le pouvoir d'augmenter

Privacy Notice

Last updated on February 1, 2023

This privacy notice for Exom Inc. (” Company,” ” We,” ” Us,” or ” Our “) describes how and why we may collect, store, use, and/or share (” process “) your information when you use our services (” Services “), for example when you:

Questions or concerns?

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at vieprivee@exom.ca.

Summary of key points

This summary provides the key points of our privacy notice, but you can find more detail on any of these topics by clicking on the link following each key point or by using our table of contents below to find the section you are looking for. You can also click
here
to go directly to our table of contents.

What personal information do we process?

When you visit, use or browse our Services, we may process personal information based on how you interact with Exom Inc. and the Services, the choices you make and the products and features you use. Click here to learn more.

Do we process sensitive personal information?

We do not process sensitive personal information.

Do we receive information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.

In what situations and with what types of parties do we share personal information?

We may share information in specific situations and with specific categories of third parties. Click here to learn more.

How do we protect your information?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security, collect, inappropriately access, steal or alter your information. Click here to learn more.

What are your rights?

The easiest way to exercise your rights is to fill out our data subject request form available here: https: //exom.ca/formulaire/vieprivee, or to contact us. We will review and act on any requests in accordance with applicable data protection laws.

What information do we collect?

Personal information you disclose to us.

In a nutshell

We collect the personal information you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise contact us.

Personal information provided by you.

The personal information we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

  • names,
  • phone numbers,
  • addresses, emails,
  • contact preferences,
  • billing addresses,
  • debit/credit card numbers.

Sensitive information.

We do not process sensitive information.

Payment data.

We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Stripe. You can find their privacy notice link(s) here: https: //stripe.com/privacy.

Social media login data.

We may offer you the opportunity to register with us using your existing social network account details, such as your Google, Microsoft or other social network account. If you choose to register in this manner, we will collect the information described in the section entitled ” How we manage your social connections ” below.

All personal information you provide to us must be true, complete and accurate, and you must inform us of any changes to such personal information.

Information collected automatically

In a nutshell

Certain information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or browse the Services. This information does not reveal your specific identity (such as your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, as well as for our internal analysis and reporting.

The information we collect includes:

  • Log and usage data. Logging and usage data is service, diagnostic, usage and performance information that our servers automatically collect when you access or use our Services and that we store in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings and information about your activity on the Services (such as time stamps associated with your use, pages and files viewed, searches and other actions you take, such as features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”) and hardware settings).
  • Location data. We collect location data such as information about the location of your device, which may be accurate or inaccurate. The amount of information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You may refuse to allow us to collect this information by either denying access to the information or disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

How do we process your information?

In a nutshell

We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so that you can create and log in to your account, as well as maintain your account in working order.
  • To protect our Services. We may process your information as part of our efforts to ensure the security of our Services, including monitoring and preventing fraud.
  • Identify usage trends. We may process information about how you use our Services to better understand how they are used so that we can improve them.
  • To safeguard or protect the vital interest of an individual. We may process your information where it is necessary to safeguard or protect the vital interests of an individual, for example to prevent harm.

On what legal basis do we process your information?

In a nutshell

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. a legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide services to you, to enter into or fulfill our contractual obligations, to protect your rights, or to satisfy our legitimate business interests.

If you live in the EU or the UK, this section applies to you.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal basis on which we process your personal information. As such, we may rely on the following legal bases for processing your personal information:

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for specific purposes. You may withdraw your consent at any time. Click here to learn more.
  • Legitimate interests. We may process your information where we believe that it is reasonably necessary to do so to achieve our legitimate business interests and that these interests do not override your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described to:
    • Analyze how our Services are used so that we can improve them to engage and retain users
    • Diagnose problems and/or prevent fraudulent activities
  • Legal obligations. We may process your information when we believe it is necessary to do so to comply with our legal obligations, such as cooperating with a law enforcement agency or regulatory body, exercising or defending our legal rights, or disclosing your information as evidence in a dispute in which we are involved.
  • Vital interests. We may process your information when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you reside in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for specific purposes, or in situations where your permission can be inferred (i.e. implied consent). You may withdraw your consent at any time. Click here to learn more.

In certain exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If the collection is clearly in the interests of an individual and consent cannot be obtained in a timely manner
  • For investigation, detection and prevention of fraud
  • For commercial transactions provided certain conditions are met
  • If contained in a witness statement and the collection is necessary to assess, process or settle an insurance claim
  • To identify injured, ill or deceased persons and contact next of kin
  • If we have reasonable grounds to believe that an individual has been, is being or may be financially exploited
  • If the collection and use with consent could reasonably be expected to compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is necessary to comply with a subpoena, warrant, court order or court rules relating to the production of documents
  • If it was generated by an individual in the course of his or her employment, business or profession and the collection is consistent with the purpose for which the information was generated
  • If the collection is solely for journalistic, artistic or literary purposes
  • If the information is publicly available and is specified by regulation

When and with whom do we share your personal information?

In a nutshell

We may share information in specific situations described in this section and/or with the following categories of third parties.

Third party suppliers, consultants and other service providers. We may share your data with third party vendors, service providers, contractors or agents (“third parties”) who perform services for us or on our behalf and who need access to this information to perform this work. We have contracts in place with our third parties that are designed to help protect your personal information. This means that they cannot do anything with your personal information unless we have asked them to do so. They will also not share your personal information with any organization other than us. They also agree to protect the data they hold on our behalf and to keep it for the length of time we request. The categories of third parties with whom we may share personal information are as follows:

  • Data analysis services (e.g. Google Analytics)
  • Payment processors (e.g. Stripes)
  • Financial and accounting tools (e.g. Quickbook)

We may also share your personal information in the following situations:

  • Transfer of business. We may share or transfer your information as part of or during negotiations for any merger, sale of company assets, financing or acquisition of all or part of our business to another company.

How do we manage your social connections?

In a nutshell

If you choose to register or sign in to our Services using a social network account, we may have access to certain information about you.

Our Services provide you with the ability to register and log in using your third-party social media account details (such as your Facebook or Twitter credentials). When you choose to do so, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the particular social media provider, but will often include your name, email address, list of friends and profile picture, as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes described in this Privacy Notice or otherwise specified to you on the relevant Services. Please note that we do not control and are not responsible for any other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and applications.

Is your information transferred internationally?

In a nutshell

We may transfer, store and process your information in countries other than your own.

Our servers are located in Canada and the United States. If you access our services from outside Canada and the United States, please be aware that your information may be transferred to, stored and processed by us at our facilities and by third parties with whom we may share your personal information (see ” When and with whom do we share your personal information? The Company is not responsible for the content of its products (e.g., the products in the “above” category), in Canada, the United States and other countries.

If you reside in the European Economic Area (EEA) or the United Kingdom (UK), these countries may not have data protection or similar laws that are as comprehensive as those in your country. However, we will take all necessary steps to protect your personal information in accordance with this privacy notice and applicable law.

How long do we keep your information?

In a nutshell

We retain your information for as long as necessary to fulfill the purposes described in this privacy notice, except as otherwise required by law.

We will retain your personal information only as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other requirements). No purpose of this notice will require us to retain your personal information for more than three (3) months after the termination of the user’s account.

When we no longer have a legitimate business need to process your personal information, we will delete or anonymize that information, or, if that is not possible (for example, because your personal information has been stored in a backup archive), securely store your personal information and isolate it from further processing until deletion is possible.

How do we keep your information secure?

In a nutshell

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. While we do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services in a secure environment.

Do we collect information from minors?

In a nutshell

We do not knowingly collect data and our Services do not target children under the age of 18.

We do not knowingly collect data and our Services do not target children under the age of 18. By using the Services, you represent that you are at least 18 years of age or the parent or guardian of such a minor and consent to the use of the Services by such dependent minor. If we learn that personal information of users under the age of 18 has been collected, we will deactivate the account and take reasonable steps to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at vieprivee@exom.ca.

What are your privacy rights?

In a nutshell

In some regions, such as the European Economic Area (EEA), the United Kingdom (UK) and Canada, you have rights that give you greater access to and control over your personal information. You may review, modify or terminate your account at any time.

In some regions (such as the EEA, the UK and Canada), you have certain rights under applicable data protection laws. These may include the right to (i) request access to and obtain a copy of your personal information, (ii) to request rectification or deletion; (iii) to restrict the processing of your personal information; and (iv) where applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You may make such a request by contacting us using the contact information provided in the ” How can you contact us about this notice? ” section below.

We will review and act on any requests in accordance with applicable data protection laws.

If you are in the EEA or the UK and you believe that we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact information here: https: //ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you live in Switzerland, the contact details of the data protection authorities are available here: https: //www.edoeb.admin.ch/edoeb/fr/home.html.

Withdrawing your consent

If we rely on your consent to process your personal information, which may be express and/or implied consent under applicable law, you have the right to withdraw your consent at any time. You may withdraw your consent at any time by contacting us using the contact information provided in the ” How can you contact us about this notice? ” section below or by updating your preferences.

However, please note that this will not affect the lawfulness of the processing prior to its withdrawal or, where permitted by applicable law, the processing of your personal information carried out on lawful processing grounds other than consent.

Unsubscribe from marketing and promotional communications

You may unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails we send, or by contacting us at the contact information provided in the ” How can you contact us about this notice? ” section below. You will then be removed from the marketing lists. However, we may still contact you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-commercial purposes.

Account Information

If at any time you wish to review or change your account information or terminate your account, you may:

  • Login to your account settings and update your user account.
  • Contact us using the details provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain certain information in our files to prevent fraud, resolve problems, assist in any investigation, enforce our legal terms and/or comply with applicable legal requirements.

If you have any questions or comments about your privacy rights, you can email us at vieprivee@exom.ca.

Commands for the functions do not follow

Most web browsers and some mobile operating systems and applications include a “Do-Not-Track” (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data monitored and collected about your online browsing activities. At this stage, no uniform technology standard for the recognition and implementation of DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If an online tracking standard is adopted that we must follow in the future, we will notify you of that practice in a revised version of this privacy notice.

Do we make any updates to this notice?

In a nutshell

Yes, we will update this notice as necessary to remain in compliance with applicable laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “revision” date and the updated version will become effective as soon as it is available. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by sending you a notice directly. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have any questions or comments about this notice, you can email us at vieprivee@exom.ca or mail us at :

Exom Inc.
554 Route 275
Saint-Zacharie, Quebec G0M 2C0
Canada

Table of contents