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Inoria Inc. (“Inoria“, “our“, “we” or “us“) is a Canadian company located at 1255 Phillips Square, Suite 307, Montreal, Quebec, H3B 3G1 that provides the contact center industry with personalized, human-centered services and solutions.
Your privacy and the protection of your personal information is very important to us. Accordingly, we have established this Policy that governs the collection, use, communication, keeping and destruction of personal information, whether or not collected by technological means. This Policy also describes how we protect personal information, as well as the process we have established for handling complaints.
2. APPLICATION AND DEFINITIONS
This Policy applies to Inoria, including its officers, employees, consultants, and any person who otherwise provides services for the benefit of Inoria.
It covers the personal information of customers (potential, current or past), job applicants, employees (current or past) or any other persons, including visitors to the website at www.inoria.com (the “Website”) or users of our applications (the “Apps”).
For the purposes of the present document, and as defined by the Act respecting the protection of personal information in the private sector (the “Act”), personal information is any information related to a natural person that allows, directly or indirectly, that person to be identified. For example, it could be a person’s first and last name, postal address, e-mail address, phone number, gender, banking information, health information, ethnic origin, language, information about the use of our Website or our Apps including technical information about visits, or any other information collected through cookies and any other personal information you consider useful to provide to us (“Personal Information“). Personal Information does not include a person’s business or professional contact information or personal information of a public nature.
BY PROVIDING PERSONAL INFORMATION TO INORIA OR ITS SUPPLIERS, THROUGH OUR WEBSITE OR APPS, BY TELEPHONE, BY E-MAIL, IN PERSON OR BY ANY OTHER MEANS, YOU CONSENT TO THE COLLECTION, USE AND COMMUNICATION, KEEPING AND DESTRUCTION OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS POLICY.
3. CONSENT, COLLECTION, USE AND COMMUNICATION
Generally, Inoria will obtain Personal Information directly from you with your consent, subject to the exceptions set out in the Act. Personal Information will only be used for the purpose for which it was collected unless we obtain your consent.
With your consent or when permitted by the Act, Inoria may also collect Personal Information from third parties.
Inoria will not collect, use or disclose Personal Information without your consent unless it is authorized or required to do so by the Act.
Please note that you have the right to refuse to provide us with Personal Information. You also have the right, subject to reasonable notice and applicable legal and contractual restrictions, to withdraw your consent to the use of Personal Information already collected by contacting our “Privacy Officer” at the contact information provided in section 15. Refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide our services or information to you.
IMPORTANT: If you provide us with Personal Information about other individuals, you declare that you have the authority to do so and, where applicable, that you have obtained the necessary consent, and you acknowledge that such information may be used in accordance with this Policy.
Without limiting the generality of the foregoing, Inoria will collect and use Personal Information for the purposes identified at the time the information is collected, subject to compliance with the Act. Collection will be limited to that which is necessary for the purposes identified.
The following is a non-exhaustive list of the information Inoria may collect. With the exception of the Personal Information of employees, job applicants, certain customers and information that may be collected during your use of our Website, the information collected and managed by Inoria is of a professional nature.
When you browse our Website or interact with us via e-mail, we may collect information about you as described below, some of which is collected automatically:
This information is collected to help us learn more about your needs, preferences, and interactions with our Website and our Apps and the services offered, to perform statistical, market and performance research to help us evaluate our Website, our Apps, and our services, measure our performance and improve the experiences and services we offer. It is not associated with a specific individual unless you request a product or service or voluntarily provide Personal Information.
The Website may host various blogs, forums and other social media apps or social media services that allow you to communicate content to other users (collectively “Social Media Apps”). Any Personal Information and other information you disclose while using a Social Media App may be read, collected, and used by other users of that Social Media App over which we have little or no control. Therefore, we are not responsible for the use, misuse, or misappropriation by another user of any Personal Information or other information you disclose using a Social Media App.
When you request information about our products and services, request a quotation and/or purchase products, we may collect information about you as described below:
This information is collected to:
When you apply for a job with Inoria, we collect Personal Information about you by e-mail, telephone or in person, which is described below:
This Personal Information is collected to manage communications with the applicant and to manage the employee file.
If you choose to participate in our surveys, contests, events, requests for information, we may collect information about you in connection with the survey, contest, request for information or event including, without limitation, your name, e-mail address, phone number; and general information about you that you choose to provide.
If you contact us by phone, we may record the call and ask you to provide us with contact information, such as your name, address, phone number and e-mail address.
If you visit our offices, you may be asked to register as a visitor and provide your name, e-mail address, phone number, as well as the time and date of your arrival.
Inoria limits the communication and disclosure of your Personal Information to purposes other than those mentioned above, but note the following clarifications and exceptions:
We may share your Personal Information to respond to law enforcement requests, court orders or other legal process or if we believe that such disclosure is necessary to investigate, prevent or respond to illegal activities, fraud, physical threats or as required by any other applicable law or regulation and to the extent necessary to protect Inoria’ property, interests, and rights.
We may share your Personal Information with a company engaged in the business of keeping documents for their general informational value.
Authorized Personnel may have access to your Personal Information in order to assist us in providing services to you. Employees access and use such Personal Information in accordance with our instructions, only if they need to know such information, and under strict confidentiality and security obligations. Please be assured that our employees manage such information with the utmost discretion and rigor and comply with this Policy and applicable legal and regulatory requirements.
When you provide Personal Information to Inoria, you grant us the right to share your Personal Information with authorized service providers acceptable to us who will use this information to help us respond to your requests and perform services. Please note that we will only share the Personal Information necessary to these third-party service providers, solely for the purpose of providing the services to you, and that we will ensure that these authorized service providers agree to keep the Personal Information confidential and secure.
Service providers retain the information they need to perform the functions for which they have been appointed and we do not authorize these third parties to use or disclose your personal information for their own marketing or other purposes.
Inoria may be involved in (1) the sale or lease of all or substantially all of its business and/or assets, (2) the modification of its legal structure by merger or otherwise, (3) a transaction to obtain a loan or other form of financing, or (4) any other similar transaction (individually and collectively the “Transaction”). As part of such Transaction, we may transfer or disclose your Personal Information to the counterparty organization, actual or potential, but we will require such organization to agree to protect the confidentiality of your Personal Information in a manner consistent with this Policy.
Inoria may also communicate your Personal Information if you expressly request or consent to such disclosure.
4. YOUR PERSONAL INFORMATION AND THIRD-PARTY WEBSITES
Our Website may contain links to independent third-party Websites. These third party Websites (“ Third-Party Websites “), whose links are provided solely for your convenience, are not under our control and may be governed by their own privacy policies. Inoria does not warrant and is not responsible for the collection, use, keeping or disclosure of your Personal Information by such Third-Party Websites. Inoria assumes no responsibility for your use of such Third-Party Websites or your access to Third-Party Websites through our Website. By using our Website, or by accessing Third-Party Websites through our Website, you release Inoria from any and all liability for the actions, practices and omissions of such third parties.
5. TRANSFER OF PERSONAL INFORMATION ABROAD
We strive to keep your Personal Information in Quebec. However, in the future, we may engage third-party service providers to process, manage and host Personal Information on our behalf that may be located abroad. As a result, some of your Personal Information may be transferred to another province or country and may be subject to the laws of that province or country.
However, we will ensure to protect the Personal Information in our custody, including Personal Information entrusted to a service provider, whether located in Quebec or abroad. Our policies and practices regarding the protection of Personal Information require that a written undertaking be signed by this service provider to respect its obligation to preserve the confidentiality and security of the Personal Information entrusted to it. This includes, but is not limited to, implementing robust and effective security measures, as well as prohibiting the disclosure, transfer, or use of your Personal Information to others in accordance with the applicable privacy legislation in the province of Quebec.
6. PROTECTION OF PERSONAL INFORMATION
We take appropriate measures to ensure the confidentiality of Personal Information and to protect such Personal Information against loss, as well as unauthorized access, disclosure, copying, use or modification, considering the sensitivity of the information and the purposes for which it is to be used.
Inoria uses commercially reasonable and appropriate physical, electronic, and managerial procedures and generally accepted industry standards to safeguard and secure the Personal Information we collect.
In addition, the Personal Information we hold is therefore only accessible to persons who are entitled to know about it and who consult it only when necessary for the performance of their duties.
To this end, we ensure to restrict access to our offices and computer equipment, train our personnel and require from our agents and suppliers of goods and services with access to Personal Information to sign confidentiality agreements and implement equivalent security measures.
Please note, however, that since no mechanism offers maximum security, using the Internet to transmit, create or host Personal Information always involves a certain amount of risk.
If you believe that your Personal Information has been compromised, we invite you to contact our Privacy Officer at the contact information appearing in section 15 of this Policy.
Inoria does not knowingly collect Personal Information from persons under the age of 18.
If a minor under the age of 14 wishes to use our Website, our Apps our services or otherwise contact us, the collection of Personal Information from that minor shall not be made without the consent of the person having parental authority or the tutor. If we become aware that we have unintentionally collected Personal Information from persons under the age of 14 without the consent of the person having parental authority or the tutor, we will ensure that such information is deleted from our records as soon as possible. If you are the person having parental authority or the tutor of a minor under the age of 14 and you are aware that your minor child has provided us with Personal Information, we invite you to contact our Privacy Officer at the contact information appearing in section 15 of this Policy so that we may take the necessary action.
8. KEEPING PERIOD
Inoria will host and keep your Personal Information for as long as necessary to fulfill the purposes set out in this Policy and to ensure compliance with our legal and regulatory obligations. You may at any time withdraw or change your consent to our use of your Personal Information, or request that we permanently delete it, subject to conditions imposed by law.
If you wish to learn more about how long we keep your Personal Information, we invite you to contact our Privacy Officer, whose contact information appears in section 15 of this Policy.
9. ACCESS, RECTIFICATION, UPDATING OF PERSONAL INFORMATION AND WITHDRAWAL OF CONSENT
You have the right to access and obtain copies of your Personal Information. You also have the right to update, rectify and correct any Personal Information that you believe is inaccurate or incomplete. You also have the right to demand that we cease disseminating Personal Information about you, or that we deindex any hyperlink attached to your name allowing access to such Personal Information by any technological means, when its dissemination contravenes the Act or a court order. You may do the same, or demand that the hyperlink providing access to Personal Information be reindexed, when certain conditions provided for in the Act are met.
To do so, please submit a written request to the Privacy Officer at the address indicated in section 15, who will reply in writing within 30 days of the date of receipt of any such request.
If you wish to obtain copies of your Personal Information, we may charge you a nominal fee, which will be disclosed to you in advance, simply to cover the cost of transcription, reproduction and/or transmission.
Subject to legal and contractual restrictions, if any, you may at any time withdraw your consent to the use or communication of Personal Information collected about you.
10. ELECTRONIC COMMUNICATIONS (E-MAILS)
Your e-mail address may be used to send you electronic communications from time to time. At any time, you may ask us to stop sending you electronic communications by contacting the Inoria Privacy Officer at the contact information appearing in section 15 of this Policy or by using the “unsubscribe” instructions appearing at the bottom of these communications, if applicable.
11. COOKIES AND OTHER TRACKING TECHNOLOGIES ON OUR WEBSITE, THROUGH OUR SERVICES AND IN E-MAIL COMMUNICATIONS.
We use common information collection tools, such as usage data collection tools, cookies, and similar technologies to automatically collect information that may contain Personal Information from your computer or mobile device when you browse our Website, our Apps or interact with emails we have sent to you.
12. MODIFICATIONS TO THIS POLICY
Inoria reserves the right to make changes to this Policy at any time. Such changes will be posted on the Website and will be effective immediately upon posting. We will take reasonable steps, if necessary, to notify you of any significant changes.
You may contact our Privacy Officer at the address or phone numbers listed in section 15 of this Policy to obtain an up-to-date copy of the Policy.
13. CONDITIONS OF USE OF THE WEBSITE
14. COMPLAINTS HANDLING PROCESS
Any complaint regarding the application of this Policy must be made in writing to the Inoria’ Privacy Officer at the e-mail address indicated in the following section.
The complaint must contain the complainant’s name, contact information, including a phone number, as well as the subject and reasons for the complaint in sufficient detail to enable Inoria to assess the complaint. The Privacy Officer may request any additional information he or she deems necessary to assess the complaint.
Please note that Inoria undertakes to treat all complaints received confidentially. Once the complaint has been received, along with any additional information deemed necessary and requested by the Privacy Officer, Inoria will have thirty (30) days to analyze it. At the end of its analysis, the Privacy Officer will provide the complainant with a written response explaining why the complaint was accepted or rejected.
Inoria undertakes to make every reasonable effort to process each complaint within thirty (30) days. However, in the event that a complaint cannot be processed within this timeframe, the complainant will be informed of the reasons for the extension, the status of the complaint and the reasonable time required to provide a definitive response.
A separate file will be created for each complaint received, where applicable. The file should contain the complaint, the analysis and documentation supporting its evaluation, as well as the response sent to the person who initiated the complaint.
You may also file a complaint in writing to the Commission d’accès à l’information – Direction de la surveillance at the following address: 900-2045, rue Stanley, Montréal, Québec, H3A 2V4 or by e-mail at email@example.com. However, we invite all interested parties to first contact the Privacy Officer, and to wait until Inoria has completed the complaint process.
15. QUESTIONS, COMMENTS AND PRIVACY OFFICER
Inoria is responsible for Personal Information in its custody or control and has designated an individual who is accountable for compliance with this Policy and applicable legislation about Personal Information.
If you have any questions or comments regarding this Policy and Inoria’ personal information practices, we invite you to contact our Privacy Officer at the following coordinates:
Mr. Alain Léonard
1255, Philippe Square, Suite 307,
Montréal (QC) H3B 3G1
Table of versions and changes
|September 22nd, 2023