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Privacy Policy

INTRODUCTION

Welcome to OXO’s website located at www.oxoinnovation.com (the “Website”). OXO takes the privacy and security of your personal information very seriously. For this reason, we have taken steps to ensure that any personal information we collect about you is protected by a range of robust business procedures and rigorous security safeguards to ensure that your information is kept confidential and used only for the purposes detailed in this Privacy Policy, unless otherwise authorized by law.

We are committed to providing transparency with respect to our practices in handling personal information. To that end, this Privacy Policy is intended to establish responsible and transparent practices for the management of personal information and to satisfy the requirements of rules established by the federal Personal Information Protection and Electronic Documents Act, as well as substantially similar provincial laws in Alberta, British Columbia and Quebec.

APPLICATION AND SCOPE

This Privacy Policy applies to the personal information that we collect when you interact with OXO through the Website or by any other means.

This Privacy Policy generally applies to any personal information (as defined below in the Definition of Personal Information section of this Privacy Policy) that OXO, or anyone acting as an agent on our behalf, collects about you through the Website or through any other interactions you may have with us (for instance if you contact us by telephone or email). At any time that you do business with OXO or interact with us in any manner, you are protected by the rights and safeguards contained in this Privacy Policy and you explicitly agree to its terms.

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.

When used in this Privacy Policy, personal information means “any information about an identifiable individual”. This may include, for example, your name, contact information, email address or information relating to an account you have created with us. It may also include other types of more technical information such as Website visitors’ IP addresses or browsing history on our Website, but only when this information can identify you as an individual. Information that is aggregated and cannot be associated with an identifiable individual 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:

  • Browser, Device and Technical Information. When you visit our Website, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit or usage, including the IP address of your device/computer (which is the number automatically assigned to your device/computer whenever you access the Internet and that can sometimes be used to derive your general geographic area) and which browser you used to access our Website, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, as well as information you entered and advertisements you have seen. You can block the use of cookies by activating the settings in your browser. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of our Website. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
  • 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

We may use your personal information to provide our translation services, for our own internal purposes as well as for marketing and advertising purposes, although in this last case, subject to your Right to Withdraw Consent provided by this Privacy Policy. We may also anonymize and/or aggregate personal information so that it no longer identifies an individual, and use it for any legal purpose.

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;
  • Subject to your Right to Withdraw Consent provided in this Privacy Policy, to communicate with you for the purposes of providing you with advertising and marketing messages such as promotional codes, including through our newsletter, or to conduct surveys on the quality of our services or customer service. When possible, rather than using personal information, we will anonymize and/or aggregate personal information so that it no longer identifies an individual, and use it for the purposes mentioned above or any legal purpose.

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).

Your information may be made available by OXO to third-parties or service providers to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. OXO will not sell your personal information to any third party. However, we may share your personal information when authorized by law or as follows:

  • 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

When you interact with OXO either through our Website or otherwise, you agree to be bound by this Privacy Policy. You have a right to withdraw your consent at any time.

In general, when you interact with OXO through our Website or otherwise (for instance, when you make a translation order), you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy. Personal information may be collected, used or disclosed without consent only as permitted by applicable laws. Your consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. To exercise these choices, you may advise us by contacting customer service or contacting us using the information detailed in the How to Contact Us section below. You may also withdraw you consent to your personal information being used as follows:

  • 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.

CHILDREN

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

This Privacy Policy only addresses the collection, use and disclosure of personal information by OXO. Other websites have their own privacy policies and practices.

This Privacy Policy only addresses the collection, use and disclosure of personal information by OXO. Other websites that may be accessible through OXO’s Website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

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.

Your personal information may in some cases be transferred to jurisdictions outside of Canada. As a result, you understand that your personal information will be subject to the laws of other jurisdictions than your country of residence and may be available without notice to you to foreign government authorities under lawful orders and laws applicable in such jurisdictions. Regardless of the company or person who processes your information and where it is processed, we will take steps to protect your information in accordance with applicable data protection laws and this Privacy Policy.

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.

RETENTION

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

If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that OXO has about you or that it may have disclosed to third parties, please contact:

Charles Lesperance

MAIL:
OXO INNOVATION INC.
1525 Sherbrooke Street West
Montreal, Quebec H3G 1L7
CANADA

TELEPHONE: 1-438-600-0063

EMAIL: clpoissant@oxoinnovation.com

CHANGE OF PRIVACY POLICY

OXO will review and update its policies and procedures as required to keep current with rules and regulations, new technologies and standards. Our Privacy Policy may therefore change from time to time. We will post any privacy policy changes on our Website and, if the changes are significant, we will provide a more prominent notice. This Privacy Policy was last updated on February 23, 2020.

In the case of a difference in the meaning or interpretation of this Privacy Policy and any translation of it, the English version will prevail.