Novatech Group Inc. (“Novatech” or “we”) recognizes the importance of privacy and is committed to protecting Personal Information that it collects and processes as part of its day-to-day operations, including information collected while visiting and interacting with our website (“our Website’’).
This Policy reflects Novatech's ongoing commitment to protect the personal information of the following individuals:
- Novatech’s clients who are natural persons (excluding companies)
- Online account holders
- Novatech websites’ visitors (to the extent that Personal Information is collected)
- Representatives of Novatech’s service providers who are required to provide Personal information to establish a business relationship, except for business contact information
- Past and current employees and other staff members
- Job applicants
- Any other natural person whose Personal Information is collected or processed over the course of Novatech’s operations.
For the purposes of this Policy, "Personal Information" means any information that relates to a natural person that allows that person to be identified directly (e.g., last name, first name, e-mail address) or indirectly (information that, when combined with other information, allows the person to be identified).
2.1. Links to Third Party Websites
Our website contains links to third-party websites; these are provided solely for your convenience. Clicking on these links will take you outside of the Novatech Network. Please be advised that we have no control over these third-party sites and, while our website may feature such links, we will not, at any time, accept liability for these sites. Consequently, personal information that you provide to a website outside of the Novatech Network is subject to the privacy policies of the given third-party site. In the event of abuse by such websites, we cannot, at any time, be held responsible. Therefore, we strongly urge you to carefully read the privacy policies of all third-party websites you choose to enter.
3. OUR GUIDING PRINCIPLES REGARDING THE PROTECTION OF PERSONAL INFORMATION
Novatech’s privacy practices are defined and applied in accordance with the following principles:
Prior to collecting, using, and disclosing your Personal Information, Novatech makes sure to obtain your consent, in accordance with applicable requirements - except in cases where exceptions are provided by law (for example, in connection with criminal or penal proceedings).
You may withdraw your consent to your Personal Information being used by Novatech for purposes that are not essential to the management and administration of its products and services, for example, to invite you to participate in surveys or contests, to send you promotional communications, to generate statistics or to analyze your data. If you so wish, Novatech will stop using it for these purposes.
It will generally not be possible to withdraw your consent to the use of your Personal Information for purposes relating to the management and administration of products and services without terminating your contract.
Any request for withdrawal of consent must be sent to the Privacy Officer, whose contact information can be found in section 4.
3.2 PERSONAL INFORMATION COLLECTION
3.2.1 Personal Information Collected
Novatech makes sure to collect only the Personal Information that is necessary for the purposes of our activities and to which you have consented. This may include:
- Identifying information, such as your first and last name, e-mail address, postal address, and telephone number
- Information that is necessary to optimize your experience on our website, such as your IP address, location, or navigation data
- Personal information contained in your curriculum vitae.
Novatech ensures that the Personal Information it collects is accurate and complete for the purposes for which it is used.
3.2.2 How is Personal Information collected
Directly from you
Most of the Personal Information that is collected is that provided directly to us, including when you:
- Contact us
- Visit our website
- Apply online for a job
- Complete our surveys/participate in our contests
From third parties
We may also collect Personal information from third parties only with your consent or as
Through our cookies
When you access the Novatech website, cookie files (commonly called “cookies”) are deposited on your computer. These cookies may collect personal information such as your IP address and are used to improve your browsing experience and the content of our website.
To better understand the usefulness of each of the cookies present on our website, you will find below a description of their functions:
- Strictly necessary cookies:
- Functional cookies:
- Performance cookies:
- Advertising cookies:
- Analytical cookies:
You can modify your cookie choices by adjusting your browser settings. However, the deactivation of functional cookies could lead to inconveniences in your browsing experience (e.g., difficulties with registration, use of services or display).
3.3 OUR USE OF YOUR PERSONAL INFORMATION
We collect, use, and disclose Personal Information for purposes to which you have consented or as permitted by law. The purposes for which we collect your personal information are identified at the time of collection.
Novatech collects Personal Information for the following purposes:
- Manage client files;
- Establish and maintain communication with clients, including participation in contests or surveys or sharing simulations with third parties;
- Evaluate the needs of clients and prospective clients and offer them products and services that meet those needs;
- Manage after-sales service requests;
- Manage and optimize access to our Website, and personalize and adapt the browsing experience to your needs;
- Detect and prevent fraud or other illegal activity;
- Manage risk, security and regulatory compliance;
- For candidates, to evaluate your application;
- For employees, to plan human resources needs, manage the employment relationship, including employee records and benefits.
You can ask us for more details about these uses at any time.
Novatech is committed to providing transparency to outside parties (which we may electronically communicate) with respect to our practices in complying with Canada’s Anti-Spam legislation and its relevant rules and regulations (“CASL”).
The types of commercial electronic messages (or CEM) that Novatech may send from time to time could include messages pertaining to our products and services to recipients that have agreed to receive them, messages sent to our current or potential customers and messages sent to our current or potential service providers or business partners by our various business units.
If you have received a CEM from Novatech it is because either you have previously provided your express consent, we have your implied consent under CASL, or because the type of message sent is exempt under CASL.
Novatech has your express consent if you have requested information about our products. Novatech may infer your implied consent if:
- Novatech has an existing business relationship with you or has a former business relationship with you which terminated less than two years ago (for instance, you are a former client)
- Novatech received an inquiry from you within the last 6 months
- You disclosed your electronic address to a Novatech employee (for example, you provided your business card to a Novatech employee) or you conspicuously published your electronic address (for example, via a corporate website or in a brochure) and the CEM sent is in connection with your business role and function.
A message sent by Novatech would be exempt if the message or the relationship between you, Novatech or the Novatech employee who sent you the message is one of the following:
- You have a personal relationship or a family relationship with the Novatech employee who contacted you
- The CEM is sent between Novatech and another business, where there is an ongoing relationship between Novatech and this other business
- The CEM was sent by Novatech to you, in order to respond to your request or inquiry
- The CEM was sent by Novatech to you, in order to enforce a legal right or obligation
- The message was sent to you once, following a referral by a current Novatech client, service provider, business partner or employee who also has a personal, family or business relationship with you
- The message only provides you with a request for a quote or an estimate, only facilitates or confirms a transaction, or only provides Novatech warranty, product recall, safety or security information.
If you have received a CEM, and you believe that you should not have, please contact us immediately at [email protected] in order to unsubscribe, and we will remove your electronic address from our list within ten (10) days.
3.4 COMMUNICATION OF YOUR PERSONAL INFORMATION
Novatech ensures that Personal Information is disclosed and accessible to its employees, representatives or mandataries who reasonably need to access it as part of their duties.
Novatech may share your Personal Information with business partners, suppliers, government authorities and others in the course of our operations. These third parties include:
- Cloud solution providers used in the course of our business, hosting data, servers or applications;
- Suppliers of marketing or advertising services;
- Suppliers and service providers as part of after-sales service requests;
- Control authorities such as the Commission d'accès à l'information;
- Any other person authorized to obtain it by law.
These service providers are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any purpose other than to facilitate the specific outsourced related operation unless you have explicitly agreed or given your prior permission to them for additional uses.
Novatech ensures that the confidentiality of your Personal Information is preserved when it is communicated to third parties. Furthermore, Novatech undertakes not to sell or share Personal Information with other third parties.
3.5 RETENTION AND DISPOSAL OF YOUR PERSONAL INFORMATION
Novatech retains your Personal information for as long as necessary for the purpose for which it was collected and for the retention periods required by law. Your personal information is generally retained in Quebec. However, it is possible that the communication of Personal Information to certain service providers may result in the transfer of such information outside of Quebec. In such cases, Novatech will first check the applicable laws and practices for protecting Personal Information in the jurisdiction concerned and will ensure adequate protection of your Personal Information.
When the Personal information collected is no longer necessary for the purposes for which it was collected, Novatech ensures that it is destroyed or anonymized, according to the defined procedures and processes.
3.6 SECURITY MEASURES
Novatech implements security measures commensurate with the sensitivity of the Personal Information it collects, the purpose of their use, their quantity, their distribution and their medium, to protect it against any theft, loss, unauthorized access, disclosure, or use.
The security measures applied by Novatech include:
- Administrative measures such as our awareness and training campaigns, our contractual measures and our management of third parties;
- Physical measures such as access controls to our premises, including surveillance video;
- Technological measures such as authentication controls, our access management system and our anti-phishing measures.
3.7 YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
Novatech respects the rights that are recognized by laws with respect to your personal information and has procedures in place to respond to them.
Access, rectification, and complaints
You have the right to consult your Personal Information held by Novatech, to verify its accuracy and to modify it, if necessary, subject to the exceptions provided for by law.
You also have the right to request information about the processing of your Personal Information (e.g., uses, categories of third parties to whom it is disclosed, applicable retention periods, etc.) and to file complaints if such processing does not comply with the principles set out in this Policy and with applicable privacy laws and regulations.
Any request for access, rectification or information, or any complaint relating to your Personal Information, must be communicated in writing to the Privacy Officer whose contact information is provided in section 4.
Before we can provide you with any information, correct any inaccuracies or delete any information, we may ask you to confirm your identity and provide other details (in a secure manner) to help us respond to your request.
Novatech undertakes to provide a response to the various requests set out above within thirty (30) days of receipt.
In so far as Novatech implements a decision-making process that is based exclusively on automated processing (without human intervention) of Personal Information for example, a process that has a specific effect on an individual (e.g., for employment eligibility) and that relies solely on an algorithm, you will be informed of the fact that you are the subject of such a process, of the decision that has been made and of your right to comment on that decision. Upon request, you may also be informed of the following:
- The Personal Information used to make this decision
- The reasons for this decision
- Your right to rectify the Personal Information used to make this decision
- Access to a person with the authority to review this decision, if necessary
4. Chief Privacy Officer
To exercise your privacy rights or ask us anything about this Policy or how we handle your personal information, you can reach Novatech’s Chief Privacy Officer in any of the following ways:
- Email: [email protected]
- Postal mail: Novatech Group inc., Attention: Chief Privacy Officer, 160 Murano Street, Sainte-Julie, Qc, Canada, J3E 0C6
- Phone: 450-922-6106
5. Policy Update
This Notice was adopted by Novatech’s Executive committee and takes effect on the date of its adoption. It replaces all previous versions. The Notice versions history may be obtained by request to the Chief Privacy Officer. The collection, use, communication and any other processing of a concerned person’s personal information are governed by the Notice in force at the time of the processing.
The Chief Privacy Officer is responsible for this Notice and its updating. This Notice may be amended at Novatech’s discretion, to reflect changes in applicable requirements or in Novatechs’ practices, and will be reviewed at least every three years.
The date of the last update of this Policy is indicated at the bottom of this page.