1. General information
a) Introduction
Purpose of this Policy. The protection of privacy is important to Pro-Tac Industries Inc. (hereinafter the “Company”, “We”, “Us”, and “Our”). For this reason, We have implemented safeguards and sound management practices for Your Personal Information in accordance with applicable laws in Quebec and Canada.
Supplement to Terms and Conditions. This privacy policy (the “Policy”), which should be read in conjunction with Our Terms and Conditions, describes Our practices with respect to the collection, use, processing, disclosure, retention, and destruction of Personal Information of persons benefiting from Our Services, visitors to Our present Web Sites and its users (hereinafter “You”, “Your”).
Consent. By using our Websites https://www.protac.ca/ and https://www.waveflex.com/ (the “Websites”) or any of Our Services, You agree that We may collect, use, disclose, communicate, disclose, and retain (hereinafter “Process” or “Process”) Your Personal Information by the terms described herein. If You do not agree to abide by and be bound by this Policy, You may not visit, access, or use Our Websites or Services, nor share Your Personal Information with Us.
Policy limitations. This Policy does not apply to Personal Information of the Company’s employees, representatives and consultants, or any other person affiliated with the Company, or to any information that does not constitute Personal Information as defined by applicable laws in Quebec and Canada.
b) Data protection officer
Contact information for the Data protection officer. All comments, questions, and complaints regarding the Company’s Privacy Policy and practices may be addressed to Our Data protection officer at the following coordinates:
Email: rprp@protac.ca
Address: 445 Jean-Clermont street, St-Célestin, QC, J0C 1G0
2. Definitions
Definitions of certain notions and expressions. The following notions and expressions, when they appear with a capitalized first letter in the Policy, have the meaning attributed to them hereinafter, unless otherwise implied or explicit in the text:
“Company”, “We”, “Us”, “Our”: Les industries Pro-Tac inc.
“Service Provider” means any individual or entity that processes Personal Information on behalf of the Company. This includes third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services, or to assist the Company in analyzing the use of the Services.
“Cookie Banner”: pop-up window requesting Your consent to certain collection of Your personal information on the Websites.
“Personal information” means any information that relates to a natural person and allows that person to be identified, i.e., that directly or indirectly reveals something about that person’s business, characteristics (e.g., abilities, preferences, psychological tendencies, predispositions, mental abilities, character, and behaviour) or activities, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, sound, visual, computerized or other).
“Data protection officer”: the person responsible for the application of this Policy and whose contact information is identified in section 1 of this Policy.
“Services”: refers to the applications of the Websites, Our pages on social networks, Our sale of products, and all programs and services rendered to You therein including Our services in connection with Our Company among which:
– Cutting services, such as die-cutting, ribbon cutting, hot-wire cutting, and precision cutting to length of various materials;
– Lamination services;
– Moulding services.
– Extrusion services.
– The presentation of information on various products we sell, including :
o solid or cellular rubbers;
o plastic products such as polyethylene foam, microcellular urethane foam, PVC foam, EVA foam, or polyurethane foam;
o heat shields; or
o adhesive products.
“Websites: https://www.protac.ca/ and https://www.waveflex.com/
“Cookies”: Cookies are text files that are installed on Your computer or mobile device. These cookies may contain information about Your search history, the web pages You visit, and Your web browser.
“Process”, “Treatment”: This term covers all operations that may affect or concern personal information, including collection, use, storage, destruction, communication, or transmission.
“You”, “Your”, “Yours”: The persons benefiting from Our Services, the visitors to the Websites, and all users having recourse to the Company’s Services.
3. Personal Data Processing
3.1 Collection of Personal Information
Categories of information collected. In the course of Our activities, We may collect and process various types of Personal Information, including the information listed below:
– Your contact information and login details, including your first and last name, address, e-mail address and telephone number;
– information necessary for the provision of Our Services, such as information concerning the Services We have rendered to You;
– information that you choose to provide or transmit to Us, for example, when you make a reservation on Our premises, over the telephone, or on Our Websites, fill out a form, purchase on Our Websites, respond to surveys, apply for one of Our job offers or contact one of Our employees or representatives;
– information collected automatically when You use the Websites and Our Services, including connection information and other information about Your activities on the Websites, such as Your IP address, the pages You consulted, the time and date of Your visits, the number of connections, the type of browser You use and other hardware and software information;
Limitation of processing to necessary and legitimate purposes. In each case, Personal Information is processed by the legitimate and necessary purposes listed in Article 3.2 below.
3.2 Use of Personal Information
Purposes of Personal Information. We may use Your Personal Information for the purposes described below:
– operate, maintain, supervise, develop, improve, and offer the functionalities of Our Websites;
– Introduce You to and provide Our Services, including :
o Cutting services, such as die-cutting, ribbon cutting, hot-wire cutting, and precision cutting to length of various materials;
o Lamination services;
o Moulding services ;
o Extrusion services;
o The presentation of information on various products we sell, including :
– solid or cellular rubbers;
– plastic products such as polyethylene foam, microcellular urethane foam, PVC foam, EVA foam or polyurethane foams;
– heat shields; or
– adhesive products.
– Find out more about our services;
– perform Our contractual obligations to You;
– develop, improve, and offer new Services;
– Send you messages, updates, and security alerts;
– Answer your questions and provide You with assistance if needed;
– conduct research, analysis, and statistics related to Our Company and Our Services;
– detect and prevent fraud, errors, spam, abuse, security incidents, and other harmful activities; and
– for any other purpose required or permitted by applicable law. Disclosure and Transfer of Personal Information.
Disclosure to third parties. We may transfer, disclose, or provide access to Your Personal Information to Our employees (including marketing and sales departments) and Service Providers who need to know that information to operate Our Websites, perform Our Services, conduct Our business, or serve You.
Safeguards for disclosure to third parties. We will only disclose Your Personal Information to Our Service Providers if they have previously agreed in writing to maintain the confidentiality of Your Personal Information in accordance with applicable laws and Our Information Governance Program through the implementation of various safeguards and information governance measures. These measures are proportionate to the sensitivity of the Personal Information processed or communicated. Without limitation, Our Service Providers may only confidentially use Your Personal Information in accordance with Our instructions and only for the purposes for which it was provided. Furthermore, We only provide Our Service Providers with the Personal Information that is necessary for the performance of their mandate, and We require such Service Providers to destroy the Personal Information properly upon termination of the contract or as soon as its use is no longer necessary.
3.3 Service providers and other third parties
Our Service Providers. 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 only share with these third parties what is necessary for them to provide the service.
3.3.1 Communication outside Quebec
Disclosure of Personal Information Outside Quebec. We may disclose Your Personal Information outside of Quebec and may direct an entity located outside of Quebec to collect, use, or retain Your Personal Information on our behalf.
Safeguards when communicating outside Quebec. Before disclosing Your Personal Information to third parties outside the province of Quebec, We conduct a privacy impact assessment to evaluate the risks that may affect the security of Your Personal Information. This assessment also identifies appropriate security measures to reduce or eliminate these risks. The communication will then be subject to a written agreement binding these third parties to respect such measures.
3.3.2 Compliance with legislation, responding to legal requests, preventing harm, and protecting Our rights
Specific disclosures of Your Personal Information. We may disclose Your Personal Information when We believe such disclosure is authorized, necessary, or appropriate, including:
– to respond to requests from public and governmental authorities, including public and governmental authorities outside Your country of residence;
– to protect our business ;
– to comply with legal proceedings;
– to protect Our rights, the privacy of Our employees, officers, and directors, Our security, and Our property,
– to protect Your privacy and Your rights, or the privacy and rights of third parties;
– to enable Us to pursue available remedies or limit the damages We may suffer; and
– by applicable laws, including laws outside Your country of residence.
3.3.3 Commercial transaction
Possibility of commercial transactions. We may share, transfer, or communicate, in strict compliance with this Policy and the provisions of the Act respecting the protection of personal information in the private sector, RLRQ c P-39.1 (the “Private Sector Act”) and the Act to modernize legislative provisions respecting the protection of personal information, LQ 2021, c 25 (the “Act 25”, assented to on September 22, 2021), your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of the Organization or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or any other business transaction, including in connection with the negotiation of such transactions). In such a case, We will inform you before Your Personal Information is transferred and is governed by another privacy policy.
3.4 Consents
Consent for Collection, Use, or Disclosure of Personal Information. Unless otherwise required by law, the Company obtains Your consent to the collection, use, and disclosure of its Personal Information. However, if You provide Us with Personal Information about other persons, You must ensure that You have duly notified them that You are providing Us with their information in addition to obtaining their consent to such disclosure.
Consent requirements. We will seek Your manifest, free, informed, and purposeful consent before using or disclosing Your Personal Information for purposes other than those set out herein. We will also seek Your express consent whenever sensitive Personal Information is involved in any of the Company’s processing activities. We will ask for Your consent for each specific purpose in clear and simple terms, separate from any other information provided to You.
BY USING OUR WEBSITES, TRANSMITTING YOUR PERSONAL INFORMATION BY E-MAIL, OR USING AN ONLINE FORM, YOU CONSENT TO THIS PRIVACY POLICY AND THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION BY THE PRIVACY POLICY.
Refusal to use the Websites. If You do not consent, please stop using the Websites. Except where otherwise provided by law, You may withdraw Your consent at any time upon reasonable notice. Please note that if You choose to withdraw Your consent to the collection, use, or disclosure of Your Personal Information, certain features of Our Websites may no longer be available to You or We may no longer be able to offer You some of Our services.
3.5 Retention of Personal Information
Retention. Subject to applicable laws, We retain Your Personal Information only for the time necessary to fulfill the purposes for which such information was collected, unless You consent to Your Personal Information being used or processed for another purpose. As an indication, the duration of certain information may extend up to 7 years following the end of the Services rendered by the Company to You. 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 violations, or to prosecute criminals).
To obtain more information on the periods during which Your Personal Information is kept, please contact our Data protection officer using the contact details provided in Article 1b) of this Policy.
4. Your rights
List of rights. As a data subject, You may exercise the rights set out below by contacting Our Data protection officer in writing at the contact information provided in section 1b) of the Policy. Please note that We may ask You to verify Your identity before responding to any of these requests.
– You have the right to be informed of the Personal Information We hold about You, its use, disclosure, retention, and destruction, subject to exceptions provided by applicable law;
– You have the right to access Your Personal Information, to request a copy, including paper copies, of the documents containing Your Personal Information, subject to the exceptions provided for by applicable law, and to obtain, if applicable, additional details on how We use, communicate, store and destroy it by communicating a written request to Our Data protection officer at the coordinates identified in section 1b) of this Policy;
– You have the right to have the Personal Information We hold about You rectified, amended, and updated if it is incomplete, ambiguous, out of date, or inaccurate by sending a written request to Our Data protection officer at the contact information identified in section 1b) of this Policy;
– You have the right to withdraw or modify Your consent to the collection, use, and disclosure of Your Personal Information at any time, subject to applicable legal and contractual restrictions;
– You have the right to ask Us to stop disseminating Your Personal Information and to de-index any link attached to Your name that gives access to this information if such dissemination contravenes the law or court order;
– You have the right to request that Your Personal Information be communicated to You or transferred to another organization in a structured and commonly used technological format;
– The right to be informed of any privacy incident concerning Your Personal Information that could cause You serious harm. To this end, we maintain a register of all privacy incidents and assess the harm they may cause;
– You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions set out in the applicable law.
5. Questions and complaints
Complaints. You may address any complaints regarding Our privacy practices and policies by contacting our Data protection officer using the contact information identified in section 1b).
Necessity to Identify You. To process Your request, You may be asked to provide an appropriate identification document or to identify Yourself in some other way.
Questions. You may also contact our Data protection officer if you have any questions about this Privacy Policy.
6. Cookies and other tracking technologies
Use of Cookies. We use cookies and similar technologies (collectively, “Cookies”) to help Us operate, protect, and optimize the Websites and the Services We offer. Cookies” are small text files that are stored on Your device or browser. They enable us to collect certain information when You visit the Websites, including Your preferred language, the type and version of Your browser, or the type of device You are using.
While some of the Cookies We use are deleted after the end of your browser session, other Cookies are retained on your device or browser. These Cookies enable Us to guarantee the operation of the Websites, improve the user’s browsing experience, and provide certain data that enables Us to better understand the traffic and interactions that take place on Our Websites, as well as to detect certain types of fraud. Cookies do not harm your device and cannot be used to extract personal information.
You can set your browser to notify you when Cookies are set on your visit to the Websites so that you can decide whether or not to accept some or all Cookies. Please note that disabling Cookies on your browser may adversely affect your browsing experience on the Websites and prevent you from using some of its features.
Cookie policies. To learn more about how we use “Cookies”, please see Our “Cookie Policy”.
7. Safety measures
Objectives of Our Security Measures. We have implemented physical, technological, and organizational security measures to adequately protect the confidentiality and security of Your personal information against loss, theft, or any unauthorized access, infringement, disclosure, reproduction, communication, use, or modification. These measures include :
Administrative measures. On the administrative front, the adoption of a series of measures, policies, and procedures as part of the implementation of our information governance program, including :
– govern the access, disclosure, retention, de-identification, destruction or anonymization of Personal Information;
– determine the roles and responsibilities of Our employees throughout the life cycle of Personal Information and documents;
– establish procedures for intervention and response in the event of a confidentiality incident;
– govern the process for requests and complaints relating to the protection and handling of Personal Information.
Technical measures. On a technical level, the use of several means such as :
– use of a secure server;
– The use of Secure Socket Layer (SSL) technology;
– the use of backup systems ;
– the use of network monitoring software; and
– a firewall system ;
Incomplete list of measures. Given the public nature of this Policy, we have not provided an exhaustive list of the measures we are implementing.
Impossibility of guaranteeing a complete absence of risk. 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 Data protection officer immediately using the contact details set out in section 1b) above.
8. Changes to this Privacy Policy
We reserve the right to modify this Policy at any time by applicable law. In the event of a change, We will post the revised version of the Privacy Policy and update the update date in the footer of the Privacy Policy. We will notify you reasonably in advance of the effective date of the new version of our Policy. If you do not agree to the new terms of the Privacy Policy, please do not continue to use Our Websites and Services. If you continue to use Our Websites or Services after the new version of our Policy becomes effective, your use of Our Websites and Services will be governed by the new version of the Policy.
9. Links to third-party websites
Responsibility for Third Party Websites. From time to time, We may include Our Website references or links to websites, products, or services provided by third parties (“Third Party Services”). These Third-Party Services, which are not operated or controlled by the Company, are governed by privacy policies that are entirely separate from and independent of ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services we offer.
10. Individuals under 14 years of age
Consent of minors under the age of 14. We do not knowingly collect or use Personal Information from persons under the age of 14. If You are under the age of 14, 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 You become aware that Your child has provided Us with Personal Information without consent, please contact Us using the contact details set out in section 1b) above to request that We delete that child’s Personal Information from Our systems.
11. Applicable laws
Quebec and Canada. The laws of Canada and Quebec, excluding its conflict of law rules, will govern this agreement and Your use of the Websites. Your use of the Websites may also be subject to other local, provincial, national, or international laws.
