Privacy Statement

Updated July 3rd , 2020


Valital Technologies Inc. (“Valital”, “we”, “us” or “our”) is committed to protecting your privacy and safeguarding your personal information.  The purpose of this Privacy Statement is to inform you about our privacy practices, including how we collect, use and disclose your personal information.

This Privacy Statement relates to all of our activities, including our website <https://www.valital.com/> (the “Website”) as well as our Valital online platforms, i.e. Platform for Recruitment, Platform for Talents and Platform for Security (together the “Platform”), unless we have provided you with a separate privacy policy for a particular product, service or activity.

Please review this Privacy Statement carefully. By submitting your personal information to us, by registering for or using any of the services we offer, by using our Website and/or Platform, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your personal information as set out in this Privacy Statement, as revised from time to time.

This Privacy Statement is incorporated into, and is subject to, our other applicable terms & conditions. Capitalized terms used but not defined in this Privacy Statement have the meaning given to them in these documents.

WHAT’S IN THIS PRIVACY STATEMENT?

• Meaning of Personal Information

• Your Consent to Collection, Use and Disclosure

• Personal Information We Collect

• How We Use Your Personal Information

• How We Share Your Personal Information

• Retention of Personal Information

• Information Security

• Rights Regarding Your Personal Information

• International Transfer and Storage of Information

• Third Party Websites and Services

• Children’s Information

• Privacy Statement Updates

• Contact Us

Meaning of Personal Information

“Personal information” means information about an identifiable individual.  Subject to applicable laws, personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work electronic address. Personal information also does not include information that has been anonymized or aggregated in such a way that there is no possibility it can be used to identify an individual, whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We collect, use and disclose your personal information with your consent or as permitted or required by law. Besides where we are not relying on your consent, under the General Data Protection Regulation (the “GDPR”), the legal basis for our processing of personal information may be that the processing is necessary for providing our products or services and that the processing is carried out in our, or in companies’, legitimate interests, which are further explained below. How we obtain your consent (i.e. the form we use) will depend on the circumstances, as well as the sensitivity of the information collected.  Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this Privacy Statement.

Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time via the Platform or by contacting us using the contact information in the “Contact Us” section below.  However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

Personal Information We Collect

The personal information we collect is generally in one or more of the following categories.

• Website.  When you access, visit or use our Website, we may collect the following information:

• Message sending: we may collect your name, e-mail address and other information that you submit when you contact us about our products and services via our Website.

• Information automatically collected: we may employ browser cookies or similar technologies to identify the computer, mobile device, and record your preferences and other data. We use browser cookies or similar technologies to evaluate how our products and services, devices or applications are used and to provide continuous improvement to our products, services and applications, to make recommendations, and to complete transactions you request. Cookies or similar technologies may be stored locally on mobile devices or on computer servers operated or controlled by our third-party service providers. In addition, when you visit our Website, our systems automatically collect your IP address and the type of browser that you use. We may employ third party service providers to place advertisements about our products, services and applications on other websites. The use of cookies or other similar technologies by such third parties is governed by their privacy policies. You may limit the automatic collection of certain information on our Website by disabling the cookies using your browser options. Please be aware that disabling cookies may prevent you from using specific features on our Website.

• Platform.  When you access, visit or use our Platform, we may collect the following information in order to prepare reports about you (the “Reports”).

• Information submitted by you: we may collect information that you submit through your use of our Platform, including information you provide in connection with the creation and management of your account, such as your first name, last name, e-mail address, mailing address, phone number, birth date, role, department, profile picture and password. It is your responsibility to provide us with true, accurate and complete information, and to maintain and update promptly any changes in this information. You can review, access, and change the information at any time via the Platform.

• Information obtained via the internet and public social media profiles: our reports are based on results from a scan of the Internet (i.e. Google, Bing and CanLII) and public social media profiles and databases for information containing content published by you, about you or on your behalf. You can dispute the information obtained via the internet and public social media profiles via the Platform.

• Information obtained/confirmed by referrals designated by you.

• Information automatically collected: we may collect log data and usage information relating to your use of our Platform and related products and services.

Please note that our Reports do not make a recommendation to our clients whether positive or negative about you. How the information contained in our Reports is weighted for decision making is entirely at the discretion of our clients and their discussions with you (if any). Compensation received by us from our clients is in no way impacted by the information provided on our Reports. No incentive exists for us to provide an opinion or alter information contained on Reports and we have no vested interest in the outcome between you and our clients.

• Other Interactions.  For individuals who otherwise interact with us, whether in person, by phone or email, through social media or otherwise, including individuals who might be interested in acquiring our products and services, or who respond to surveys and questionnaires, we may collect information that you provide to us during these interactions. This information may include your name, e-mail address and other contact information.

• Other Sources. we may obtain information, including personal information, from third parties and sources other than our products and services, such as our partners, third party service providers or advertisers. If we combine or associate information from other sources with personal information that we collect through our products and services, we will treat the combined information as personal information in accordance with this Privacy Statement.

We will not request any sensitive personal information such as your race, religion, or sexual orientation. Please do not send us such sensitive personal information by any means.

How We Use Your Personal Information

We may use your personal information and other information for the following purposes. In each case, we identify the ground that we rely on to use your personal information under the GDPR:

• to provide you and/or our clients with our products and services and to support your use of our products and services. Applicable legal ground: contract performance;

• to contact you relating to our products and services. Applicable legal ground: consent;

• to monitor and improve our products and services, and to develop new products and services. Applicable legal ground: legitimate interests;

• to analyze the needs and activities of our customers to help us better serve them. Applicable legal ground: legitimate interests;

• to conduct research and analysis related to our business, products and services. Applicable legal ground: legitimate interests;

• to collect opinions and comments in regard to our products and services. Applicable legal ground: legitimate interests;

• to provide you with information that we think may interest you, including in regards to our products and services. Applicable legal ground: consent; and

• to investigate legal claims or comply with our legal obligations. Applicable legal ground: legal obligations.

We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

How We Share Your Personal Information

Although we try to avoid sharing your personal information with third parties where possible, we have set out below the instances in which such sharing may occur.

We may use and disclose Reports about you (including personal information obtained via public record sources and/or referrals, see above) to our clients or any requesting employer for the purpose of providing our service or for other lawful employment purposes.

We may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

We may rely on third party service providers to perform a variety of services on our behalf.

If we provide your information to third party service providers, we take reasonable measures to ensure that the rules set forth in this Privacy Statement are complied with and these third parties provide sufficient guarantees to implement appropriate security measures. We also require that they only use your personal information for the limited purposes for which it is provided.  When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

Retention of Personal Information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. However, once our clients or any requesting employer have receive Reports about you, we do not control their data retention practices. If you would like further information regarding the periods for which your personal information will be retained, please contact us as set forth in the “Contact Us” section below.

Information Security

You are entirely responsible for the security and confidentiality of your password. Furthermore, you are entirely responsible for any and all activities that occur under your account.

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below. If we learn of a security breach involving your personal information, we will inform you and the relevant authorities of the occurrence of the breach as required under applicable law.

Rights Regarding Your Personal Information

Under certain circumstances and in accordance with the GDPR or other applicable data protection laws, an individual has the following rights:

• Access: entitled to ask if we are processing information and, if we are, request access to personal information. This enables the individual to receive a copy of the personal information we hold and certain other information about him or her;

• Correction: entitled to request that any incomplete or inaccurate personal information we hold be corrected;

• Erasure: entitled to ask us to delete or remove personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with claims;

• Restriction: entitled to ask us to suspend the processing of certain personal information, for example to establish its accuracy or the reason for processing it;

• Transfer: request the transfer of certain personal information to another party;

• Objection: one may challenge when we are processing personal information based on a legitimate interest (or those of a third party) or for direct marketing purposes. However, we may be entitled to continue processing information;

• Automated decisions: contest any automated decision made where this has a legal or similar significant effect and ask for it to be reconsidered; and

• Consent: where we are processing personal information with consent, withdrawal of consent.

You also have a right to make a complaint with a data protection supervisory authority, in particular in the country/province/state where you normally reside, where we are based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact us as set forth in the “Contact Us” section below. Please note that we may require that you provide appropriate identification to fulfill your request. Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

Your personal information will be stored and processed in Canada. Further, our practices regarding your personal information will at all times continue to be governed by this Privacy Statement and, if applicable, we will comply with GDPR data transfer requirements.

Third Party Websites and Services

This Privacy Statement applies only to our products and services. This Privacy Statement does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Children’s Information

We do not knowingly collect personal information from children under the age of 16. If you are under this age, you should not provide us with your personal information. If you are a parent or guardian and discover that your child under the age stated above has provided personal information, then you may alert us as set forth in the “Contact Us” section below and request that we delete that child’s personal information from our systems.

Privacy Statement Updates

This Privacy Statement is current as of the “updated” date which appears at the top of this page.  We may modify this Privacy Statement from time to time. When changes are made to this Privacy Statement they will become immediately effective when published in a revised Privacy Statement posted on our Website or Platform unless otherwise noted. We may also communicate the changes through our services or by other means. By submitting your personal information to us, by registering for or using any of the services we offer, by using our Website and/or Platform, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this Privacy Statement, you consent to our collecting, using and disclosing your personal information as set out in the revised Privacy Statement.

Contact Us

All comments, questions, concerns, request or complaints regarding your personal information or our privacy practices (including with respect to any service providers outside of your country of residence) should be sent to our Privacy Officer at: privacy@valital.com