Privacy policy

General Information
1. Introduction
  Protecting your privacy is important to Alteo Inc. (hereinafter "Alteo", "we", "our"). This is why we have implemented safeguards and sound management practices to maintain the confidentiality and security of your personal information in accordance with applicable laws.
  
  This privacy policy (the "Policy"), describes our practices regarding the collection, use, processing, disclosure, and retention of Personal Information (as defined below) of our clients, applicants, visitors and users.
  
  By using our website www.alteo.ca (the "Website") or any of our Services, you agree that we may collect, use, process, disclose and retain your Personal Information in accordance with the terms and conditions described herein. If you do not agree to comply with and be bound by this Policy, you may not visit, access, or use our Website or Services or share your Personal Information with us. However, we invite you to contact our Privacy Officer to discuss an arrangement that may be suitable for you.
  
  This Policy does not apply to Personal Information of Alteo's employees, agents, and consultants, or any other person affiliated with Alteo, or to any information that is not Personal Information as defined by applicable law.
2. Data Protection Officer
  If you have any questions, comments, or complaints regarding our privacy practices and policy, please contact our Data Protection Officer (as defined below) at the following address:
  Email: privacy@alteo.ca
  Address: 765 rue Beaubien Est, CP 176, Montréal QC H2S 1S8
Definitions
The following words and expressions, when appearing with a capitalized first letter in the Policy, shall have the meanings set forth below, unless otherwise implied or expressed in the text:
"Data Protection Officer" means the person who is responsible for the enforcement and the implementation of this Policy and whose contact information is identified in Section 1.2 above.
"Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could be linked, directly or indirectly, to a person, whatever the nature of its medium and whatever the form in which the information is accessible (written, graphic, sound, visual, computerized or other). Personal Information includes, but is not limited to, information that reveals something about the identity, characteristics (e.g., the abilities, preferences, psychological tendencies, predispositions, mental abilities, character, and behavior), or activities of that person.
"Sensitive Personal Information" means Personal Information that, by its nature or the context of its use or disclosure, gives rise to a reasonable expectation of privacy. Examples include biometric, genetic or financial information, or information about life or sexual orientation, religious or philosophical beliefs, union membership or ethnic origin.
"Service Provider" means any person or entity that processes data on behalf of Alteo. These are third-party companies or individuals with whom Alteo contracts to facilitate the Services, to provide the Services on behalf of Alteo, to perform services related to the Services or to assist Alteo in analyzing the use of the Services.
"Services" means the Website and all related services offered by Alteo, including professional services and, where applicable, associated media, printed materials, and "online" or electronic documentation.

Processing of Personal Information

Collection of Personal Information

You consent to share your personal information with us

Alteo values your privacy and the confidentiality of your data. 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 contractors or third parties.

By consenting, you authorize Alteo to collect and process your personal information as necessary to provide our services to you. Please be aware that you remain in control of your personal information at all times and that the consent you give us at the time of collection or processing of your personal information may be withdrawn at any time. We will ensure that we respect your choice in accordance with our legal obligations.

We may collect different types of Personal Information while operating our business and providing our Services. These include, but are not limited to:

Via our Website or Forms

●	Contact information, such as your first and last name, address, e-mail address, and telephone number;
●	Information automatically collected through the use of our Website and Services, including;
●	professional or employment-related information, such as your resume, place of employment, government titles or positions, employers, business ownership, salary or self-employment income, as well as information with respect to your criminal history and other information you provide to us when you apply for employment with Alteo;
●	Information you choose to provide or share with us, for example, when you fill out a form, respond to surveys or contact one of our employees or representatives, including your preferences or interests.

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. If there is any subsequent use of your Personal Information, we will notify you as required by law.

Use of Personal Information

As stated in Section 3.1, we only use your Personal Information as permitted by law. We may use your Personal Information for the legitimate purposes described below:

●	To provide Services to you;
●	To verify your identity and review your background as permitted by law;
●	Operate, administer, maintain, monitor, develop, improve and provide all the features of our Website;
●	To manage risks and activites;
●	To meet 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 you messages, updates, security alerts;
●	Answer your questions and provide assistance when needed;
●	Administer a contest, promotion, survey, or other feature of the Website or our Services;
●	Collect opinions and comments about our Services;
●	Conduct research and analysis related to our business and Services;
●	Detect and prevent fraud, errors, spam, abuse, security incidents, and other harmful activities;
●	Establish, exercise or defend a right or proceeding in court;
●	Send you communications as required by law; and
●	Enable an individual to apply for employment with Alteo.
●	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. This Personal Information is disclosed only when we have a legal obligation to do so.

The Personal Information we collect and maintain is securely stored on the third party servers listed in section 3.3.1 below which are located in the United States. Please be assured that this Personal Information is disclosed only when we have a legal obligation to do so.

Disclosure of Personal Information

We may disclose your Personal Information to our employees, contractors, consultants, agents, Service providers and other trusted third parties who need to know that information in order to help us operate our Website, conduct and protect our business, or serve you, provided that such Service Providers have previously agreed in writing to maintain 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.

Service providers and other third parties
While we try to avoid sharing your Personal Information with third parties, we may use Service Providers to perform various services on our behalf, such as IT management and security, marketing, and data analysis, hosting and storage. We have defined below the instances in which such sharing may occur:

●	We use CATS to track and manage your application on our website. Check out their privacy policy.
●	We use Dropbox services to store and share files with our customers. Check out their privacy policy.
●	We use the services of LinkedIn to receive and transmit job postings. View their privacy policy.
●	We use the services of Indeed to receive and transmit job postings. View their privacy policy.

When we disclose your Personal Information to Service Providers, we enter into written contracts with them before your Personal Information is disclosed to them and we provide them with only the Personal Information that is necessary to perform their mandate. As part of these contracts with our Service Providers, we are committed to the principles set out in this Policy 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 guarantees that they will implement appropriate safeguards that are proportionate to the sensitivity of the Personal Information being processed or disclosed. When our Service Providers no longer need your Personal Information, we require them to destroy such data appropriately.

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 authorized, necessary, or appropriate, including:

●	To respond to requests from public and government authorities, including public and government authorities outside your country of residence;
●	To protect our operations and business;
●	To comply with legal proceedings;
●	to protect our rights, privacy, safety, property, or those of you or others;
●	to allow us to seek available remedies or limit the damages we may suffer; and
●	in accordance with applicable laws, including laws outside your country of residence.

Commercial 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 Alteo 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 cases, we will notify you before your Personal Information is transferred and is governed by a different privacy policy.
Consent
Wherever possible, Alteo obtains directly from the person concerned consent to collect, use and disclose their Personal Information. However, if you provide us with Personal Information about other individuals, you must ensure that you have properly notified them that you are providing their Personal Information to us and 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 set out herein.
Retention of Personal Information
Subject to applicable laws, we keep your Personal Information only for the time necessary to fulfill the purposes for which it was collected unless you consent to have your Personal Information used or processed for another purpose. In addition, our retention 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).

For more information about our retention periods, please contact our Data Protection Officer using the contact information provided in Section 1.2 of this Policy.

Your Rights
As a data subject, you may exercise the rights set out below by sending an e-mail or by mail to the attention of our Data Protection Officer at the contact information provided in Section 1.2 above:

●	You have the right to be informed about the collection and use of your Personal Information and to request a paper copy of the documents containing your Personal Information, subject to certain exceptions provided by applicable law;
●	You have the right to have Your Personal Information corrected, amended, and updated if it is incomplete, ambiguous, out of date, or inaccurate;
●	You have the right to withdraw or change your consent to our processing of your Personal Information at any time by using the form here, subject to applicable legal and contractual restrictions;
●	You have the right to ask us to stop disclosing your Personal Information and to de-index any link attached to your name that provides access to that information if such disclosure violates the law or court order;
●	You have the right to request that your Personal Information be disclosed to you or transferred to another organization in a structured, commonly used technological format;
●	You have the right to make a complaint to the appropriate data protection authority, subject to the requirements of applicable law.

To process your request, you may be asked to provide appropriate identification or otherwise identify yourself. We will do our best to respond within thirty (30) days.

If you are not satisfied with our use of your Personal Information or our response to any exercise of these rights, you have the right to complain to the relevant data protection authority.

Security Measures
Alteo implements a range of reasonable physical, technological and organizational security measures to adequately protect the confidentiality and security of your Personal Information against loss, theft, or unauthorized access, disclosure, copying, communication, use, modification, or destruction. These measures include encryption, access control, segregation of duties, internal audit, and confidentiality agreements with our Service Providers, etc.

Among the various measures put in place:

●	Our Website has a Secure Sockets Layer (SSL) protocol that ensures a secure connection between your device and our server;
●	Alteo employees have read this Policy and are committed to comply with it and to respect the confidentiality of Personal Information about our potential and existing clients. In addition, each employee is committed to following and respecting a data governance policy applicable to all Alteo personnel;
●	We have implemented access measures to Personal Information that limit access only to those individuals who have a valid reason to view, process, communicate or otherwise use your information;
●	Companies and third parties who do business with Alteo and with whom we may need to share your Personal Information have previously agreed to protect the confidentiality and privacy of that information.
●	When the purpose for which your Personal Information was collected is satisfied and we no longer need to retain it, Alteo will destroy or anonymize it, 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 information provided in Section 1.2 above.

Updating Our Privacy Policy
We reserve the right to update and modify this Policy at any time in accordance with applicable law. If we make any changes, we will post the most current version of the Policy on our Website and update its version number and date, which can be found on the footer of the Policy. We, therefore, encourage you to review our Privacy Policy when you visit the Website to stay informed of how we are using Personal Information. If you do not agree with the new terms of the Privacy Policy, we invite you to stop using our Website and Services. Your continued use of or access to the Website following the posting of any changes constitutes acceptance of those changes.
Links to Third-Party Websites
We may from time to time include on our Website references or links to websites, content, products, or services provided by third parties ("Third-Party Services"). These Third-Party Services, which are not operated or controlled by Alteo, are governed by privacy policies that are entirely separate and independent from this Policy. We, therefore, assume no responsibility for the content and activities of these websites. This Policy applies only to the Website and the Services we offer. The Policy does not extend to any Third-Party Services.
Limitation of Liability
Alteo undertakes to take all reasonable steps to ensure a level of confidentiality and security of Personal Information that meets the 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 agree that Alteo 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 agree to waive any claim in this regard, except in the case of gross negligence or intentional misconduct on the part of Alteo. Accordingly, you agree to hold Alteo and its officers, directors, affiliates and business partners harmless from any damages of any kind, whether direct or indirect, incidental, special or consequential, arising out of the use of your Personal Information.

In the event of a breach of confidentiality or security of your Personal Information that poses a high risk to your rights and freedom, you will be notified of such breach as soon as possible, and Alteo will take appropriate steps to preserve the confidentiality and security of your Personal Information in accordance with the applicable Law.
Individuals under the age of 14
We do not knowingly collect or use Personal Information from individuals under the age of 14. If you are under the age of 14, you must not provide us with any of your Personal Information without the express 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 express consent, please contact us using the contact information provided in Section 1.2 above to request that we delete that child's Personal Information from our systems.
Juridiction
This Policy and your use of the Website are governed by the laws of the Province of Quebec and the laws of Canada applicable therein, excluding its conflict of law rules.

In the event of a disagreement between you and Alteo regarding the application of this Policy or any matter relating to your Personal Information, we invite you to first contact us in the manner provided herein. We will make every effort to reach an amicable resolution and to find an appropriate solution to the situation, without prejudice to the right of either party to resort to the courts in the manner and at the time it deems appropriate.
Contact Us
Any questions, comments, requests, or concerns regarding this Privacy Policy should be directed to our Data Protection Officer at the contact information provided in Section 1.2 of this Policy.