CONFIDENTIALITY AND PRIVACY POLICY

At The Universalia Management Group Limited (hereinafter referred to as “Universalia”), we strongly believe in the importance of protecting the personal information of our clients, employees and representatives (hereinafter referred to as "you", "your"). We are subject to the Personal Information Protection and Electronic Documents Act in the private sector, and as such, we are committed to maintaining the confidentiality of the personal data we collect during our activities.
 
Our Privacy Policy (the “Policy”) is designed to inform you of our practices regarding the collection, use, disclosure and retention of personal information. By choosing to provide us with personal information (whether via our website, email, in person or by telephone), you agree to the terms and conditions of this Policy and authorize us to process your personal information in accordance with this Policy, for the purposes set out below.
 

DEFINITIONS

For the purposes of this Policy:
 
  • “Account” means a unique account created for you to access our website or parts of it.
  • “Cookies” are small files that a website places on your computer, mobile device or other device that, among other things, contain details of your browsing history on that website, among its many uses.
  • “Device” means any device – a computer, mobile phone or digital tablet – that can access the Website.
  • “Personal information” or “data” means any information or data relating to an identified or identifiable individual.
  • “Service Provider” means any natural or legal person who processes such data on behalf of Universalia. This includes third party companies or individuals who are engaged by Universalia to facilitate the Service, to provide the Service on behalf of Universalia, to perform services related to the Service, or to assist Universalia in analyzing how the Service is used.
  • “Third Party Service” means any website or social networking site through which a user can log in or create an account to use the Service.
  • “Usage Data” means data that is automatically collected, whether generated by use of the website or by the website infrastructure itself (for example, the duration of a visit to a page).
  • “Website” means the Universalia website accessible at https://www.universalia.com
  • “User” means the individual who accesses or uses the website, or the company or legal entity on whose behalf such individual accesses or uses the website.
We may use cookies to collect usage data and improve your experience on our Website. We may also use third party services such as Google Analytics.
 

CONSENT

We are committed to protecting the privacy of our users and only collect and use personal information with their consent and to the extent permitted or required by law.
 
By using our website located at www.universalia.com, or by providing us with personal information, you agree to the terms of our Policy and consent to the collection and use of your personal information in accordance with this Policy.
 
You may withdraw your consent at any time, except where restricted by law or applicable contracts. We will inform you of the consequences of such withdrawal, including the possibility that we may not be able to provide a product or process a request. Please note that your decision to withdraw your consent will be recorded in our files.
 
In certain circumstances, we may collect, use or disclose personal information without your explicit consent. This may occur when it is impossible or impractical to obtain your consent for legal, medical or security reasons, or when information is collected to investigate a possible breach of contract, to prevent or detect fraud, or for law enforcement purposes.
 

COLLECTION AND USE OF YOUR PERSONAL INFORMATION

When you use our website, we may ask you to provide certain personal information that can be used to contact or identify you. This information may include, but is not limited to: 
  • Contact information such as your name, address, email address and telephone number;
  • Biographical information such as job title, employer, photograph and video or audio content;
  • Recruitment information, such as your curriculum vitae, educational and employment background, details of professional affiliations and other information relevant to a potential recruitment or association with Universalia;
  • Usage data may include information such as the IP address of your device, the type of browser you are using, the browser version, the pages of our website that you visit, the date and time of your visit, the time spent on those pages, unique device identifiers and other diagnostic data ;
  • If you access our website from a mobile device, we may automatically collect certain information, including the type of mobile device you are using, the unique identifier of your mobile device, the IP address of your mobile device, the operating system of your mobile device, the type of mobile Internet browser you are using, unique device identifiers and other diagnostic information.
  • We may also collect information that your browser sends when you visit our website or access our website from a mobile device.
  • Any other personal information that you provide to us. Please note that if you provide us with personal information about other individuals (such as your customers, directors, officers, shareholders, employees or beneficial owners), you must ensure that you have appropriately informed such individuals that you are providing us with their information and that you have obtained their consent to such disclosure. Universalia shall not be liable for your failure to provide such notice or obtain such consent, or for any consequences arising from such failures.
 

WE MAY USE YOUR PERSONAL INFORMATION FOR THE FOLLOWING PURPOSES:

Universalia's collection, use and disclosure of personal information is limited to what is necessary for the purposes for which it is collected.
 
Universalia collects personal information for a variety of purposes, including: 
  • Responding to your requests ;
  • Processing payments and issuing receipts ;
  • Completing your registration for an event, training course, newsletter, website download or webinar in which you wish to participate;
  • Managing human resources and service contracts;
  • Respecting your opt-out choices;
  • Operating, maintaining, improving and providing all features of the website, providing the services and information you request, responding to comments and questions and providing support to the website’s users;
  • Providing and improving our website, understanding how users interact with our website and personalizing your online experience. In addition, we may use your information to manage your account as a user of the website, including to provide you with access to various features and to respond to your requests. 

 

ACCURACY OF INFORMATION

We make every effort to ensure that your personal information is as accurate and complete as is necessary for the purposes of its collection, use or disclosure.
 

USE OF COOKIES AND OTHER ON-LINE TRACKING SYSTEMS AS GOOGLE ANALYTICS

 
We use tracking technologies such as cookies, beacons and scripts to improve and analyze our website. We use temporary and persistent cookies for a variety of reasons, including to provide the services available on the website, to authenticate users, to personalize the user experience and to track information about website traffic and usage.
 
Some cookies are essential to provide the requested services and to prevent fraudulent use of user accounts. We also use persistent cookies to remember user choices, such as logins and language preferences, to enhance the user experience.
 
We also use persistent tracking and performance cookies to track information about website traffic and to test new pages, features or functionality on the website to monitor user response. These cookies may be managed by third parties and may directly or indirectly identify you as an individual visitor.
 
You can set your browser to refuse cookies or to notify you when a cookie is being sent. Please note, however, that some parts of our website may not function properly if you refuse cookies.
 

COOKIES WE USE

ANALYTICAL DATA

We may use third parties, such as Google Analytics, to help us collect and analyze information about the areas of the website that are visited in order to evaluate and improve the user experience and the website. These third parties may use cookies and other tracking technologies. If you do not wish Google or other similar third parties to store and process this information (including your IP address), you may  download and install the browser plug-in available at the following link: Google Analytics opt-out browser plug-in download page. 
 
You can also read the Google Analytics privacy policy by clicking on the following link: Privacy Policy and Terms of Use - Google.
 

CONVERSION PIXELS

Conversion pixels, also known as “clear GIFs” or “spy pixels”, are tiny images, usually a single pixel, that can be placed on a web page or in an email to let us know when you have viewed that page or opened that email and to analyze response rates.
 

RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

We will only keep your personal information for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use it to the extent necessary to comply with our legal obligations, to resolve disputes and to enforce our legal policies.
 
We will also retain usage information for internal analysis purposes. This information is generally retained for a shorter period of time, unless it is used to enhance the security or improve the functionality of our website, or we are required by law to retain it for a longer period.
 

DISCLOSURE OF YOUR PERSONAL INFORMATION

Your information, including your personal information, will be processed at our operational offices and at any other location where the parties involved in such processing (such as our service providers) are located. This means that this information may be transferred to computers located outside your State, Province, Country or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction. As a result, under certain circumstances, foreign governments, courts, law enforcement agencies or regulatory bodies may be authorized to access personal information collected and stored under our control.
 
By using our website, you consent to this transfer. We will take all necessary steps to ensure that your personal information is treated securely and in accordance with this Policy. No transfer of your personal data will take place to any organization or country without adequate controls in place, including with respect to the security of your personal data and other personal information.
 
Each employee, director, volunteer, independent contractor or ad hoc consultant who serves on our Board committees agrees to respect the personal information we collect. In addition, these individuals agree to maintain the confidentiality of information specific to our activities and not to divulge it or use it for personal gain or for the benefit of others. This obligation comes into force at the time the employee, director, volunteer, independent contractor or ad hoc consultant assumes his or her position and continues indefinitely.
 

SALE OR TRANSFER OF BUSINESS OR ASSETS

If a business is sold or transferred, your personal information may also be transferred to the acquirer or transferee of the assets. If this occurs, Universalia will require the acquirer to use your personal information in accordance with this Privacy Policy. This includes the use of your personal information only by the acquirer and its affiliates. If we become involved in a reorganization, dissolution or liquidation, this may also result in the transfer of your personal information to a third party. In all cases, we will endeavor to protect your personal information and to notify you of any transfer to the extent required by applicable law.
 

SECURITY OF YOUR PERSONAL INFORMATION

We have implemented appropriate physical, technical and administrative security measures to protect the personal information you provide to us from unauthorized access, use or disclosure. These measures are periodically reviewed and improved to ensure the best protection of your information.
 
Although we make every effort to protect your personal information, you should be aware that no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.
 
It is also important to note that we cannot be held responsible for personal information that you share with other users or that you post in public areas such as our blogs. These public areas can be consulted or viewed by anyone who visits our website and are therefore not covered by this policy.
 

LINKS TO OTHER WEBSITES

Our website may contain links to third-party websites. If you follow these links, you will leave our website. Information exchanged at that point is no longer covered by our Privacy Policy. We encourage you read the privacy statements of other websites you visit before providing any information to them.
 

CHILDREN'S PRIVACY

We do not knowingly collect or solicit personal information from children under the age of 14. By using our website, you confirm hat you are at least 14 years old. If you are under 14, please do not attempt to send us any personal information. If we learn that we have inadvertently collected personal information from a user under the age of 14, we will attempt to promptly delete that information from our files and records. We also encourage website users under the age of 14 to ask their parents or guardians for permission before sending any information about themselves over the Internet.
 
If you believe that a child under the age of 14 has provided us with personal information, please contact us using the information provided below.
 

YOUR RIGHTS

You have the right to know whether we hold any personal information about you and to access that information. You also have the right to ask how we have collected your information, how we have used it and to whom it may have been disclosed.
 
Subject to applicable laws, upon receipt of a written request from an individual and after verification of the individual’s identity, we will inform the individual whether we hold personal information about him or her and will disclose such information to him or her.
 
We may refuse an individual access to his or her information in accordance with applicable laws, in which case we will provide reasons for our refusal.
 
Any request for access to information or request for modification may be addressed to the Privacy Officer at the following address:
 
Lynne Leduc, CPA, Director, Finance and administration (lleduc@universalia.com)
245 avenue Victoria, suite #200, 
Westmount (Québec), 
H3Z 2M6
 

COMPLAINTS AND CONCERNS

Our employees and agents are trained to respond to questions or concerns about your personal information. If you are not satisfied with the response from our employee or representative, you may contact the Privacy Officer at the above address.
 

CHANGES TO THE PRIVACY POLICY

We may change this Policy from time to time and will post the most current version online. We encourage you to review this Policy periodically to stay informed of any changes.
 
Updated: December 12, 2024