Updated on September 12, 2023

Innovation Tootelo inc. (“Tootelo”, “we”, “us”, “our”), Telmatik’s parent company, greatly values privacy. That is why Tootely has implemented this personal information privacy policy ("Policy") with the purpose of providing a framework as to how Tootelo is to handle Personal information.

This Policy describes our practices regarding privacy and the protection of Personal information, including how we handle, collect, use and disclose your Personal information (defined below).

By visiting our web site telmatik.com (the "Website") or using any of our Services (as defined below), you agree that we can process, collect, use, transfer, disclose and retain your Personal information in accordance with the terms of this Policy. If you do not agree to abide by and be bound by the Policy, you may not visit, access or use the Website or the Services or share your Personal information with us.

This Policy does not apply to the Personal information of Tootelo's employees, representatives and consultants, or to any other person affiliated with Tootelo, as well as to any information that does not constitute Personal information as defined by law.
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1. DEFINITIONS

The following words and expressions, when appearing with a capital letter in the Policy, bear the meaning attributed to them hereinafter, unless implicitly or explicitly stated otherwise in the text: 

"Personal information" means any information that relates to a physical person and allows that person to be identified, as defined by the Loi sur la protection des renseignements personnels dans le secteur privé (Quebec - Act to protect personal information in the private sector) or by any other equivalent legislation in other jurisdictions. Generally speaking, information relates to a physical person and allows that person to be identified when it reveals, directly or indirectly, something about the identity, characteristics (for example, the abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour of the person in question) or activities of that person, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, audio, visual, computerized or other). 

"Privacy officer" means the person who is responsible for implementing this Policy and whose contact information is set out in section 2 of the Policy.

"Services" refers to the Website and its functionality as well as all related services offered online or in person by Tootelo, which could include a newsletter, customer service, contact (when you request to be contacted) and documentation made available to you.

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2. PRIVACY OFFICER
Questions relating to the Policy and Tootelo’s procedures in terms of privacy may be addressed to our Privacy officer at the following addresses and phone number:

Privacy officer: François Guérin, Pilot, Telmatik
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By phone: 450-655-1001

By email: confidentialite@tootelo.com (addressed to François Guérin, Privacy officer)

By mail: 500, d’Avaugour Street, office 2500, Boucherville (Quebec) J4B 0G6

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3. CHANGE IN POLICY

We reserve the right to update and modify this Policy at any time in accordance with the applicable law. In the event of a change, we will post the revised version of the Privacy Policy and update the last update date at the top of this page. We encourage you to review our Privacy Policy when you visit the Website to stay informed as to how we handle Personal information. If you do not agree with the updated terms of the Privacy Policy, we encourage you to stop using our Website and Services. Your continued use of our Website or Services following the posting of any changes to the Policy constitutes acceptance of those changes.

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4. PROCESS OF PERSONAL INFORMATION

4.1.  Collection of Personal information

As part of our activities, we may handle different types of Personal information, including the information listed below:

• contact details and personal information, such as your first and last name, postal address, e-mail address, telephone number, date of birth, preferred language (if you fill out our contact form or login to your client account);
  

• information that you choose to provide or transmit to us, for example, when you fill in a form, respond to surveys or communicate with one of our employees, such as your preferences and interests;

• information collected automatically when you use the Website and our Services, including:

• login information and other information about your activities on the Website, such as your IP address, the pages you visit, the time and date of your visits, the type of browser you use, the operating system of your device and other hardware and software information;

• geolocation data, such as your IP address, a precise or approximate location based on your IP address or the GPS of your mobile device (depending on your device and browser settings).

4.2.  Use of Personal information

‍As part of our activities, we may handle different types of Personal information, including the information listed below:

• to operate, administer, maintain, monitor, develop, improve and provide all the features of our Website;
• to provide you with Services and to ensure the proper functioning of the Website;
• to improve our Services and develop new Services and Website features;
• to send you messages, updates, security alerts and account notifications for marketing and business development purposes, if you have previously consented to the processing of your Personal information for such purposes;
• to answer your questions and provide you with assistance when necessary;
• to collect notices, comments, questions, requests and complaints regarding our Services and Website;
• to perform research and analysis relating to our business and Services;
• to detect and prevent fraud, error, spam, abuse, security incidents and other harmful activities; 
• to send you communications as required by law;
• to reorganize or change the structure of our business;
• for any other purpose permitted or required by law.

Please note that we do not use the information we collect to draw any inferences or interpretations. 

4.3.  Communication of Personal information

We may communicate your Personal information to our employees, contractors, consultants, agents, service providers and other trusted third parties (collectively, "Service providers"), who require such information to assist us in operating our Website, conducting and protecting our business, or serving you, provided that such Service providers have previously agreed in writing to protect the confidentiality of your Personal information in accordance with applicable laws and our information governance program.

‍We do not sell, trade or otherwise disclose your Personal information to third parties, subject to exceptions provided by law or unless we have obtained your prior consent.

4.3.1. Service providers and other third parties

Although we try to avoid disclosing your Personal information to third parties, some products and services offered through Tootelo may be provided or performed by service providers on our behalf. In order to provide you with the products or services you seek, we may need to communicate or transfer information about you to these third parties in various situations. We have set out below the circumstances in which sharing information may take place:

Google Analytics - We use this to analyse the website's audience and traffic. See their privacy policy;

Google Tag Manager - We use it to manage tracking codes and code fragments ("tags"). See their privacy policy;

Google Ad Manager - We use this tool as an online ad management platform. See their privacy policy;

Google API - We use APIs to allow communication with Google Services and integration to other services (ex.: Search, Gmail, Translate or Google Maps). See their privacy policy;

Meta (Facebook) - We use this to promote our services. See their privacy policy;

JQuery - We use this JavaScript library to develop and run the Website. See their privacy policy; 

CloudFare - We use it to enhance the security, performance and reliability of the Website. This is their privacy policy.

Microsoft Dynamics - We use it to automate processes, analyze data and build apps. See their privacy policy.

We establish written contracts with our Service providers before disclosing your Personal information to them and we only provide them with the Personal information they need to perform their duties. As part of these contracts with our Service providers, we are committed to ensuring that the principles set out in this Policy are observed, and these Service providers are required to use Personal information as directed by us and only for the purposes for which it was provided. In addition, these Service providers provide us with sufficient assurances that they will implement appropriate security measures that are consistent with the sensitivity of the Personal information being processed or communicated. When our Service providers no longer require your Personal information, we require them to destroy this data in an appropriate manner.

4.3.2. Compliance with legislation, responding to legal requests, preventing harm and protecting our rights

‍We may disclose your Personal information when we believe that such disclosure is permitted, necessary or appropriate, including:

• to comply with requests from public and government authorities, including public and government authorities outside your country of residence;
• to protect our business;
• to comply with legal proceedings;
• to protect our rights, privacy, safety, property, or those of our affiliates, yours, or those of third parties;
• to allow us to enforce available recourses or limit the damages we may suffer; and
• to comply with applicable laws, including laws outside your country of residence.

4.3.3. Commercial transactions

We may share, transfer or communicate, strictly in accordance with this Policy, your Personal information in the event of the sale, transfer or assignment, in whole or in part, of Tootelo or our assets (for example, as a result of a merger, consolidation, change in control, reorganization, bankruptcy, liquidation or any other business transaction, including as part of the negotiation of such transactions). In such cases, we will notify you before your Personal information is transferred and is governed by a different privacy policy.

4.4.  Consent

‍We will only use your Personal information for the purposes for which it was collected in accordance with this Policy. We will seek your consent before using your Personal information for purposes other than those set out herein, subject to exceptions provided by the law, including when the new proposed use is consistent with the purpose for which the Personal information was originally collected.

Whenever possible, Tootelo obtains consent directly from the individual in question for us to collect, use and communicate their 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 in addition to having obtained their consent to such disclosure.

 4.5.  Retention of Personal information

We retain your Personal information only for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. If you would like more information about the periods during which your Personal information will be retained, please contact our Privacy officer.

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5. YOUR RIGHTS

As a person subject to this Policy, you may exercise the rights set out below by sending a written request by e-mail or by mail to the attention of our Privacy officer at the contact information provided in section 2 of the Policy:

• You have the right to be informed of the Personal information we have collected about you, and information about the purposes for which we have used and are using your Personal information;
• You have the right 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 have about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
• You have the right to request the deletion of your Personal information if the collecting such information is not permitted by law;
• You have the right at any time to withdraw or change your consent to our processing of your Personal information, subject to applicable legal and contractual restrictions. In some instances, withdrawing your consent may result in Tootelo no longer being able to provide you with certain products or services, as applicable;
• You have the right to ask us to stop disseminating your Personal information and to de-index any link connected to your name that provides access to such information if such dissemination violates the law or a court order;
• You have the right to request that your Personal information be provided to you or transferred to another organization in a structured and commonly used technological format;
• You have the right to make a complaint to the appropriate privacy authority, subject to the conditions set out in the applicable law. To file a complaint with the Commission d'accès à l'information (Québec - Information Access Commission), please use the appropriate form available at the following address: https://www.cai.gouv.qc.ca/english/ 

In order to process your request, you may be asked to provide appropriate identification or other identification. We will do our best to respond within a month.

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6. COOKIES AND OTHER TRACKING AND PROFILING TECHNOLOGIES

We use cookies and other tracking or profiling technologies (collectively, "Cookies") when you access or use our Website, unless you have set your browser or device to block some or all Cookies. These Cookies help us to operate, protect and optimize the Website, improve the Services and customize your browsing experience according to your interests. Cookies are small text files that a website stores on your computer, mobile device or web browser when you first access a website. Cookies are used to collect, store and transmit identifiers, image files and other information, such as your language preference, IP address, browser type and version, the type of device you are using and your device's unique identifier, which allow the website operator to recognize your device and browsing preferences and to pre-fill forms or certain required fields during future visits.

While some of the Cookies we use are deleted at the end of each of your browsing sessions, other Cookies are persistent and are stored on your device or browser for the length of time defined in the relevant Cookie file to allow us to recognize your browser the next time you visit the Website.

Trusted third parties, such as Google Analytics or other similar Service providers, may also use Cookies to collect this data for us in accordance with their privacy policies.

Most of the information collected through Cookies is generic and does not directly identify you. Such information allows us, among other things, to ensure the functioning and security of the Website, to improve your browsing experience and to better understand the traffic and interactions that take place on it. Cookies do not cause any physical damage to your computer or device and are not used to extract your Personal information.

6.1.  Management and deletion of Cookies

You can change your browser's Cookie settings, delete Cookies and enable additional privacy settings. This includes disabling Cookies altogether by going to your browser's "Options", "Settings", "Preferences" or "Help" menu, as available. The following links may help you better understand how to manage Cookies depending on the browser you are using:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

You can opt out of personalized advertising by enabling your mobile device's privacy features, such as "Limit Ad Tracking" and "App Tracking Transparency" (iOS) and "Opt Out of Ads Personalization" (Android) to block all Cookies. 

You can opt out of having information about your activities on our website shared with Google Analytics by installing the Google Analytics Opt-out Browser Add-on on your browser. This add-on prevents the Google Analytics JavaScript code (ga.js, analytics.js and dc.js) inserted on websites from sharing information about your visits to Google Analytics.

You can opt out of interest-based Facebook ads by following Facebook's instructions. For information on how Facebook interest-based ads work, click here.

You can also opt out of network advertising programs that track your activities on various websites in order to provide you with personalized advertising content. To learn more, please visit the following pages:

Vous pouvez refuser que des informations sur vos activités sur notre Site web soit partagées à Google Analytics en installant sur votre navigateur le module de navigation complémentaire pour la désactivation de Google Analytics. Ce module empêche le code JavaScript de Google Analytics (ga.js, analytics.js et dc.js) inséré sur les sites Web de partager à Google Analytics des informations concernant vos visites.

• Association of Canadian Advertisers 
• Network Advertising Initiative
• Opting out of targeted advertising (AdChoices)

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7. SECURITY MEASURES

Tootelo implements a series of reasonable physical, administrative, 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, modification or destruction. These measures include encryption, a firewall, access control and confidentiality agreements with our Service providers, etc.

Tootelo reviews its security measures and procedures on a regular basis and modifies them as needed. 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 protected, please contact our Privacy officer immediately using the contact information provided in section 2 above.

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8. LINKS TO THIRD PARTY SERVICES

We may occasionally include on the Website references or links to websites, content, products or services provided by third parties (the "Third party services"). These Third party services, which are not operated or controlled by Tootelo, are governed by privacy policies that are entirely separate and independent from ours. Therefore, we do not assume any responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services we offer and therefore does not extend to websites, content, products or services provided by third parties.

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9. CHILDREN UNDER THE AGE OF 14

We do not knowingly collect or use Personal information from children under the age of 14. If you are under 14 years of age, you must not provide us with your Personal information without the consent of your parent or guardian. If you are a parent or guardian and become aware that your child has provided us with Personal information without your consent, please contact our Privacy officer using the contact information in Section 2 above to request that we delete that child's Personal information from our systems.

In addition, only a parent or legal guardian of a child under the age of 14 may access or amend the child's Personal information. For this purpose, we may request any relevant documentation from the parent or legal guardian, such as a copy of any custody and access agreement or related court order, to process any access or amendment request.

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10. CONTACT US

 Any questions, requests, comments, complaints or concerns regarding this Privacy Policy, our privacy practices or your Personal information should be directed to our Privacy officer at the contact information provided in Section 2 of this Policy.

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