Introduction
In accordance with the Act Respecting the Protection of Personal Information in the Private Sector (CQLR c P-39.1) as amended by the Act to Modernize Legislative Provisions respecting the Protection of Personal Information, CENTRALIO TECHNOLOGIES INC. (hereinafter referred to as “Centralio,” “we,” or “our”) implements measures to protect data, personal information, and non-personal information (collectively referred to as “Information”) relating to users and subscribers of our website (https://centralio.com/) and our Centralio platform (https://app.centralio.com/ or other subdomains) (collectively referred to as the “Services”).
This privacy policy governs our privacy practices concerning the Information you voluntarily share with us when using the Services (hereinafter the “Policy”) and aims to inform you about:
- The Information we collect from you and its purposes;
- How we use your Information and with whom we may share it;
- Your choices regarding the collection and use of Information;
- The types of security procedures in place to protect your Information;
- How you can access and/or correct inaccurate Information;
- How your Information is stored and destroyed;
- How to contact us for questions, comments, or complaints.
When you provide us with Information via the website, Centralio platform, support system, email, phone, or other means, you consent to its processing in accordance with this Policy.
We limit the Information we collect to what is necessary to: (i) enable you to use Centralio’s Services (e.g., client account, application, quotes, and forms); (ii) allow us to communicate with you, personalize the content of our Services, and improve them by analyzing how you and other users interact with the Services.
What Personal Information Do We Collect and Why?
We collect two (2) categories of personal and non-personal information: (1) information you provide to us; and (2) information automatically collected when you use our Services.
Information you provide includes, but is not limited to:
- Your name and contact details (email address, postal address, phone number);
- Additional information about you (gender, location, preferred language);
- Your exchanges and communication history with us (service call recordings, chats and instant messages, interactions with our representatives or on social media);
- Business-related information (products, services, pricing, contacts, configurations, quotes, feedback, notes, and other user-generated content).
Information automatically collected when you use or visit our Services:
- Log data and device information (details about your use of the Services, time spent, IP address, visit time and date, hardware and software information, device information, event data, unique identifiers, crash data, cookie data, location data, and pages viewed or clicks);
- Geolocation data (IP address, browser data, or GPS data);
- Cookies and similar technologies (web beacons, pixels, and mobile identifiers).
Why Do We Collect Information and With Whom Do We Share It?
The purposes for collecting information are outlined in the previous section. We also collect Information for the following reasons:
- To provide advice and Services;
- To respond to your inquiries;
- To comply with legal and regulatory requirements related to personal information protection;
- To develop, improve, and promote our Services;
- To facilitate the use of our Services;
- To maintain our databases and administration systems;
- To send you informational communications.
We will notify you and ensure your consent before collecting, using, or disclosing any Information for purposes other than those listed above, if applicable.
We may engage external companies to provide services (e.g., hosting the Services or analyzing anonymous data). We may share your Information with such service providers to enable them to deliver the requested services. These providers are contractually bound to confidentiality and the protection of your Information as we are, and you agree that we may share such Information with them for these purposes.
We may also disclose your Information if we believe it is required under applicable Canadian or Quebec laws to comply with legal processes or government requests, enforce the Acceptable Use Policy accessible at: https://centralio.com/privacy/, or protect the rights, property, or safety of Centralio Technologies Inc., other users, partners, or the public.
Where Do We Host Personal Information?
We host our data and your Information with Amazon Web Services, Inc. (AWS) and its cloud infrastructure in the ca-central region. To learn more about their privacy policy, visit AWS Privacy Policy (https://aws.amazon.com/compliance/data-privacy/). To learn more about their data protection policy, visit AWS Data Protection Policy (https://aws.amazon.com/compliance/data-protection/). Consequently, your Information may be disclosed outside of Quebec.
How Long Do We Retain Personal Information?
In accordance with our secure Information retention and destruction procedures, we retain Information only as long as necessary for the purposes outlined in this Policy and to comply with our legal obligations. We reserve the right to close a completed file or account that has been inactive for more than seven (7) years. Thereafter, the Information will be securely and confidentially destroyed.
How Do We Protect Your Information?
We implement security measures commensurate with the nature of the Information provided to us. We maintain adequate physical, technological, and administrative safeguards to protect Information and prevent accidental or unauthorized destruction, alteration, access, misuse, malicious attacks, or other illegal use. Access to your Information is restricted to members of our organization who need it to perform their duties.
How Do We Use Cookies and Third-Party Data Processors?
By visiting our website and using our Services, you consent to the use of cookies, which enable us to provide services and content tailored to your needs and browser preferences.
A cookie is a small data file stored on a user’s device by a web server. Cookies help us identify you when you return to the Services and customize the information you receive while navigating. They provide non-personal information that helps us better understand user profiles and behaviors across the Services.
Cookies are used solely to enhance your experience on our Services and track your favorite pages. You may refuse cookies by adjusting your browser settings. However, declining cookies may interfere with or limit access to certain features of our Services, reducing your ability to fully use them.
Third-party data processors are software tools that may access and/or process data.
We use the following types of cookies and third-party data processors: AWS, Google, Mixpanel, SendGrid, Pipedrive, LinkedIn, and Meta.
How Can You Withdraw Your Consent?
Subject to applicable laws and contractual terms, you may withdraw or modify your consent to the collection, use, or disclosure of your Information. To do so, contact our Privacy Officer, Pierre-André Roy, at confidentialite@centralio.com. However, withdrawing consent may prevent us from providing certain Services. Note that withdrawing your consent does not affect anonymized Information.
How Can You Access Information About Yourself?
Starting in September 2023, the Act Respecting the Protection of Personal Information in the Private Sector (the “Act”) grants you the right to access and correct your Information upon request. Under the Act, anyone who makes a request has the right to be informed about the existence of their personal information, how it is used, and whether it has been disclosed to third parties. The requester may also access their personal information, subject to exceptions under applicable law.
Centralio Technologies Inc. acknowledges the right to access and rectify Information for individuals wishing to consult, modify, or delete their data.
Our Privacy Officer is responsible for ensuring compliance with this Policy.
You may also request corrections to your Information. We ask that you update or correct the Information we hold about you, as necessary, by modifying your account details.
For comments or requests related to this Privacy Policy, contact our Privacy Officer, Pierre-André Roy, at confidentialite@centralio.com.
Can You Use Our Website Without Providing Information?
You can use the website https://centralio.com/ without providing personal Information. However, you will not have access to certain Services.
How to Contact Us?
We are responsible for the personal information you provide to us. To this end, we have appointed a Privacy Officer to oversee compliance with this Policy. To exercise your rights, ask questions, provide comments, or file a complaint regarding this Policy or how we handle personal information, contact our Privacy Officer, Pierre-André Roy, at confidentialite@centralio.com.
We will review your request and respond within twenty (20) calendar days of receipt. This timeframe may be extended if compliance with the initial timeframe interferes with our operations or if the request requires consultation that makes meeting the initial timeframe difficult. We will not charge any fees for processing such requests unless they are complex. We reserve the right to refuse any request, in accordance with applicable personal information protection laws.
If you contact us to exercise your rights, we will verify your identity and your authority to assert these rights.
Updates to This Policy
We may amend this Policy from time to time, in accordance with applicable law. We will notify you of any changes to this Policy by indicating the date of the latest update at the beginning of the Policy.
Your continued use of our website and Services, or the provision of personal information following the posting of changes to this Policy, constitutes implicit acceptance of the changes, subject to applicable law.
Caution Regarding Third-Party Websites, Products, and Services
When using our Services, you may follow links to other websites or third-party products and services (collectively, “Third-Party Products”). Third-Party Products are beyond our control. Centralio Technologies Inc. is not responsible for the content or privacy practices of these Third-Party Products. We are not liable for any personal information that may be collected, used, or disclosed by such Third-Party Products, and Centralio Technologies Inc. expressly disclaims any responsibility related to such collection, use, disclosure, or retention by these third parties.
Acknowledgment
By providing Information to Centralio Technologies Inc., you acknowledge that you have freely and expressly consented to the collection, use, and disclosure of your Information by Centralio Technologies Inc. for the purposes specified in this Policy or as otherwise identified when collecting your Information.