DEFINITION AND SCOPE
Thank you for visiting 360.Agency or one of our product websites, including but not limited to, CRM Pro Suite of Products and XMS Pro Suite of Products (the “Website”), provided to you by Solutions Medias 360 and operated by 360.Agency (“We”). We respect the privacy of every individual who visits the Website and are sensitive to privacy issues on the Internet. We believe it is important that you know how we deal with information received about you.
WHAT INFORMATION WE COLLECT
We collect and use several types of information from and about you, including:
- Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, and any other identifier we may use to contact you online or offline.
- Non-personal information is information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature.
- Usage information, including your login information, Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platforms, or information about your Internet connection, the equipment you use to access the Website, and usage details.
- Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), click stream to, through and from our Website (including dates and times), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
- Business email communications
HOW WE COLLECT THE INFORMATION
Information You Provide to Us
The information we collect directly from you may include:
- Online Accounts: If you sign up for an online account through the Website, we may ask you to provide your username, password, email address and phone number.
- Marketing Communications: If you would like to receive marketing communications from us, you may do so by signing up on the Website. We will ask you to provide your email address or phone number so we can send you marketing materials.
- Communicating with us: When you contact us about a customer service issue, or to make other inquiries, we collect the content of those communications, and any additional information about the method of communication such as phone, SMS, email, chat, or through social media platforms. For example, if you email us, we will collect your email address; if you send us a text message, we will collect your phone number; and so on.
- Other information you provide online.
Information We Collect While You Interact With Us Through Cookies and Other Automatic Data Collection Technologies
- We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). To learn more or to opt out of tailored advertising, please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioural tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioural tracking.
- The information we collect automatically is statistical data and does not include Personal Information. However, we may maintain it or associate it with Personal Information we collect in other ways that you provide to us or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to: estimate our audience size and usage patterns, store information about your preferences, allowing us to customize the Website according to your individual interests, speed up your searches and recognize you when you return to the Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
- Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow us, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Information We Collect When You Allow Us Access To Your Mailbox
In the CRM Pro, when you configure the service to read your mailbox on your behalf, we access all incoming and outgoing business email communications. Our software reads the “To” or “From” fields as well as the body of the message to associate email communications with existing customer communications.
Information We Collect About You From Third Parties
We may receive Personal Information about you from various third parties and public sources, such as credit card issuers, financial partners, and data analytics firms. We may collect information about you in connection with investigations into fraudulent or criminal activities on the Website. We may also collect information from other sources, including for example, joint marketing partners, data analytics firms, public databases, publicly available social media pages, and other third parties we work with.
Information We Create Ourselves
We may aggregate and/or anonymize Personal Information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose.
HOW WE USE YOUR INFORMATION
We use your information, including your Personal Information, to manage our business and to maintain and develop commercial relationships with you. We will collect, use, and disclose such information only to the extent that is necessary for those purposes.
We use information that we collect about you or that you provide to us, including any Personal Information:
- To present the Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements.
- To notify you about changes to the Website or any products or services we offer or provide through it.
- To improve the Website, products or services, marketing, or customer relationships and experiences.
- To allow you to participate in interactive features, social media, or similar features on the Website.
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Your Personal Information is also accessible to our employees or representatives who require it in the performance of their duties. Employees or representatives must maintain the confidentiality of your Personal Information at all times, and are required to undergo regular training and awareness-raising activities on security and the protection of personal information.
HOW WE SHARE YOUR INFORMATION
Sharing With Our Partners
We may provide your data, including your Personal Information, to our affiliated companies and third parties who provide services to you or us as needed to carry out our business, or comply with a legal obligation. This information can be shared with third parties for promotional purposes.
For example, we may share your Personal Information with the following types of suppliers and partners:
- Communications solutions provider;
- Billing and payment services;
- Statistical data collection and behavioral analysis tools;
- Marketing, advertising or retargeting solutions partners, including social networks;
- Software development services;
- Cloud computing, web hosting and data processing services;
- IT services and products;
- Human resources management and training services;
- Credit bureaus and collection agencies;
- Legal services;
HOW WE STORE AND SECURE YOUR INFORMATION
We are committed to protecting the confidentiality, integrity, availability and privacy of your Personal Information. We have put appropriate physical, technological and procedural security measures in place designed to help prevent your Personal Information from being lost, used, modified or accessed in an unauthorized way, or improperly disclosed. Examples of such measures include restricted access to offices, training of personnel, using passwords and well-defined internal policies and practices. We also use encryption technology and Secure Socket Layers (“SSL”) in all areas of the Website where your personal account information is required, which means the Personal Information you submit to us via the Website is encrypted by your computer and decrypted again on our side. Your personal account information and transaction history are kept behind a firewall.
In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a legitimate business reason for accessing your Personal Information. They will be required to process your Personal Information only on our instructions and they are subject to an obligation of confidentiality. Our service providers are required to maintain adequate security protections in place designed to help safeguard your Personal Information and are not permitted to use it for any purpose other than fulfilling services to us.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Any transmission you provide is at your own risk. Once we have received your information, we will apply our security practices to try to prevent unauthorized access, use and/or disclosure. 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 account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “How to contact us” section below.
We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.
Once your Personal Information is no longer needed to fulfill the purposes we collected it for, our service providers and third party vendors will dispose of your Personal Information as provided for in their internal data retention and disposal policy.
Communications outside Quebec
By providing us with Personal Information, you understand that it may be communicated to or stored outside Quebec or Canada by us or one of our suppliers or partners.
In such cases, we will ensure that your Personal Information is adequately protected, in particular with respect to generally accepted principles of protection that are reasonable in the circumstances.
THIRD PARTY WEBSITES AND SERVICES
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
You can review and change your personal information by logging into the Website and visiting your account profile page.
If you want to review, verify, or correct the use of your personal information, you may also contact us in accordance with the “How to contact us” section below.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us in accordance with the “How to contact us” section below. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
We also provide an opportunity for any user to unsubscribe from our email communications or opt-out of contact for marketing or informational purposes on an ongoing basis using the unsubscribe mechanism at the bottom of our e-mails.
HANDLING OF COMPLAINTS
Any person wishing to make a complaint concerning the application of this policy or, more generally, the protection of his or her Personal Information, must do so by writing to the Privacy Officer at the e-mail address indicated below.
The individual must provide his or her name, contact information, including a telephone number, as well as the subject of the complaint and the reasons for it, giving sufficient details to allow the complaint to be evaluated. If the complaint is not specific enough, the Privacy Officer may request any additional information he or she deems necessary to assess the complaint.
We undertake to treat all complaints received confidentially.
If the complaint cannot be processed within this timeframe, the plaintiff must be informed of the reasons for the extension, the status of the complaint and the reasonable time required to provide a definitive response.
You may also file a complaint with the Commission d’accès à l’information du Québec or any other privacy oversight body responsible for enforcing the law relating to the subject of the complaint.
However, we invite anyone interested to first contact the Privacy Officer and wait until the processing is complete.
HOW TO CONTACT US
355 Peel, 9th
Phone: (833) 360-0485
This document may be updated on a regular basis in line with legislative, technological and organizational developments.
Current version: September 20, 2023.