Introduction
Respecting your privacy is an important concern for O-Possum’s team. We are therefore committed to respecting the confidentiality of Personal Information by complying with the following Privacy Policy (hereinafter “Policy”). This Policy govern the use of the transactional websites beginning by https://ecom.o-possum.com/[…].
This Policy is binding on all users of any of the above-mentioned sites (hereinafter “you”) and O-possum solutions also named 9413-8856 Québec inc. (hereinafter “we” or ” O-Possum”). It does not bind any other company that is not owned or controlled or any person who is not an employee of O-Possum. This Policy is also binding on any legal entity whose representative is legally authorized to bind such entity to this Policy. If you do not have the authority to bind the legal entity you represent or if you do not consent to the terms and conditions set forth herein, it is your responsibility not to browse the Website or use any other product or service offered by O-Possum that requires the collection of Personal Information.
This Policy describes the types of personal information that we may collect or that you may voluntarily provide to us through the O-Possum website or any other O-Possum affiliated site or platform to manage business activities that require interaction with you.
Terminology
“Platform” means, in addition to this website, any other website, software or technology made available to users by O-Possum or its affiliate O-possum Solutions.
“Cookies” means information exchanged between a browser and a web server when a user visits a website.
“Personal information” means “any information that relates to a natural person and allows that person to be identified” (Translation – s. 2 of the Act respecting the protection of personal information in the private sector);
“Sensitive personal information” is defined as information which, because of “its medical, biometric or other intimate nature, or because of the context in which it is used or communicated, […] gives rise to a high reasonable expectation of privacy” according to the Commission d’accès à l’information du Québec (translated) (https://www.cai.gouv.qc.ca/espace-evolutif-modernisation-lois/thematiques/renseignements-sensibles/ );
Default privacy setting
As required by law, as an organization we are committed to ensuring, by default, the highest level of confidentiality at all stages of the life cycle of our users’ personal information, without any intervention on your part.
Please note that this clause does not apply to the confidentiality settings for cookies. For more information on Cookie settings, please refer to Section 11: Cookies.
Consent
Users’ consent to the various stages of the personal information life cycle must be manifest, free, informed and given for specific purposes. A user’s consent will be required except in exceptional situations provided for by law.
We undertake to use a user’s personal information only for the purposes for which it was requested and for which a user has consented to provide it (see Section 6: Use of collected information). If we need to use a user’s personal information for purposes other than those for which he or she originally consented, we undertake to obtain his or her consent again.
For all non-sensitive Personal Information, each user will be asked to give implicit consent, i.e. by voluntarily providing the requested information.
For any sensitive personal information, each user will have to provide us with express consent, by checking the box to this effect on the form requesting this type of information, without which we will not be authorized to use this information.
By browsing the website or using any other product or service offered by O-Possum, the user acknowledges having read and understood this Policy and is deemed to have agreed to be bound by its terms and conditions.
Minors
We will not collect any personal information from children under the age of eighteen (18) without the consent of their parent or legal guardian. If you are a user under the age of eighteen (18), please do not submit any personal information about yourself through our website or any other O-Possum Products and Services.
If you have reason to believe that a child under the age of eighteen (18) has provided us with personal information without the consent of the parent or legal guardian, please notify us as soon as possible so that we can proceed with the destruction of the child’s personal information (see Section 17: Privacy Officer).
We strongly encourage parents and legal guardians to instruct their children not to provide any personal information to any organization, whether in a branch or via a website, without their permission, and to take all necessary precautions in this regard.
Collection of personal information
It is possible to browse our website or use certain products and services offered by O-Possum without disclosing any information that would identify you as a specific individual.
However, certain features of our website and certain on-site transactions require you to provide personal information to access a product or service. Thus, users choose to voluntarily provide personal information to gain access to the products and services in question.
Users may choose not to provide the personal information requested. However, they may not be able to access certain products or services. If you have any questions about the information you are required to provide, please contact us so that we can help you (see Section 17: Privacy officer).
Use of collected information
Use is the period during which a person authorized by O-Possum uses confidential information for the purposes for which a user has consented to provide such information.
At the use stage, we are committed to ensuring that access to personal information is only given to those persons who are qualified to receive this type of information to perform their duties. In addition, we undertake to obtain a user’s consent if we need to use confidential information for a purpose other than that for which he or she initially gave consent, subject to the exceptions provided by law.
Depending on the type of product or service desired by a user, the personal information collected may be used for the following purposes:
User account management
Security
Payments
Deliver products or services
Send administrative information
Send marketing and promotional communications
Send product and service updates
Respond to inquiries and offer support
Deliver targeted advertising
Produce Relevé 24
Data analysis for marketing and advertising
Payment processing
When a user needs to make a payment, he or she will inevitably be asked to provide credit card details or other payment information. This information will only be used to carry out the transaction for which it was provided. We use intermediaries, i.e. payment processors, to process payment data securely. The information covered by this section includes an e-mail address, home address, credit card details and/or bank account number to enable them to complete the desired transactions.
Personal information required to process future or recurring payments will be stored in encrypted form on the secure servers of our payment processors if prior consent has been given by the user.
Right of access and modification
A user may make a request to the Privacy Officer to have certain personal information stored in our databases deleted or modified. To do so, the user must send an e-mail to the Privacy Officer with the following subject line: Access or modify my personal information.
As required by law, the Privacy Officer will respond to any user’s request for access or rectification within 30 days of receipt of the request.
It should be noted that when information is deleted or modified, we retain a copy of the personal information present prior to the modification or deletion in our files for as long as is necessary to comply with our legal and tax obligations.
Transparency
In the interests of transparency, and upon request from a user, we also undertake to provide the following information:
The personal information we hold about them;
A list of the categories of people who have access to information about the user within the company.
The length of time we keep the information in question;
The contact details of the person responsible for the protection of personal information.
This information will be transmitted to the user in a structured and commonly used technological format, at the user’s request, as required by law.
Disclosure of personal information
Service providers
Depending on the nature of the transaction a user wishes to perform, we may be required to share personal information with service providers who are essential to the proper operation of the website or certain products and services offered by O-Possum. We assure you that the privacy policies of all our service providers are consistent with ours or that they agree to abide by our Policy to ensure the protection of our users’ personal information.
Service providers are not authorized to use or disclose your personal information except to the extent necessary to perform services on our behalf or to comply with legal requirements. Thus, we disclose only the information necessary for them to perform their functions. Finally, these suppliers are not authorized to use or disclose any information we have provided to them for their own marketing or benefit.
Third parties
We do not share any confidential information with third parties. However, we may disclose any personal information we collect, use or receive if required or permitted by law.
Retention of personal information
We will retain and use your personal information for as long as necessary to provide the product or service requested by a user, to comply with our legal obligations, to enforce our agreements or to resolve disputes unless a longer retention period is required or permitted by law.
Once the retention period has expired, the personal information will be deleted. Consequently, the right of access, the right to erase, the right to modify and the right to data portability cannot be exercised after the expiry of the retention period.
Destruction of personal data
Personal information is destroyed at the end of its life cycle, when the purpose for which the information was collected has been fulfilled or as required by law. At this point, we will securely destroy personal information.
Cookies
Our Web site may use third-party analysis tools that deposit different cookies or other similar technologies to collect standard information about Internet activity and usage. Cookies allow users to optimize their website navigation and enhance their customer experience with O-Possum.
The main cookies used are:
Google Analytics
Google Tag Manager
Facebook Pixel
Here is a description of the categories of cookies used.
Necessary cookies
These are cookies that are required to navigate and use the basic functions of our website. This type of cookie is activated by default, otherwise you will not be able to access the website.
Performance cookies
With performance cookies, the information collected is used to compile statistical reports on user activity, such as how often users visit our website, which pages they visit, for how long, the type of browser used, etc. We use the information obtained from performance cookies to help us improve our website. We use the information obtained from these analysis tools to monitor performance and improve our website and our products and services. These cookies are not enabled by default.
Targeted advertising cookies
Targeted advertising cookies collect information that can be used to personalize advertisements, evaluate the effectiveness of an advertising campaign and improve the products and services offered by O-Possum. These cookies are not activated by default.
Please note that we do not use third-party analytics tools to track or collect personally identifiable information. Furthermore, we do not associate any information gathered from statistical reports with a specific user.
Modification of preferences
Most web sites use cookies, and it’s safe to share information on the web site of a company you trust. You have control over what information is shared on the website, and you can change your preferences at any time.
Here are two options for modifying your cookie preferences:
Band displayed at the bottom of the screen on the website
Settings on your device or browser – Please refer to your device’s or browser’s instructions on this subject.
Advertising
We may allow certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect or use other data about users’ activities on the website. These companies may serve ads that may place cookies and track user behavior.
Social networking features
Our website may include social network features, such as Facebook and Instagram buttons, Share buttons, etc. (collectively, “social network features”). These social network features may collect your IP address, the page you visit on our website, and may set a cookie to enable the social network features to function properly. Social network features are hosted either by their respective providers or directly on our website. Your interactions with these social network features are governed by the privacy policies of their respective providers.
E-mail advertising
We offer electronic newsletters and advertising campaigns to which you may voluntarily subscribe at any time. We will keep your e-mail address confidential and will not disclose it to third parties, except as permitted in Section 6: Use of Personal Information or for the purpose of using a service provider to send such e-mails (see Section 9: Disclosure of Personal Information). We will retain information sent by e-mail in accordance with applicable laws and regulations.
In compliance with Canada’s anti-spam legislation, all e-mails we send will clearly indicate their origin and provide clear information on how to contact the sender. You may choose not to receive any further newsletters or promotional e-mails from us by following the unsubscribe instructions included in these e-mails or by contacting us by replying to the e-mail. However, you will continue to receive essential transactional e-mails.
Links to other resources
The website may contain links to other resources that we do not own or control. Please note that we are not responsible for the privacy practices of such resources. We encourage you to be aware when you leave our website and to read the privacy statements of each and every resource that may collect personal information.
Security of information provided
We secure the information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. We maintain reasonable administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of personal information in our control and custody. However, no data transmission over the Internet or a wireless network can be guaranteed.
Therefore, while we strive to protect your personal information, you acknowledge that :
There are security and privacy limitations of the Internet that are beyond our control.
The security, integrity and confidentiality of all information and data exchanged between you and the website and services cannot be guaranteed; and
Such information and data may be accessed or altered in transit by a third party, despite our best efforts.
Since the security of personal information depends in part on the security of the device you use to communicate with us and the methods you use to protect your identifying information, please take appropriate measures to protect such information.
Privacy incident
If we learn that the security of the website has been compromised or that users’ personal information has been disclosed to unauthorized third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate action, including, but not limited to, investigation and reporting, and notifying and cooperating with law enforcement authorities.
In the event of a privacy incident, we will make reasonable efforts to notify affected individuals if we believe there is a reasonable risk of harm as a result of the incident or if notice is otherwise required by law. If required, we will post a notice on the website and send an e-mail. In the event of an incident involving personal information that could cause serious harm, we undertake to notify the Commission d’accès à l’information as required by law.
In addition, we undertake to keep a register of confidentiality incidents, which may be communicated to the Commission d’accès à l’information upon request.
Policy changes
We reserve the right to change this Policy at any time, at our discretion. When we do so, we will change the update date at the bottom of this page. We may also notify you of changes to the Policy by e-mail.
The updated version of this Policy will be effective immediately upon posting of the revised Policy, unless otherwise specified. Your continued use of the website and the products and services offered by O-Possum after the effective date of the revised Policy constitutes implied consent to such changes.
However, we will not, without your consent, use your personal information in a manner materially different from that stated at the time your personal information was collected.
Persons responsible for the protection of personal information
The O-Possum Privacy Officer is responsible for the management of all data collected.
If you have any questions, concerns or complaints about this policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
info@o-possum.com
Acceptance of this policy
You acknowledge that you have read this policy and agree to all of its terms and conditions. By accessing the website, using the products and services offered by O-Possum or voluntarily submitting your personal information, you agree to be bound by this Policy. If you do not agree to be bound by the Policy, please do not access the website, use our products and services or provide us with any personal information.
This document was last updated on XXXXX
