This document
was last updated on September 19, 2023
This
privacy policy ("Policy") describes how the personally identifiable
information ("Personal Information") you may provide on the
dblectro.com Website ("Website" or "Service") and any of
its related products and services (collectively, "Services") is collected,
protected and used. It also describes the choices available to you regarding
our use of your Personal Information and how you can access and update this
information. This Policy is a legally binding agreement between you
("User", "you" or "your") and DB Lectro Inc.
("DB Lectro Inc.", "we", "us" or
"our"). By accessing and using the Website and Services, you
acknowledge that you have read, understood, and agree to be bound by the terms
of this Policy. This Policy does not apply to the practices of companies that
we do not own or control, or to individuals that we do not employ or manage.
Collection
of information
Our top
priority is customer data security and, as such, we exercise the no logs
policy. We may process only minimal user data, only as much as it is absolutely
necessary to maintain the Website and Services. Information collected
automatically is used only to identify potential cases of abuse and establish
statistical information regarding the usage and traffic of the Website and
Services. This statistical information is not otherwise aggregated in such a
way that would identify any particular user of the system.
Use and
processing of collected information
In order to
make the Website and Services available to you, or to meet a legal obligation,
we may need to collect and use certain Personal Information. If you do not
provide the information that we request, we may not be able to provide you with
the requested products or services. Any of the information we collect from you
may be used for the following purposes:
Processing
your Personal Information depends on how you interact with the Website and
Services, where you are located in the world and if one of the following
applies: (i) you have given your consent for one or more specific purposes;
this, however, does not apply, whenever the processing of Personal Information
is subject to California Consumer Privacy Act or European data protection law;
(ii) provision of information is necessary for the performance of an agreement
with you and/or for any pre-contractual obligations thereof; (iii) processing
is necessary for compliance with a legal obligation to which you are subject;
(iv) processing is related to a task that is carried out in the public interest
or in the exercise of official authority vested in us; (v) processing is
necessary for the purposes of the legitimate interests pursued by us or by a
third party.
Note that
under some legislations we may be allowed to process information until you
object to such processing (by opting out), without having to rely on consent or
any other of the following legal bases below. In any case, we will be happy to
clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Information is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.
Disclosure
of information
Depending
on the requested Services or as necessary to complete any transaction or
provide any service you have requested, we may share your information with your
consent with our trusted third parties that work with us, any other affiliates
and subsidiaries we rely upon to assist in the operation of the Website and
Services available to you. We do not share Personal Information with
unaffiliated third parties. These service providers are not authorized to use
or disclose your information except as necessary to perform services on our
behalf or comply with legal requirements. We may share your Personal
Information for these purposes only with third parties whose privacy policies
are consistent with ours or who agree to abide by our policies with respect to
Personal Information. These third parties are given Personal Information they
need only in order to perform their designated functions, and we do not
authorize them to use or disclose Personal Information for their own marketing
or other purposes.
Retention
of information
We will
retain and use your Personal Information for the period necessary to comply
with our legal obligations, resolve disputes, and enforce our agreements unless
a longer retention period is required or permitted by law. We may use any
aggregated data derived from or incorporating your Personal Information after
you update or delete it, but not in a manner that would identify you
personally. Once the retention period expires, Personal Information shall be
deleted. Therefore, the right to access, the right to erasure, the right to
rectification and the right to data portability cannot be enforced after the
expiration of the retention period.
The rights
of users
You may
exercise certain rights regarding your information processed by us. In
particular, you have the right to do the following: (i) you have the right to
withdraw consent where you have previously given your consent to the processing
of your information; (ii) you have the right to object to the processing of
your information if the processing is carried out on a legal basis other than
consent; (iii) you have the right to learn if information is being processed by
us, obtain disclosure regarding certain aspects of the processing and obtain a
copy of the information undergoing processing; (iv) you have the right to
verify the accuracy of your information and ask for it to be updated or
corrected; (v) you have the right, under certain circumstances, to restrict the
processing of your information, in which case, we will not process your
information for any purpose other than storing it; (vi) you have the right,
under certain circumstances, to obtain the erasure of your Personal Information
from us; (vii) you have the right to receive your information in a structured,
commonly used and machine readable format and, if technically feasible, to have
it transmitted to another controller without any hindrance. This provision is
applicable provided that your information is processed by automated means and
that the processing is based on your consent, on a contract which you are part
of or on pre-contractual obligations thereof.
California
privacy rights
In addition
to the rights as explained in this Policy, California residents who provide
Personal Information (as defined in the statute) to obtain products or services
for personal, family, or household use are entitled to request and obtain from
us, once a calendar year, information about the Personal Information we shared,
if any, with other businesses for marketing uses. If applicable, this
information would include the categories of Personal Information and the names
and addresses of those businesses with which we shared such personal
information for the immediately prior calendar year (e.g., requests made in the
current year will receive information about the prior year). To obtain this
information please contact us.
How to
exercise these rights
Any
requests to exercise your rights can be directed to DB Lectro Inc. through the
contact details provided in this document. Please note that we may ask you to
verify your identity before responding to such requests. Your request must
provide sufficient information that allows us to verify that you are the person
you are claiming to be or that you are the authorized representative of such person.
You must include sufficient details to allow us to properly understand the
request and respond to it. We cannot respond to your request or provide you
with Personal Information unless we first verify your identity or authority to
make such a request and confirm that the Personal Information relates to you.
Privacy of
children
We do not
knowingly collect any Personal Information from children under the age of 18.
If you are under the age of 18, please do not submit any Personal Information
through the Website and Services. We encourage parents and legal guardians to
monitor their children's Internet usage and to help enforce this Policy by
instructing their children never to provide Personal Information through the
Website and Services without their permission. If you have reason to believe
that a child under the age of 18 has provided Personal Information to us
through the Website and Services, please contact us. You must also be old
enough to consent to the processing of your Personal Information in your
country (in some countries we may allow your parent or guardian to do so on
your behalf).
Do Not
Track signals
Some
browsers incorporate a Do Not Track feature that signals to websites you visit
that you do not want to have your online activity tracked. Tracking is not the
same as using or collecting information in connection with a website. For these
purposes, tracking refers to collecting personally identifiable information
from consumers who use or visit a website or online service as they move across
different websites over time. The Website and Services do not track its
visitors over time and across third party websites. However, some third party
sites may keep track of your browsing activities when they serve you content,
which enables them to tailor what they present to you.
Advertisements
We may
permit certain third party companies to help us tailor advertising that we
think may be of interest to users and to collect and use other data about user
activities on the Website. These companies may deliver ads that might place
cookies and otherwise track user behavior.
Affiliates
We may
engage in affiliate marketing and have affiliate links present on the Website
and Services. If you click on an affiliate link, a cookie will be placed on
your browser to track any sales for purposes of commissions.
Email
marketing
We offer
electronic newsletters to which you may voluntarily subscribe at any time. We
are committed to keeping your courriel address confidential and will not
disclose your email address to any third parties except as allowed in the
information use and processing section or for the purposes of utilizing a third
party provider to send such emails. We will maintain the information sent via courriel
in accordance with applicable laws and regulations.
In
compliance with the CAN-SPAM Act, all courriels sent from us will clearly state
who the courriel is from and provide clear information on how to contact the
sender. You may choose to stop receiving our newsletter or marketing emails by
following the unsubscribe instructions included in these emails or by
contacting us.
Links to
other resources
The Website
and Services contain links to other resources that are not owned or controlled
by us. Please be aware that we are not responsible for the privacy practices of
such other resources or third parties. We encourage you to be aware when you
leave the Website and Services and to read the privacy statements of each and
every resource that may collect Personal Information.
Information
security
We secure
information you provide on computer servers in a controlled, secure
environment, protected from unauthorized access, use, or disclosure. We
maintain reasonable administrative, technical, and physical safeguards in an
effort to protect against unauthorized access, use, modification, and
disclosure of Personal Information in its control and custody. However, no data
transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you
acknowledge that (i) there are security and privacy limitations of the Internet
which are beyond our control; (ii) the security, integrity, and privacy of any
and all information and data exchanged between you and the Website and Services
cannot be guaranteed; and (iii) any such information and data may be viewed or
tampered with in transit by a third party, despite best efforts.
Data breach
In the
event we become aware that the security of the Website and Services has been
compromised or users Personal Information has been disclosed to unrelated third
parties as a result of external activity, including, but not limited to,
security attacks or fraud, we reserve the right to take reasonably appropriate
measures, including, but not limited to, investigation and reporting, as well
as notification to and cooperation with law enforcement authorities. In the
event of a data breach, we will make reasonable efforts to notify affected
individuals if we believe that there is a reasonable risk of harm to the user
as a result of the breach or if notice is otherwise required by law. When we
do, we will send you an email.
Changes and
amendments
We reserve
the right to modify this Policy or its terms relating to the Website and
Services from time to time in our discretion and will notify you of any
material changes to the way in which we treat Personal Information. When we do,
we will revise the updated date at the bottom of this page. We may also provide
notice to you in other ways in our discretion, such as through contact
information you have provided. Any updated version of this Policy will be
effective immediately upon the posting of the revised Policy unless otherwise
specified. Your continued use of the Website and Services after the effective
date of the revised Policy (or such other act specified at that time) will
constitute your consent to those changes. However, we will not, without your
consent, use your Personal Information in a manner materially different than
what was stated at the time your Personal Information was collected.
Acceptance
of this policy
You
acknowledge that you have read this Policy and agree to all its terms and
conditions. By accessing and using the Website and Services you agree to be
bound by this Policy. If you do not agree to abide by the terms of this Policy,
you are not authorized to access or use the Website and Services.
Contacting
us
If you
would like to contact us to understand more about this Policy or wish to
contact us concerning any matter relating to individual rights and your
Personal Information, you may do this by reaching our Privacy officer at the address below:
DB LECTRO INC.
C/O Francois Bergeron, VP of Operations
3755 Place Java, suite 140, Brossard, QC J4Y 0E4