Laboratoire d'Innovation Technologique GSoft Inc. (“GLab”) offers tools and platforms commercialized as Custodian (“Custodian”) which helps companies to manage their software. 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.
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).
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.
Collection and Use of Personal Information through Custodian When providing Custodian, GLab only processes personal information in accordance with 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 Custodian, 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 Custodian and customer support related to Custodian; • 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 Custodian 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.
Collection and Use of Personal Information through the Website GLab generally collects and uses personal information from or about its website users as follows:
- 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 Custodian and/or an Custodian demo / 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 Custodian and/or a Custodian demo / trial, to the extent such demo / trial is available.
- 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.
- 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.
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:
- 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.
- 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.
- 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.
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”).
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.
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.
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: firstname.lastname@example.org