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PRIVACY POLICY
1. General Information
1.1 Introduction
Protecting your privacy is important to the Northern Incubator-Accelerator (hereinafter the “NORTHERN I-A”, “we”, “us”, “our”). For this reason, we have implemented safeguards and best management practices for your personal information in accordance with applicable laws.
This privacy policy (the “Policy”) describes our practices regarding the collection, use, processing, disclosure and storage of Personal Information of our customers, visitors and users.
By using our website [https://www.ianord.ca/] (the “Website”) or any of our Services, you agree that we may collect, use, process, disclose and store your Personal Information in accordance with the terms described herein. If you do not agree to follow and be bound by this Policy, you may not visit, access or use our Website or Services, or share your Personal Information with us.
This Policy does not apply to Personal Information of NORTHERN I-A employees, representatives and consultants, or any other person affiliated with NORTHERN I-A, or to any information that is not Personal Information as defined by applicable law.
1.2 Privacy Officer
Questions, comments and complaints regarding the NORTHERN I-A’s Policy and privacy practices may be addressed to our Privacy Officer at the following coordinates:
Email: ddugre@fpq.com
Address: 3137 Laberge Street, Québec, Québec, G1X 4B5
2. Definitions
The following words and expressions, when they appear with a capitalized first letter in the Policy, have the meanings attributed to them below unless otherwise implied or explicited in the text:
“Service Supplier”: Any individual or legal entity that processes data on behalf of the NORTHERN I-A. This includes third-party companies or individuals employed by the NORTHERN I-A to facilitate the Services, provide the Services on behalf of the NORTHERN I-A, perform services related to the Services, or assist the NORTHERN I-A in analyzing the use of the Services.
“Personal Information”: Any information that relates to a natural person and allows that person to be identified, i.e. that directly or indirectly reveals something about that person’s identity, characteristics (e.g. abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour) or activities, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, sound, visual, computerized or other).
“Sensitive Personal Information”: Refers to Personal Information which, by its nature or because of the context of its use or communication, gives rise to a high degree of reasonable expectation of privacy. Examples include medical, biometric, genetic or financial information, or information about a person’s life or sexual orientation, religious or philosophical beliefs, union membership or ethnic origin.
“Privacy Officer”: The person who is responsible for the application of this Policy and whose contact information is identified in section 1.2 of this Policy.
“Services”: Services refers to the website and all related services offered by the NORTHERN I-A, which include professional services and, where applicable, associated media, printed materials and “online” or electronic documentation.
3. Personal Information Processing
3.1 Personal Information Collection
Your consent to share your personal information with us
For the NORTHERN I-A, respecting your privacy and the confidentiality of your data is paramount. That is why we have developed this privacy policy to tell you what information we collect, how we process it, and when we need to share it with subcontractors or third parties.
By giving your consent, you authorize the NORTHERN I-A to proceed with the collection and processing of your personal information that is required to offer our services. Please note that you remain in control of your personal information at all times, and that the consent you give us to collect or process your personal information may be withdrawn at any time. We will respect your choice in accordance with our legal obligations.
In our business course, we may collect, process and use various types of Personal Information that you provide to us only as permitted by law, including the information listed below:
Via our Website:
● Information collected automatically when using the Website and our Services, including:
○ Connection and other information about your activities on the Website, such as your IP address, the pages you have visited, the time and date of your visits, the type of browser you are using, your device’s operating system and other hardware and software information;
○ Geolocation data, such as your IP address, a precise or approximate location determined from your IP address or your mobile device’s GPS (depending on your device settings).
In the performance of mandates, you entrust to us:
● Contact information such as your first and last name, email address, telephone number, address and company number for the creation of a customer account;
● Information relating to products or services, such as information concerning the services we have performed for you;
● Transaction and payment information such as the payment method used, the date and time, the payment amount, the billing zip code, your address and other related information;
● Information you choose to provide or transmit to us, for example, when you fill out a form, respond to surveys or contact one of our employees or representatives.
In each case, such personal information is processed in accordance with the legitimate and necessary purposes listed in section 3.2 below. In addition, we ensure that we only collect and process data and Personal Information that is strictly necessary for the purposes for which you provide it to us. In the event of any subsequent use of your Personal Information, we will notify you as required by law.
3.2 Personal Information Use
As stated in paragraph 3.1, we use your Personal Information only as permitted by law. We may use your Personal Information for the legitimate purposes described below:
● provide Services;
● enable you to subscribe to our newsletter;
● verify your identity and review your personal history, as permitted by law;
● operate, maintain, supervise, develop, improve and offer all functionalities of our Website;
● manage risk and operations;
● comply with our obligations under applicable laws and regulations;
● develop new Services and improve our Website and Services;
● for marketing and business development purposes, if you have previously consented to the processing of your personal information for these purposes;
● send messages, updates, security alerts;
● answer your questions and provide you with assistance if required;
● manage a contest, promotion, survey or other feature of the Website or our Services;
● collect notices and comments regarding our Services;
● conduct research and analysis in connection with our business and Services;
● detect and prevent fraud, error, spam, abuse, security incidents and other harmful activities;
● establish, exercise or defend any legal right or proceeding;
● transmit communications in accordance with the law;
● any other purpose permitted or required by law.
Please note that we do not use the information we collect for any inference or interpretation whatsoever.
3.3 Personal Information Disclosure
We may disclose your Personal Information to our employees, contractors, consultants, agents, Service Suppliers and other trusted third parties who require such information to assist us in operating our Website, conducting and protecting our business or serving you. That such Service Suppliers have previously agreed in writing to maintain the confidentiality of your Personal Information in accordance with applicable laws. In addition, only those employees of our organization who have a need to access and process your Personal Information will have access to it, in accordance with our internal Privacy Policy.
We do not sell, trade or otherwise disclose your Personal Information to third parties, subject to exceptions provided by law.
3.3.1 Service Suppliers and Other Third Parties
Although we try to avoid sharing your Personal Information with third parties, we may use Service Suppliers to perform various services on our behalf, such as IT management and security, marketing, and data analysis, hosting and storage.
When we disclose your Personal Information to Service Suppliers, we have written contracts with them prior to disclosing your Personal Information to them, and we only provide them with the Personal Information necessary to perform their mandate. As part of these contracts with our Service Suppliers, we are committed to ensuring that the principles set out in this Policy are respected, and these Service Suppliers are required to use Personal Information in accordance with our instructions and only for the purposes for which it was provided. In addition, these Service Suppliers provide us with sufficient guarantees of the implementation of adequate safeguards that are proportionate to the sensitivity of the Personal Information processed or communicated. When our Service Suppliers no longer need your Personal Information, we ask them to destroy this data in an appropriate manner.
3.3.2 Complying With Legislation, Responding to Legal Requests, Preventing Harm and Protecting Our Rights
We may disclose your Personal Information when we believe such disclosure is authorized, necessary or appropriate, including:
● respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence;
● protect our business;
● comply with legal proceedings;
● protect our rights, privacy, security, property, yours or those of third parties;
● allow us to pursue available remedies or limit the damages we may suffer; and
● in accordance with applicable laws, including laws outside your country of residence.
3.3.3 Business Transaction
We may share, transfer or disclose, strictly in accordance with this Policy, your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of the NORTHERN I-A or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or other business transaction, including in connection with the negotiation of such transactions). In such a case, we will inform you before your Personal Information is transferred and is governed by another privacy policy.
3.3.4 Personal Information Consent
Whenever possible, the NORTHERN I-A obtains consent directly from the individual concerned for us to collect, use and disclose his or her Personal Information. However, if you provide us with Personal Information about other individuals, you must ensure that you have duly notified them that you are providing us with their information and that you have obtained their consent to such disclosure.
We will seek your express consent before using or disclosing your Personal Information for purposes other than those described herein.
3.3.5 Personal Information Storage
Subject to applicable laws, we store your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected, unless you consent to your Personal Information being used or processed for another purpose. In addition, our storage periods may be modified from time to time due to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and breaches or to prosecute criminals).
You can also rest assured that once the purpose for which the information was collected has been fulfilled, we will destroy or anonymize the information in accordance with applicable legislation.
For more information on the periods during which your Personal Information is kept, please contact our Privacy Officer using the contact details provided in section 1.2 of this Policy.
4. Your Rights
As a data subject, you may exercise the rights set out below by completing the form available on request and sending it by email or mail to the attention of our Privacy Officer at the contact information provided in section 1.2 of the Policy:
● You have the right to be informed of the Personal Information we hold about you and to request a paper copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;
● You have the right to have the Personal Information we hold about you rectified, amended and updated if it is incomplete, equivocal, out of date or inaccurate;
● You have the right to withdraw or change your consent to the collection, use, disclosure or storage of your Personal Information by the NORTHERN I-A at any time, subject to applicable legal and contractual restrictions;
● You have the right to ask us to cease disseminating your Personal Information and to de-index any link attached to your name that provides access to such information if such dissemination contravenes the law or a court order;
● You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions set out in the applicable law.
In order to process your request, you may be asked to provide appropriate identification or to identify yourself in some other way.
We encourage all our customers to keep their personal information with us up to date. Decisions regarding the various services we can offer our customers may vary according to the accuracy of this data. Therefore, it is essential to ensure that we have an accurate picture of your situation.
5. Security Measures
The NORTHERN I-A has implemented physical, technological and organizational security measures to adequately protect the confidentiality and security of your Personal Information against loss, theft or any unauthorized access, disclosure, reproduction, communication, use or modification. These measures include encryption, access control, segregation of duties, internal audit, etc.
Among these various measures:
● Our Website is equipped with SSL (Secure Sockets Layer), and firewalls;
● As mentioned in section 3.3, we have put in place measures to restrict access to Personal Information to those who have a valid reason to consult, process, communicate or otherwise use your information;
● As mentioned in section 3.3, subcontractors and third parties who do business with the NORTHERN I-A and with whom we may need to communicate your Personal Information have previously agreed to protect the confidentiality and privacy of such information;
● When the purpose for which your Personal Information was collected has been fulfilled and we no longer need to store it, the NORTHERN I-A will destroy or anonymize such data, subject to applicable laws.
Despite the measures described above, we cannot guarantee the absolute security of your Personal Information. If you have reason to believe that your Personal Information is no longer secure, please contact our Privacy Officer immediately using the contact details provided in section 1.2 above.
6. Changes to This Privacy Policy
We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a change, we will post the revised Privacy Policy and indicate the updated date in the footer of the Privacy Policy. If you do not agree to the new terms of the Privacy Policy, please do not continue to use our Website and Services. If you choose to continue using our Website or Services after the new version of our Policy becomes effective, your use of our Website and Services will be governed by the new version of the Policy.
7. Links to Third Party Websites
From time to time, we may include on our Website references or links to websites, products or services provided by third parties (“Third Party Services”). These Third-Party Services, which are not operated or controlled by the NORTHERN I-A, are governed by privacy policies entirely separate from and independent of our own. We therefore assume no responsibility for the content or activities of these sites. This Policy applies only to the Website and the Services we offer. This Policy does not extend to Third Party Services.
Liability Limitation
The NORTHERN I-A undertakes to take all reasonable measures to ensure the confidentiality and security of Personal Information in accordance with technological standards appropriate to its sector of activity.
Notwithstanding the foregoing, you declare that you understand and acknowledge that no computer system offers absolute security and that there is always a degree of risk involved in transmitting Personal Information over the public network that is the Internet.
You therefore agree that the NORTHERN I-A cannot be held responsible for any breach of confidentiality, hacking, virus, loss, theft, misuse, or alteration of Personal Information transmitted or hosted on its systems or those of a third party. You also waive any claim in this regard, except in the case of gross negligence or wilful misconduct on the part of the NORTHERN I-A. Accordingly, you agree to hold the NORTHERN I-A and its officers, directors, affiliates, and business partners harmless from any and all damages of any kind, whether direct or indirect, incidental, special or consequential, arising out of or in connection with the use of your Personal Information.
In the event of a breach of the confidentiality or security of your Personal Information that presents a high risk to your rights and freedom, you will be notified of such breach as soon as possible, and the NORTHERN I-A will take the necessary steps to preserve the confidentiality and security of your Personal Information.
8. Contact Us
Any questions, comments, requests or concerns regarding this Privacy Policy should be directed to our Privacy Officer at the contact information provided in section 1.2 of this Policy.