1. Acceptance and amendments
When the Visitor decides to access and use ILN’s website (hereinafter the “Site”), they accept ILN’s practices regarding the processing of and the measures to safeguard their personal information (hereinafter the “Policy”). It is therefore important for the Visitor to read the Policy to understand their rights and responsibilities. The Visitor agrees, in particular, to the gathering and use of their personal information by ILN in accordance with the Policy, it being understood that ILN complies with prevailing legislation in personal information matters.
The Visitor agrees and acknowledges that ILN reserves the right, at any time, to amend, change or update the Policy and the Visitor agrees to be bound by such amendments, changes or updates. The Visitor’s use of the Site after any amendment such amendment constitutes their acceptance to be bound by and to comply with the Policy thus amended and to be bound by it. Consequently, it is the Visitor’s responsibility to verify if there have been any amendments to the Policy by referring to the date they were last modified, which is found below.
If the Visitor does not accept this Policy or, as the case may be, the Policy as amended from time to time, ILN does not authorize the Visitor to access or use the Site, and they should stop accessing and using the Site.
2. Personal information
Subject to the Policy, ILN does not gather any personal information about the Visitor unless they, at their sole discretion, decide to provide such information voluntarily. The Visitor is free to access and use the Site, subject to the Terms of Us, without personal information being collected. However, if the Visitor wishes to receive information from ILN or to have their name added to ILN’s mailing list, the Visitor must disclose certain information, particularly their name and e-mail address, so that ILN’s server can respond to their request or, as the case may be, send them the requested information. This other information is also gathered so as to enable and manage the Visitor’s inclusion on ILN’s mailing list (including, in particular, the modification of the parameters of the Visitor’s inclusion on or deletion of their name and e-mail address from the mailing list), to facilitate the communication of relevant information to Visitors and for better knowledge of their profiles. This information is strictly confidential and will not be used for commercial prospection.
ILN handles and retains personal information in complete confidentiality, pursuant to applicable laws. ILN only uses personal information to the extent provided for by applicable laws.
The Visitor can access the personal information they provides to ILN and notify ILN to update, change or delete certain information that ILN gathered during their visit, by sending an e-mail to [firstname.lastname@example.org] or by answering messages sent to them because of their inclusion on ILN’s mailing list.
ILN applies adequate security measures to protect personal information. Where it deems it appropriate, ILN uses encryption or authentication tools, or both, as well as other means to protect certain personal information derived from the internet and kept on its servers. The Visitor acknowledges and agrees that the e-mail messages that they send to ILN can be tampered with before they reach ILN’s servers.
Personal information, electronic or other, gathered by ILN is not disclosed to any one, except ILN’s Representatives who need such information to discharge a duty associated with the fulfillment of the purposes set out in this Policy. The Visitor agrees and acknowledges that ILN is also authorized to use, disclose or communicate the Visitor’s personal information to the extent provided or required by law, including pursuant to court orders or to execute a contract granted to a supplier. In such a case, confidentiality clauses shall ensure that personal information is adequately protected.
ILN retains personal information in accordance with applicable law.
3. Information automatically exchanged
Even though the Visitor can access and visit the Site without informing ILN of who they are and without revealing information about themselves, in accessing the Site there is an automatic exchange of information between the Visitor’s computer, smart phone, electronic tablet or other device on which the Site can be accessed (each a “Device”) and ILN’s server. This exchange of information does not enable ILN to identify the Visitor, their name or e-mail address. However, this exchange, among other things, enables ILN to obtain the internet domain name that the Visitor used to access the Site (for instance, “xcompany.com” where the Visitor uses a private Internet access account, or “university.edu” where the Visitor accesses through a university), the Visitor’s IP address (IP stands for Internet Protocol, a single number assigned to the Visitor’s Device when it is connected to the internet and which enables documents intended for the Visitor to be downloaded without mistake), the type of browser and the operating system used by the Visitor to access the Site, the date and time the Visitor accessed the Site, the pages they visited and, where the Visitor accesses the Site from another site, then, this site’s address (referent site).
The operating system of the Site can automatically gather this information about the Visitor’s visit to the Site by means of cookies. Cookies are small bits of information stored by the Visitor’s Internet browser on their Device’s hard drive that enable ILN to recognize the Visitor when they access the Site. When the Visitor browses the Internet, a cookie is used for the purposes described above.
If the Visitor does not want ILN to gather information about their visit, they can, at their sole discretion, configure their browser so that it warns them when they receive a cookie or to prevent such cookies from being sent.
ILN uses this information to gauge the number of Site visits by visitors as well as the different pages they view, the average time that a Visitor spends on the Site, and to compile other statistics on visitors to the Site in general. With this information, ILN can also verify the Site’s performance for system administration purposes to make the Site easier and more user-friendly and to relay certain overall processed information to ILN Representatives for whom the transmission of such information is necessary to perform their duties.
4. General provisions
For the purposes of this Policy, the word “Representatives” includes ILN, members of ILN and their respective directors, officers, employees, shareholders, agents, service providers and subcontractors.
For the purposes of this Policy, the word “Visitor” means the person who, in fact, browses the Site as well as the person who authorizes the use of a Device or, as the case may be, the browsing equipment.
Section titles herein are used solely for easy reading purposes and may not be used to interpret the sections.
The Policy covers the entire agreement between the Visitor and ILN regarding ILN’s processing and use of the Visitor’s personal information and supersedes the prior written or verbal agreements between the Visitor and ILN with regard to the subject matter hereof. The Policy forms an integral part of the Conditions of Use (the “Conditions”).
4.3 Applicable law
This Policy is governed by the laws the Province of Québec and Canadian federal laws applicable therein, and any applicable legislation on personal information protection, notwithstanding any principle governing conflicting laws. The Visitor agrees to be bound by and to comply with the aforementioned laws. In addition, the Visitor who accesses or uses the Site from another jurisdiction shall be responsible for ensuring that their access and use is legally permitted in that jurisdiction and they agree to comply with local laws, to the extent that they apply to the Visitor. In the event of any dispute related to this Site or to the Conditions (including this Policy), the Visitor accepts the exclusive jurisdiction of the courts of the Province of Québec and the Federal Court of Canada. The Visitor agrees not to initiate any action or proceeding anywhere other than in Montréal, Québec (Canada) with regard to such a dispute.
4.4 Specific rules
In the event of inconsistency or conflict between one of the terms set out in the Conditions and a specific condition rule set out on a page of the Site in relation to some particular Content (including the Policy), the specific condition rule takes precedence.
4.5 General Data Protection Regulation
The General Data Protection Regulation (“GDPR”) is a European Union regulation to strengthen and standardize personal data protection for all its residents. In carrying out its activities, ILN may process Personal Data subject to the GDPR. ILN aims to comply with the requirements of the GDPR.
“Personal Data” is any information relating to an identified or identifiable physical person.
a) Data controller: Investor Leadership Network, 20 Carlton Street. Suite 123, Toronto, Ontario, M5B 2H5.
b) Purposes of the processing
ILN agrees to collect Personal Data only for determined, explicit and legitimate purposes, and to process the data in a way that is consistent with these purposes.
ILN is likely to process Personal Data when performing human resource management activities.
To process Personal Data, ILN always relies on the explicit consent of the Data Subject, on compliance with a legal obligation, on the execution of a contract to which the Data Subject is party, or on carrying out legitimate interests.
c) Recipients, transfer and storage
Authorized ILN Representatives are the recipients of Personal Data. ILN may use subcontractors to process all or part of Personal Data, to the extent necessary to accomplish their tasks in compliance with previously provided instructions.
ILN processes and stores Personal Data in a secure environment for the period necessary to achieve the purposes for which the Personal Data was collected.
Because of the international scope of ILN’s activities, some Personal Data may be transferred outside of the European Union to a member of the group. Such a transfer can only take place if the data are adequately protected, in compliance with European legislation.
d) Rights of the Data Subject
- The Data Subject has certain rights regarding the processing of their Personal Data:
- The right to request access to their Personal Data;
- The right to request that their Personal Data be rectified;
- The right to request, for legitimate reasons, the erasure or restriction of their Personal Data;
- The right to object to the processing of their Personal Data.
To exercise one or more of these rights, the Data Subject must contact the Data Protection Officer (DPO), by e-mail at: [email@example.com].
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Last update: November 26, 2018