Privacy Policy

PRIVACY POLICY FOR WEBSITE, AFFILIATE SITES, ADMIN PORTAL, BLOG, AND SOCIAL MEDIA

9217-0182 Quebec Inc. DBA Secure Group (1176, Rue Bishop, Montréal Québec H3G 2E3, Canada) (“Secure Group” “SG” or “us” or “we”) believes the right to privacy is one of paramount importance. This is why we have implemented this privacy policy (“Privacy Policy”), allowing the protection of your integrity and of your right to disclose or not your personal information.

Our privacy practices are consistent with:

EU General Data Protection Regulation (GDPR)

In accordance with these laws, SG may share information, including Personal Information (as defined in section 5 below) provided on a voluntary basis with its promotion and marketing agency and mass-mailing agency.

All Personal Information is collected with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. SG values the privacy of its customers, employees, job applicants and other visitors to its website who may choose to provide Personal Information.

This Privacy Policy will assist you to understand what types of information we may collect on securegroup.com (hereinafter the “Website”), how that information may be used and with whom the information may be shared, with regards to our site, portal and social media pages. See our Privacy Policy for Secure Pack for information specific to the privacy guidelines applicable to our product line.

Secure Group’s Commitment: Our Privacy Principles

Our commitment regarding your Personal Information is reflected in a series of 10 Privacy Principles, which are as follows:

1. Principle – Accountability

SG is responsible for Personal Information under its control.

2. Principle – Identifying the Purposes for Collection of Personal Information

SG will identify the purpose for which Personal Information is collected at or before the time the information is collected. Some of the identified purposes for which SG collects, uses and discloses your Personal Information are described below in this Privacy Policy. If we intend to collect, use or disclose your Personal Information for additional purposes, we will seek your consent.

3. Principle – Consent for Collection, Use, or Disclosure of Personal Information

SG will obtain your informed consent for the collection, use or disclosure of your Personal Information, except as permitted by law.

4. Principle – Limiting Collection of Personal Information

SG will limit the collection of personal information, both the amount and the type of information, to what is necessary for the purposes identified by SG.

5. Principle – Limiting Use, Disclosure and Retention of Personal Information

SG will not use or disclose Personal Information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. SG will retain your Personal Information only as long as necessary to fulfill the identified purposes.

6. Principle – Accuracy of Personal Information

SG will attempt to make sure that your Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

7. Principle – Security Safeguards

SG will protect your Personal Information by security safeguards appropriate to the sensitivity of the information.

8. Principle – Openness Concerning Policies and Practices

SG will make readily available to you specific information about our policies and practices relating to the management of Personal Information.

9. Principle – Individual Access to Personal Information

Upon written request, subject to certain exceptions, SG will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information. You are able to challenge the accuracy and completeness of the information and have it amended as appropriate.

10. Principle – Challenging Compliance

You have the right to address a challenge concerning compliance with this Privacy Policy to SG’s Privacy Officer.

Consent

This Privacy Policy applies to all information gathered for and on behalf of SG via its website or customer support, whether in writing, verbally or electronically. By using the Website, registering for SG ‘s Services or participating in any program or service managed by SG, save and except Secure Pack, which use is governed by a distinct Privacy Policy, you consent to the data collection and use practices described in this Privacy Policy. If you have question about this Privacy Policy or the protection of your information, please refer to section 17 on how to contact our Privacy Officer.
1. BY SUBMITTING PERSONAL INFORMATION TO SG, OR BY ACCESSING AND USING THE WEBSITE OR THE SERVICES OF SG (for the purpose of this Privacy Policy, Secure Pack is not part of the Services), YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW.

Consent to Share and Disclose Information

In addition to consenting to this Privacy Policy and our Terms and Conditions, including any relevant supplemental policies, you expressly consent to SG sharing the information that you have provided, as described herein. SG may share information with its promotion and marketing agency and mass-mailing agency.

Consent to Electronic Notice if There is a Security Breach

If SG is required to provide notice of unauthorized access of certain security systems, you agree that SG may do so when required or voluntarily by posting notice on the Website or sending notice to any email address that we have for you, at SG’s sole discretion. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

Type of information we May Collect

“Personal Information” is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
Personal Information shall include but is not limited to: name, home address, home postal code, home telephone number, mobile phone number, email address and employment related information such as may be found on resumes, applications, background verification information, or in employment references.
Non-personal Information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.

Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information

Cookies – in addition to Personal Information, we use data collection devices such as “cookies” on certain web pages to facilitate the transactions to be completed on the Website, help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.
1. Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.
2. Internet Protocol (IP) Address an Internet Protocol (IP) Address is associated with your computer’s connection to the internet. SG may use your IP address to help diagnose problems with SG’s servers, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Website. SG does not link IP addresses to any Personal Information.
3. Aggregate Information €“ is used to measure the visitors’ interest in, and use of, various areas of the Website and the various services and programs that SG offers, SG will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, SG may undertake statistical and other summary analyses of the visitors’ behaviors and characteristics. Although SG may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.
4. We also use the services of Google analytics to gather Aggregate Information on our website. To opt out of being tracked by Google Analytics across all websites visit: tools.google.com/dlpage/gaoptout.

Our Use of Your Information

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.
1. With your prior consent, SG may market to you directly by email, mail or by telephone for the purposes, among others, of offering you some of SG new or current product. You may remove yourself from our list at any time.
2. SG undertakes not to use any Personal Information it gathers in compliance with this policy or with any applicable legislation, to any other purposes unless we obtain your consent for that purpose or in certain exceptional circumstances, where we believe in good faith that the law requires or allows it.

Collection and Use of Customer Information

SG will not collect Personal Information, unless you register for our services directly. In the future, and only to the extent that you expressly consented thereto, it is possible that we may use this information to contact you regarding products or promotions, as well as other products and services, which may be of interest to you. If you do provide us with Personal Information and expressly consent thereto, we may use the information to contact you, via e-mail, regular mail, telephone or other means, to provide you with information that you requested about specific products or services, provide additional future information about products or services that may be of interest to you, and to learn about and develop products and services. You may withdraw your consent at any time by unsubscribing from our database or contacting us in writing, as described below in the section 17.

Mobile Information

This section applies to individuals who visit our Website through a mobile device such as cellphone or tablet computer:

1. Mobile Information We Collect

Personally identifiable information (e.g. Name, email address) we collect only of what you share with us. For example, we may ask for this type of information so that we may contact you by phone or email at your request.
1. If you use any location-enabled products, you may be sending us location information. SG does not store or use this information other than to provide the service you requested.
2. Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve our customers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to SG, it may however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.
3. Use of third party services such as social sharing sites (e.g., Facebook, Twitter, Google+, and Pinterest) is governed by the privacy practices of those services. SG does not capture or store your login information or other personally identifiable information for these services; however session info or cookies may be stored.

2. How We Use Mobile Collected Information

We use the information collected through your mobile device to personalize your experience with the application and to improve your overall experience including the development of new products, services, and features. We also use the information to provide customer support, and when applicable, register and administer your account. Additionally, we may use the information you provide to contact you about updates to our service.
1. Information you provide may be used to fulfill the service(s) or carry out the transaction(s) you have requested or authorized.

3. Except as Required by Law, SG Does Not Share Any Collected Mobile Information with Third Oarties With the Following Exceptions:

SG may provide some personal data to third-party partners that are providing services essential to your mobile user experience.
1. All requests are sent through your mobile carrier’s network and your carrier may have access to it. Consult your carrier’s privacy policies for additional information.

4. Opt-Out of Email and Mobile Updates

You may have the opportunity to elect to receive email and mobile communications from us. We will only email you if you consented to receive emails from us. If you elect to receive emails, SG will send you occasional updates about new additions to the Website as well as special offers and promotions of which you can take advantage. If at any time you decide you would rather not receive these types of communications from SG, you can opt-out by clicking the unsubscribe link at the bottom of any SG’s email. You may opt-out by contacting us, according to section 17 of the present Privacy Policy.

5. Sharing of Personal Information

SG does not sell Personal Information to third parties. Except as described in this Privacy Policy, SG will not disclose Personal Information with a third party, unless a customer requests or, consents to such disclosure, or such disclosure is required or authorized by law.
1. We may share your Personal Information with agents, affiliates or service providers who act for or on behalf of SG in connection with the business of SG, or for further processing the data in accordance with the purpose(s) for which the data was originally collected, e.g., account creation, billing, third party maintenance of secure listing databases. We require our agents, affiliates and service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we retained them. We also require any third parties we retain to protect Personal Information disclosed by us in accordance with all applicable privacy requirements and the general privacy principles described in this Privacy Policy.
2. The Personal Information you provide us information that forms part of our business and may be disclosed and/or transferred to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of SG or of any of the business assets or a division thereof, in order to permit the third party to evaluate the proposed transaction to enable a customer to continue to receive the same products and services from the third party. We will require such third parties to agree in writing to maintain the confidentiality and security of Personal Information they receive and not to use it for any purpose other than the evaluation of a proposed purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing, or the delivery of services to you in accordance with the terms of this Privacy Policy.
3. Although we make every effort to preserve user privacy, we reserve the right to disclose Personally Identifiable Information to a third party in certain limited circumstances, specifically: to comply with a law, regulation, search warrant, subpoena, judicial proceeding, a court order, or as otherwise may be required by law, to enforce our policies or contracts, to collect amounts owed to us, to protect users of our sites from fraudulent or abusive use, during emergencies when safety is at risk, as determined by us, or otherwise where necessary for the establishment, exercise or defense of legal claims. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on the Website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities. Such disclosures will be made in accordance with our Law Enforcement Guidelines.

6. Security

We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.
1. We safeguard your Personal Information on the Internet by using industry-standard practices. Although “guaranteed security” does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.

7. Storage, Retention and Accuracy of Personal Information

SG takes all reasonable steps to insure that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.
1. SG will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose(s) remains valid after termination of our relationship with you.
2. We may store your Personal Information in our databases located in Montreal, Canada or in other datacenter outside Canada where they will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by SG. We undertake to notify you using the email address contained in your account in the event of such disclosure.

8. Access, Control and Update Information About You

We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you may use your account manager or you may contact us (see section 6) to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us also by contacting the Privacy Officer.

9. Links to Non-SG Web Sites and Third Parties

Please note that the securegroup.com website may contain links to other websites for your convenience and information. SG does not control those sites or their privacy practices, which may differ from securegroup.com. Our privacy policy cannot and does not apply to external websites. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their personal data with us; that sharing is governed by that third party’s privacy policy.

10. Social Media and Online Engagement

We use a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, we uses several third-party platforms including, but not limited to, Facebook, Twitter, Google+ and Pinterest. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by us. When interacting with our presence on those TPWA, you may reveal certain personal information to SG or to third parties. Except when used by our employees for the purpose of responding to a specific message or request, we will not use, share, or retain your Personal Information gathered through a TPWA.
1. At this time, we are present on five (5) Social Media websites, Facebook.com/Securegroup, Twitter.com/ thesecuregroup, plus.google.com/+SecureGroup/, www.youtube.com/user/TheSecuregroup and pinterest.com/securegroup/
2. Facebook: On our Facebook page, we post news and other items of interest to individuals. If you have a Facebook account or ‘Like’ Facebook.com/ Secure Group Facebook page, you can post comments or click on the ‘like’ option for individual entries. If you comment or click on the ‘like’ button, personally identifying information will be visible to us and other Facebook site visitors. The amount of visible personal information will depend on your own Facebook privacy settings. Our staff does not collect, use or disclose any information about visitors who comment or ‘like’ the SG Facebook site. Facebook collects and reports on non-personally identifiable information about activities on Facebook pages. This information is password protected and only available to the SG employees, members of the SG Communications and Web Teams, and other designated staff who require this information to perform their duties. The Facebook privacy policy is available at: http://www.facebook.com/about/privacy/.
3. Twitter: SG uses Twitter to send short messages (up to 140 characters) or ‘Tweets’ to share information about us with visitors and respond to comments and inquiries we received via Twitter. While visitors may view our Twitter feeds without subscribing or follow us, visitors who want to subscribe to (or follow) us must create a Twitter account at www.twitter.com. To create an account, you must provide some personal information, such as name, user name, password and email address. Visitors have the option to provide additional personal information including a short biography, location or a picture. Most information you provide for a Twitter account is available to the public, but you can modify how much of your information is visible by changing your privacy settings on the Twitter.com Web site. While we do monitor the number of subscribers and respond to comments and queries via Twitter, we never gather Personal Information belonging to our followers. We do not collect, maintain, disclose or share any information about our followers. The Twitter privacy policy is available at: http://twitter.com/privacy.
4. Google+: On our Google+ page, we post news and other items of interest to individuals. If you have a Google+ account you can post comments or click on the “+1” option for individual entries. If you comment or click on the “+1” button, personally identifying information will be visible to us and the other follower of our page. The amount of visible personal information will depend on your own Google+ privacy settings. Our staff does not collect, use or disclose any information about visitors who comment or “+1” our Google+. Google collects and reports on non-personally identifiable information about activities on Google+ pages. This information is password protected and only available to the SG employees, members of the SG Communications and Web Teams, and other designated staff who require this information to perform their duties. The Google privacy policy is available at:https://www.google.com/intl/en/policies/privacy/
5. YouTube: SG uses YouTube to share videos with its visitors. While you may view our videos without creating an account, if you want to subscribe or comment on our video, you must create a Google account at www.youtube.com. To create an account, you must provide some personal information, such as name, user name, password and email address. You will have the option to provide additional personal information including a short biography, location or a picture. Most information you provide for a YouTube account is available to the public, but you can modify how much of your information is visible by changing your privacy settings on YouTube’s website. While we do monitor the number of subscribers and respond to comments made on our videos, we never gather Personal Information belonging to subscribers. We do not collect, maintain, disclose or share any information about our follower. The Google privacy policy is available at: https://www.google.com/intl/en/policies/privacy/
6. Pinterest: SG uses Pinterest to pin articles and post that we believe to be relevant with our services or web site creation and management. While you may view the list of our boards without creating an account, if you want to view to content of a board, you must create a Pinterest account at www.pinterest.com. To create an account, you must provide some personal information, such as name, user name, password and email address. The Pinterest privacy policy is available at: https://about.pinterest.com/en/privacy-policy

11. Our Privacy Officer

You may contact our Privacy Office to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact the appropriate employee to fulfill your request.
1. Should you have any questions or complaints, do not hesitate to contact the Privacy Officer. The Privacy Officer may be reached:
  By phone at:
  514-461-3030
  By mail at:
  Attention: 9217-0182 Quebec Inc. DBA Secure Group Privacy Officer
  1176, Rue Bishop, Montréal Québec H3G 2E3, Canada
  By Email:
  privacy@securegroup.com

12. Changes to our Privacy Policy

This Privacy Policy is effective as of November 30, 2014. We reserve the right to update this Privacy Policy occasionally. We encourage you to review this Privacy Policy periodically to be informed of how we are protecting your information and to be aware of any changes to the Privacy Policy. Your continued use of the site after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. This Privacy Policy is incorporated into any Terms and Conditions governing the Website and any programs or services operated or managed on or behalf of SG. Any changes to this Privacy Policy are effective immediately after being posted by SG.

13. Terms and Conditions of Website Use

The Terms and Conditions governing your use of this Website are located at securegroup.com/policy/#term contain important provisions disclaiming and excluding the liability of SG regarding your use of our Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding your use of this Website. Each of these provisions applies to any disputes that may arise in relation to this privacy policy and the collection, use and disclosure of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy.