Privacy and Data Protection Policies

    Privacy Policy

    At Prosomo, ensuring your privacy is of utmost importance to us. We want you to be transparently informed about our use of your information when you browse our website. By transacting with the Prosomo platform, you agree to abide by these policies. We therefore invite you to read the following policy regarding the information confidentiality.

    For reference purposes, by personal information we mean :

    “Any information that identifies you such as your name, phone number, email and address”.

    The terms “company”, “our” and “we” are used to refer to Prosomo.

    The term “customer” is used to refer to companies that use our platform for their business unless otherwise specified.

    The following policy is the latest version available and is only valid for our platform. If there are any significant changes, you will receive a notice to inform you.

    COLLECTED DATA

    Our platform does not collect personal information unless you voluntarily submit it when using our services, for example:

    1. Creation of your user account by you or a platform administrator.
    2. Submitting a message to obtain additional information about a service. In this case, your last name, first name, e-mail address and telephone number are collected

    You will always be informed of the reasons for collecting this information, and the information used will be clearly explained.

    CELL PHONE USE OR OTHER MOBILE DEVICES

    When you access our platform on your cell phone or mobile device, we may obtain information about your device ID and location. However, it is possible to block the location service directly on the device you are using.

    COOKIES

    Only cookies that are ESSENTIAL to the operation of the platform are used. These cookies are as follows:

    • SCCookiesConsent: Cookie to store consent which expires every 6 months.
    • PHPSESSID: Preserves the logged-in user’s session. The user will have to log in again when he closes his browser.

    TOOLS

    Certain data is automatically collected when you use our platform, such as your IP address, your operating system and browser, the pages you have visited and the requests you have made to them, and the time and day of your connection to the platform. This information does not reveal your identity and is therefore not considered confidential.

    This information is collected in order to:

    • authenticate users, apply security measures and prevent abuse ;
    • measure your use of our platform, strictly for debugging purposes;
    • develop and improve our products and services.

    PUBLICATION AND THIRD PARTIES

    We may be called upon to share information that is neither personalized nor confidential about the company including trends in the use of our services to third parties. We ensure that no transmission of confidential information is made without the client’s consent.

    SECURITY

    We do as much as possible to protect the user. The personal information we collect is encrypted using SSL (Secure Sockets Layer) technology as mentioned above and access to the data is strictly limited to those who process the data. These are subject to strict confidentiality obligations.

    The data stored in the servers is only communicated in case of legal obligation; to apply our terms of use; to preserve our rights, property and safety as well as those of our users; to counter fraud; or with your consent and is protected by a confidentiality and security parameter.

    MINOR CHILDREN

    Our platform is not intended for minors.

    TRANSITION

    In the event of a sale, purchase, partnership, reorganization, merger, bankruptcy or other possible transition of the company, we are committed to protecting the information collected in the transfer process.

    LINKS TO EXTERNAL SITES

    Our platform may contain links to external sites. These sites are not governed by our privacy policy. We recommend that you check the privacy policies of these sites to understand their procedures regarding your confidential information. The company cannot be held responsible for the treatment of confidential data on these sites, to which it provides links for the convenience of its users.

    Please feel free to contact Prosomo for more information on how we handle your personal data or to change the data we already have. We will be pleased to inform you further.

    info@prosomo.com

    PROSOMO INC.
    95 Boulevard de la Technologie, Suite 103
    Gatineau, QC, J8Z3G4

    Personal Information Protection Policy

    The purpose of this policy is to ensure the protection of personal information, as well as to define the procedures for the collection, use, communication, retention, destruction and management of information by Prosomo, including management, employees, suppliers, etc. In addition, it is intended to inform any person concerned about the processing of their personal information by Prosomo.

    The term “customer” may mean the administrator or an employee of the business or organism who rents the Synfony platform. The term “customer” means the customer of the business who uses our platform only when so specified.

    Synfony is a platform used by our customers for e-commerce platform, database, reservation software, billing software or any other applicable purpose depending on the specialized software developed to meet the specific needs of our customers’ various industries.

    The data collected in the database is used exclusively by our customers, who collect information concerning their own customers carrying out transactions or other functions through our platform. Prosomo does not make any use of the data collected through its platform.

    Prosomo takes all reasonable means known to ensure the protection of personal information of users of its platform. The information collected, used, communicated, retained or destroyed is governed by this policy with the objective of protecting the privacy of users of our platform.

    To ensure the optimal protection of personal information, Prosomo’s Privacy Officer shall:

    • Oversee and review internal practices and procedures for processing personal information as well as compliance with current laws;
    • Suggest measures to ensure ongoing protection of personal information in line with Privacy Impact Assessments.
    • Implement necessary measures within the business to ensure the protection of information;
    • Ensure staff compliance and training in best practices for protecting personal information.
    • Coordinate, investigate, and respond to inquiries and complaints about personal information protection;
    • Communicate with the concerned individual(s) and the Commission d’accès à l’information (CAI) in case of a data leak or any incident;
    • Keep a record of personal data-related incidents.

    We make every effort to protect data and secure our platform. However, as no online method is perfectly secure, we cannot guarantee total protection of your data.

    We will retain data for as long as is necessary for the purposes for which it was obtained. The length of retention depends on the nature of the data, the risks associated with unauthorized disclosure, the purposes of processing, available alternatives and legal obligations. If a customer ceases to use the platform, the data is retained for a period agreed with the customer. Data is deleted in accordance with the agreement with the customer and on request.

    The protection of personal information is everyone’s business. No retaliation can be made against an individual who files a complaint about the protection of personal information or participates in a CAI investigation procedure.

    WHY DO WE USE YOUR DATA?

    We use data primarily to fulfill contractual obligations, such as processing subscription payments. In addition, we or our partners may need the data collected for business purposes, to meet the following non-exhaustive purposes:

    • fraud and risk prevention
    • responding to your requests or providing assistance
    • to improve and supply our products and services

    We will only use your data for these “legitimate interests” after assessing and mitigating any risks to your privacy. For example, by ensuring full transparency about our privacy policies, by giving you control over your data where possible, by restricting the amount and use of your data, by being selective about who receives it, by limiting its retention period and by employing technical measures to secure it.

    We process data collected on the basis of your consent, especially where no other legal basis is applicable.

    COLLECTION OF PERSONAL INFORMATION

    The personal information collected allows Prosomo to perform its functions and conduct its business in accordance with applicable laws and standards. Synfony collects personal information only for specific, contractual and pre-defined purposes, such as e-commerce on its platform. The collection of personal information is done through the client company and is only stored with no other purpose than the creation of a database on Prosomos’ servers. The information stored is the property of the customer who conducts e-commerce or other practical business using the Prosomo.

    The communication of personal information from one of your customers may be requested in order to assist you in the event of an emergency, for example. It is your responsibility to obtain the consent of the person concerned before authorizing us to access his or her contact details, unless we are legally obliged to provide the information.

    SOURCES OF PERSONAL INFORMATION

    To optimize the use of the Synfony platform and the management of your customers, through you and/or directly by your customers, we collect and use the personal data of your customers and employees in several ways:

    • On your part: We collect the data you entrust to us when using our platform. This includes your customers’ registrations, their visits to the platform, order information, your interaction with the platform, and your actions on our site, such as the search terms you use.
    • From third parties: We also collect information from our partners, for example:
      • Service providers: These partners help us offer additional services, and also provide us with certain information.
      • Subcontractors: We collaborate with third parties for various services such as cloud hosting, data analysis, and more.

    This data collection enables us to continually improve our service to provide you and your customers with a better experience.

    CONSENT AND ACCURACY OF PERSONAL INFORMATION

    It is the customer’s responsibility to ensure that personal information is collected for justified, clear and specific reasons and with the free and informed consent of the individual.

    LIMITS ON THE USE OF PERSONAL INFORMATION

    Prosomo must provide certain information in order to satisfy legal and regulatory audit requirements and processes. Use may vary, but may include, for example, dispute resolution or legal requirements.

    Information may be transmitted to third parties to the extent necessary for the purposes of the Law. Prosomo cannot be held responsible for the behavior and use undertaken by third parties.

    Personal information will not be used or disclosed for purposes other than those specifically related to the customer contract unless required by Law.

    PROTECTION OF YOUR PERSONAL INFORMATION

    Prosomo takes all reasonable precautions and has implemented significant physical and technical measures to prevent unauthorized or illegal use of, and access to, personal information. The measures in place include, among others:

    • Use of information only when necessary ;
    • Ensure the confidentiality and protection of personal information that someone may have learned in the course of their duties, unless authorized to disclose it by the person concerned ;
    • Protection files with selective and limited access to authorized persons ;
    • Secure access to offices with locked doors and access codes ;
    • Secure shredding of paper files ;
    • Two-factor authentication for all platform connections;
    • Immediate withdrawal of access following the end of a business relationship.

    All individuals are required to contribute to the protection of personal information. If you suspect that sensitive information has been compromised, you must immediately notify the Privacy Officer.

    RETENTION PERIOD FOR YOUR PERSONAL INFORMATION

    Prosomo undertakes to comply with the minimum retention periods provided by the category of personal information and applicable laws. However, if the information collected is no longer useful to Prosomo and its retention is not necessary or mandatory according to different legislative frameworks, it will be destroyed, erased, or converted in such a way as to remain anonymous.

    COMMITMENT TO TRANSPARENCY

    Prosomo is committed to being transparent about the processing, procedures, and purposes for which personal information is used with customers, employees, interns and business partners.

    ACCESS TO PERSONAL INFORMATION OF USERS OF THE SYNFONY PLATFORM

    For any consultation, withdrawal and/or modification of personal information stored on the platform, our customer may write to the e-mail address info@prosomo.com. A written request should be submitted to the Privacy Officer at info@prosomo.com. A reply will be provided within 30 days of receipt. Where it is not possible to share the requested information, legal justification and support must be provided to support the decision with the requestor.

    COMPLAINTS

    A person who believes that their personal information has been collected, retained, used, disclosed, or destroyed in a way that is not in accordance with the provisions of this policy, may file a confidential complaint with the Privacy Officer at info@prosomo.com. The individual must provide their name, contact details, including a phone number, and the subject and grounds for the complaint. It is necessary to provide sufficient details for the complaint to be properly assessed. A response will be provided within 30 days following the date of receipt of the complaint. If the complaint is insufficiently specific, the Privacy Officer may request any additional information deemed necessary to evaluate the complaint. The Privacy Officer will conduct an investigation into the received complaints, minimize any possible damage, and make the necessary corrections.

    You may also file a complaint with the Commission d’accès à l’information du Québec. However, Prosomo encourages concerned individuals to first communicate with the Privacy Officer and wait for the conclusion of the planned management process.

    APPROVAL

    This policy is approved by the Privacy Officer at Prosomo.

    Privacy Officer

    95 Boulevard de la Technologie, Suite 103
    Gatineau (Québec) J8Z 3G4
    info@prosomo.com

    For all requests, questions or comments relating to this policy, please contact the Privacy Officer by email.