in paragraph 16.1(g). Despite this, once the applicable archiving period is over, we will securely delete your Personal Information pursuant to privacy legislation.

12.3 Anonymizing Personal Information.
 In certain circumstances, we will anonymize your Personal Information (so that it will be no longer be possible to associate it with you) for research and statistical purposes and in such a case we may use this anonymized Information indefinitely without subsequently notifying you.

12.4 Archiving systems.

We use archiving systems to safeguard our computer systems, which store your Personal Information. Once the normal deletion cycle of our backed up information has expired, all of your stored Personal Information will be definitively deleted. We cannot not delete this Personal Information before the expiry.  
 
12.5 Other information on request.
 For any question about the archiving of your Personal Information, please contact the Coractive Privacy Officer, whose contact information is given in paragraph 3.1.2.

13. ACCURACY

Coractive uses reasonable efforts to maintain the accuracy of your Personal Information and to ensure that it is complete and up to date. If however, you should note any inaccuracy in our files or if your Personal Information changes, please notify Coractive right away.

14. PROTECTION OF PERSONAL INFORMATION

Coractive has resolved to protect the confidentiality, integrity, availability and confidentiality of your Personal Information. Coractive uses protection measures that are usually used for websites and which are reasonable, considering the sensitivity of Personal Information, namely physical, electronic and organizational measures.

For example, Coractive restricts access to its offices, trains its staff accordingly, restricts access to Personal Information to its staff which has a need to know, discloses the Personal Information at single points in time and as specified in this Notice, uses two-factor authentication passwords and establishes well-defined internal practices which namely specify that Coractive staff may handle your Personal Information only in compliance with these policies. All of Coractive’s staff has signed a confidentiality agreement which specifically includes the confidentiality of your Personal Information.

Unfortunately, the transmission of information by Internet is not completely safe. Although Coractive does everything that may possibly be done by it to protect your Personal Information, Coractive cannot guarantee the security of information sent through the Website. Any transmission of Personal Information by a Person Concerned is done at his/her own risk. Once we receive Personal Information from a Person Concerned, we will apply our safety measures to try to prevent any unauthorized access, use and disclosure.

Coractive may archive and process the Personal Information of a Person Concerned at its Quebec City office. Coractive has established agreements and controls with all third party service providers to require that they protect your Personal Information which they archive, handle and process, in a way that is comparable to what is specified in this Notice.

16. OPENNESS, TRANSPARENCY

Coractive shall be open about its policies and it invites Persons Concerned to contact the Privacy Officer for any questions.

16. YOUR RIGHTS AND THEIR EXERCISE

16.1  Your rights.

You have several rights regarding our use of your Personal Information:

a)  Access: You have the right to request a copy of your Personal Information which we archive, or to consult said Personal Information. We may not however disclose to you your own Personal Information if its disclosure would reveal Personal Information about another person or would be an infringement of applicable laws.
b)  Accuracy: We strive to ensure that your Personal Information is accurate, up to date and complete. We invite you to contact the Privacy Officer using the contact information at paragraph 3.1.2 to notify us if some of your Personal Information is not exact or if changes were made thereto, so we may keep your Personal Information up to date.
c)  Processing: Your may request information about the processing of your Personal Information. More specifically, you may request what Personal Information was collected, how it was processed, the categories of persons at Coractive who may access said Personal Information, the applicable archiving period, the Privacy Officer’s contact information and the source of Personal Information if it was collected from third parties.
d)  Refusal: In certain circumstances, you may also have the right to contest the processing of your Personal Information and to request that we block, delete your Personal Information or limit access to it.
e)  Right to request a restriction: You are entitled to ask Coractive to limit the use of your Personal Information in certain circumstances.
f)   Data portability: In certain circumstances, you have the right to demand that some of your Personal Information be given to you or to another person responsible for processing it, in a structured technological format in general use and machine readable.
g)   Deletion: You have the right to demand that your Personal Information be deleted when it is no longer required for the purposes for which it was collected or namely when your Personal Information was illegally used.
h)   Complaint: If you consider that your right to the protection of Personal Information could have been infringed, you are entitled to file a complaint with the applicable Control Authority or to have recourse to the courts.

16.2  Exercising your rights.
You may, at any time, exercise any right mentioned above by contacting the Privacy Officer using the contact information in paragraph 3.1.2.

16.2.1  Access to Information
Persons Concerned may obtain details about their Personal Information which we handle by contacting the Privacy Officer using the contact information in paragraph 3.1.2

Coractive will generally answer all requests within 30 days following the receipt of the required information. If Coractive is unable to grant access or if more time is required to answer a request, Coractive will notify the Person Concerned in writing.

Coractive may refuse to forward certain types of information to Persons Concerned due to exceptions provided under applicable law (for example, when Coractive files contain information about other Persons Concerned, if the information was produced during a dispute settlement process, if the information was collected for an investigation regarding an agreement or an offence under applicable laws or if the information is subject to a legal privilege). To the extent possible, Coractive will delete the information that will not be disclosed and will give the Person Concerned access to the remaining information. If Coractive should be unable to grant access to the Personal Information to the Person Concerned or to disclose said Personal Information, Coractive shall give an explanation to the Person Concerned, subject to any restrictions.

Access to your Personal Information is free of charge. In certain circumstances, namely if the request is excessive or groundless, Coractive may require that you pay administration fees for the transcript, photocopying or transmission of your Personal Information. Coractive may also invoice additional copies. Before granting a request, Coractive will advise the Person Concerned if he/she has to pay any fees.

16.2.2      Right to withdraw consent
If you have given your consent and if it’s required for the collection, processing or transfer of your Personal Information, you are entitled to withdraw your consent in whole or in part. Please contact the Privacy Officer to do so. Please click on the “unsubscribe” link in any marketing email sent to you to withdraw your consent to receiving electronic marketing communications.

Once we receive your notice that you have withdrawn your consent, we will no longer use the information for the purposes for which you gave your consent, unless there is a legal basis for processing said Personal Information.