PRIVACY POLICY

Last updated: August 29, 2024

Privacy Officer: Virginie Boivin, Partner and COO

Thank you for visiting the website of Groupe Videns Analytiques Inc. ("Videns"). This Privacy Policy applies to the website accessible at www.videns.ai (the "Website").‍

1. WHO WE ARE

For the purposes of this Privacy Policy (the "Privacy Policy"), references to Videns are to be understood as including its affiliated companies (including any subsidiaries), its divisions, and other companies within its corporate group, as well as its suppliers or licensors, and their respective employees, officers, directors, shareholders, agents, contractors, and other representatives.

This Privacy Policy has been developed on behalf of Videns: when we use the terms "we," "our," or "us" below, we refer to the Videns entity 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 inform you aboutour practices regarding the collection, use, disclosure, sharing, andmanagement of personal information provided on the Website or otherwisecollected in the course of Videns's activities. Our Privacy Policy alsodescribes the measures we take to protect the security of this information andhow you can access, modify, or delete your personal information. In addition tothis Privacy Policy, your visit to this Website is subject to (i) our WebsiteTerms of Use, accessible at https://www.videns.ai, and (ii) any other terms of use that may be communicated to you from time totime by Videns.

If you do not consent to the terms regarding our collection, use, disclosure, sharing, and management of personal information outlined 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 personal information you provide to us in various ways, including:

‍2.1 Through Direct Interactions

• Communicating with us via a form available on the Website;
• Communicating with us about the services and products we offer;
• Communicating with us to ask a question, provide feedback, or file a complaint (customer service);
• Subscribing to our mailing lists, email communications, and messaging services to receive updates and news;
• Applying for employment;
• Using social media.

2.2 Through Automatic Technologies or Interactions

When you use our Website, we automatically collect certain technical data (further detailed below) about your equipment and internet browsing. Our Website uses a technology called "cookies." A cookie is a small data file that our Website can send to your browser, which can then be stored on your computer’s hard drive to recognize you on future visits. We use cookies to understand which parts of our Website are useful and which parts need improvement, allowing us to plan enhancements to our Website. You can configure your browser to be notified when you receive a cookie or to refuse certain cookies. However, if you choose to refuse cookies from our Website, you may not be able to take full advantage of all the benefits and features of the site.

Our Website may also use a technology called "web beacons" or "invisible pixels". This technology allows us to understand which pages of our Website you visit. We use 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 clients, service providers, and business partners, and combine this information with the information we have collected about you.

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

• Perform remarketing, which involves displaying ads to individuals who have previously visited our Website on other websites, including through Google Analytics (an internet audience analysis tool). In such cases, the third parties involved, including Google, may display our ads on websites across the internet;
• Use the following features of Google Analytics: generating reports on the impressions recorded of our ads (i.e., a solution for placing ads across a range of news sites, blogs, and other specialized websites) to attract more potential customers; integration with any management tool comprising a set of features used for ad delivery, targeting, ad verification for our online and mobile ad campaigns, and related reports, and creating reports on internet users' demographics and interests;
• Collect, analyze, and/or aggregate your personal information (such as IP address, gender, age, and interests of internet users), including through creating reports on users’ demographics and interests, to help us understand how visitors interact with our Website and to improve our Website and our products and services. Remarketing companies may combine the use of first-party cookies (e.g., Google Analytics cookie) and third-party cookies (e.g., DoubleClick cookie) to (i) collect personal information; (ii) inform, optimize, and display ads based on your previous visits to our Website; and (iii) determine the relationship between visits recorded on our Website and ad impressions, other ad service uses, and interactions with these ad impressions and services. These companies may also use web beacons or invisible pixels to report certain information about your visits to our Website and to websites containing links to our site and advertising it, to measure the effectiveness of our ads.

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 times pent 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 when you visit the Web Site, including 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 aggregate 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 in order 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 collectpersonal information from you, if you do not provide such information uponrequest, 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 serviceyou have requested from us to the extent that your refusal makes it impossiblefor us to perform our obligations, but we will inform you if this is the caseat 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 interests and fundamental rights do not override those interests: a legitimate interest means Videns' 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 any of the Videns entities and individuals listed above and may also be shared internally to enable us to respond 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).Nécessaire en raison de nos intérêts légitimes (pour opérer notre entreprise et traiter les formulaires pour les fins visées).

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 for the purpose of asking a question, submitting a comment or making a complaint (customer service)‍

If you choose to send us an electronic feedback form or e-mail us 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

Occasionally, 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 similar application documents)
In connection with a job application or related inquiry, we use this information to process 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 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).
  

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‍Visiting our Web Sites - Technical Data
When you visit our Web Site, Videns will collect certain information about you. We collect the Internet Protocol (IP) addresses of all visitors to our Web Site, clickstream data, and other information such as the Web sites you visited immediately before and after ours, the pages you requested, your browser type, operating system, the Internet service provider you use, the number of times you visited our Web Site, and the date and average time you spent 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 about Videns' 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 customers (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

Unless expressly stated 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 Videns, including its staff, management, and marketing team members who need access to this information as part of their duties for Videns.

5.2 Exceptions

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

• Service providers, i.e., third parties (or otherwise make it available to them) that provide services on our behalf in Canada, the United States, or abroad, including Google, for the purpose of using the various Google Analytics features described herein. We provide our service providers with the information they need to perform their tasks, 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 judicial purposes. In other words, we and our third-party service providers may disclose your personal information to comply with a search warrant or other lawful request or order, or to respond to an investigative body in case of a contract violation or breach of law, or as otherwise required or authorized by law. We may also disclose personal information as necessary to assert or exercise legal claims or defend against such claims, or to prevent actual or suspected losses, or to avoid bodily harm or property damage; and/or
• Another entity in the event that we sell part or all of our business or if we sell or transfer assets or otherwise participate in a merger or business transfer. In such a case, we may transfer personal information about you to a third party as part of the transaction.

Our Website may contain links to other sites that are not owned or operated by Videns. Additionally, links to our Website may appear on third-party websites where we advertise. Except as provided herein, we will not disclose your personal information to these third parties without your consent. We provide users with links to third-party websites for convenience. These links are not intended to be endorsements or recommendations 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 do not control these websites, and therefore we cannot be held responsible for how the organizations operating these linked websites may collect, use, disclose, obtain, or otherwise process your personal information.

6. HOW WE PROTECT YOUR PERSONAL INFORMATION

We have established and implemented administrative, technical, and physical security measures to protect your personal information under our custody and control against unauthorized access, use, modification, and disclosure. We also take special steps to assess potential risks related to the disclosure of your personal information. In the event of a security breach—if your personal information is lost, disclosed without your consent, or becomes accessible to an unauthorized person—we will inform you of such a breach if it poses a real risk of significant harm. For example, a real risk of significant harm includes bodily harm, humiliation, loss of employment opportunities, financial loss, or identity theft. If the breach poses a real risk of significant harm, we will notify you directly as soon as possible. If we are unable to inform you directly, we will notify you of the breach through a public communication. We will provide the necessary information to help you understand the significance of the security breach and to take steps to reduce the risks of potential harm. We will also report the security breach to the government and any other organizations we believe can help mitigate the risk of harm resulting from the breach. We keep a record of all security breaches. Following a security breach, Videns investigates its causes and reviews the protection measures in place to prevent future breaches.

7. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We have established retention procedures designed to keep personal information only for as long as necessary to achieve the purposes outlined in this Privacy Policy or to comply with legal requirements.

Specific retention periods may vary depending on the nature of the data and the applicable legal obligations. For example, information related to financial transactions may be retained longer to comply with tax or accounting requirements. In the absence of specific retention periods, data will be destroyed or anonymized when its retention is no longer justified.

8. TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES

Your personal information will be accessible from Canada. In certain cases, your personal information may be collected, disclosed, used, or stored outside of Canada by any entities and individuals comprising Videns, a subsidiary, or a third-party service provider, and such personal information may be disclosed in accordance with the applicable laws in the respective territories. We will take all reasonably necessary steps 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 where the information is processed or stored. These laws may not offer the same level of protection as the Canadian or EEA privacy laws.

The described measures may include, but are not limited to, the use of standard contractual clauses approved by competent authorities or the application of adequacy decisions recognizing that the destination country provides an adequate level of protection. We are committed to ensuring that all data transfers comply with the applicable legal requirements and protect the privacy rights of the individuals involved.

9. CHANGES TO THE 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 process your personal information in accordance with the most recent version of the Privacy Policy.

10. HOW TO CONTACT US

We have appointed a Data Protection Officer responsible for overseeing matters related to this Policy. Videns has not currently designated 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 how we handle your personal information, including any requests to exercise your rights, or if you wish to request access to, update, or correct your personal information held by us, please contact our officer as follows:
Attention: Virginie Boivin, Partner and COO
Mailing Address: 2828 boulevard Laurier, Suite 700, Quebec (Quebec), G1V 0B9
Email: virginie.boivin@videns.ai

You may also withdraw your consent to the collection, use, and disclosure of your personal information at any time using the contact details above. However, if you withdraw your consent, we may no longer be able to respond to your requests, process any queries submitted to us, or otherwise assist you regarding the Website.

11. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You have the following rights regarding 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 check that we are processing it lawfully.
• Request correction or updating 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 to us.
• Request the deletion of your personal information: This allows you to ask us to delete or remove personal information where there is no valid reason for us to continue processing it. You also have the right to ask us to delete or remove 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 are required to erase your personal information to comply with applicable law. However, we may not always be able to comply with your request for deletion for specific legal reasons that will be notified to you, if applicable, at the time of your request.
• Object to the processing of your personal information: When we rely on our legitimate interests (or those of a third party), you may object to this processing if there is something in your particular situation that makes you believe that the processing impacts 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 demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, in which case we may decide to continue processing your personal information.
• Request the restriction of the processing of your personal information: This allows you to ask us to suspend the processing of your personal information in the following cases:
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  • If you want us to verify the accuracy of the information;
  • Where our use of the information is unlawful, but you do not want us to erase it;
  • If you need us to retain the information even if we no longer require it, as you need it to establish, exercise, or defend legal claims; or
  • ou have objected to our use of your information, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal information to yourself or a third party: We will provide you, or a third party you have chosen, with your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially consented to us using or where we used the information to perform a contract with you.
• Withdraw your consent at any time where we rely on your consent to process your personal information: However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services, which could prevent us from responding to inquiries, providing technical support, or assisting you in other ways in the use of our products and services. We will notify you if this is the case at the time you withdraw your consent.

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

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

If you wish to exercise one of the mentioned rights, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise your other rights). This is a security measure to ensure that personal information is not disclosed to someone who has no right to receive it. We may also contact you to request further information regarding your request to speed up our response.

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

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