Effective date: April 18th, 2018
LIONFRONT LFD., with registered office at 3rd. Floor 5162 Duke St, Halifax, NS, Canada B3J 1N7, (hereinafter referred to as “Lionfront”, “we” or “us”), in its capacity as data controller regarding the processing of Personal Data, is committed to protecting and respecting the privacy of its users, customers and suppliers, even prospective (hereinafter singularly and collectively referred to as the “you” or “your”), pursuant to the applicable Canadian laws on data protection (hereinafter referred to as the “National Law”) and, if you are an European citizen, also pursuant to the European Regulation no. 679/2016 (hereinafter referred to as the “GDPR”) (hereinafter the National Law and the GDPR will be referred to as the “Applicable Law”).
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
SECT. 1 – PERSONAL DATA WE PROCESS
When you visit the Site or when we provide you with our Services, we may collect the following Personal Data:
1.1. Information you give us. You may, through our Site, our Services or other contact channel (e.g., e-mail, etc.), voluntarily provide us Personal Data and/or information and documents containing Personal Data. We will process these data in accordance with the Applicable Law and on the assumption that they refer to you or to third parties who have authorized you to provide them pursuant to an appropriate legal basis which legitimize the processing at stake. In this case, you act as independent data controller, assuming all relevant obligations and responsibilities according to the Applicable Law. In this regard, you hence waive, in the full sense of the term, the right to all disputes, claims, claims for damages due to processing, etc., which may be submitted to us by the said third parties whose Personal Data have been processed through your use of the Site or the Services in breach of the Applicable Law.
1.2. Browsing data. Computer systems and software procedures used to operate the Site collect some Personal Data, the transmission of which is an integral part of internet communication protocols. This information is not collected to be associated with you but, by its very nature, it may allow you to be identified by processing and associating it with data held by third parties. Among collected Personal Data there are: (i) IP addresses or domain names of the devices used by you to connect to the Site; (ii) the URI (Uniform Resource Identifier) of requested resources; (iii) the time of the request, the method used to submit the request to the server; (iv) the size of the file received as a reply; (v) the numeric code indicating the status of the reply given by the server (successful, error, etc.); (vi) other parameters regarding your operating system and device environment.
1.3. Cookies and similar technologies. We may collect Personal Data using cookies. You can find further information on the use of cookie and similar technologies here.
SECT. 2 – PURPOSES AND LEGAL BASIS OF THE PROCESSING
2.1. Purposes. Personal Data provided by you will be processed by us for the purposes and legal basis specified below
|To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and Services that you requested from us (e.g., user account information, contact requests, requests for subscription to our newsletter, etc.)||This processing is necessary for the performance of our mutual contractual obligations and/or carried out with your consent|
|To send you service-related information by email or any other communication means||This processing is necessary for the performance of our mutual contractual obligations and/or carried out with your consent|
|To give you access to our support services and to enable you to communicate with our team||This processing is necessary for the performance of our mutual contractual obligations, carried out with your consent and/or necessary for the establishment, exercise or defense of legal claims|
|To send information to authorized third-parties (e.g., customers, end-users, etc.)||This processing is necessary for the performance of our mutual contractual obligations and/or carried out with your consent|
|To send marketing materials, as well as suggestions and recommendations on our services that may be of interest to you||This processing is based on your consent|
|To carry on statistical research / analysis of aggregated or anonymous data, without identifying you, as well as to measure and evaluate the operation of our Site, its traffic and usability||This processing does not involve the processing of Personal Data|
|To the fulfill a legal obligation to which Lionfront is subject or to ascertain, exercise or defend a right in Court or whenever an authority exercises its jurisdiction.||This processing is necessary for the establishment, exercise or defense of legal claims.|
2.2. Voluntary nature of the processing. Providing your Personal Data for the above-mentioned purposes is voluntary and not mandatory. However, any refusal to provide any of such data may not allow us to establish and/or continue a contractual relationship with you, or to fulfill your requests, or to comply with legal obligations to which we are subject.
SECT. 3 – WHAT IS DATA RETENTION PERIOD AND WHAT SECURITY MEASURES HAVE BEEN TAKEN FOR YOUR PERSONAL DATA SAFEGUARD
3.1. Data retention. Personal Data collected by us will be processed for the time strictly necessary to achieve the purposes referred to in above. In particular:
3.1.a. Personal Data collected through the provision of Services will be deleted or anonymized for statistical purposes after 2 (two) years from the termination of the Services or, if earlier, after your cancellation request;
3.1.b. Personal Data needed for the provision of our newsletter service will be processed until you decide to unsubscribe.
3.2. Security measures. We use appropriate measures to protect the security of your Personal Data. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Please note that no service is completely secure. So, while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur. Notwithstanding the preceding, we operate with the aim of mitigating the risks associated with processing your Personal Data through several measures, including:
3.2.a. Data Minimization. We only ever obtain, retain, process and share Personal Data that is essential to carry out our services and legal obligations: only that which is relevant and necessary is collected. In particular, by way of example, our electronic collections (i.e., via the Site, etc.), have only fields that are relevant to the purpose of collection and subsequent processing, while the physical collection (i.e., face-to-face contacts, phone calls, etc.) is supported using scripts and internal forms using predefined fields.
3.2.b. Pseudonymization. Whenever possible, we utilize pseudonymization to record and store Personal Data in a way that ensures that such data can no longer be attributed to a specific data subject without the use of separate additional information (i.e., personal identifiers) which are protected with encryption, partitioning and other technical and operational measures of risk reduction and data protection.
3.2.c. Encryption. Although we use encryption (i.e., using a secret key to make Personal Data indecipherable unless decryption of the dataset is carried out using such assigned key) as a form of pseudonymization, we also utilize it as a secondary risk prevention measure for securing the Personal Data that we process. In particular, we utilize encryption via secret key for transferring Personal Data and/or special category of information to any external party and provide the secret key in a separate format.
3.2.d. Access restriction. We use company-wide restriction methods for restricting access into the foundation of our processes, systems and structure, in order to ensure that only those with authorization and/or a relevant purpose, have access to Personal Data. Special category data is restricted at all levels and can only be accessed by our authorized personnel.
3.2.e. No hard copy data. We never store any Personal Data in hard copy format.
SECT. 4 – WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA
4.1. Third-party service providers or consultants. We may share your Personal Data with third-party service providers or consultants who need access to such data to perform their work on our behalf (e.g., sharing data with our storage provider for the purposes of storing your data on our behalf, etc.). These third-party service providers are limited to only accessing or using this data to provide services to us, such as: (i) IT systems and services; (ii) communication services; (iii) Customer Relations Management; (iv) support tools; (v) accounting and financing services.
4.2. Aggregated or de-identified data. We might share data with third parties if that data has been de-identified or aggregated in a way that does not directly identify you.
4.3. Third parties required by laws or authorities. We may disclose your data to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If we are required by law to disclose any of your Personal Data, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.
SECT. 5 – WHERE YOUR PERSONAL DATA MAY BE TRANSFERRED
Personal Data will be processed, for the purposes set out above, in Colombia, Canada and Mauritius Island and any transfer out of the territories above mentioned will be made by us taking appropriate or suitable safeguards.
SECT. 6 – YOUR RIGHTS
6.1. Right of access. You are always entitled to receive confirmation as to whether or not your Personal Data are being processed and, where that is the case, access and receive copy of such Personal Data in an intelligible form. Furthermore, you are also entitled to receive information concerning: the purposes of the processing; the categories of Personal Data concerned; the recipients (or categories thereof) to whom the Personal Data have been or will be disclosed; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from us rectification or erasure of personal data or restriction of processing of your Personal Data or to object to such processing; the right to lodge a complaint with a supervisory authority; the source of the Personal Data; the existence of automated decision-making; where Personal Data are transferred to a third country or to an international organization, the appropriate safeguards relating to the transfer.
6.2. Right to withdraw consent. You are always entitled to withdraw, at any time, your consent to the processing of your Personal Data, both on legitimate grounds (even though they are relevant to the purpose of the collection) and if the processing is carried out for direct marketing purpose. The preceding will not affect the lawfulness of processing based on consent before the withdrawal.
6.3. Right to rectification, erasure and restriction. You are always entitled to obtain from us, without undue delay: the rectification or integration of your Personal Data that are inaccurate or incomplete; the erasure of your Personal Data that have been processed unlawfully or whose retention is unnecessary for the Purposes; the restriction of processing, in case you challenge either the accuracy of your Personal data or the lawfulness of the processing, or in case we no longer need the Personal Data for the Purposes, but they are required by you for the establishment, exercise or defense of a legal claim.
6.4. Right to data portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format, as well as the right to transmit those data to another controller without hindrance from us, where technically feasible.
6.5. Right to lodge a complaint before an European supervisory authority. In case you are an European citizen, you have the right to lodge a complaint with the Supervisory Authority located in your place of residence.
6.6. Contacts. Requests to exercise the rights above must be sent to LIONFRONT LFD., 3rd. Floor 5162 Duke St, Halifax, NS, Canada B3J 1N7, or by e-mail to firstname.lastname@example.org. Any access request is always completed within one month; however, where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months. If this is the case, we will write to the individual within one month and keep him/her informed of the delay and the reasons thereof.
SECT. 7 – AMENDMENTS TO THIS POLICY