Privacy policy

This document outlines the policy for the protection of personal information as applied by Capsana, its employees and representatives.

Introduction

In its normal course of business, Capsana collects personal information about its employees, its clients and their employees, participants in its various campaigns, and its subcontractors. All personal information collected respects the general laws and regulations that apply to confidentiality and/or is subject to Capsana’s policy for the protection of personal information.

Capsana is committed to ensuring the accuracy, confidentiality, security, and private nature of the personal information it collects by stringently applying its policy and ensuring that it is respected by all of its employees and representatives.

Responsibility

The directors of business units and departments are responsible for ensuring that the policy is respected and for taking the appropriate measures to facilitate its application on a day-to-day basis. In cases where the policy is not respected, they will take appropriate measures to correct the situation.

Consent

Through its policies, Capsana will inform all persons concerned before it collects, uses or transmits personal information, unless it is inappropriate to do so under applicable laws.

Limits on information collected

Capsana will take measures to ensure that only information needed for the purpose identified will be collected. Personal information will not be transmitted or used for any purpose other than that for which consent was obtained directly or through third parties (see section on third party providers).

Subject to applicable laws, Capsana may keep personal information on file for as long as necessary for pre-established purposes, even if the person is no longer an employee, client, or participant.

Third party service providers: content, advertising, audience and networking

Part of the content, advertising and functionalities of the services provided (portals, Web sites and applications) can be supplied by third parties who are not affiliated with Capsana. These third parties include, for instance: content providers, advertising providers, audience measurement companies and social networking services (Google, Facebook, Twitter, Instagram, etc.). They can collect information on the usage of Capsana’s services through the use of cookies, clear pixels and other technologies. This information can be collected and combined with online services to present you offers (targeted advertising, connection or functionalities) based on your interests. These technologies and the information collected can be used on all types of devices.

The use of third party cookies is not covered in this policy as these companies have their own privacy policies. Consult the following sites to learn more about the use of this data: the Digital Advertising Alliance of Canada , the Facebook Data Policy , the Facebook list of social plugins , and the Google Privacy Policy .

You can stop the collection and use of information intended for targeted advertising by visiting www.aboutads.info/choices .

Accuracy

Capsana’s employees are required to inform the directors of business units or departments of any changes to information in their file. Clients, participants, and subcontractors are also requested to provide any changes to information previously submitted to Capsana.

Capsana will update personal information as soon as it is received from employees, clients, participants and subcontractors, when it is relevant to do so.

Security

Personal information is protected by security measures that are commensurate with the degree of sensitivity of the information.

Security measures protect personal information against loss or theft and against unauthorized consultation, transmission, copying, use, or modification.

The nature of the security measures will vary depending on the degree of sensitivity of the personal information, the quantity, distribution and format of the information, as well as how it is conserved. Various methods may be used, such as rendering the information anonymous, restricting access, applying password protection, or any other means judged to be appropriate under the circumstances.

Transparency

This policy is distributed to all managers, administrators, employees, and contributors, and to any person who requests it.

Access to personal information

Capsana will inform anyone who inquires as to the existence of personal information concerning them, how the information is used and the fact that it has been provided to third parties, and will allow them to consult it. It will be possible to confirm the accuracy and comprehensiveness of the information and to make corrections if required. Complaints will be handled according to the appropriate procedures and within a reasonable time frame. This policy will be upgraded periodically.