Declaration of Confidentiality (Privacy Policy)

LAST UPDATED AUGUST 28, 2023

This Privacy Policy governs how INTELLIFORM SOLUTIONS TECHNOLOGIQUES INC. (doing business as "ECCENTRIX") (hereinafter "ECCENTRIX") collects, uses, maintains, and discloses Personal Information collected from you and other Users ("you" or "User") when using this website (the "Site"), whether accessed via the Internet, mobile device, other electronic devices, or by any other means. The Site is the property of ECCENTRIX.

This Privacy Policy applies to the Site and all products and services we offer on the Site.

We are committed to protecting the information that personally identifies you (as defined below) that we collect.

1. Definitions

"Collection" means the action of collecting, using, acquiring or obtaining Personal Information in any way and by any means, including from Third Parties.

"Consent" means a free agreement to the Collection and/or disclosure of Personal Information for the purposes we have determined. Consent may be express or implied, as provided by law, and may be given directly by the User or by an authorized agent. It must be unequivocal.

"Disclosure" means the act of revealing Personal Information to a Third Party.

“Personal information” means any information which relates to a natural person and allows, directly or indirectly, to identify that person.

"Personal Information Protection Officer" means the person at ECCENTRIX responsible for ensuring compliance with and application of this policy in accordance with section 3.1 of the Act to modernize the legislative provisions for the protection of personal information.

“Third Party” means a person other than a User, ECCENTRIX or an agent of the latter;

"User" means any customer or person who accesses any customer service offered by ECCENTRIX or the Site.

“Use” means the processing, handling, and management of Personal Information by ECCENTRIX.

2. Liability

We will inform you upon Collection and thereafter upon request:

i) the purposes for which the Personal Information is collected;

(ii) the means by which they are collected;

iii) the rights of access and rectification provided by law which are to the effect that any person may, free of charge, consult and have rectified a file or information that ECCENTRIX holds on him, that he can thus have inaccurate, incomplete or ambiguous information and that it may also have information that is out of date or not justified by the subject of the file deleted;

(iv) your right to withdraw your Consent;

v) where applicable, the name of the Third Party for whom the Collection is made, the name of the Third Parties or categories of Third Parties to whom it is necessary to communicate the Personal Information for the purposes for which it was collected; And

vi) where applicable, the possibility that this Personal Information may be communicated outside Quebec.

Any User who provides his Personal Information in accordance with the preceding paragraph consents to their use and disclosure for the purposes referred to in paragraph i) of the preceding paragraph. To this end, when you provide us with your Personal Information to register for our training, we assume that you consent to our collecting your Information and using it for this purpose only.

We are responsible for Personal Information in our possession or custody, which includes Personal Information transferred to a Third Party for processing.

In addition, we have appointed a Personal Information Protection Officer who will ensure compliance with, and application of, the principles set out in this policy and the Act to modernize legislative provisions for the protection of personal information. Other persons may also be designated, from time to time and at the discretion of the Privacy Officer, to perform, in whole or in part, the functions of the Privacy Officer.

We will send, upon request, the name of the Personal Information Protection Officer whose contact details are set out below.

Where applicable, we will make sure to obtain the Consent of the person having parental authority or guardian when we collect Personal Information from a child under 14 years of age.

We have developed various guidelines and practices for the concrete application of this policy, including:

The implementation of policies and practices governing our governance with respect to Personal Information and intended to protect Personal Information and to ensure compliance with this policy, which provide for:

i) the framework applicable to the retention and destruction of Personal Information; And

ii) the roles and responsibilities of our personnel throughout the life cycle of Personal Information.

The implementation of procedures relating to the receipt and processing of requests for information or complaints;
The establishment of a register of confidentiality incidents;
Establishment of a retention schedule for Personal Information;
Provide information and training given to employees regarding the protection of Personal Information.

3. What personal information do we collect?

We may collect two types of information from Users of our Site:

"information that personally identifies you” that can be used to locate you, contact you, or establish your identity (such as your name, email address, phone number, credit card information, etc.), this information is stored securely in your client account with us;
"aggregate information" which is information about your activities on the Site or relating to the services or products and which cannot be used to identify, locate, or communicate with you (such as the frequency of visits to this Site, the data entered when using the Site, the most consulted pages, the type of browser, the links on which Users click, the IP address, as well as other similar information).

4. When do we collect Personal Information?

We collect Personal Information and other data in the following situations:

When you use a credit card or other payment method authorized under our Site's terms and conditions to pay for our services, we (or one of our Square partners) may ask you for your name, address, and information relating to your credit card or other authorized means of payment, if applicable.
When you begin to fill out a transaction or service request form, automated technologies (cookies) automatically record the information filled in so that it can already be completed the next time you visit the form.
When you communicate with us by e-mail, to obtain information about our services, to obtain clarifications on invoices or to terminate a contract, when it is possible to do so.
When you subscribe to our newsletter.
During each transaction or request for services, you have the possibility of modifying your profile and providing information which identifies you personally.
When you make comments, give feedback, or submit suggestions through the Site.
When you visit the Site, even if you do not log in, we collect information about your computer's operating system (i.e. Microsoft Windows, Mac OS, etc.), your address IP, the web browser (i.e., Firefox, Internet Explorer, Chrome, etc.) that is being used, the originating website, Usage Data relating to your activity on the Site, including but not limited to, the pages you visit or those you share, the functions you use, as well as the total time spent on the Site. This data is used for the purpose of analyzing the performance of the Site and services.

You can refuse to provide Personal Information that identifies you personally, but this may prevent you from having access to all the functionalities of the Site, including proceeding with any transaction or request regarding our services.

5. Web browser cookies and other technologies used to collect data

In addition to the Data Collection described above, we use various technologies to collect information from your computer about your activities on our Site.

Cookies. When you visit our website, we may assign one or more cookies to your computer to facilitate your access and personalize your experience on our Site. A cookie consists of a small text file, containing no information that identifies you personally, that we install in the browser of the User's computer. Using a cookie may also allow us to collect data about your online activity on our Site, such as the web pages you visit and the links you click on. Most browsers automatically accept cookies, but you can usually modify your browser settings to decline them. If you choose to refuse cookies, you may not be able to log in or use other interactive features offered on the Site.

Other technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Site. Web beacons are small images inserted into a web page that serve similar purposes as cookies to track activity. We may also embed web beacons in emails or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this way allows us to customize the services we provide to our visitors to deliver targeted ads and to measure the overall effectiveness of our online advertising, content, programming, or other activities.
Information Collected by Third Parties. We may allow Third Parties, including our authorized service providers, advertising companies, and advertising networks, to serve advertising on our Site. These companies may use tracking technologies, such as cookies, to collect data about Users who view or interact with their advertisements. Our Site does not transmit any Personal Information to these Third Parties. This data allows them to serve targeted ads and measure their effectiveness.

6. How do we use the Personal Information collected?

We collect and use Personal Information or other data for the following purposes:

To personalize the User's experience

We may use information in aggregate form to understand how Users, as a group, use the services and resources provided on our Site.

To improve our Site and the User experience

We are continually making efforts to improve the offer on our Site based on the data, suggestions and comments we receive from you.
We may use the information we collect about you to, among other things, present data trends across different demographics, or present offers and discounts to you.

To improve customer service

The information you submit helps us respond more effectively to your customer service requests and support needs.
When you submit questions or comments to us, we may use this information to respond to you.
By providing us with your Personal Information, you are deemed to consent to our contacting you by phone, email, mail, or text message i) to answer questions you submit to us or ii) to follow up of one of your requests in relation to our services or in relation to the purchase or performance of the services.

To process transactions

We may use information provided by Users at the time of making a purchase or requesting training only to process that request/purchase.
We do not exchange credit card information with Third Parties except as necessary to provide the service.
If a transaction occurs, for example by the conclusion of a training purchase contract, we may have to communicate Personal Information to a Third Party if this communication is necessary for the execution of the contract, in particular the trainer.
We may use your Personal Information to secure payment of amounts due for services purchased or provided.

To communicate with you and keep you informed

The email addresses provided by the User will be used to send information and service updates. These addresses may also be used to respond to Users or other requests or questions.
At the end of the service, you may be asked to subscribe to our mailing list for commercial electronic messages by selecting "Yes" to the question asked from a course evaluation form. Upon your confirmation, you will receive emails and text messages which may include company news, updates, or information about our services. If at any time you no longer wish to receive emails, you can unsubscribe by contacting us through our Site, by clicking on the bottom of the promotional email to unsubscribe with a form or by directly contacting the Personal Information Protection Officer.

For commercial purposes

We may use information provided by Users to display targeted advertisements or content that we believe may be of interest to the User based on the information provided by the User.
We may provide data mining services to Third Parties wishing to better understand our Users by providing them with aggregate information based on Site Users, such as interests and purchases made.
By sending us your Personal Information, you consent to us communicating with you, for marketing and commercial prospecting purposes, at the telephone number you provided and at your email address.

We may also use or sell aggregate information, including data relating to pages visited, to improve the design, content, and performance of our Site, or to analyze the use and popularity of certain pages of the Site.

7. Limit on the collection of Personal Information

We may only collect Personal Information necessary for the purposes identified prior to Collection. We collect Personal Information from the User only unless the User consents or the law authorizes collection from a Third Party.

We will ensure that you are informed of the purposes and means for which your Personal Information is Collected.

8. Limit on Use of Personal Information

We may provide information that personally identifies you to authorized service providers who assist us in providing services and performing functions on our behalf. They are not authorized to use this

information otherwise. Where applicable, we will enter a contract with these partners providing i) the implementation of measures to protect the confidentiality of your Personal Information, ii) the commitment to use this Personal Information in the exercise of their mandate or the execution of the contract only and iii) the commitment not to keep this Information after the expiration of the contract.

We may disclose the Personal Information we hold when required to do so by law, such as in response to a court order.

We may also disclose such Personal Information in response to requests from law enforcement or other public agencies, if we believe that such disclosure could prevent incitement to commit a criminal act.

We may communicate depersonalized information to a person or organization that wishes to use this information for study, research, or statistical purposes.

Finally, we may disclose Personal Information in the event of a transfer of our assets or ownership as part of a proposed or actual corporate reorganization, such as a merger or acquisition, to the extent permitted by law. If such a reorganization, merger or acquisition takes place, we may use or disclose Personal Information during our activities, in accordance with this Privacy Policy. In such a case, we will notify you that your Personal Information has been disclosed within a reasonable time following the reorganization, merger, or acquisition.

We may disclose or use your Personal Information to recover a debt we have against you.

9. How do we protect your Personal Information?

We adopt appropriate practices for the Collection, storage and processing of data, as well as security measures to protect against unauthorized access to your Personal Information, your User name, your password, information relating to transactions and your data recorded on our Site, as well as their protection against modification, disclosure or destruction.

The exchange of sensitive and private data between the Site and its Users takes place by means of a secure communication channel and is encrypted and protected by digital signatures. Your information will be encrypted with the SSL security protocol and stored with AES-256 type encryption.

When you purchase our services, we (or our partners) will ask you to provide your credit card information or billing data and an email address. We will use the information provided in relation to a purchase made by a User to process the order and for no other purpose.

For your information, our Site is hosted on LiquidWeb, an online platform that allows us to present our IT training services to you. Your data is stored in LiquidWeb's storage system, as well as on the Microsoft 365 cloud platform, on secure servers protected by a firewall and encryption using a compliant algorithm.

We want you to use our Site with confidence. However, no system is completely secure. Therefore, although we take all necessary measures to protect your Personal Information, we cannot guarantee that such Personal Information, research, or other communications will always remain secure. Users acknowledge providing such Personal Information at their own risk. To this end, Users should also remain vigilant in the processing and disclosure of their Personal Information, and they should avoid transmitting Personal Information by unsecured email.

10. Third Party Websites

On our Site, Users may find advertising or other content that links to the sites and services of our partners, suppliers, advertising agencies, sponsors, licensors or other third parties. We do not control the content or the links that appear on these sites and we are not responsible for the practices put forward by the websites displaying links in or to our Site. In addition, these sites or services, including their content and links, may change constantly. These sites and services may have their own privacy and customer service policies.

Browsing and interacting with other sites, including sites displaying links to our Site, is subject to the policies and terms of those sites. Under no circumstances can we be held responsible for the Personal Information protection practices of websites that are not the property of ECCENTRIX.

11. Accuracy and Access to Personal Information

We ensure that the Personal Information we hold about a User is up-to-date and accurate when deciding on an application. We will update a User's Personal Information when necessary to decide, to meet the identified purposes or to correct, at the request of a User, incorrect personal information.

You can, by writing to the Personal Information Protection Officer, obtain a copy of the Personal Information file that we hold about you and collected from you. In addition, you can, by writing to the Personal Information Protection Officer, find out about the categories of people who have access to your Personal Information, the use made of it, including its disclosure. to third parties and their retention period.

If you demonstrate in your written request that the Personal Information, we hold about you is inaccurate or incomplete, we will make the necessary changes. We will follow up and respond to any such request for access or modifications diligently and within a reasonable period, which will not exceed 30 days.

We will not charge any fee for access to the file of Personal Information that we hold about you. However, we will charge certain fees in the event of reproduction, transmission, or transcription of the Information.

We may refuse to communicate Personal Information if this communication could cause harm to ECCENTRIX, to a Third Party or if it violates the law. If necessary, we will justify our refusal.

12. Retention of your Personal Information

Your Personal Information is stored on a server located in Canada for a period to fulfill the purposes that have been specified in this Privacy Policy. However, your Personal Information may be communicated and stored outside of Quebec by one of our partners, but in doing so we undertake to respect the conditions set out in section 17 of the Privacy Act. in the private sector. Once our purposes have been fulfilled and according to our retention schedule for your Personal Information, we will destroy, remove, or anonymize your Personal Information. However, if a law provides for a specific retention period, we may keep them for the period provided for by this law.

When the information is destroyed or removed, we will ensure that the process is secure to irretrievably destroy the Personal Information or its support, so that it is impossible to reconstruct it in any way.

We are committed to protecting the confidentiality of Personal Information, by ensuring that our server meets applicable security and computer protection standards. Access to personal information will only be possible to persons authorized for business purposes or whose functions require it.

13. Your acceptance of this policy and its amendments

By your use of this Site, you confirm your acceptance of this policy. If you disagree with this policy, please refrain from using our Site. By continuing to use this Site following the posting of changes to this policy, you will be deemed to have accepted those changes.

We encourage all Users to frequently check this page to be aware of changes to this policy and how we are helping to protect the Personal Information we collect. We will post any changes to this policy on the Site. Any changes to this policy take effect upon posting.

14. Withdrawal of your Consent

You may contact the Personal Information Protection Officer at the coordinates below to withdraw your Consent to the Collection or Disclosure of your Personal Information in our possession. You will note that such a withdrawal may have the consequence of making the use of our services unavailable to you.

15. Subsidiaries and entities

You consent to ECCENTRIX, its subsidiaries and related entities respectively communicating to each other the Personal Information Collected by one or the other in accordance with this privacy policy.

16. Complaint

Anyone can file a complaint by contacting the Personal Information Protection Officer. To this end, ECCENTRIX has established a complaints handling process relating to the processing of Personal Information.

17. Intellectual property, copyrights, and trademarks

All content (information, writings, images, logos, icons etc.) of this Site is the exclusive property of ECCENTRIX, its subsidiaries, its related entities or Third Parties having granted it licenses and may not be used, reproduced, distributed, displayed, or sold in any way without the written permission of ECCENTRIX. All content on this Site is protected by copyright laws applicable in Canada.

Only the downloading and printing of the content for purely personal and non-commercial purposes is permitted. The downloading and printing of the content does not expressly or implicitly confer any license or any other right on the User.

The trademarks appearing on this Site (both the written and visual aspects) are the exclusive property of ECCENTRIX, its subsidiaries, its related entities or third parties having granted it licenses and may not be used, reproduced, or imitated without the authorization written by ECCENTRIX and are subject to applicable Canadian trademark laws.

18. Official Release

The French version of this policy is the official version and prevails over the English version.

19. Applicable Laws

This privacy policy is governed by the provincial and federal laws applicable in the province of residence of the User.

20. To contact us

For any questions or complaints related to this Privacy Policy, the practices on this Site or your interaction with this Site, or for any other request, please contact us at:

www.eccentrix.ca

AS: Boris Gigovic, President

INTELLIFORM SOLUTIONS TECHNOLOGIQUES INC.

2000, McGill College, 6th floor,

Montreal, QC

H3A 3H3 Boris.Gigovic@eccentrix.ca