Privacy Policy

Last update : octobre 23, 2020

1. PURPOSE

12434270 Canada Inc. f.a.s.r.s. Plan Monark (hereinafter “Monark,” “our,” “we,” or “us”), owner and operator of the Monark Platform (the “Platform”) places great importance on your privacy and the protection of your personal information and wishes to provide their users with a secure environment that respects their privacy. That is why we are committed to ensuring the accuracy, security, and confidentiality of your personal information through the strict application of this Privacy Policy (“Policy”) in accordance with the governing laws.

The purpose of this Policy is to explain how Monark collects, uses, discloses, stores, and protects your personal information.

This Policy does not apply to third-party websites and software that may be accessed through the Platform.

To offer you our quality services, we need access to certain personal information. We ensure that our employees and business partners who have access to your personal information in the course of their duties manage your information with the necessary discretion and precision in accordance with the legal and regulatory requirements.

“Personal information” means any information about an individual that can, whether on its own or in combination with other data, identify an individual.

Monark a désigné une personne responsable de la confidentialité. Si vous avez des questions, des commentaires ou des plaintes à propos de la présente Politique, veuillez la contacter à l’adresse suivante : confidentialité@planmonark.com.

2. INFORMATION COLLECTED

Nous ne recueillons que les renseignements personnels vous concernant qui sont nécessaires à l’établissement, à la gestion et au maintien de notre relation avec vous, et ce, dans le but de vous offrir le meilleur service possible.

Selon les circonstances, nous pouvons recueillir les renseignements personnels suivants à votre sujet :

  • Vos nom et prénom;
  • Your email address;
  • Votre date de naissance;
  • Your profession or your trade as well as your years of experience in that profession or trade;
  • Votre utilisation de la Plateforme et d’autres renseignements techniques relatifs à votre comportement de navigation;
  • Any requests you may have (for processing and archiving purposes).
  • Des renseignements relatifs au marketing et aux préférences de communication comme des commentaires ou des réponses à des sondages.


3. HOW WE COLLECT YOUR PERSONAL INFORMATION

Monark collects your personal information from you, from third parties, and from cookies.

From You

You provide us with personal information directly, such as when you create an account on the Platform, click on an advertisement we have placed on a third-party website (e.g., Google, Facebook, etc.), contact us, complete a training program, or fill out an online application form.

From a Third Party

We may also collect personal information from third parties or public records as permitted by law or with the necessary consent.

Cookies

Les témoins de connexion (cookies) sont de petits fichiers de données communément stockés sur votre appareil lors de l’utilisation de sites web et de services en ligne. Ils sont utilisés pour le fonctionnement efficace de la Plateforme et peuvent fournir de l’information et aider à la personnalisation des services. Monark collecte les renseignements personnels fournis par les témoins de connexion.

Monark utilise différents types de témoins de connexions (collectivement nommés « témoins » ici) :

  • Performance and Functionality Cookies : These cookies are not essential to the provision of our services. They help personalize and enhance your user experience. For example, they can remember your preferences so you do not have to reenter information, or they can remember your log-in information, so you do not need to enter it each time you use the service. They help us understand your behavior so we can improve the Platform.
  • Advertising and Targeting Cookies : These cookies are not essential to the provision of our services. They use the information about your visit to the site, such as the pages you viewed or your response to advertisements, to help us provide you with the best user experience.

If you wish to disable the use of cookies, it is possible to do so from your browser’s preference menu. You can disable cookies or use a private browsing mode when you use the Platform. However, if you disable them, you may not be able to use certain features of our Platform.

Beacons

Beacons are tiny images that we place on our web pages or in our emails. They can be used to anonymously track the number of times a particular page has been visited by a user. Beacons are invisible and could be anywhere on the Platform, including advertisements. Unlike cookies, beacons are not stored in your computer.

Monark uses two primary types of cookies :

  • Session Cookies : These cookies are stored on your device when you visit the Platform and then are deleted when you leave. They allow us to identity you and will then be deleted when you leave the Platform.
  • Persistent Cookies : These cookies are stored on your device until they expire and will be retrieved the next time you visit the Platform. Our persistent cookies have a maximum duration of 30 days.

Please note that the use of cookies only allows us to identify you as a user and not recognize you by your name or address.

4. USE OF PERSONAL INFORMATION

Personal information collected by Monark will be used for the following purposes:

  • To provide and maintain our services and Platform, such as providing customer service and connecting consultants with clients who use the Platform;
  • To enable Monark to perform internal operations in conjunction with the services offered;
  • To manage, plan, improve, and customize the services offered;
  • To develop and improve the Platform based on your research, usage, and the options you choose;
  • To communicate with you regarding changes and improvements to services offered and changes to the Platform.

Except as already provided under applicable privacy laws, Monark will obtain your consent before using your personal information for purposes not previously specified.

5. CONSENT TO THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION

We require your consent to the collection, use, and disclosure of your personal information, except when inappropriate. (It may be impossible or impractical to obtain consent for legal or security reasons.)

BY AGREEING TO USE THE MONARK PLATFORM AND SERVICES, YOU GIVE MONARK YOUR VOLUNTARY CONSENT TO COLLECT, PROCESS, AND USE YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY.

You represent that you understand why Monark collects, processes, and uses your personal information, how the collection will be carried out, and how your privacy will be protected.

You may withdraw your consent at any time, subject to governing legal or contractual restrictions and with reasonable notice. If you refuse to disclose your information or if you withdraw your consent, this may prevent us from providing or continuing to provide you with some of our services.

6. PEOPLE TO WHOM YOUR PERSONAL INFORMATION MAY BE DISCLOSED

To provide you with our services, we may need to disclose the personal information we have collected to certain third parties. In the context of business, Monark may disclose your information to third parties, including but not limited to:

  • Third party service providers for services related to the Platform (hosting, security, etc.). The personal information provided is limited to the personal information needed to perform their services and these providers are obligated to maintain the confidentiality of this personal information;
  • Public government authorities and law enforcement agencies when required by the governing law or when needed to provide our services.

Outside of the previously mentioned scenarios, Monark will not disclose your personal information to third parties without first obtaining your consent to do so. In addition, prior to disclosing your personal information, said third parties must agree to strict contractual terms that require them to (i) maintain the confidentiality of the personal information disclosed; (ii) retain and use said personal information only for the purposes set out in this policy; and (iii) destroy said personal information once it has been used for the authorized purposes.

Finally, we will disclose your personal information if we are required to do so by law, by court order, by order of another authority with the jurisdiction to compel us to do so, or to protect or defend a legal interest.

7. RETENTION OF PERSONAL INFORMATION

We will retain your personal information for as long as needed to fulfill the purpose for which it was collected, to meet the legal retention requirements, or to protect our legitimate business interests.

8. SECURITY MEASURES

Monark has implemented the appropriate security measures needed to protect their clients and partners from unauthorized access, use, alteration, illegal or accidental destruction, or the loss of their personal information.

Unfortunately, we cannot guarantee the security of the personal information collected or transmitted on the Platform.

You therefore understand and agree (i) that there are limits to the security and privacy of the personal information collected that are beyond Monark’s control; (ii) that we cannot guarantee the security, integrity, and privacy of all personal information and data exchanged between you and Monark through the Platform; (iii) and that such personal information may be viewed or altered by a third party at the time of transfer. For these reasons, Monark cannot be held liable for any loss, interception, or alteration of personal information.


9. ACCESS, MODIFICATION, AND RETRACTION OF PERSONAL INFORMATION

You may access, correct, or update your personal information through your Platform user account.

You may also obtain a copy of your personal information, or have it corrected if it is inaccurate, by sending us a written request by email.

A request for access, correction, or deletion may only be considered if it is made by you in writing, and if you are able to prove that you are the person referenced in the request.

When we receive a request for access, correction, or deletion, we will endeavor to respond in a timely manner.

In certain situations, it may not be possible for Monark to disclose all the personal information they have about you. These exceptions are limited and specific. Reasons for denied access will be provided upon request.

Exceptions include information that is prohibitively costly to provide; information that contains details about other individuals; legal reasons, security reasons, or business reasons that prevent us from providing you with the information; or information that is protected by an attorney-client or litigation privilege.

A reasonable fee may be charged for transcribing, reproducing, or transmitting personal information.

10. OPPORTUNITY TO FILE A COMPLAINT

At their sole discretion, Monark may update, revise, modify, or supplement this Policy from time to time. If changes are made to this Policy, you will be notified when you log-in and/or we will send you a link to the latest version of the Policy. The Policy and any other related agreements will be posted on the Platform. Monark asks that users consult the modified Policy before continuing to use the Platform.

Your continued use of the Platform after the modified Policy has come into effect, constitutes your consent to this modified Policy.

11. OPPORTUNITY TO FILE A COMPLAINT

Monark has established procedures for receiving complaints and inquiries about its personal information management policies and practices. The complaint procedure is easily accessible and simple to use.

Monark will inform individuals who make inquiries or lodge complaints of the existing relevant procedures.

Monark will investigate all complaints. If a complaint is justified, Monark will take the appropriate measures, including amending their policies and practices if necessary.

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