Last update : December 2024

Privacy Officer: Sophie Marin, CEO and Founder of Innovsa

Thank you for visiting theINNOVSA INC ("Innovsa") website. This Privacy Policy applies to the website accessible at www.Innovsa.ca (the "Website").

1. WHO WE ARE

For the purposes of this Privacy Policy (the "Privacy Policy"), any reference to Innovsa shall be deemed to include its affiliates (including any subsidiaries), divisions and other related companies, suppliers or licensors, and their respective employees, officers, directors, shareholders, agents, subcontractors and other representatives.

This Privacy Policy has been developed on behalf of Innovsa: when we use the terms "we", "us", or "our" below, we are referring to the Innovsa entity that is responsible for processing your personal information. Additional privacy laws and practices apply to individuals whose personal information is collected and used in the European Economic Area ("EEA").

The purpose of this Privacy Policy is to tell you about our practices regarding the collection, use, disclosure, sharing and management of personal information provided on the Website or otherwise collected in the context of Innovsa's activities. Our Privacy Policy also describes the measures we take to protect the security of this information and how you can access, change or delete your personal information. In addition to this Privacy Policy, your visit to this Website is subject to (i) our Website Terms of Use, available at https://www.innovsa.ca, and (ii) any other terms of use that may be communicated to you by Innovsa from time to time.

If you do not agree with the terms of our collection, use, disclosure, sharing and management of personal information as set out in this Privacy Policy, please do not provide us with your personal information or use the Website.

2. WHEN AND HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect the personal information you provide to us in a variety of ways, including:

2.1 Through our direct exchanges:

Communication with us via a form available on the Website; Communication with us about the services and products we offer;
Communication with us to ask a question, submit a comment or make a complaint (customer service);
Subscribe to our mailing lists, e-mail communications and messaging services to receive news and updates;
Job applications;
Use of social media.

2.2 Through automatic technologies or interactions :

When you use our Website, we automatically collect certain technical data (more fully detailed below) about your equipment and Internet browsing. Our Website uses a technology called "cookies". A cookie is a small data file that our Web Site can send to your browser, which may then be stored on your computer's hard drive to enable us to recognize you on subsequent visits. We use cookies to understand which portions of our Web Site are useful and which portions we need to optimize, enabling us to plan improvements to our Web Site. You can set your browser to notify you when you receive a cookie, or to refuse certain cookies. However, if you choose to decline cookies from our Web Site, you may not be able to take advantage of all the benefits and features of the Web Site. Our Web site may also use a technology called "Internet tags" or "web beacons". This technology enables us to understand which pages of our Website you are visiting. We use these web beacons to optimize and tailor our Website for you and other potential visitors. We may also collect certain technical information about you if you visit other websites that use our cookies.

2.3 Through third parties:

We may obtain information about you from other sources, including customers, service providers and business partners, and combine this information with information we have collected about you.

For example, we may use third parties, such as Google, to:

Carry out remarketing, which consists in displaying advertising to people who have already visited our Website, on websites other than our own, including through Google Analytics (a web analytics solution). In such cases, the third parties involved, including Google Analytics, may display our advertisements on sites across the Internet.
Use the following functions of Google Analytics: reporting on the recorded impressions of our advertisements (i.e., a solution for placing advertisements on a range of news sites, blogs and other specialized Internet sites) in order to attract more potential customers; integration with any management tool comprising a set of functionalities used for the delivery, targeting, verification and reporting of advertisements for our advertising campaigns on Internet sites and mobile devices; and reporting on the demographics of Internet users and their interests;
Collect, analyze and/or aggregate your personal information (such as IP address, gender, age and interests), including through the creation of reports on user demographics and interests, to help us understand how visitors interact with our Website and to improve our Website and our products and services. Companies providing remarketing may combine the use of first-level cookies (e.g., the Google Analytics cookie) and third-party cookies (e.g., the DoubleClick cookie) to (i) collect personal information; and (ii) to inform, optimize and serve advertisements based on your previous visits to our Website, and (iii) to determine the relationship between recorded visits to our Website and ad impressions, other uses of advertising services and interactions with such ad impressions and advertising services. These companies may also use Internet tags or web beacons to report certain information about your visits to our Website and to websites that link to and advertise on our Website, in order to measure the effectiveness of our advertising.

3. WHAT PERSONAL INFORMATION WE COLLECT

For the purposes of this Privacy Policy, "personal information" means any information about an individual from which that person can be identified. This does not include information from which the identity has been removed (anonymous data). We may collect, use, store and transfer various types of personal information about you, which we have grouped together as follows:

Contact information includes last name, first name, e-mail address, title, telephone number, mailing address and contact preferences;
All information that may appear in a curriculum vitae or similar document submitted in connection with a job application;
Social media data includes information associated with any social media account you hold and the profile associated with it, such as name, username, e-mail address, profile photo, date of birth and gender;
Technical data includes your IP (Internet Protocol) address, your connection data, the number of clicks and other related information, such as the websites you visited immediately before and after visiting our Website, your time zone and geographical settings, the Internet service provider you use and other technologies on the devices you use to access our Website;
Usage data includes the number of visits to our Web Sites, the date and average time spent on our Web Sites, and information about how you use our products and services;
Marketing and communication data includes your preferences for receiving marketing from us and related third parties, and your communication preferences.

For example, certain information may be requested from you when you visit the Web Site, such as your name, mailing address, e-mail address, telephone number, country of residence and curriculum vitae, when you choose to communicate or otherwise engage with us through one of the various means offered on our Web Site.

We also collect, use, store and share aggregated information, such as statistical or demographic information. Aggregate information may be derived from your personal information, but is not considered personal information if it does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of our Website. However, if we combine or connect aggregated information with your personal information to identify you directly or indirectly, we treat it as personal information that will be used in accordance with this Policy.

We do not collect any personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Consequences of refusing to provide certain personal information

Where we are required by law or by contract to collect personal information from you, if you do not provide such information upon request, we may not be able to perform the contract in question. In this case, we may have to cancel the delivery of a product or the performance of a service you have requested from us to the extent that your refusal makes it impossible for us to perform our obligations, but we will inform you if this is the case at the appropriate time.

4. HOW WE USE THE PERSONAL INFORMATION WE COLLECT

4.1 General principles

We limit the collection of personal information to that which is reasonably required to fulfill the purposes for which it is collected. Most often, we will use your personal information in the circumstances described below.

With your consent: for example, we will obtain your consent before sending you marketing communications; Where we need to perform the contract we are about to enter into or have entered into with you: contract performance means processing your personal information where this is necessary for the performance of a contract to which you are a party or to take steps on your behalf and at your request prior to entering into such a contract;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental interests and rights do not override those interests: a legitimate interest means Innovsa's interest in conducting and managing our business to enable us to give you the best service or product. We make sure to consider and adjust any potential impact on you (both positive and negative) and your rights before processing your personal information for our legitimate interests. We do not use your personal information for activities in relation to which our interests are outweighed by the impact on you (unless we have your consent or are required or permitted by law to do so). You can obtain further information on how we assess our legitimate interests in relation to any potential impact on you in relation to specific activities by contacting our Privacy Officer.
Where we have to comply with a legal obligation: complying with a legal obligation means processing your personal information where this is necessary to comply with a legal obligation to which we are subject.

4.2 Purposes for which personal information is collected

The personal information we collect may be collected or used by all of the entities and individuals comprising Innovsa and listed above, and may also be communicated internally to enable us to respond appropriately to your requests, communicate with you or assist you for the purposes described in this Privacy Policy.

We describe below all the ways in which we intend to use your personal information and the legal grounds on which we do so. We have also identified our legitimate interests, where applicable. Please note that we may process your personal information for more than one legitimate reason, depending on the specific purpose for which we are using your information. Please contact our Privacy Officer if you require further details on the specific legal ground on which we rely to process your personal information.

Description of the activity, use and justification:

Communication with us via a form available on the Website

Our Website may make available to you forms that help structure the information sent to us, including forms that allow you to download documents from our Website.

Consent;
Necessary for our legitimate interests (to operate our business and process forms for the purposes intended).

Communication with us about the services and products we offer.

We use this information to process your request and to send you information about the services and products we offer.

Consent;
Necessary for our legitimate interests (to operate our business and respond to customer requests for information about our services and products.

Communication with us to ask a question, submit a comment or make a complaint (customer service).

If you choose to send us an electronic feedback form or send us an e-mail with your comments, questions or feedback, we may collect some of your personal information as well as your comments, suggestions or feedback. This personal information will be used to respond to your comments, questions or feedback. We may also use your comments, suggestions or feedback to monitor and/or improve our product and service offerings and our Web Site.

Fulfillment of a contract;
Necessary for our legitimate interests (to operate our business and respond to various requests from current and potential customers).

Subscription to our mailing lists, communications and e-mail services.

From time to time, we may collect certain personal information (e.g. last name, first name, postal code, country, province, gender, telephone number and e-mail address) in order to send you e-mails about our services or promotions, as well as those of third parties with whom we have a relationship. You may remove your e-mail address from the distribution list at any time by following the instructions provided in each of our e-mails. You may also remove your e-mail address from our distribution list by contacting us as indicated in the "Contact Us" section on the last page of this document. Your request will be processed within the timeframe prescribed by law, if applicable.

Consent;
Necessary for our legitimate interests (to analyze how our customers (current or potential) use our products and services, to improve our marketing strategies, to develop our product and service offering, and to operate and grow our business).

Application for employment (for example, information contained in a resume, cover letter or other similar documents relating to an application for employment).

In connection with a job application or related inquiry, we use this information to process your application and respond to your inquiry regarding current and future career opportunities.

Consent;
Necessary for our legitimate interests (to operate our business and respond to your job application).

Social media.

We may offer you the opportunity to enjoy our content from or through third-party networking sites, plug-ins and applications. When you enjoy our content in this way, you may also allow us to access certain information associated with your social media accounts (for example, your name, username, e-mail address, profile picture and gender) for the purpose of distributing content or in connection with the operation of our Website, plug-ins and applications. When you provide information about your social media accounts, we may use that information to personalize your experience on our Website and third-party networking websites, plug-ins and applications, and to provide you with other products or services you may request.

Necessary due to our legitimate interests (to analyze how our customers (current or potential) use our products and services, to improve our marketing strategies, to develop our product and service offering, and to operate and grow our business).

Visiting our Websites - Technical data.

When you visit our Web site, Innovsa collects certain information about you. We collect the IP (Internet Protocol) addresses of all visitors to our Web Site, clickstream data and other information such as the Web sites visited immediately before and after ours, the pages requested, your browser type, operating system, the Internet service provider you use, the number of times you visit our Web Site and the date and average time you spend on our Web Site. We use this information to administer our Web Site, monitor and improve our services and Web Site, determine how our Web Site is used, understand which portions of our Web Site are popular, and analyze trends and usage patterns.

Necessary for our legitimate interests (to operate our business, provide administrative and technical services, prevent fraud);
Necessary to comply with a legal obligation.

Customer Relationship Management (CRM) databases.

When you participate in any of the activities described above, we collect the personal information provided in connection with those activities to complete and update our customer relationship management databases. In this context, the personal information collected is used to generate mailing lists and reports for internal use on Innovsa's relationships with its customers or potential customers in order to monitor and/or improve our product and service offerings and our Website.

Necessary for our legitimate interests (to analyze how our current or potential customers use our products and services, to improve our marketing strategies, to develop our product and service offerings and to operate and grow our business).

5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

5.1 Principle :

Except as expressly set out in this Privacy Policy, we do not sell, rent, transfer or disclose your personal information to third parties for undisclosed purposes without your consent. Access to your personal information is restricted to Innovsa staff, management and marketing team members who need access to your personal information in order to perform their duties for Innovsa.

5.2 Exceptions:

We may transfer personal information that is not encrypted and to which we have access to:

- Service providers, that is, third parties (or otherwise make it available to them) who provide services on our behalf in Canada, the United States or abroad, including Google and Hubspot, for the purpose of using the various Google and Hubspot features described herein. We provide our service providers with the information they need to fulfill their mandate, and we do not authorize them to use or disclose this personal information for their own commercial or other purposes;
- Entities, organizations and authorities for legal purposes. In other words, we and our third-party service providers may disclose your personal information in response to a search warrant or other lawful request or order, or to respond to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by law. We may also disclose personal information as necessary for the purpose of asserting or enforcing legal claims or defending against such claims, or for the purpose of preventing actual or alleged loss or injury to persons or damage to property; and/or
- Another entity, in the event we sell all or part of our business, or if we sell or transfer assets or otherwise participate in a merger or transfer of business. In such a case, we may transfer your personal information to a third party as part of the transaction.

Our Web Site may contain links to other sites that are not owned or operated by Innovsa.In addition, links to our Web Site may appear on third-party Web sites on which we advertise. Except as provided herein, we will not disclose your personal information to such third parties without your consent. We provide links to third-party websites for your convenience. These links are not intended as an endorsement or recommendation of the linked sites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose, obtain or otherwise treat your personal information.

6. HOW WE PROTECT YOUR PERSONAL INFORMATION

We have established and maintain administrative, technical and physical safeguards to protect your personal information in our custody and control from unauthorized access, use, modification or disclosure. We also take special measures to assess potential risks applicable to the disclosure of your personal information. In the event of a security breach, that is, if your personal information is lost, disclosed without your authorization or becomes accessible to an unauthorized person, we will notify you of such a breach if it involves a real risk of serious harm. For example, a real risk of serious harm includes bodily harm, humiliation, loss of professional opportunities, financial loss or identity theft. If the breach creates a real risk of serious harm, we will notify you directly as soon as possible. If we are unable to inform you directly, we will inform you of the breach through public communication. We will provide you with the information you need to understand the significance of the security breach and take the necessary steps to reduce the risk of harm that may result. We will also report the security breach to the government and any other organizations that we believe can reduce the risk of harm that may result from the breach. We keep a record of all security breaches. Following a security breach, Innovsa investigates the cause and reviews the safeguards in place to prevent future breaches.

7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We have implemented procedures regarding the retention of personal information that are designed to retain personal information only as long as necessary for the fulfillment of the purposes described in this Privacy Policy or as required by law.

8. TRANSFERS OF PERSONAL INFORMATION TO OTHER COUNTRIES

Your personal information will be accessible from Canada. In some cases, your personal information may be collected, communicated, used or stored outside of Canada by all of the entities and individuals that make up Innovsa, a subsidiary or a third-party service provider, and such personal information may be disclosed in accordance with applicable laws in the relevant jurisdictions. We will take all steps reasonably necessary to ensure that any personal information transferred outside of Canada or the EEA is treated securely and in accordance with the data protection laws applicable in the jurisdiction in which the information is processed or stored. These laws may not offer the same level of privacy protection as Canadian or EEA laws.

9. CHANGES TO PRIVACY POLICY

This Privacy Policy is regularly reviewed and may be updated from time to time to reflect changes in applicable laws or our personal information practices. The revised Policy will be posted on the Website. We will treat your personal information in accordance with the most current version of the Privacy Policy.

10. HOW TO CONTACT US

We have appointed a Privacy Officer to oversee matters relating to this Policy. Innovsa has not currently appointed a representative in the European Union as its processing of personal information of EEA nationals is occasional, does not include large-scale sensitive data and is unlikely to result in a breach of individuals' rights and freedoms.

If you have any questions or comments about the way we process your personal information, including any request to exercise your rights, or if you wish to request access to, update or correct your personal information in our possession, please contact our delegate as indicated below:

Attention: Sophie Marin, CEO and Founder

Mailing address:107-1370 av. du Golf-de-Bélair Québec (Québec) G3J0H3 Canada

E-mail: smarin@innovsa.ca

You may also withdraw your consent to the collection, use and disclosure of your personal information at any time by using the contact information above. However, if you withdraw your consent, we may not be able to continue to respond to your inquiries, process any requests made to us or otherwise assist you in connection with the Website.

11.YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You have the following rights with respect to your personal information:

Request access to your personal information: this allows you to receive a copy of the personal information we hold about you and to verify that we are processing it lawfully.
Request correction or update of the personal information we hold about you: this allows you to correct or update incomplete, inaccurate or outdated data we hold about you. However, we may need to verify the accuracy of the new data you provide.
Request the deletion of your personal information: thisallows you to ask us to delete or withdraw personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or withdraw your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we need to erase your personal information to comply with applicable law. Please note, however, that we may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Objecting to the processing of your personal information : where we rely on our legitimate interest (or that of a third party), you may object to such processing where there is an element in your particular circumstances that leads you to believe that the processing contravenes your fundamental rights and freedoms. You also have the right to object when we process your personal information for direct marketing purposes. In some cases, we may be able to demonstrate that we have legitimate grounds for processing your information that override your rights and freedoms and, in such cases, we may decide to continue processing your personal information.
Request to restrict the processing of your personal information: this allows you to ask us to suspend the processing of your personal information in the following cases:
- If you wish us to verify the accuracy of the information;
- Where our use of the information is unlawful, but you do not wish us to delete it;
- If you need us to keep the information even if we no longer need it, because you need it to establish, exercise or defend legal claims; or
- You have objected to the use of your information, but we need to verify that we have legitimate grounds for using it.
Request that we transfer your personal information to you or to a third party: we will provide you, or a third party of your choice, with your personal information in a structured, machine-readable, commonly used format. Note that this right applies only to automated information that you have initially consented to provide to us for our use or where we have used that information to perform a contract with you.
Withdraw your consent at any time when we rely on your consent to process your personal information: this will not, however, affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide you with certain products or services, which may prevent us from responding to inquiries, providing technical support or otherwise assisting you in using our products and services. We will inform you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the above rights, please contact our Privacy Officer.

You will not be charged a fee to access your personal information (or to exercise any of the other rights).

If you wish to exercise any of the above rights, we may need to ask you for specific information to enable us to confirm your identity so that you can access your personal information (or exercise your other rights). This is a security measure to ensure that personal information is not disclosed to anyone who is not entitled to receive it. We may also contact you to request additional information regarding your request in order to expedite our response.

We will respond to all legitimate requests within thirty (30) days.

12. POLICY REGARDING MINORS

We recognize the importance of protecting the privacy and safety of children. Our Website and services are not intended for children under the age of 18, and we do not knowingly collect personal information from children under that age.

If we learn that we have collected personal information from a child under the specified age without verification of parental consent, we will take steps to delete such information from our records as soon as possible. If you believe that we may have information from or about a child under the specified age, please contact us using the information provided in the "Contact Us" section.