PRIVACY POLICY AND PROTECTION OF PERSONAL INFORMATION

This policy is not an official translation and is provided to you as a means to understand an original document that was in a different language. Therefore, it will not be interpreted as being conforms to the French version and the French version will prevail in the event of any discrepancy between the French version and this translation.

 

Last updated: September 17, 2023

 

Introduction

 

At MICRO-FUTURE we believe that it is necessary to pay particular attention to the protection of privacy. This is why we are committed to respecting the confidentiality of the personal information we collect.

 

The processing of personal information is regulated (for example, in Quebec, by the Private Sector Act as amended by Law 25 modernizing legislative provisions regarding the protection of personal information (formerly “Bill 64”) and we must obtain your consent before carrying out certain transactions. By accepting this policy and providing us with personal information, you consent to the collection, use, disclosure, retention and destruction of personal information about you in accordance with the terms described in this policy.

 

This privacy policy covers all types of personal information managed by MICRO-FUTURE, whether it is the information of its clients, potential or current, its consultants, its employees, its members or any other persons such as visitors to the website. Or other.

 

As defined by law, according to the Commission d'access à l'information du Québec, personal information is information that allows a natural person to be identified, directly or indirectly. For example, this could be a person's name, address, email address, telephone number, gender or banking information, health information, ethnic origin, language , etc. It is also contained in the law that certain information is considered of public order such as information concerning the exercise of a function of a person within a company or a public body such as the name, title, the position, email address, address and telephone number of their place of work. For more information about the law that requires us to draft this policy, please refer to the Commission d’access à l’information du Québec. (https://www.cai.gouv.qc.ca/)

 

By accessing or using www.micro-future.net (our “Website”) or our services you indicate that you understand, accept and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this website or our online or offline services after we make changes indicates your acceptance and consent to those changes, so please check this policy regularly for updates. We will never materially change our policies and practices to make them less protective of personal information collected in the past without the consent of the individuals concerned.

 

If you do not accept this privacy policy, please stop browsing the website, using it or using our other online or offline services, as applicable. Contact us immediately so we can delete any information we have about you. Contact information for our Privacy Officer is available at the bottom of this document.

 

If you have any concerns or suspect unauthorized use of your personal information coming from our company, please contact us promptly at the following contact details: privacy@micro-future.net

 

Collection of personal information

 

As part of the provision of our services, we must collect certain information concerning individuals which allows them to be identified.

 

The types of personal information that are collected by us depend on several factors and context, as described below. We only collect personal information necessary to conduct our activities and achieve the specified purposes.

 

You can refuse to provide your personal information. However, some personal information is necessary for the use of our services, so your refusal to provide personal information may prevent the use of our services.

 

You may provide us with personal information in several ways, including for example when you visit our website or use our services ("cookies"), when you create an account on our website, or when you otherwise use our services, including when you correspond or interact with us in any way.

 

In order to conduct our business, we may collect information that is provided to us voluntarily, through the website (by completing a form) or otherwise (for example by post, by email, by telephone call, by text message, by message electronic and others). In certain situations, we may also collect personal information from third parties, without the consent of the person concerned, if they have a serious and legitimate interest in doing so and if the collection is in the interest of the person and it is not possible to do so with him in a timely manner, or if this collection is necessary to ensure that the information is accurate.

 

  • First and last name
  • Email Address
  • Address
  • Mailing address of your employer
  • Postal code
  • Country, province
  • Occupation
  • Position in a company
  • Personal phone number
  • Business phone number
  • Phone number
  • Fax number
  • Website
  • Name of your employer
  • Your employer's business name
  • IP adress
  • And other similar information

 

The personal information we collect is collected in order to:

 

  • Facilitate the communication and support that you or your employer request from us.
  • To establish and manage relationships with our customers.
  • To provide a service (e.g. guidance or support service)
  • To identify you (e.g. in order to install services linked to your employer. Email and others)
  • Respond to a request for information.
  • Send you information by email.
  • Ensure payment of costs related to the use of our services.
  • And other similar uses.

 

When using personal information we hold, we will ensure that the information is up to date in order to make a decision about the individual.

 

 

Other possible uses of your personal information

 

Except as provided in this policy or in accordance with applicable laws, including the Act respecting the protection of personal information in the private sector, we do not disclose your personal information to third parties other than our service providers, and their directors , respective officers, employees, agents, consultants, advisors or other representatives for whom it is necessary to have access to your personal information in order to provide our services to you. We do not sell, trade, or rent your personal information.

 

We may, by law, only use an individual's personal information for the reasons stated herein or for any other reasons provided at the time of collection. Therefore, if we need to use this information for another reason or another purpose, we will contact you to obtain new consent, which must be obtained expressly if it concerns sensitive personal information.

 

However, in accordance with applicable laws including the Act respecting the protection of personal information in the private sector (https://www.legisquebec.gouv.qc.ca/fr/document/lc/P-39.1) we may be required to communicate your personal information to certain third parties, including:

 

  • To any service provider who necessarily needs certain personal information in the context of their provision of services to us, in particular in connection with the uses of personal information described in this Policy. We will only disclose personal information that is reasonably necessary to enable them to carry out their functions;
  • To government authorities and law enforcement agencies where required by applicable laws. We may disclose your personal information if we are required to do so in order to comply with any applicable legal obligation, including if disclosure is required to comply with a subpoena, warrant, court order or court rules. relating to the production of files;
  • For the purpose of recovering a debt owed;
  • To a body charged by law with preventing, detecting or repressing crime or offenses against laws, which requires it in the exercise of its functions, if the information is necessary for the prosecution of an offense against an applicable law particularly in Quebec;
  • If we transfer or contemplate transferring control of our business, including the Website and Services, to a third party acquiring all or substantially all of our assets, including our rights and obligations relating to our Website and to our Services, to a third party. The third party may continue to retain and use the personal information you provide to us. We will act reasonably,
  • To the purchaser, successor or assignee in connection with any merger, acquisition, debt financing, sale of assets or similar transaction, as well as in the event of insolvency, bankruptcy or receivership providing for the transfer, to one or more third parties, of personal information as a business asset. In such circumstances, we will make every effort to ensure that the merging, consolidated or amalgamated entity agrees to also be bound by this Policy or by a contractual agreement stipulating measures substantially similar to those we employ to protect the confidentiality of your personal information and to similarly comply with applicable legislation regarding the protection of personal information; 
  • If required or permitted by law.

 

 

Data security

 

We are committed to implementing reasonable security measures to ensure the protection of the personal information we manage. The security measures in place correspond, among other things, to the purpose, quantity, distribution, medium and sensitivity of the information. Thus, this means that information that can be qualified as sensitive will have to be subject to greater security measures and will have to be better protected.

 

Here, for the sake of transparency, is a list of the main software that we use and which may contain personal information. This personal information is stored in software that we trust for this type of personal information.

 

 

Emails

 

Microsoft Exchange Online

https://www.microsoft.com/fr-ca/microsoft-365/exchange/exchange-online

 

Here is their privacy policy.

 

https://privacy.microsoft.com/en-us/privacystatement

 

https://learn.microsoft.com/en-us/exchange/about-documentation/privacy-statement?view=exchserver-2019

 

 

For our part, to secure the information we store on Microsoft Exchange online (Office 365) we use strong, unique passwords as well as two-factor authentication with protected one-time password generation software. by biometric security, allowing two-factor authentication.

 

 

Accounting

 

Quickbooks online

https://quickbooks.intuit.com/fr-ca/

 

Here is their privacy policy.

 

https://www.intuit.com/privacy/statement/fr-ca/

 

For our part, to secure the information we store on Quickbooks Online we use strong, unique passwords as well as two-factor authentication with one-time password generation software, protected by biometric security, allowing two-factor authentication or with code sent by text message.

 

 

Note-taking app

 

Evernote

https://evernote.com/

 

Here is their privacy policy.

https://evernote.com/privacy/policy/

 

 

For our part, to secure the information we store on Evernote, we use strong, unique passwords as well as two-factor authentication with one-time password generation software, protected by biometric security, allowing two-factor authentication.

 

Other software/services/devices that may contain personal information about you.

 

 

  • Microsoft ToDo
  • Microsoft Teams
  • Sage 50 Accounting Pro (2021.3)
  • Microsoft Outlook
  • Apple mail
  • Google Gmail
  • Smartphone
  • Desktop computer
  • Laptop
  • Backup disk
  • Online backup
  • And others

 

The personal information we collect is stored in a secure environment. To ensure the security of your personal information, we use, among other things, the following measures:

 

  • SSL protocol
  • Network monitoring software
  • Computer backup
  • Login password
  • Two-factor authentication (MFA)
  • Biometric security
  • Firewall
  • DMARC, SPF and DKIM
  • Security logs
  • BitLocker

 

We are committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your personal information. However, as no mechanism offers maximum security, an element of risk is always present.

 

If you do not accept this risk, please stop browsing the website, using it or using our other online or offline services, as applicable. Contact us immediately so we can delete any information we have about you. Contact information for our Privacy Officer is available at the bottom of this document.

 

If you have any concerns or suspect unauthorized use of your personal information coming from our company, please contact us promptly at the following contact details: privacy@micro-future.net

 

 

Collection of more sensitive personal information.

 

In providing our services, we may need to collect and store certain more sensitive information with your permission. For example, but not limited to:

 

  • Login password
  • Wifi password
  • And other similar information

 

More sensitive personal information that we collect with your permission is collected to facilitate technical assistance that you or your employer requests from us. This information is treated confidentially and not shared with third parties without your consent.

 

To secure the personal information you entrust to us, we use the services of an online password manager that works with the Zero-Knowledge model, which uses AES-256 data encryption with PBKDF2 hashing and SHA-256 salting. . The password manager used is designed for privacy and follows industry standards. It holds third-party security certifications, including ISO 27001, SOC2 Type II, SOC3, BSI C5, and TRUSTe, among others. It employs trusted and reputable third-party security organizations to regularly conduct audits and tests of its service and infrastructure. It also participates in the Bug Bounty reward program which allows ethical hackers to report detected bugs and vulnerabilities.

 

For our part, we use various technologies, such as multi-factor authentication and biometric security, to secure access to the service.

 

We are committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your personal information. However, as no mechanism offers maximum security, an element of risk is always present.

 

If you do not accept this risk, please stop browsing the website, using it or using our other online or offline services, as applicable. Contact us immediately so we can delete any information we have about you. Contact information for our Privacy Officer is available at the bottom of this document.

 

If you have any concerns or suspect unauthorized use of your personal information coming from our company, please contact us promptly at the following contact details: privacy@micro-future.net

 

 

Conservation and security

 

We store your personal information in Quebec where possible, but once we have collected your personal information, it may be transferred to and stored in computer or cloud computing systems located outside of Quebec or Canada, and in jurisdictions where the laws on the protection of personal information may differ from those of Quebec and offer lesser guarantees regarding the protection of your personal information.

 

We retain and use your personal information for as long as is reasonably necessary given the purposes for which the personal information was collected.

 

We take appropriate security measures to attempt to ensure the security and confidentiality of your personal information. These measures are reasonable taking into account the sensitivity of the information concerned, the purposes for which it will be used, the quantity and distribution of the information and the medium on which it is stored.

 

We do our best to protect personal information from the moment we collect it, but no data transmited over the Internet or any other public communications network can be guaranteed to be completely secure.

 

If you do not accept this risk, please contact us immediately so that we can delete all information we have about you. Contact information for our Privacy Officer is available at the bottom of this document.

 

If you have any concerns or suspect unauthorized use of your personal information coming from our company, please contact us promptly at the following contact details: privacy@micro-future.net

 

Use of cookie 

 

Our Services may use cookies or similar technologies such as beacons, tags and scripts. Cookies are small text files that are stored on your device by the browser. Some cookies remain stored on your device until you delete them. Cookies allow us, for example, to recognize your browser more easily the next time you visit.

 

If this goes against your preferences, you can configure your browser so that it informs you of the installation of cookies and only allows it in certain cases.

 

Disabling cookies may limit the functionality of our services as well as those of the vast majority of other websites you visit.

 

Here are external links to methods for managing or blocking the use of cookies in the most popular browsers.

 

Google Chrome

https://support.google.com/chrome/answer/95647?hl=fr&co=GENIE.Platform%3DDesktop&oco=0#zippy=%2Callow-or-block-cookies

 

Internet Explorer

https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

 

Microsoft Edge

https://support.microsoft.com/fr-fr/windows/microsoft-edge-donn%C3%A9es-de-navigation-et-confidentialit%C3%A9-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd

 

Mozilla Firefox

https://support.mozilla.org/fr/kb/prevent-sites-web-store-cookies-donnees-site-firefox

 

 

Cookies are generally classified as follows:

 

Necessary (essential) cookies: The purpose of these cookies is to provide the requested service, application or resource. None of your requests can be completed properly without these cookies. In general, their purpose is to manage the actions you take on our website, for example, they help you obtain visual elements, use page resources and log in to your account. In addition to enabling essential functions, with these cookies we can ensure the security and effectiveness of our website.

 

Analytics/Performance Cookies: These allow a website to recognize and count the number of visitors and see how visitors move around a website when using it. This helps website operators improve the way a website functions, for example by ensuring that users easily find what they are looking for.

 

Functionality (personalization) cookies: These are used to recognize you when you return to a website. This allows a website operator to remember your preferences.

 

Targeting (advertising) cookies: These cookies record your visit to a website, the pages you visited and the links you followed. They are used to make a website, including any advertising displayed on it, more relevant to your interests.

 

Here is the list of 3 “cookies” used by our website on the date of writing of this confidentiality policy.

 

Cookie #1

 

Cookie: PHP session cookie

 

Type: Functionality required cookie

 

Name: PHPSESSID

 

Expiration: When the browsing session ends

 

Personal information collected: none

 

Purpose: The PHPSESSID cookie is native to PHP and allows websites to store serialized state data. It is used to establish a user session and transmit state data through a temporary cookie, commonly called a session cookie. As the PHPSESSID cookie has no scheduled expiration, it disappears when you close your browser.

 

Cookie #2

 

Cookie: MotoCMS 3 cookie

 

Type: Functionality required cookie

 

Name: _session-started 

 

Expiration: When the browsing session ends

 

Personal information collected: none

 

Purpose: The MotoCMS 3 template generates an impersonal cookie. It contains a description with information about when each specific client enters the site for the first time, so the system must configure the work of automatic pop-ups (when to display these pop-ups and when to avoid them). This is the only information collected by the MotoCMS impersonal cookie. https://support.motocms.com/hc/en-us/articles/360060028092-New-Cookie-Policy-and-MotoCMS-How-to-avoid-the-violation-of-the-Cookie-Law

 

Cookie #3

 

Cookie: Banner validation cookie

 

Type: Functionality required cookie

 

Name: _cookie-notification-applied

 

Expiry: 10 days

 

Personal information collected: none

 

Purpose: The “_cookie-notification-applied” cookie is used to remember your acceptance of our use of cookies as well as the provision of our Privacy Policy which is displayed when you first open our website. This cookie allows the cookie banner to disappear from our website for a period of 10 days following your acceptance of it. After 10 days or if you delete this cookie and then return to our website the cookie banner will reappear.

 

 

Website Analytics Tools

 

Our website does NOT currently collect analytics data using web analytics tools such as Google Analytics, however if you wish to opt out of Google Analytics for other websites you can install the " Google Analytics Opt-out Browser Add-on” which is available at:

https://tools.google.com/dlpage/gaoptout

 

Links to other websites

 

Our site offers hyperlinks to other sites. The information exchanged on these sites is not subject to this confidentiality policy, but to that of the external site.

 

Personal information relating to minors

 

We do not intentionally obtain personal information from minors. Under the terms of Law 25, in Quebec, the consent of any minor under 14 years of age must be given by the holder of parental authority or a guardian.

 

If you suspect that we hold personal information about a minor, please notify us promptly either by email at privacy@micro-future.net or by contacting our Privacy Officer. Contact information is available at the end of this document.

 

If we discover personal information concerning minors, we will immediately destroy their information or promptly request authorization from the holder of parental authority or guardian if their personal information is necessary.

 

Rights of access, rectification and withdrawal of consent (Right to be forgotten)

 

To assert their rights of access, rectification or withdrawal of consent, the person concerned must submit a written request to this effect to the person responsible for the protection of personal information, at the email or postal address indicated at the bottom of this document .

 

By law, data subjects may request access to the personal information we hold and request its correction if it is inaccurate, incomplete or ambiguous. They may also demand the cessation of the dissemination of personal information concerning them or that any hyperlink attached to their name allowing access to this information by technological means be deindexed, when the dissemination of this information contravenes the law or to a court order. They can do the same, or even require that the hyperlink allowing access to this information be reindexed, when certain conditions provided for by law are met.

 

Our Privacy Officer must respond to such requests in writing within 20 calendar days of the date the request is received. The deadline for responding may also be extended if the request concerns industrial, financial, commercial, scientific, technical or union information provided by a third party. The person responsible for access to documents may, in fact, have to ask a third party whether or not they agree to communicate such information. He must nevertheless inform the applicant of this approach within 20 calendar days of receipt of the request.

 

Any refusal by the person responsible will be motivated and accompanied by the legal provision justifying the refusal. In these cases, the response will indicate the remedies under the law and the time limit for exercising them. Our manager will help the applicant understand the refusal if necessary.

 

The data subject may also ask our Privacy Officer what personal information is collected from them, the categories of people who have access to it and their retention period.

 

Complaint handling process

 

Any person who wishes to make a complaint relating to the application of this policy or, more generally, to the protection of their personal information by our company is invited to do so in writing to our personal information protection manager. Contact information for our Privacy Officer is available at the bottom of this document.

 

When making a complaint, the person concerned must indicate their name, their contact details, including their telephone number, as well as the subject and reasons for the complaint, giving sufficient detail so that it this can be evaluated by our personal information protection officer. Our manager may request any additional information he deems necessary to evaluate the complaint.

 

Within 20 days following receipt of the complaint or following receipt of all additional information deemed necessary and required by our personal information protection manager to be able to process it, the latter must evaluate and formulate a reasoned written response by email, to the complainant. This assessment will aim to determine whether our processing of personal information complies with this policy, any other policies and practices in place within our company and applicable legislation or regulations.

 

In the event that the complaint cannot be processed within this period, our personal information protection officer will inform the complainant of the reasons justifying the extension of the deadline, the progress of the processing of his complaint and the reasonable deadline. necessary to be able to provide a definitive answer.

 

Our personal information protection manager must create a separate file for each complaint addressed to him. Each file must contain the complaint, the analysis and documentation supporting its evaluation, as well as the response sent to the person who made the complaint.

 

Please note that it is also possible to file a complaint directly with the Commission d'access à l'information du Québec or any other monitoring body regarding the protection of personal information responsible for the application of the law concerned by the subject of the complaint. However, we invite anyone interested to first contact our Privacy Officer and wait for the processing process to complete.

 

Privacy incident involving personal information

 

In order to comply with the Laws, in Quebec, our personal information protection manager maintains a register of confidentiality incidents.

 

For law enforcement, a confidentiality incident corresponds to any access, use or communication not authorized by law of personal information, as well as the loss of personal information or any other breach of its protection.

 

For example, a privacy incident could occur when:

 

  • A staff member consults personal information without authorization;
  • A staff member communicates personal information to the wrong recipient;
  • The organization is the victim of a cyberattack: phishing, ransomware, etc.

 

If we have reason to believe that a confidentiality incident involving personal information that we hold has occurred, we:

 

  • will assess whether the incident presents a serious risk of harm.
  • will take reasonable measures to reduce the risk of harm being caused and prevent new incidents of the same nature from occurring.
  • will notify the Quebec Commission for Access to Information without delay.

 

  • If serious harm is suspected, we will communicate with the people affected by the data leak in order to warn them and guide them to the best of our knowledge on how to reduce this harm as quickly as possible. Unless this notice is likely to hinder an investigation carried out under the law to prevent, detect, repress crime or offenses. Or if another Law prohibits us from doing so.

 

More information about this policy

 

If you have any questions regarding this policy, we invite you to contact us using one of the communication methods presented in the section responsible for the protection of personal information at the bottom of this document.

 

We reserve the right to change or modify the terms of this Privacy Policy without notice, while respecting the terms of the Law.

 

This policy is published on the website in French at https://micro-future.net/politique/  and in English at https://micro-future.net/privacy-policy/  and is made available in paper version to any person who requests it directly to the postal address of our person responsible for the protection of personal information.

 

This confidentiality and protection of personal information policy has been in effect since September 17, 2023, and is version 1.0 (First Version). In order to comply with the law, we will publish all modifications to this policy on our website as well as by any means likely to reach the persons concerned.

 

 

Responsible for access to documents and protection of personal information

 

The person responsible for applying the Personal Information Protection Act is, as such, also responsible for ensuring compliance with this policy. To make comments or complain about non-compliance with this policy, you can contact:

 

François Deschênes 

Micro-Future

 

1500 du Bosquet,

Saint-Lazare, Qc

J7T 1Z2

 

514-951-9876

privacy@micro-future.net