Otonom Solution Inc. (“Otonom Solution”, “we”, “us” or “our”) is takes the privacy of your personal information seriously and is committed to respecting the confidentiality of the information it collects.
Otonom Solution undertakes to respect, in accordance with applicable laws, the obligations concerning the collection and processing of personal information obtained in the course of its activities.
This Policy is composed of the following elements:
- Purposes of the Policy
- Scope of the Policy
- Update date
- How we obtain consent
- Purposes of collecting personal information
- Customers and Users
- Personal information collected
- Governance and safety measures
- Your rights
- Sharing and reasons for sharing personal information with third parties
- Anti Spam Law
- Retention of personal information
- Reporting confidentiality incidents
- Privacy Officer
1.Purposes of the Policy
Respect for privacy and the protection of personal information are essential to us, which is why, through this Policy, we intend to protect personal information in accordance with applicable laws.
To ensure this protection, Otonom Solution will only collect, process and share personal information with the consent of the individual, unless permitted or required by law, in which case your consent will not be required.
This Policy describes the information we may collect from you in the course of our business, the purposes for which we collect it, how we use it and the circumstances in which we may transfer it to third parties. In addition, this Policy informs you of your rights regarding the collection, use and disclosure of your personal information. Otonom Solution will not collect, use or disclose your personal information other than in accordance with this Policy and applicable laws in Canada and Quebec.
For the purposes of this Policy, “personal information” means any information about an identifiable individual or information that allows an individual to be identified. Wherever possible, we will anonymize such information so that it no longer identifies an individual.
2. Scope of the Policy
By browsing the Site or our Platform, you agree to the terms and conditions of this Policy. We may make changes to this Policy from time to time. Any diminution of your rights under this Policy will not be enforced without your express consent. Otherwise, if you continue to use the Site or the Platform after a new version of this Policy has been posted, you consent to and are bound by the changes. We always indicate the date on which the latest changes were made at the beginning of this Policy.
The information we collect is necessary for us to provide you with a service or carry out a transaction you have requested. By providing us with this information, you consent to its collection and use as set out in this Policy.
This Policy applies only to our products and services and does not extend to websites or products or services provided by third parties. Otonom Solution assumes no responsibility for the privacy practices of such third parties and invites you to review the privacy policies of third parties before using their services or browsing their websites.
3. Update date
This Policy was last updated on September 22, 2023.
4. How to obtain consent
We are committed to receiving consent prior to collecting personal information from an individual, where such consent is required by applicable law. Consent may be express or implied, and may be provided directly by the individual or by his or her authorized representative.
We prefer to obtain express consent, whether verbally, electronically or in writing. However, implied consent may be reasonably inferred from a person’s action or inaction. For example, providing a name and address to receive a publication, or a name and telephone number to obtain an answer to a question, is considered implied consent to the collection of information containing personal information. In determining the appropriate type of consent, we take into account the sensitivity of the personal information involved, the purposes for which it is collected and the reasonable expectations of a similarly situated individual.
If we want to use personal information for a new purpose, we will describe the intended use and ask for consent again.
It is not always possible, particularly in the case of a government request, to obtain consent from an individual to collect, use or disclose his or her personal Information. We will never disclose such information other than in accordance with this Policy, except as required or permitted by law.
5. Purpose of collecting personal information
Your personal information is collected in accordance with the purposes and objectives set out in this Policy. Here are some of the reasons why we collect your personal information:
- – To carry out activities: We will collect and process personal information necessary to fulfill our mission and contractual obligations.
- – To ensure and improve these activities: personal information collected during your interactions with our activities may be used to analyze and improve the operation of our business.
- – To develop new activities: personal information collected may be used for research and development purposes in order to offer new functionalities to our Customers.
- – To evaluate our activities: Data is collected to obtain information on the advantages and disadvantages of our activities and services, in order to evaluate and improve them, notably through surveys. This enables us to ensure the quality of our activities and services.
- – To protect the privacy of our Users: The personal information collected allows us to verify the identity and protect the privacy of individuals who communicate with us by telephone, electronically or otherwise.
- – To fulfill our legal obligations: personal information is collected to fulfill our obligations arising from laws, regulations or contractual agreements.
- – For statistical purposes for our activity report.
- – For the database that allows us to get to know our customers.
Our Site and our Platform are designed for use by adults only, as understood in Canada. Otonom Solution does not knowingly collect personal information from persons under the age of fourteen (14).
For more information on the protection of your personal information and your related rights, please contact the Office of the Privacy Commissioner of Canada or the Information Access Commission of Quebec
- – Office of the Privacy Commissioner of Canada priv.gc.ca/en/
- – Information Access Commission of Quebec (Commission d’accès à l’information du Québec) cai.gouv.qc.ca
6. Customers and Users
For the purposes of the Policy, “Customer(s)” is generally an individual or a legal entity representing a condominium syndicate, a retirement home, a business, a building or a property retaining one or more services offered by our company.
For the purposes of the Policy, “User(s)” may be a visitor to our Site, the Customer itself (building owner, management firm owner, business owner etc.) or employees of our Customers, but may also be the manager in office including its employees, building residents of all kinds (co-owners, tenants, sub-tenants, etc.), third-party service providers and others. There are different types of Users, and each has a different and unique relationship with the Platform and the information we process. Most Users will be associated with one or more Customers (condominium corporations, property owners, apartment buildings, retirement homes etc.) in which case we will use Users’ personal information for and on behalf of the Customer, according to their specific instructions. As a general rule, the information we process from our Customers and Users is processed on behalf of our Customers.
Please contact the Customer directly if you have any questions about their privacy and data protection practices.
7. Personal information collected
Otonom Solution may collect personal information in various forms, but will do so only by lawful means and only for the necessary purposes disclosed to you, as described in this Policy, or as permitted or required by law.
The personal Information we collect, and its sensitivity, may vary depending on the context of your interactions with Otonom Solution. This is why we must first inform you of the nature of the personal information we use.
We protect all personal information in our possession or under our control. Among the personal information that may be collected and used, we pay particular attention to:
- – Name and contact information. First and last name, e-mail address, mailing address, telephone number and other similar data used to contact you.
- – Proof of identity. Security information used to identify you so that we can offer you the support or service you require.
- – Demographic data. Information about you, such as your country and language of communication.
- – Payment details. Data required to process your payments.
8. Governance and safety measures
In order to protect your personal information, we have put in place policies, practices and procedures relating to the management of the personal information we hold. For more information about these policies, practices and procedures, please contact our Privacy Officer.
Our employees are required to have access to personal information; each employee signs a confidentiality undertaking, and access is withdrawn when the employee leaves his or her duties. Your personal information is hosted by our service providers, who undertake to use reasonable security measures to preserve the integrity and confidentiality of your personal information.
Otonom Solution attaches the utmost importance to the security of your personal information and undertakes to treat it in accordance with the norms and standards required, solely for the purposes for which it is collected, as described in this Policy or in a specific notice to that effect. These safeguards vary according to the sensitivity of the data in our possession and are based on the best industry standards. Nevertheless, it is impossible to safeguard data completely / fully, given the security limits inherent in transmission via the Internet. Information transmitted to us is therefore ultimately at the User’s own risk.
If you have any questions about the security of your interaction with us (if, for example, you feel that the security of any account you may have with us has been compromised), you may contact our Privacy Officer.
9. Your rights
Depending on applicable laws, where you live and how you interact with the Site, you may be granted certain rights with respect to the personal information we hold about you. For example, you may have the right to request the deletion of your personal information, the withdrawal of your consent (if applicable), the portability of your personal information in a structured, commonly used and machine-readable format and the right to obtain additional information, for example on the categories of third parties to whom we disclose your personal information.
Otonom Solution ensures that all personal information in its possession is as accurate, current and complete as necessary for the purposes for which it is to be used. In addition to the other rights detailed above, you also have the right to request access to your personal information for verification purposes and to request a correction if your personal information is inaccurate. If you believe that your personal information is inaccurate, or if you wish to have access to your personal information, you may make a request using the contact information provided at the end of this Policy. To the best of our ability, we will provide you with timely access to your personal information. However, for security reasons, we may need to verify your identity. In addition, there may be circumstances where we will not be able to provide you with access to your personal information. In particular, when access may lead to the disclosure of another person’s personal information and that person refuses to consent to its disclosure, or when legal restrictions apply. If such a situation arises, we will advise you of the reason why we cannot provide you with access to your personal information.
You may file a complaint with the Privacy Officer if you are dissatisfied with our handling of your personal information or with our compliance with this Policy. You are also permitted by law to file a complaint with a privacy commissioner or other competent supervisory authority for the protection of personal information.
You can exercise your rights listed above by sending a written request to our Privacy Officer. He or she will be happy to assist you in any way he or she can.
If your request concerns data appearing on third-party web pages or platforms, please contact these third parties directly.
10. Sharing and reason for sharing personal information with third parties
We do not share your personal information with companies, organizations or individuals outside of our organization, with the exception of our employees, authorities authorized by law and our authorized suppliers and partners who need access to the information for the purposes listed in this Policy (for example, our providers of insurance services, computer services and products, cloud services, web hosting and data processing, creative and promotional agencies and our legal service providers) and within the limits of this Policy, as well as in the following cases:
- – With your consent.
- – For hosting on cloud servers, in which case personal information may be transferred to third-party jurisdictions. Please note that we only retain the services of reputable companies with privacy policies.
- – For external processing purposes: We transfer personal information to other companies or trusted persons who process it on our behalf, according to our instructions, in accordance with this Policy, with a level of data security at least equivalent to our own and in compliance with any other appropriate security and confidentiality measures.
- – For legal reasons: We transmit personal information outside our organization if access to it is necessary to comply with applicable laws and regulations.
- We may need to share your personal information without your consent in the event of a merger, acquisition or sale of all or part of our business, for example, as part of a due diligence review. In such a case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction. Otonom Solution will not sell or rent your personal information to third parties.
Your personal information may be disclosed and stored outside your province, state, territory or country of residence. Our business partners and service providers may be located in the province of Quebec or in other provinces, territories or countries. Please be aware that we have contractual agreements with these third parties and suppliers to ensure that your personal information is handled in accordance with the laws applicable to us. Where applicable, we conduct Privacy Impact Assessments prior to any transfer of personal information to another jurisdiction, such as outside Quebec.
11. Cookies and similar technologies
The following cookies are used:
- Necessary cookies. These cookies are necessary for the operation of the Site and provide basic functions and may include maintaining your session and preventing security threats. We cannot disable these cookies in our systems without affecting the operation of the Site. However, if you wish, you can block or delete them by changing your browser settings and forcing all cookies on the Site to be blocked.
- Non-essential cookies. Non-essential cookies provide certain non-essential functionalities on our Site, for functional, analytical, advertising or performance purposes. We will ask for your consent before using these Cookies.
- – Functional Cookies. Functional Cookies make it possible to perform certain functions such as sharing Site content on social media platforms, collecting comments and other third-party functions.
- – Advertising cookies. Advertising cookies are used to provide visitors with personalized advertisements based on the pages previously visited and to analyze the effectiveness of the advertising campaign.
- – Performance cookies. Performance cookies are used to understand and analyze the Site’s key performance indicators, thereby providing visitors with a better user experience.
- – Analytical cookies. Analytical cookies are used to understand how visitors interact with the Site. These cookies help us to obtain information such as the number of visitors, the bounce rate and the source of traffic.
It is important to note that, depending on the settings you choose, activating the non-essential cookies option may allow other servers to install cookies on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.
12. Anti-spam law
Otonom Solution is committed to complying with the requirements of the Canadian antispam law (“CASL”). To unsubscribe from our electronic communications mailing list, simply contact us at [email protected] or click on the unsubscribe link included in these communications.
13. Retention of personal information
Otonom Solution keeps personal information collected for various periods, depending on their usefulness in offering our activities and the legal, tax or regulatory requirements to which we are subject. During the retention period, Otonom Solution takes physical and technical measures to ensure the security of data containing personal information.
Personal information may be maintained outside the province of Quebec and the jurisdiction in which you live, for example, if a third-party supplier or other entity to whom we disclose personal information in accordance with this Policy is located outside the province of Quebec. In such cases, personal information may be subject to the local laws of the countries or territories in which the information is collected, used, disclosed or stored, and may be accessible to the governmental and law enforcement authorities of such countries or territories.
Once the retention period has expired, personal information is destroyed or anonymized. Only statistics or reports containing anonymized data may be retained for extended periods.
14. Reporting confidentiality incidents
A procedure has been set up to identify confidentiality incidents, and the organization will analyze the degree of harm caused by each incident by filling in an incident register, and if this is the result of the analysis, will send a notification to the authorities and the victims.
15. Privacy Officer
If you have any questions, comments or complaints about this Policy, please contact our Privacy Officer:
Otonom Solution inc.
300-4 Place Ville-Marie
Montréal (Québec) H3B 2E7
Telephone: 514 360-6661 x 702
E-mail: [email protected]