Privacy Policy

Latest Update: 2020-07-27

This Privacy Policy (the “Policy”) contains information about how Civalgo Inc. (referred to as “Civalgo”, “we”, or “us”) collects, uses and discloses your personal information when you are:

● using the website www.civalgo.com (the “Website”);

● using our project management platform, which is available as a web application, and the associated services (the “Platform”); and

● exchanging with us by e-mails, or social media or otherwise.

(together with Website and Platform referred to as the “Services”).

This Privacy Policy also covers our use of cookies and tracking technologies, such as pixels and beacons (together, the “cookies”). For the purpose of this Policy, we consider that your cookies are personal information, regardless of applicable laws. The definition of what constitutes personal information is subject to the laws applicable in your jurisdiction, and this Policy shall be interpreted in accordance with applicable laws.

In addition, this Privacy Policy covers the use of your personal information for interest-based advertising. For more information about this topic, please click here to jump directly to the relevant section of this Privacy Policy.  We do not conduct interest-based advertising within our Platform or as part of our Services or using Platform Users data when they are within the Platform or using the Services. We only conduct interest-based advertising through our Website and social medias.  

As a participant of the Digital Advertising Alliance (“DAA”), we adhere to DAA’s interest-based advertising principles by providing you with an enhanced notice, transparency and control of our digital marketing practices as stated at http://www.aboutads.info/principles.

If you have any questions regarding the processing of your personal information, you can e-mail us at privacy@civalgo.com, or reach us by mail at the following address:

Civalgo - Attention: Privacy Officer
55 rue Louvain Ouest, Suite 460-03/04
Montreal (Québec) H2N 1A4
Canada

1) Key terms

In the Privacy Policy, the term “Platform User” refers to end users who are authorized to use our Platform by our customers with whom we have an agreement.

By comparison, the term “Website User” refers to someone who is navigating our website, or is interacting with us by e-mails, social media or otherwise.

The term “User” or “you” refers indistinctively to a Platform User or a Website User. A User can be both a Platform User and a Website User.

In this Privacy Policy, we use the term “workers” to refer to both employees and subcontractor personnel, or anyone whose work is being managed through the Services by Platform Users.

2) What do we mean by “personal information”?

Personal information is information that relates to a natural person or allows for the identification of a natural person. Some information may not be personal on its own, but may become personal information if associated with personal information or if the sum of the information allows us to identify you. We include cookies in our definition of personal information.

For the purposes of this Privacy Policy, we define personal information as any information which relates to a natural person and allows that person to be identified. For example, this means that we consider electronic identifiers, such as e-mails and passwords, as personal information. You should know that some laws do not include business contact information (ex. name, title, work email, etc.) and other employee personal information in the legal definition of personal information. However, to be transparent with our Users, we included such personal information in our own definition of personal information. Click here to learn more about what type of personal information we collect and why.

We include cookies in our definition of personal information, although some laws may not consider cookies as personal information. Cookies are messages that web services pass to your web browser when you navigate the Internet. Your browser stores each of these messages in a small file. Our definition of cookies also includes similar technologies, like pixel and web beacons that are installed on your devices. Cookies can track you across different websites, and service different purposes. There are various types of cookies: (1) essential; (2) functional; (3) marketing and (4) analytics. Some stay installed only during your session on a website, other are installed for several months or years. Click here to have more information on the cookies we collect.

3) What types of personal information does Civalgo collect, and why?

We collect personal information to provide you with our Services, for the purpose of obtaining analytics on your use of our Services, or in connection with our marketing activities. This section does not cover the cookies that we use. Our use of cookies is covered in the questions below.

4) What cookies do you use and why?

We use cookies for our Services to function as intended, to conduct marketing, to provide functionalities on our Platform, to analyse our performance and ensure that our Services are secure. Cookies are also useful to identify bugs and errors. We use both first-party and third-party cookies installed by partners on our Website.

We collect cookies that classify in each of these categories:

5) Do you use Google Analytics?

Yes we do. Google Analytics is Google’s analytical tool that helps us to understand how Users engage with our Services. It uses a set of cookies to collect information and report site usage statistics without allowing us to identify individual visitors.

In addition to reporting site usage statistics, the data collected by Google Analytics is leveraged to do remarketing, including across devices, through cookies such as Google Adwords and DoubleClick. We provide more information on interest-based advertising in the following question.

6) Do you conduct interest-based advertising (IBA)?

Yes. We use targeting cookies as part of our marketing strategy. This is called interest-based advertising. We do not conduct interest-based advertising within our Platform or as part of our Services or using Platform Users data when they are within the Platform or using the Services. We only conduct interest-based advertising through our Website and social medias.  

You can opt-out of interest-based advertising by managing your cookies. Click here to jump to the section of the Privacy Policy that explains you how to do this. You can also use WebChoices which is a browser-based tool for opting out of interest-based advertising. Mobile users can also download the DAA Choice App in the Apple App Store, Google PlayStore or Amazon Store. AdChoices provides additional solutions and explanations to control block and control cookies, as well as plug-ins to retain opt-out cookie preferences, even if you delete your cookies.

Interest-based advertising is also referred to as targeted advertising (re-targeting) or behavioral advertising. Re-targeting means that the ads that you are being served are personalized based on your behavior when browsing online. This is enabled through cookies and requires the processing of electronic data that is considered personal information under certain laws.

For instance, we may display interest-based ads to you when you are using Facebook through a tool offered by Facebook called the Custom Audience Tool.  This tool allows us to personalize our ads based on your behavior. We do not share any of your personal information, including your behavior, with Facebook.  The tool lets us convert your email address to a unique number that Facebook uses to match to unique numbers it generates from email addresses of its users as part of real-time bidding.

We use Facebook Conversion Tracking Pixel to record how efficient our advertisements are for statistical and market research purposes. Facebook collects such data for us based on your agreement with Facebook.  The collected data remains anonymous for us - we can only see aggregated data. This means that we cannot see the personal information of individual user by using Facebook Conversion Tracking Pixel. However, this personal information is available to Facebook, and Facebook may connect such data with your Facebook account and use this data for their own advertising purposes, in accordance with its current privacy policy, which you can find here.

We also use Google Remarketing and Google AdWords for interest-based advertising purpose, including re-targeting, which allows us to serve relevant ads to the relevant individuals. It also allows us to create segments based on the analytics that we have obtained, and then use it as part of remarketing campaigns on our Google Ads account. Google Ads uses a different cookie than Google Analytics. You can disable Google’s use of advertising cookies at all times by clicking here. Google Analytics also offers a function about remarketing audiences. Google AdWords Remarketing keeps track of all our Website users and follows these Website users online to show our ads.

If you are not comfortable with this, you can manage your Cookie preferences. Click here to jump to the relevant section of this notice.

7) To whom do you disclose my personal information to?

Let’s be clear, we do not sell your personal information to data brokers. However, we do share your personal information with certain types of third parties to provide you with the Services, conduct marketing and as required by the law. We can also share your personal information in the context of a merger and acquisition, as part of bankruptcy procedures or for other corporate requirements.

We may share your personal information with our financial and legal advisors or auditors if reasonably required, or in the event we would be required to do so to defend our rights and interests.

In the case of a merger or acquisition, sale of assets, corporate reorganization, bankruptcy filing, insolvency procedures or similar circumstances, your personal information would be considered our assets and property. In these circumstances, ownership of the personal information we collected may be transferred or we may have to share some of your personal information to conclude, negotiate or discuss with third parties. We will only share what we are required to share for these specific purposes.

8) Where do you store my personal information?

We use Google Cloud Platform to host our Services and store your personal information. The servers are located in Canada. However, our suppliers and third parties may process your personal information internationally, including in the United States.

9) How long do you retain my personal information?

We retain personal information for as long as necessary to provide you with the Services, to perform our marketing campaigns effectively or as required by applicable laws, whichever is longer. We use both persistent and session Cookies. Session cookies are deleted once you close your browser, whereas persistent cookies remain active on your device for some time. For instance, Google Analytics cookies remain installed on your device for 2 years. This allows Google Analytics to track you for analytic purposes, as well as for marketing purposes, and to provide us with aggregated data on your behavior.

10) How do you keep my personal information secure?

We strive to implement security features that are proportional to the risks, taking into consideration factors such as the sensitivity of the personal information that we collect.  For instance, we use SSL 2048-bit certificates and all our network traffic is encrypted using SSL 256-bit. Our physical facilities are secured with camera 24 hours per day. We audit our platform against the vulnerabilities identified by the Open Web Application Security Project (also known as “OWASP”), we use intrusion-detection technologies and firewalls, among other cybersecurity controls.

However, it is important to understand that we cannot guarantee the security of personal information on the Internet, and that you must also take precautions, such as not sharing your credentials with anyone.

11) Can I manage my Cookie preferences?

You can always manage your Cookie preferences. However, some functionalities may require Cookies in order to perform as expected, or for security purposes. You can control your Cookie preferences through your browser. Depending on the browser that you are using, different instructions are applicable. Click on your browser for more information:

1. Google Chrome
You can also browse on Incognito Mode while using Chrome.
2.Firefox
3.Safari
4.Internet Explorer
5.Opera

12) Do I have any rights over my personal information?

Yes! These rights vary depending on where you are located.

You generally have the right to access your personal information and to correct your personal information if inaccurate, in certain circumstances.

If you want to exercise your rights, you can contact us at privacy@civalgo.com. You can also reach out to us by mail at the following address:

Civalgo - Attention: Privacy Officer
55 rue Louvain Ouest, Suite 460-03/04
Montreal (Québec) H2N 1A4
Canada

We will respond to your request within 30 days. If we can’t comply with your request, we will tell you why.

If you are located in Canada, note that the Office of the Privacy Commissioner of Canada drafted this FAQ to help you access your personal information when it is held by a business. You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:

Telephone
9:00 am to 4:00 pm EST
Toll-free: 1-800-282-1376

Mailing address
Office of the Privacy Commissioner
30 Victoria Street
Gatineau, Québec
K1A 1H3

If you have any issue with how we collect, use or disclose your personal information, or how we responded to your request, please let us know at privacy@civalgo.com. We will do our best to improve our processes to make certain that it does not happen again. We will also provide you with additional information about our practices if you would like us to do so.

If you are still not satisfied, you can lodge a complaint to the Office of the Privacy Commissioner of Canada  or to your local privacy regulators.

12) Can we change this Policy?

We may need to modify this Privacy Policy to reflect new processing activities, adapt to new laws and regulations or reflect technological changes or corporate changes, such as a result of a merger and acquisition. We may also change this Privacy Policy at our sole discretion. In case of material changes, we will send an email to Platform Users. You can view the date of the latest update at the top of this page, and you can always reach out to us at privacy@civalgo.com, should you have any questions. Your continued use of the Services is deemed an acceptance of this Privacy Policy.