Geneseeq Privacy Policy

Effective Date: January 1, 2020

  1. Application

Geneseeq Technology Inc. and its affiliates (collectively, “Geneseeq”, “we”, “our”, “us”) are committed to maintain the privacy and security of your Personal Information that is collected through our interactions with you and through our products, services and events and programs – including our website  (collectively, our “Services”). “Personal Information” is information about an identifiable individual. This Privacy Policy provides information about the types of Personal Information we may collect, use, disclose and otherwise manage your Personal Information. This Privacy Policy should be read in conjunction with our Terms of Use.

By using the Services, you consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy.

  1. Personal Information We May Collect

When you interact with us through our Services, we may collect data, including Personal Information from you or from other sources. Data that we collect may be information that you directly provide to us, such as Personal Information you provide when you use our Services, or information that is passively or automatically collected from you, such as information collected from your browser or device. The data we collect primarily includes:

(a) Data that you provide us through interaction with or use of our Services, including job applications made on our website. This data will vary, but typically include, name, email address, telephone number, mailing address, other contact information and customer relationship and/or service information, and for job applications, employment history, education background and other information provided in your resume and/or cover letter.

(b) Anonymous information related to your use of our website, such as the date and time you visit the site, and the pages you visit on the website.

(c) Location data, such as IP addresses transmitted from your device.

(d) “Cookie” information from your browser to identify your computer and provide us with a record of your visits to our website. The technology used to gather “cookie” information is provided by the Internet browser you use, and may be turned off by using your browser preference buttons.

(e) Payment data or banking information, such as for wire transfers, electronic funds transfers (EFTs) or automatic clearing house (ACH) transfers and billing address.

(f) Demographic data, such as age, gender, country and language preference.

(g) Device data, such as type of device, operating system and device identifiers.

(h) Third party integrations. If you connect your use of the Services through a third party service (e.g., a social media platform), the third party may share certain information from your third party account with us.

(i) Other third party data, such as data from our affiliates, partners or vendors, data brokers or public sources. 

  1. Purpose and Use of Personal Information

We may use your Personal Information for the following purposes.

(a) To provide Services which you use, request or inquire about. For example, to perform contractual obligations, process transactions, provide technical support and respond to inquiries, to prevent fraud or misconduct, engage in discussions, pursue business opportunities and/or relationships and for business development purposes.

(b) To provide effective marketing and advertising. We also use the data we collect and receive to provide advertisements for our Services and certain third-party services and to send you promotional communications. For example, to send you electronic and other marketing messages about our Services, or other third-party business partners that may be tailored to your preferences and interests and to conduct analytical and/or market research to enable us to improve the goods and services we offer.

(c) To assess or enter into an employment relationship with you. For example, to assess job applications, obtain references from you or third parties, to inform you of job opportunities and to review and assess our hiring policies, practices and statistics.

(d) To improve our operations and services. For example, to solicit, process and review input and feedback from you, identify and address technical issues on our Services.

(e) To use the data we collect and receive, including Personal Information, to anonymize you, after which we may use it to provide insights for ourselves and third parties.

We may use the data we collect and receive for other purposes that will be described to you at the point of collection or for which you provide consent.

In some circumstances, we engage agents and service providers to assist us in providing our Services. As such, we may share your Personal Information with these agents, service providers and other organizations who will use it on our behalf. However, we will require these agents, service providers and other organizations to agree that they will only use and disclose information solely for those purposes, and that they will not be permitted to use it for any other purposes.

  1. Disclosure of Personal Information

We may share data we collect with select third parties for the purposes set out below. We will not otherwise sell, transfer or disclose your Personal Information. We may disclose data we collect and receive to:

(a) Our affiliates to perform or inquire about the Services.

(b) Third party service providers to perform or inquire about the Services. We sometimes engage or partner with other companies to operate the Services or perform certain functions on our behalf. For example, such third party service providers may process data, provide IT services, operate our website and deliver messages and advertising on our behalf.

(c) Certain third parties in the context of a merger, acquisition, or sale of all or a portion of our shares or assets, subject in all cases to such third parties signing a confidentiality agreement.

(d) Third parties where we are required by law, regulations, court order or other valid legal process, such as to comply with a subpoena, in any country where we operate.

(e) To a government entity in response to a government request.

(f) Third parties when it is reasonably believed that disclosure is necessary to protect a third party or our safety, security, rights or property, including enforcing terms of our agreements.

(g) Third parties to prevent crime, fraud, corruption or other unlawful or unauthorized activities.

We may also share your data for any other purpose as disclosed to you at the time of collection, or when we have obtained valid consent. This Privacy Policy is not intended to limit our ability to share or disclose aggregated, pseudonymized or anonymized data in a manner that accords with applicable privacy law.

  1. International Transfer and Processing of Personal Information

We operate globally and have worldwide affiliates and third party service providers. Your Personal Information may be transferred, processed and stored on servers in Canada, or in other countries. To this extent, such Personal Information may not be afforded the same protection as under the laws of the jurisdiction in which you reside.

International transfers of Personal Information are subject to appropriate security measures and we will take all reasonable steps to ensure that your Personal Information is protected and maintained in accordance with this Privacy Policy and applicable data privacy laws. By providing your Personal Information to us, you consent to our transmission to, and processing of, your Personal Information outside of your country of residence.

  1. Security of Personal Information

We employ reasonable and a variety of security measures to maintain the safety of your Personal Information and protect against loss, misuse, and unauthorized access, disclosure, alteration and destruction thereof, following the standards generally accepted in the industry to protect your Personal Information and to comply with applicable law.

It is important to note that no data transmission or storage can be guaranteed to be 100% secure. Complete confidentiality and security cannot currently be guaranteed on the Internet. The provision of services and communications via the Internet are subject to a risk of interception, loss, or alteration. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information. By using our Services, you acknowledge and agree that we cannot be held responsible for damages resulting from the transmission of confidential information or Personal Information over the Internet and that such communications are at your own risk. In the event of a breach of security safeguards for Personal Information, we will comply with all reporting and notification obligations.

  1. Links to other Websites

Our website may contain links to other websites or services which are beyond our control and are not covered by this Privacy Policy. If you access or share data to other sites using the links provided, the operators of such sites may collect data from you which will be used by them in accordance with their privacy policies, which may be materially different from ours. We strongly encourage you to read the privacy statements of all such third party websites. We are not responsible or liable for the privacy standards and practices of third parties. Your use of such websites is at your own risk.

  1. Social Media Platforms and Widgets

Any information you post or disclose on social media platforms (for example, Linkedin, Twitter, WeChat) is public. We do not control the use of information disclosed in social media platforms. You should exercise caution when disclosing information on such public platforms, and you should be careful what Personal Information you disclose and how you disclose it. We do not endorse, support, verify, or agree with any content posted on social media platforms linked to our website.

Our website includes social media widgets. Your interactions with these widgets are governed by the privacy policies of the companies providing them. These widgets may collect your IP address, which of our webpage you are visiting, and may set a cookie or similar tracking technologies to enable the feature to function properly. If you wish to disable cookies, you may adjust your browser settings to reject digital markers, including cookies. By doing so, it may affect the performance of some services on our website.

  1. Retention of Personal Information

We retain your Personal Information for no longer than is necessary. We will further retain and use your Personal Information as necessary in order to comply with our legal obligations, resolve disputes, and enforce agreements.

  1. Access to Personal Information

In accordance with applicable law, you have the right to reasonable access a copy of your Personal Information, to have your Personal Information corrected or updated, to request deletion of your Personal Information, and to request restriction of processing of your Personal Information. To assist with your request, you can contact us by email or by letter to the Privacy Officer at the address below.

We will respond to such requests within thirty (30) days of receipt or within any other period required or authorized by applicable law. We will take reasonable steps to update, correct or delete your Personal Information from our database(s) upon request. However, we may keep a copy for archival purposes in compliance with applicable laws. Before we provide you with any data, correct any inaccuracies or delete any data, we may request additional information from you to verify your identity or to respond to your request.

  1. No Users Under 13 Years Old

In general, we do not knowingly collect Personal Information from children under 13. We may use age screening mechanisms to help us determine if a user is under the age of 13.

  1. Changes to Privacy Policy

We may need to make changes to this Privacy Policy from time to time to reflect any changes in data protection and privacy laws and to update our privacy practices.  We encourage you to review this Privacy Policy periodically. The revised version is effective as of the published effective date. By your continued use of our Services, you acknowledge that any revised Privacy Policy will supersede any prior privacy policies to which you and your information may have been subject.

  1. European Privacy Rights

This section of the Privacy Policy applies only if you use our Services covered by this Policy from a country that is a Member State of the European Union, (the “EU”), and supplements the provisions in this Privacy Policy.

Under the General Data Protection Regulation (“GDPR”), you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your Personal Information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of Personal Information about you, under certain conditions; (v) the right to demand that we restrict processing of your Personal Information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your Personal Information is inaccurate; (vi) the right to data portability of Personal Information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection at: http://ec.europa.eu/justice/data-protection/index_en.htm.

  1. Geneseeq Contact Information

If you have any questions about the Privacy Policy or the privacy practices of the Services, please contact us by email or letter at:

Geneseeq Technology Inc.
Suite 200, MaRS Centre, South Tower
101 College Street, Toronto
Ontario, M5G 1L7 Canada
Attention: Chief Privacy Policy Officer
Email: privacy.toronto@geneseeq.com