PRIVACY & COOKIE POLICY

M32 Connect Inc. (‘we’ or ‘our’) operates the website https://m32connect.com and certain technologies, such as its scripts, its website ‘m32.report,’ and its advertising platform (the ‘Service’). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Definitions

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

 

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  •  Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

M32 Connect Inc. uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Retention of Data

M32 Connect Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
M32 Connect Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
M32 Connect Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure of Data

Business Transaction

If M32 Connect Inc. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Disclosure for Law Enforcement
Under certain circumstances, M32 Connect Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

M32 Connect Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of M32 Connect Inc.
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Rights

M32 Connect Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the right:

  • To access and receive a copy of the Personal Data we hold about you
  • To rectify any Personal Data held about you that is inaccurate
  • To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to M32 Connect Inc. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

Google AdSense & Google Ad Manager Cookies

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the Ad Manager cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
You may opt out of the use of the Ad Manager Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

 

Behavioral Remarketing

M32 Connect Inc. uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords

Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook

Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/610457675797481/ 
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance.
You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Xandr (AppNexus)

Xandr remarketing service is provided by Microsoft Inc.
You can opt-out of Xandr remarketing by visiting the Privacy Platform web page: https://about.ads.microsoft.com/en-us/solutions/xandr/platform-privacy-policy 
For more information on the privacy practices of Xandr, please visit the Privacy Policy web page: https://about.ads.microsoft.com/en-us/solutions/xandr/platform-privacy-policy 
The duration of ‘cookies’ on the Xandr platform can extend up to 120 days.

M32 Connect

M32 Connect is acting as our advertising service partner. You can delete all cookies gathered and managed through their process at https://m32.connect. M32 Connect DMP cookies are stored for a duration of 6 months.

Other Considerations

Deleting or protecting opt-outs:

If you delete your cookies, you will need to opt out again. There are browser plugins to help you preserve your opt-out cookies. For more information, please visit http://www.aboutads.info/PMC or https://youradchoices.ca/choices/protect-my-choices/

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

PERSONAL INFORMATION GOVERNANCE POLICY AND PRACTICES

 

Organisational commitment

  • Privacy is of prime importance to M32. M32 has implemented a personal information (PI) management program and allocates the necessary resources to it.
  • M32 has appointed a manager to manage the Personal Information Governance (PRP) program, Claude Cajolet (dataprotection@m32connect.com), who is responsible for providing regular reports to management.

Control measures

  • M32 maintains an inventory of the PI that it collects, uses, communicates, retains and destroys. Any PI collected, used and communicated is for business purposes only. It is only kept for as long as necessary for business purposes, subject to a longer period required by law. It is stored and destroyed securely.
  • M32 has implemented policies and guidelines for PR management. These policies and guidelines cover the following topics:
    • Roles and responsibilities of M32 staff,
    • Collect, use and communication of PIs,
    • Conservation, destruction and anonymization of PIs,
    • Security measures of PIs,
    • Handling requests and complaints relating to PIs,
    • Management of confidentiality incidents involving a PI and
    • Privacy policy for PI collected via the website.
  • M32 ensures that its staff are aware of the need to protect the confidentiality of PI through information sessions on the subject. These sessions cover:
      • Our internal process
      • The handling of confidentiality incidents
      • Complaint management
      • The law and the consequences of non-compliance with obligations
  • M32 has a privacy incident management protocol and maintains a log of all incidents.
  • When M32 works with an external supplier, and that supplier requires access to a certain PI, a contract will define the supplier’s obligations in relation to the protection of the PI.

      Update

      • On a regular basis, M32 reviews its PI governance program to ensure that it is always up to date and adapted to current regulations. This includes updating its PI inventory and procedures.

      How to Contact Us?

      Privacy Inquiries

      If you have any questions or concerns regarding the protection of your personal information or if you wish to exercise your rights, please feel free to reach out to Claude Cajolet, our Privacy Officer, using the following contact details:

      We value your privacy and are committed to addressing any inquiries or requests you may have regarding your personal information. Please don’t hesitate to contact us using the information provided above.

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