Technology Innovation Lab GSoft Inc. (Laboratoire d'Innovation Technologique GSoft Inc.) (GLab) offers tools and platforms commercialized as SnoozIT (SnoozIT) which optimizes the uptime of certain Azure Virtual Machines selected by Customer. GLab understands the importance of protecting personal information. For this reason, GLab strives to have business procedures and security safeguards in place to protect personal information under its control.
1. Application and Scope
2. International Compliance
GLab complies with: (i) data protection laws applicable to GLab; and (ii) applicable industry standards concerning data protection, confidentiality or information security. GLab has global operations and therefore, in some cases, information managed by GLab may be transferred, processed and stored in other countries, although at all times, GLab will ensure that personal information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by GLab itself.
GLab complies with this Policy as well as applicable Canadian private sector data protection laws such as the Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial laws pertaining to the collection, use and disclosure of personal information. PIPEDA provides for an adequate protection of personal information according to the European Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and the Council.
GLab also complies with the General Data Protection Regulation (Regulation (EU) 2016/679).
3. Definition of Personal Information
Personal information is defined as any information about an identifiable individual. This may include, for example, email addresses and contact details and any similar information provided to GLab in the course of its business operations, or which GLab may receive from business inquiries. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.
4. Collection and Use of Personal Information through SnoozIT
When providing SnoozIT, GLab only processes personal information in accordance with the General Terms, this Policy and applicable laws. GLab generally uses personal information from or about its Customers or which is received from Customers and belongs to their own customers or end users (hereinafter referred to as Customer's Personal Information) for the following purposes:
- to create, establish and administer Customer's subscription to SnoozIT, to respond to Customer inquiries related to its subscription and to contact Customer about GLab products or subscription-related matters;
- to provide services, including to provide Customer with SnoozIT and customer support related to SnoozIT;
- to measure and analyze user behavior in order to, among others, monitor, maintain and improve GLab products or features and to create new products, services or features;
- to meet legal and regulatory requirements and to allow GLab to meet contractual requirements relating to the products provided to Customer;
- to conduct surveys on the quality of SnoozIT or to collect feedbacks on the products and services; and
- to provide Customer with offers for additional products that GLab believes may be of interest to Customer. Unless required or authorized by law, when providing products, GLab will not use personal information for any other or new purpose without obtaining its Customers' consent.
5. Collection and Use of Personal Information through the Website
GLab generally collects and uses personal information from or about its website users as follows:
5.1. Information provided by users. In many cases, GLab collects personal information directly from users when they visit or use the website. For instance, GLab may collect the following types of information:
- Inquiries. GLab may collect users' name, contact information, e-mail address and any information provided when users make an inquiry or contact GLab through the website, download documentation or gated content from the website, sign up for a webinar through the website and/or sign up to receive GLab's newsletter.
- Requests for SnoozIT and/or an SnoozIT trial. GLab may collect users' name, contact information, e-mail address and any other information provided to GLab when users submit a request or an order for SnoozIT and/or an SnoozIT trial, to the extent such trial is available.
5.2. Technical information. When users visit the website, GLab may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including IP address of the users' computer and which browser was used to view the website, the users' operating system, resolution of screen, location, language settings in browsers, the site the user came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the website or enhance the experience for users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, GLab will treat this information as personal information. GLab may also, without limitations, collect and use the following type of information when users visit and/or interact with GLab on the website:
- Google Analytics: GLab uses Google Analytics which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of GLab's use of Google Analytics by visiting the Google Analytics opt-out page.
- Intercom: GLab uses Intercom which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. However, this information is not depersonalized and users may not opt-out of GLab's use of Intercom.
- Unbounce: GLab uses Unbounce, which provides landing page management services and allows GLab to track and analyze the response of the landing pages visitors regarding changes to the structure, text or any other component of the created landing pages.
- Google AdWords: GLab uses Google AdWords Remarketing to advertise SnoozIT across the Internet and to advertise on third party websites (including Google) to previous visitors to the website. AdWords remarketing will display ads to users based on what parts of the GLab website they have viewed by placing a cookie on the users' web browser. It could mean that GLab advertises to previous visitors who haven't completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the user or give access to the users' computer or mobile device. The cookie is only used to indicate to other websites that the user has visited a particular page on the website, so that they may show the user ads relating to that page. If users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google's Ads Preferences Manager.
5.4. Privacy Policies of other Websites. This Policy only addresses the use and disclosure of information by GLab. Other websites that may be accessible through the website have their own privacy policies and data collection, use and disclosure practices.
5.5. Personal Information from other Sources. GLab may obtain from third parties additional personal information about a website user if such user gave permission to those third parties to share its information.
6. Sharing of Personal Information
GLAB will not sell, rent or trade personal information to any third party. However, GLab may share personal information when authorized and/or required by law or as follows:
6.1. Service providers. GLab may grant access to personal information to third party services providers in connection with the performance or the improvement of its website and products. Before sharing any personal information with any of its third party service providers, GLab will ensure that the third party maintains reasonable data management practices for maintaining the confidentiality and security of personal information and preventing unauthorized access.
6.2. As permitted or required by law. GLab may disclose personal information as required by applicable law or by proper legal or governmental authority. GLab may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. GLab may also release certain personal information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and itself, in accordance with or as authorized by law. In the event GLab receives a governmental or other regulatory request for any Customer's Personal Information, it agrees to immediately notify Customer in order that Customer shall have the option to defend such action. GLab shall reasonably cooperate with Customer in such defense.
6.3. Business transaction. GLab may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, personal information will remain protected by applicable data protection laws. In the event the transaction is not completed, GLab will require the other party not to use or disclose the personal information received in any manner whatsoever and to delete such information.
7. Security of Personal Information
GLab will store and process the personal information in a manner consistent with industry security standards. GLab has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of personal information and to mitigate the risk of unauthorized access to or use of personal information, including (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the personal information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit or at rest; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with up-to-date virus definitions and security patches so as to avoid any adverse impact to the personal information that it manages; appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; permitting only authorized users access to systems and applications; and (iv) all persons with authorized access to personal information must have a genuine business need-to-know prior to access (Security Program).
8. Training and Supervision
GLab maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. GLab shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the personal information it manages.
9. Data Incidents involving Customer's Personal Information
When required by privacy law, GLab will immediately notify Customer of any reasonably suspected or actual loss of data or breach or compromise of its Security Program which has or may result in the loss or unauthorized access, disclosure, use or acquisition of Customer's Personal Information (including hard copy records) or otherwise presents a potential threat to such information (Data Incident). While the initial notice may be in summary form, a comprehensive written notice shall be given to Customer at the earliest feasible opportunity. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action already taken or to be taken by GLab. GLab shall promptly take all necessary and advisable corrective actions and shall cooperate fully with Customer in all reasonable efforts to mitigate the adverse effects of Data Incident and to prevent its recurrence.
10. How to Contact Us
Any questions or complaints regarding this Policy or GLab handling of personal information can be addressed by sending an email to: mailto:legal@SnoozIT.cloud.
This Policy was last updated on December 21, 2018"