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PRIVACY POLICY

 (Cogni®)  WEBSITE PRIVACY POLICY

INTRODUCTION 

Faced with new issues and dangers relating to the preservation of the security of personal information arising from online business, it is necessary to pay particular attention to the protection of privacy. This is why Cogni® is seriously concerned about the privacy of your personal information and is committed to respecting the confidentiality of the information that is collected.

Cogni® undertakes to respect, by this personal information protection policy (hereinafter the “ Policy ”) and the laws applicable and in force in Canada and Quebec, the obligations concerning the collection and processing of your personal and confidential information, obtained in the context of the operation of its business, so that everyone can benefit from compliance with his private life.

In this context, Cogni® wishes to ensure the accuracy, security, and confidentiality of your personal information, and not to collect, use, or communicate your personal information other than by this Policy and these laws. applicable.

The Policy describes the information that Cogni® may collect in the course of its activities from its Users.

The Policy also describes, among other things, how Cogni® collects, processes, and stores your information, the purposes for which it is collected, the use made of it and the circumstances in which it may be transmitted to third parties. The Policy explains your rights regarding the collection, use, and communication of your personal information. 

ACCOMMODATION 

The Platform is hosted on a private virtual server and our site on WordPress has the necessary SSL security rules required. 

Host: Azur

Address: Quebec 

Server location: Montreal

SCOPE OF THE POLICY 

We collect your personal information as part of our mission, which aims to better understand your needs and personalize our offer accordingly. In addition, we help health and social services professionals who work in clinics, Integrated University Health and Social Services Centers, mental health or student service professionals who work in schools or private practice, community organizations, employee assistance program (EAP) services or organizations dedicated to the well-being of individuals. Cogni® also offers wellness programs already designed in collaboration by professional Affiliates and mental health counselors to customers awaiting service (waiting list) via referrals or direct requests. They need your data to better understand your needs and personalize a health support offer unique to your needs.

When the User browses the Platform or subscribes to our publications by email, he accepts the terms and conditions of this Policy. You accept that your personal information collected when filling out any online form in order, in particular, to take contact, upload content to the Platform, or provide other services related to the products, are transmitted to the relevant and authorized Cogni® personnel. The latter will only communicate to third parties whose participation is strictly necessary for the delivery of services and/or the maintenance of our commercial relationship with you, where applicable, only the information necessary for these purposes (the aforementioned third parties may be hereinafter collectively referred to as the “ Third-party providers »).

By providing Cogni® with your personal information, you authorize it to use it and communicate it to third-party providers, where applicable, in the context of the delivery of services, the management of our contractual relationship, our commercial relationship with you, and this by this Policy and as authorized or required by law, as well as implicitly, if indicated by the circumstances.

 Furthermore, Cogni® will request your authorization before using your personal information for purposes other than those covered by your initial consent given under the Policy.

 Finally, you may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please be aware, however, that without your consent, Cogni® may no longer be able to provide you or continue to provide you with certain services or information that may be useful to you.

 If you provide Cogni® or its Third Party Service Providers with personal information concerning another natural or legal person, you undertake to have the necessary authorization to do so and/or that you have obtained all necessary consents from this person. third parties to allow us to collect, use, and communicate their personal information for the purposes set out in this Policy.

 To withdraw your consent or no longer receive electronic communications from us, please write to the following email address: [email protected].

COLLECTION OF PERSONAL INFORMATION

Personal information is information associated specifically with a natural person and which can be used to identify him or her, either as such or by combining it with other information held by Cogni® that may have access to it. Information that has been made anonymous or has been arranged so that it can no longer be used to identify a particular individual does not constitute personal information. For example, the postal address of an individual’s office is not personal information in itself, except when it is mentioned with other information about him, or when its sole mention would reveal personal information about him.

Cogni® may obtain personal information from the User when saving personal information on the Platform or, where applicable, by otherwise transmitting personal information, in particular, by requesting a service. By completing such a form, you authorize us to collect your personal information.

We collect the following information from the User when registering:

  • First and last names;
  • Email address; 
  • Age (age group);
  • Pseudonymous data;
  • Cities, Province, and/or Country in which the User resides; And 
  • Banking information if applicable.

Generally speaking, we are also likely to know your location, your IP address, and data concerning your use of the Platform and any other information allowing us to provide you with our services in the most appropriate way possible.

The User’s information is also collected through the interaction that may take place between the User and the Platform and can be used for the following purposes:

  • Understand the User’s use of the Platform;
  • Improve the Platform;
  • Provide services to the User;
  • Manage customer accounts;
  • Comply with compliance laws and regulations;
  • Send newsletters; And
  • Send promotions tailored to the User’s needs.

The User’s personal information will not be kept beyond the reasons for which it was collected. Cogni® respects the retention period established by this policy, which is consistent with the Personal Information Protection Act (R.S.C. (1985), c. P-21) and the Act modernizing legislative provisions regarding the protection of personal information, (LQ 2021, c 25). The deletion of data takes place when the User deletes their account. The User will then have thirty (30) days to recover their data, failing which Cogni® will permanently delete them. 

Cogni® may also compile your names and correspondence addresses into lists for philanthropic purposes, anonymized statistics, or market research. If you do not want your names and correspondence addresses to be compiled for these purposes, please contact us by writing to the following email address: [email protected].

 The deletion of personal information takes place when the User makes a written request to the aforementioned address. Cogni® reserves the right to refuse a User’s request when the latter continues to use, in any way, the services of Cogni® respects the retention period established by this policy, which is by the Act respecting the protection of personal information in the private sector (RLRQ c P-39.1). Consequently, and unless the regulatory framework provides otherwise, the deletion of the data will be effective thirty (30) days after the processing of the request for deletion of personal information by the person responsible for the protection of personal information.

The Platform is designed for use by adults only as understood in the province of Quebec. Cogni® does not knowingly collect personal information from persons under the age of eighteen (18). Where applicable, information is collected from the child’s parent, representative, or teacher. Except for these sections, the Platform is not designed for persons under eighteen (18) years of age.

For more information on the protection of your personal information and your related rights, you can contact the Office of the Privacy Commissioner of Canada or the Commission d’access à l’information du Québec.

  • Office of the Privacy Commissioner of Canada www.privcom.gc.ca 
  • Quebec Commission for Access to Information www.cai.gouv.qc.ca

FORMS AND INTERACTIONS 

Cogni® collects your personal information in compliance with legal requirements. Where possible and appropriate, we collect your personal information directly from you or from the people you choose to provide us with your personal information.

The User’s personal information may be collected through forms, namely:

  • Platform registration form;
  • Order form ;
  • Survey ;
  • User profile update form
  • Resource download form;
  • Authorization of the User’s access to their information;
  • Support form
  • Community Chat Form
  • Contact form; And
  • Competition.

Your basic personal information, such as your email, first name, last name, and telephone number, may also be collected on our Platform, in particular by email or by telephone.

ADVERTISING INFORMATION

Cogni® will only communicate with you if you wish. 

If the User is not subscribed to our newsletter, does not have a commercial relationship with Cogni®, or has never purchased one of our products, he will not receive any email from Cogni®, without first having consented.

If you prefer not to receive advertising information from us or if you do not want us to use your personal information to enhance your experience as a User, please let us know by contacting us at the contact indicated in section ” Your rights ” below. 

Please remember to include your full name and the email address you used when you registered or made a purchase from us. There may be a processing time for a request sent by email or post and you may continue to receive communications from Cogni® in the meantime. 

ANTI-SPAM LAWS

Cogni® complies with the requirements of the Canadian Anti-Spam Law (CASL) (L.C. 2010, ch. 23). 

The User understands that he can expressly or tacitly consent to receive messages from Cogni®.

Express consent is the consent requested from the User, consent which must be stated in simple and clear terms, and must include the purposes for which the consent is requested, the regulatory information allowing the identification of the person requesting the consent, and, if it is solicited on behalf of another person, regulatory information enabling that person to be identified; as well as any other information specified by the regulations made under this Act.

The User understands that he is giving his tacit consent during ongoing business relationships or ongoing private relationships; when the User publishes his email address without mentioning that he does not wish to receive unsolicited commercial electronic messages; or when the message is sent in other circumstances provided for by the regulations made under this Act. 

  • For this Policy, ongoing business relationships refer to commercial relationships established between two people such as a purchase or rental within two years preceding the date the message was sent; an investment or game offered; the barter of a thing; any contract in force or which expired during this period; or a request during the six months preceding the date the message was sent.
  • For this Policy, ongoing private relationship means relationships between two people other than business relationships, such as a donation or gift, work done on a volunteer basis; and a membership, in the sense of regulations; all during the two preceding the date the message was sent.

To unsubscribe from our electronic communications mailing list, simply contact us at [email protected].

PROTECTION AGAINST FRAUD AND THEFT OF YOUR PERSONAL INFORMATION

 Cogni® undertakes at all times to respect the laws and regulations applicable to its activity and to take all useful and necessary measures to detect and prevent negligence, fraud, and the theft of your personal information. However, although Cogni® takes precautions, Cogni® cannot guarantee that no case of fraud or theft of your personal information can take place.

 Cogni® keeps an up-to-date record of confidentiality incidents and will contact any User whose personal information is the subject of such an incident and presents a risk of serious harm.

THIRD-PARTY ADVERTISING DISPLAYED ON OUR PLATFORM

You may find third-party advertising displayed on our Platform. We do not allow third parties to collect your personal information on our Platform without your consent.

Cogni® prohibits and is not responsible for the resale or use by third parties of the “ opt-in » obtained through the Platform by these third parties. If you have agreed to share your contact details with partner organizations, then we will share them with them.

We do not sell or rent your personal information without your consent.

SERVICES TIERS 

Cogni® may use, as part of its service provision and/or management of its activity and its Platform, third-party services. Under no circumstances is Cogni® liable for any harm that may arise from these third-party services. To find out the conditions of use of these services, we invite the User to consult their respective websites. 

DATA EXCHANGED AUTOMATICALLY

Thanks to cookie files (hereinafter the “ Cookies “), we collect certain information during exchanges between your computer and our server. Cookies are files created by a website that records information relating to your computer’s navigation on the site. They are stored automatically on your electronic devices, allow you to connect to the Platform during subsequent uses, and allow Cogni® to personalize the Platform. 

This mainly concerns the following information: 

  • Navigation history ;
  • Browser type and/or OS;
  • Analytics and performance – User behavior;
  • Analytics and performance – product effectiveness data, most used product;
  • Advertising/redirect; And
  • Third-party software served to the User.

Most of the information transmitted automatically does not allow us to know the identity of the User. They are only collected due to technological requirements inherent to Internet browsing. Most browsers automatically accept Cookies, but it is generally possible to modify this behavior. On the other hand, if the User chooses to refuse Cookies, he may not be able to identify himself or use certain functions of the Platform.

Using such information allows us to improve the service, personalize the User experience, and better track your past use. 

In addition to the methods described above, we may also collect information using Cookies or similar technologies, particularly during your visits to our Platform. These methods allow us to collect various types of information, including the pages you visit, emails you read, and other information.

This information is also used to:

  • Identify the User;
  • Communicate with the User (by email, post, or otherwise) and send them advertising material or additional information on products, services, surveys, contests, promotions, and special offers;
  • Develop new products and services; And
  • Conduct market research and performance research to evaluate customer service, measure performance, enhance the User experience, and improve products.

These Cookies are multiple, some expire when the User closes their browser and no longer have any effect while others can be kept. At any time, the User can deactivate Cookies. In this eventuality, Cogni® does not guarantee the optimal functioning of the Platform.

It is also possible to prohibit the recording of Cookies by configuring your Internet browsing software. However, if you choose the latter option, you may not be able to take advantage of the entire Platform.

INTERNATIONAL COMMUNICATIONS

In certain situations, the User’s data may pass through servers outside Quebec, particularly in North America. In this case, the servers in question are located in other Canadian provinces or territories and the United States.

Cogni® may also communicate your personal information to third parties located outside Quebec, by the terms provided for in the Policy.

 Cogni® undertakes not to communicate your personal information with third parties located in jurisdictions that do not offer a level of protection of personal information similar to that of Quebec.

SHARING OF PERSONAL INFORMATION

Cogni® undertakes not to market the personal information collected without the express consent of the User. The only situation where personal information can be sold is that of a partial or total transfer of the activity to a third party. In such a case, the information transferred as Cogni® assets will be subject to the same guarantees as those in this Policy. 

Unless otherwise stated in this Policy, the personal information that the User provides will not be transmitted to third parties without their authorization. However, we sometimes share this information with third-party providers in connection with promotional offers to which you have consented. In such a case and from now on, you expressly consent to this sharing.

Cogni® may also publicly re-publish or re-share personally identifiable information when you post Cogni®-related content on Social Media. In addition, it is possible that by clicking on an external link located on the Platform, you access External Websites that have their information protection policy. It is therefore advisable that you consult them because you will be subject to them.

If the User does not wish his personal information to be communicated to third parties or partners, he can object to this at any time, as mentioned in the section “ Your rights ” next.

Cogni® may, in the following cases, exceptionally communicate the User’s personal information without their consent:

  • In the event of a legal obligation, in particular when a court order requires Cogni® to communicate the User’s personal information.
  • When it is impossible to obtain the User’s consent privacy laws allow Cogni® to communicate this personal information. This is particularly the case when the protection of the public interest requires it. 

YOUR RIGHTS

We undertake to offer the User the following rights regarding their personal information: 

  • The right of access;
  • The right of rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;
  • The right to file a complaint with a supervisory authority; And
  • The right to withdraw consent.

You have the right to obtain confirmation as to whether or not we are processing your personal information and, where we do, to access the personal information, as well as certain additional information. This additional information includes details of the purposes of the processing, the categories of personal information concerned, and the recipients of the personal information. Provided that the rights and freedoms of others are not affected, we will provide you with a copy of your personal information.

In certain circumstances, you have the right to obtain the deletion of your personal information without undue delay. These circumstances are: 

  • The personal information is no longer necessary about the purposes for which it was collected or otherwise processed; 
  • You withdraw your consent to processing based on consent; 
  • You object to processing under certain rules of applicable data protection legislation; 
  • The processing is carried out for direct marketing purposes; And 
  • Personal information was processed illegally. 

However, there are exclusions from the right to erasure. General exclusions include when processing is necessary: 

  • For the exercise of the right to freedom of expression and information; 
  • For compliance with a legal obligation; Or 
  • For the establishment, exercise, or defense of legal rights.

Your request relating to any right mentioned in this section, or the following section, must be made in writing and sent according to the procedure provided for in this section and the section “ Responsible for the protection of personal information ».

The deletion of personal information takes place when you make a written request to the person responsible for the protection of personal information. Cogni® reserves the right to refuse a User’s request when the latter continues to use Cogni® services in any way.

Cogni® respects the retention period established by this policy, which is consistent with the Act respecting the protection of personal information in the private sector (CQLR c P-39.1) And the Act to modernize legislative provisions regarding the protection of personal information, (LQ 2021, c 25). Consequently, and unless the regulatory framework provides otherwise, the deletion of data will be effective thirty (30) days after the processing of the request for deletion of personal information by the person responsible for the protection of personal information.

ACCESS TO YOUR PERSONAL INFORMATION

The personal information we hold about you must be accurate and up to date. Please keep us informed of any changes to your personal information. The act respecting the protection of personal information in the private sector (RLRQ c P-39.1) And the Act to modernize legislative provisions regarding the protection of personal information, (LQ 2021, c 25) gives you the right to request access to and correction of the personal information we hold about you. You can also modify your personal information at any time via your user account. 

In addition to the cases of sharing mentioned in this Policy, your personal information collected by Cogni® hereunder will be accessible only by authorized and concerned employees as defined by Cogni®.

 Cogni®, subject to certain exceptions, may inform you of the personal information concerning you, the use made of it, and the fact that it has been communicated to third-party service providers. You may also have access to this information for any modification or deletion.

 Your request for consultation, verification, correction or to withdraw your consent to the use of your personal information, or to request access, correction or deletion of any personal information that you have provided to us must be made in writing and sent according to the procedure provided for in this section and the section “ Responsible for the protection of personal information ” below. Remember to include your full name and the email address you used when you registered. There may be a processing time for a request sent by email or post and you may continue to receive communications from Cogni® in the meantime. 

Cogni® will acknowledge receipt of your request in writing and may ask you to confirm your identity before providing you with this information. In principle, access to this information will be provided free of charge, but, if you request a copy or transmission of your information, we may charge a reasonable fee. Cogni® will inform you of the amount in advance and allow you to withdraw your request. Cogni® will provide you with access to your information within thirty (30) days of receipt of your request or provide you with written notice to advise you that additional time is required to respond to your request.

 In some cases, we may be unable to provide you with access to information about you, in whole or in part. If we are unable to do so or the law does not permit us to do so, we will provide you with an explanation and indicate what other measures are available to you.

WITHDRAW YOUR CONSENT

Where you have provided consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent in certain circumstances. To withdraw your consent, if applicable, contact us at the email address: [email protected]. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. Cogni® will explain the impact to you at that time to help you in your decision.

SECURITY 

The personal information that Cogni® collects is stored in a secure environment. Cogni® has adopted appropriate measures to preserve the confidentiality of personal information and protect it against loss or theft, as well as unauthorized access, communication, reproduction, use, or modification, taking into account, in particular, their sensitivity and the purposes for which they are used. In addition, Cogni® requires each employee, agent, or representative of Cogni® to comply with this Policy.

To ensure the security of the User’s personal information, Cogni® uses, among others, the following measures:

  • Protected access to servers and computers;
  • Firewall; 
  • Use of password-protected data networks;
  • Confidentiality agreements with employees;
  • Internal personal information protection policies;
  • Current update of security measures; And
  • Encrypted and secure electronic communications.

Cogni® is thus committed to maintaining a high degree of security by integrating the latest technological innovations to ensure the confidentiality of the User’s transactions to ensure the protection of their personal information and prevent it from being consulted, used, or disclosed without authorization. Cogni® undertakes to keep a record of confidentiality incidents.

However, as no mechanism offers maximum security, some risk is always present when using the Internet to transmit personal information. If a password is used to protect the User’s account and personal information, it is their responsibility to ensure that it remains confidential. 

In the event of a confidentiality incident involving a User’s personal information held by Cogni®, Cogni® will notify the User concerned and the Commission d’access à l’information du Québec of any confidentiality incident presenting a risk of serious harm.

FRENCH AND ENGLISH LANGUAGE

In the event of a definition or interpretation problem between the French and English versions of the Legal Notices, the French version will prevail. 

APPLICABLE LAW AND COMPETENT COURTS

The Platform and its content are managed by Cogni® from Canada and the United States. The Platform, this Legal Notice, and the User’s use of it are all governed by the laws of Quebec and Canada which are applicable, without giving effect to any principle whatsoever relating to the conflict of laws. 

You agree that all questions and disputes concerning the Social Media Platform and the use thereof will first be brought before a mediator and, in the absence of compromise, resolved by the courts of Montreal.

Notwithstanding any attribution of jurisdiction and applicable law, when the User is a consumer within the meaning of the Consumer Protection Act (RLRQ c P-40.1) then any dispute relating to this Policy will be governed by the law of the province of Quebec, and will necessarily be brought before a competent court by the rules of the Code of Civil Procedure.

PERSONAL INFORMATION PROTECTION MANAGER

If you have any questions about processing or updating your personal information or to raise any concerns in this regard, please contact us at the following email address: https: [email protected] or the following postal address: 405 Av. Ogilvy #101, Montreal, Quebec H3N 1M3

The person responsible for the protection of personal information will contact you within thirty (30) days of receiving your email.

INTERPRETATION

This Policy is governed by applicable Quebec and Canadian laws, including the Information Protection Act personal (L.R.C. (1985), ch. P-21) of Canada and the Act modernizing legislative provisions regarding the protection of personal information, (LQ 2021, c 25). These laws apply without giving effect to any principle relating to conflict of laws. 

Whenever the context requires it, any word written in the singular also includes the plural and vice versa; any word written in the masculine gender also includes the feminine gender and vice versa.

DIVISIBILITY

Each provision of this Policy forms a separate whole so that any decision of a court to the effect that one of the provisions of this Policy is void or unenforceable in no way affects the validity of the other provisions of this Policy Political or even their enforceable nature.  

MODIFICATION OF THIS POLICY 

We occasionally update this Policy. Continued use of the Platform constitutes the User’s agreement to this Privacy Policy and its updates. 

However, Cogni® will notify Users of the Platform thirty (30) days before the entry into force of the modification hereof. This notification will be made by sending an email, informing the User of the possibility of consulting the details of the modifications on the Cogni® website. If the User refuses these modifications and wishes to terminate the contract, he will have no later than thirty (30) days following the entry into force of the modifications to send a notice to Cogni® and resolve, without cost or penalty, his obligations towards Cogni ®.

Last updated on July 30, 2024