APPLICATION AND SCOPE
DEFINITION OF PERSONAL INFORMATION
“Personal information” is broadly defined and includes any information about an identifiable individual, as well as more technical information which is collected automatically. Information that is aggregated and/or anonymized is not considered to be personal information.
COLLECTION OF PERSONAL INFORMATION
We usually collect personal information directly from you, for instance when you register to create an account on our Website. We may also collect information automatically through our Website, although it may not necessarily identify you as an individual.
Information you provide directly to us.
In many cases, we collect personal information directly from you when you are interacting with us, for instance:
- Contact information, such as name, email address, postal address, phone number, and mobile number when you make an order on our Website, create an account, sign up for our newsletter or make an inquiry or contact us through our Website or otherwise (for instance by phone or email);
- Any personal information that appears in any document that you provide to us as part of your translation order (for instance if you ask us to translate your birth certificate or your driver’s licence).
Information Collected Automatically.
We may collect information automatically, which may not necessarily identify you as an individual, when you visit our Website. For instance, we may collect the following type of information:
- Google Analytics: We use Google Analytics which allows us to see information on users’ online activities including, but not limited to, page views, source and time spent on our Website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
- Retargeting. We use services such as Google AdWords remarketing to advertise OXO across the Internet and to advertise on third party websites (including Google) to previous visitors to our Website. AdWords remarketing will display ads to you based on what parts of the Website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our Website or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our Website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords remarketing, you can opt out by visiting Google’s Ads Preferences Manager.
USE OF PERSONAL INFORMATION
OXO generally uses personal information to provide our translation services to our customers. For instance, we will use your contact information and the information related to your OXO account to process your translation order and to communicate with you in relation to your order. We will also use your personal information to authenticate your identity if you contact us by telephone or otherwise.
We may also use your personal information for the following purposes, but always in compliance with applicable laws:
- For internal training, quality assurance, risk management and fraud detecting purposes or to meet our legal and regulatory requirements;
- To understand and assess the interests and changing needs of our customers with a view to providing personalized services, to improve our services and to develop new services;
SHARING OF PERSONAL INFORMATION
OXO may share your information with freelance translators for the purposes of executing your translation order. We may also share your personal information with our service providers or with another business in the event of a business transaction. In some situations, we may also provide your personal information to third parties as permitted or required by law (for instance in response to a court order or investigation).
- Freelance translators. In order to process your translation order, OXO may use the services of translators who may not be employed by OXO. These translators are contractually required to only use your information for the purposes of performing the translation and may not disclose such information to any third party. Please note that your information is only being accessed by such translators, for the performance of their services, through a secured platform. Translators are only being granted access to the documents they are assigned to translate on the platform.
- Service providers. We may hire service providers to perform services on our behalf. For instance, this may include the providers of software that OXO uses in order to provide our services. We provide our service providers with the limited amount of information necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. OXO will strive to protect personal information disclosed to third parties by contractual agreements.
- As permitted or required by law. OXO may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
- Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
YOUR CONSENT AND RIGHT TO WITHDRAW CONSENT
- to communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional services that may be of interest to you, including through our newsletter. You can always limit the electronic communications that OXO sends to you. To opt out of commercial emails, simply click the link labeled “Unsubscribe” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account;
- to conduct surveys on the quality of our services or customer service.
We do not knowingly collect personal information from children under 13 without the consent of a legal guardian. To purchase services, we must obtain the consent of your parent or legal guardian if you are under the age of majority and such consent is a requirement in the jurisdiction of your residence. If we learn we have collected or received personal information from a child where parental confirmation was required, we will delete that information. If you believe we might have any information from or about a child where we should have obtained parental consent, please contact us using the contact information detailed in the How to Contact Us section below.
PRIVACY POLICIES OF THIRD PARTIES
PERSONAL INFORMATION OUTSIDE YOUR COUNTRY OF RESIDENCE
We may store your personal information outside of Canada and, as a result, it may be subject to the laws of other jurisdictions and made available to foreign government authorities.
SECURITY OF PERSONAL INFORMATION
We strive to protect your personal information against unauthorized access.
We will use reasonable security measures to protect your personal information against unauthorized access. OXO has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information.
We only retain your personal information for the time period necessary to fulfill the purpose for which it was collected, unless authorized or required by applicable law.
Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise authorized or required by law. For example, we usually retain information as long as we need to provide services to a customer, and for a period of 3 years after the business relationship ends, unless otherwise compelled by the law to retain such information, or in the case of a litigation, or potential litigation.
Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. OXO has developed and implemented detailed retention principles, and will ensure destruction of personal information in a method that prevents improper access.
ACCESS AND CORRECTION
You have the right to access your personal information and to have it corrected by contacting us as detailed in the How to Contact Us section.
OXO respects your right to access and correct your personal information. If you have an online account with us, you can log into your account at any time to access and update the information you have provided to us, such as your contact information. Additionally, OXO complies with all laws regarding access and correction. If you need assistance updating your personal information, please contact us using the contact information detailed in the How to Contact Us section below.
HOW TO CONTACT US
OXO INNOVATION INC.
1525 Sherbrooke Street West
Montreal, Quebec H3G 1L7