PRIVACY POLICY

Last update: June 7, 2023

Cedulify respects your privacy. As such, we are committed to protecting the personal information of our users. We have adopted this privacy policy (the "Policy") in order to be transparent about what data we collect, why we collect it, with whom we share it, how you can access it and how to correct it, if necessary. In this Policy, the terms "Cedulify", "we", "us" and "our" refer to Cedulify Inc. 

We recognize our obligation to manage your data responsibly. We do not and will not sell your data to third parties.

This Policy applies to the use of services offered by Cedulify, including mobile and web applications ("the Application", collectively the "Services"). Please read it carefully to understand when you provide us with your data and how we use it. By providing us with personal information, you consent to the collection and use of that information as described in this Policy. If you do not agree with our Policy, please do not use our Services.

Any questions or concerns?

Reading this Policy will help you understand your privacy rights and choices. If you still have questions or concerns, please contact us at contact@cedulify.com.


SUMMARY OF KEY POINTS

This summary presents the key points of our Policy.


What personal information do we collect? 

When you visit, use or browse our Services, we may process personal information based on how you interact with Cedulify and the Services, the choices you make and the products and features you use. 


Do we process sensitive personal information? 

We may process sensitive personal information where necessary with your consent or as permitted by applicable law.


Do we receive information from third parties? 

We receive information from third parties as authorized by you through the Services.


How do we use your information? 

We process your information to provide, improve and administer our Services, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We will only process your information where we have a valid legal reason to do so.


In which situations and with which parties do we share personal information? 

We may share information in specific situations and with specific third parties. 


How do we ensure the security of your information? 

We have implemented organizational and technical processes and procedures to protect your personal information. 


What are your rights? 

Depending on where you are geographically, applicable privacy laws may mean that you have certain rights regarding your personal information. 


How can you exercise your rights? 

The easiest way to exercise your rights is to contact us with your request at the following address contact@cedulify.com. We will investigate and respond to all requests in accordance with applicable data protection laws.


WHAT INFORMATION DO WE COLLECT?

When you open an account on our Services :

  • Full name ;

  • E-mail address ;

  • Genre ;

  • Ethnicity; and

  • Pronouns.

Why: We use this information to open your account and to contact you, if necessary, for requests related to your account. We also use this information to be respectful towards you when you use our Services.

Legal basis: Your consent. In addition, this information is necessary for the legitimate interests of users (to open an account on our platform, as requested, and to be able to receive communications in connection therewith). It is also necessary for our legitimate interests, i.e. to identify our users and contact them when necessary.

When you personalize your profile on our Services :

  • the purpose for which you use our Services;

  • the type of accommodation you live in;

  • number and type of people you live with + pets ;

  • whether you have children and, if so, their age range ;

  • your employment status ;

  • your household income bracket ;

  • your satisfaction with your household income ;

  • the culture you identify with ;

  • your daily physical activities; and

  • your favorite activities.

Why: This information enables us to tailor our Services to your needs and generate your "harmony wheel". It also enables us to fine-tune our recommendations by helping us understand our users, how they interact with their environment, and the nature of their activities and experiences. 

Legal basis: your consent. This information is also necessary for our legitimate interests (improvement and personalization of our Services) and yours (optimized use of our Services).

When you use the Services, according to your preferences :

  • Your location data, when the settings on your device or browser allow us to do so;

  • Information contained in your calendar, when the settings on your device or browser allow us to do so;

  • Sleep data available through Apple Health, when using an Apple device.

Why: The data we collect enables us to personalize your use of our Services and take full advantage of its features. It also gives us more information about our user base, enabling us to enhance the functionality of our Services and optimize them to better meet our users' needs. 

Legal basis: necessary for our legitimate interests (improving and personalizing our Services) and yours (personalizing your experience)

If you wish to change our access or permissions, you can do so in your device settings.

When you use our Services, automatically :

  • information about the device you are using (such as the identifier, model and manufacturer of your mobile device);

  • operating system information such as the version and configuration;

  • type and version of browser used, if applicable ;

  • Internet service provider and/or mobile operator, and Internet Protocol (IP) address (or proxy server);

  • the telephone network associated with your mobile device ;

  • information on the functionalities of our Services that you have accessed;

  • language preferences; and

  • information on events during the use of our Services, such as breakdown reports.

Why: This information is mainly required to maintain the security and operation of the Services, for troubleshooting purposes and for our internal analysis and reporting. It also enables us to compile statistics to improve the Services.

Legal basis: necessary for our legitimate interests (improving and personalizing our Services) and yours (maintaining the security and operation of the Services)

If you wish to contact us :

  • name ;

  • first name ;

  • e-mail address; and

  • any other information you provide to us in the course of our dealings.

Why: We use this information to identify you and respond to your questions or requests.

Legal basis: This information is necessary to correctly identify any person contacting us and to be able to respond to your needs.


HOW DO WE USE YOUR INFORMATION?

In short: We use your information to provide, improve and administer our Services, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We use your personal information for a variety of purposes, depending on how you interact with our Services, including:

  • To evaluate and improve our Services by developing new features, conducting research and maintaining the current performance of our Services;

  • To facilitate account creation and authentication, and manage user accounts differently;

  • To provide you with the requested Services;

  • To provide you with the best possible customer service;

  • To communicate with you, whether for marketing, advertising or account management purposes;

  • To keep track of your purchases ;

  • To enable communication between users ;

  • To request feedback and contact you regarding your use of our services;

  • To compile statistics to guide our business decisions;

  • To update our files; and

  • To ensure that we meet our contractual and legal obligations to you.


OUR USE OF COOKIES

When you visit our Web Services, you may provide us with information via cookies or similar technologies. 

Cookies are files containing a small amount of data about a given user. This data may include an anonymous unique identifier. Cookies are stored on the user's computer or on the hard drive of another device. They enable us to tailor your user experience each time you visit our site.

Essential cookies

 

Analytics cookies

 

List of advertising cookies

 

Please note that you can set your browser to disable or restrict the cookies we use. However, this may prevent you from accessing our Services properly.

For more information on cookies and the policies of their suppliers, you can consult the section "When and with whom do we share your personal information?"

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in specific situations described in this section and/or with the following third parties.

We do not sell our users' personal information. Your information is shared only in accordance with this Policy. When you consent to this Policy, however, we may share your personal information with the following parties:

Third-party suppliers: In the course of our business, we may need to share some of your data with certain third parties.  For example, we may share some of your data with our IT suppliers, in the performance of their mandate, or with service providers such as marketing consultants in the performance of their service agreement with us.

In general, the suppliers we use will only collect, use and disclose your information to the extent necessary to perform the services they provide to us, such as hosting our Application via Firebase (Google).

However, some third-party service providers have their own privacy policies regarding the information we are required to provide to them when we use their services. With respect to these providers, we recommend that you read their privacy policies carefully so that you can understand how they will treat your personal information collected. 

Once you leave our Services or are redirected to a third-party website or application, you are no longer governed by this Policy.

IT suppliers

Apple: https://www.apple.com/ca/fr/legal/privacy/fr-ca/

  • Apple uses the European Union's standard contractual clauses.

AWS (hosting - United States): https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice_French_Translation.pdf

Flodesk (e-mail marketing - United States): https://flodesk.com/privacy-policy

Google (analytics, API, hosting - United States): https://developers.google.com/terms/api-services-user-data-policy

Meta (advertising - United States): https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

Stripe (payment processor - Ireland): https://stripe.com/en-ca/privacy

Squarespace (web content management - United States): https://fr.squarespace.com/confidentialite

Parties with whom it may be legally necessary: we may disclose your information if required to do so by law or if such disclosure is necessary in order to: 

  • Comply with the law or any legal process;

  • Protect the rights or property of Cedulify ;

  • Protect the security of our Services, our users and their data.

Parties likely to be involved in a financial transaction: we may transfer your data following a change of control, merger, liquidation, or other transaction involving Cedulify. The information required for this process will only be transferred once the transaction has been completed, and we will only disclose this information without your consent if we are permitted to do so by law. We will take the necessary measures to protect the confidentiality of this information and will destroy it if the transaction is not concluded or if its use is no longer necessary for the purposes of concluding the transaction.

WHAT ARE YOUR PRIVACY RIGHTS?

In short: Depending on the jurisdiction in which you are located, you have rights that allow you to access and control your personal information. You can consult, modify or cancel your account at any time.

Rights can include : 

  1. request access to and obtain a copy of your personal information (please note that we reserve the right to ask you for additional information in order to confirm your identity);

  2. request the correction of personal information;

  3. withdraw your consent to the processing of your personal data, in certain situations;

  4. request the erasure of personal data held by us, unless we are required to retain such data in order to comply with legal obligations, for instance;

  5. object to the processing of your data, unless we have legitimate grounds that outweigh your rights or interests or if we need to continue processing the data for the establishment, exercise or defence of a legal claim;

  6. ask us to restrict the processing of your data if it is incorrect, if you believe that our processing of your data is unlawful, or if we no longer need to process your data but must retain it for legal purposes;

  7. request your personal data and information in an accessible format; and

  8. lodge a complaint with the competent authority if you believe that we are processing your data in breach of applicable data protection laws.

We will investigate and respond to all requests in accordance with applicable data protection laws. 

Note that some of your information can be modified through your account settings.

HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We retain your information for as long as necessary to fulfill the purposes described in this Policy, unless otherwise required by law.

We will only retain your personal information for as long as is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 

We will destroy this data at the end of this period, or if you decide to withdraw your consent (where possible). If you so request, once your data has been deleted, you will receive confirmation that your request has been processed.

HOW DO WE ENSURE THE SECURITY OF YOUR INFORMATION?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. For example, we ensure that only authorized persons within our organization who need to access your information have access to it. We also use the HTTPS protocol for communications, secured by an SSL certificate and ensure that the various service providers whose technology is incorporated into our Services also have robust safeguards.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We therefore cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services in a secure environment.

DO WE COLLECT INFORMATION ON MINORS?

In short: We do not knowingly collect data from children under the age of 18, nor do we market such data.

We do not knowingly solicit or market data from children under the age of 18. By using the Services, you represent that you are at least 18 years of age or the parent or guardian of such a minor and that you consent to the use of the Services by such dependent minor. If we learn that personal information of users under the age of 18 has been collected, we will deactivate the account and take reasonable steps to promptly delete such data from our records. If you are aware of any data that we may have collected from children under the age of 18, please contact us at contact@cedulify.com.

COMPETENT AUTHORITY

If you are not satisfied with our response to a request in regards to your personal information, you may contact the Commission d'accès à l'information du Québec, the public body responsible for overseeing personal data management and processing practices in Québec.

Commission d'accès à l'information du Québec

Address:

Office 900

2045 Stanley Street

Montréal (Québec) H3A 2V4

 Telephone: 514 873-4196 Fax: 514 844-6170

Toll-free telephone: 1 888 528-7741
E-mail: cai.communications@cai.gouv.qc.ca

Website: http://www.cai.gouv.qc.ca

If you are in Europe, you can contact the competent authority in your jurisdiction: https://edpb.europa.eu/about-edpb/about-edpb/members_en

DO WE UPDATE THIS POLICY?

In short: Yes, we will update this Policy as necessary to remain compliant with relevant legislation and to ensure that the Policy reflects our current practices.

We reserve the right to change this Policy at any time; please check back frequently. Unless otherwise specified, changes to this Policy are effective immediately upon posting on our Services. If changes are made to this Policy, we will notify you here of the update so that you are aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by sending you a notice directly.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you would like to access, correct, amend or delete any personal information we have about you, lodge a complaint, or if you would simply like more information, you can contact us using the details below:

Cedulify Inc.

To the attention of the Privacy Officer

891 Rue Hyacinthe Hudon

Boucherville, QC, J4B 7E3, Canada

contact@cedulify.com