1. DEFINITION AND SCOPE
This Policy applies to Astek, including its directors, employees and consultants, as well as any person offering services on behalf of Astek, and may be modified at any time.
“Personal information” (also called “personal data”) means any information about an identifiable individual. This may include email addresses and contact details as well as any similar information provided to Astek in the course of its business activities or received by Astek through inquiries. Such information is not considered personal data when it is aggregated and cannot be associated
with an identifiable individual. Furthermore, personal information does not include a person’s business or professional contact information, such as their name, title, address, email or phone number at work. More specifically and in the interest of clarity, under the Act Respecting the Protection of Personal Information in the Private Sector, and as of September 22, 2023, the divisions 3 (collection), 4 (use and communication) and 6 (retention and destruction) do not apply to personal information concerning the performance of duties within an enterprise by the person concerned, such as their name, title and duties, as well as their workplace address, email and phone number.
2. INTERNATIONAL COMPLIANCE
Astek complies with (i) this Policy; (ii) private sector data protection statutes, including the Act Respecting the Protection of Personal Information in the Private Sector (Canada), the Personal Information Protection and Electronic Documents Act (Canada), the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data
Protection Regulation) and substantially similar provincial statutes pertaining to the collection, use and disclosure of personal information; and (iii) industry standards concerning the protection, privacy and security of data.
Personal information held by Astek may be disclosed outside Quebec; for example, when Astek uses cloud service providers with servers located outside Quebec or when Astek deals with subcontractors located outside the province. Nevertheless, Astek always ensures that personal information is protected by security and privacy procedures and measures that are, at a minimum, equivalent to those employed by Astek.
3. INFORMATION COLLECTED BY ASTEK
a) Directly from you
When using our contact form, subscribing to a newsletter or applying for a job, you may provide us with personal data, such as your name and contact details (email, address and phone number), job search criteria and preferences, work experience, educational/training background, skills, references and any other information included in your CV. We may also collect data that is publicly available or provided by third parties. For example, we may collect certain information that is posted on social media sites (e.g. LinkedIn), blogs and other websites.
In general, Astek collects personal data directly from the individual concerned and with their consent, except in certain cases as provided for by the law. Consent may be obtained implicitly in certain situations; for example, when the individual decides to provide their personal information after being informed by this Policy of its use and disclosure for the purposes stated herein.
b) By means of cookies
When you visit the Website, we may place a cookie on your computer or mobile device. A “cookie” is a small text file sent to your browser by a web server, which is then stored on your device’s hard drive.
Session cookies and persistent cookies
The Astek website also uses Google Analytics cookies to measure the website’s audience and analyze visits to the site. More specifically, the type of data collected includes:
- Truncated IP address of computer or mobile device
- Internet service provider
- Operating system
- Device type and model
- City where user is located at the time of visiting the Website
This data may be stored outside the province of Quebec, particularly in the United States. While the data collected is anonymized, your consent is required to allow the use of these cookies. During your first visit to the Astek website, you will be asked to accept or reject the cookies. You can withdraw your consent at
any time. You can also configure your browser to prevent cookies from being stored on your device.
Astek uses tools provided by third-party service providers: Google Double Click, Google Video, YouTube, Google Fonts, Google Tag Manager, Amcharts and Google Ggpht. Used primarily for site personalization or marketing purposes, these tools may store information outside of Quebec, particularly in Europe and
the United States. Your consent is required. Once again, when you first visit the Website, you will be asked to accept or reject these cookies. You can withdraw your consent at any time. You can also configure your browser to prevent the cookies from being stored on your device.
4.USE OF PERSONAL INFORMATION
Astek may use your personal data for the following purposes: i) surveys, ii) analysis, iii) corporate communications, iv) communication with you (via email, mail or other means), and v) business proposals.
In addition, we will use and disclose personal information, as necessary, i) under applicable laws, including the laws of jurisdictions outside Canada; ii) to comply with a legal process; iii) to respond to requests from public and governmental authorities, including public and governmental authorities outside Canada; iv) to enforce our Terms and Conditions; v) to protect our business activities or those of any of our affiliates; vi) to protect our rights, safety or property, and/or those of our affiliates, yours or those of others; vii) to enable us to pursue available remedies or limit the damages we may incur; or viii) in the event of a sale or transfer of business or assets, merger, reorganization or financing of business units.
Astek has implemented measures to limit access to personal information only to individuals within its organization who are authorized to access it and require such data to perform their duties. Additionally, the Website is designed for use by adults only. Astek does not knowingly collect personal information from individuals under age 16. Individuals under age 16 should not use the Website or provide any personal information.
In certain circumstances, Astek may share your personal information with its service providers or partners. For example, Astek may disclose your personal data with its cloud, Web hosting and data processing service providers. When Astek discloses your personal information to its suppliers, it ensures that the contracts include the necessary data protection clauses to safeguard the privacy of your personal information.
5. ACCESS TO YOUR PERSONAL INFORMATION
Astek ensures that all the personal data it collects is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. You have the right to request access to and correction of your personal information collected by us, if needed. You may send such a request in writing to our Privacy Officer using the contact details provided in section 8 of this Policy.
6. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
If you have agreed to the collection, use and/or disclosure of your personal data as described herein, please note that you may withdraw your consent at any time by communicating with our Privacy Officer using the contact details provided in section 8 of this Policy.
Astek only keeps personal information for the duration necessary to achieve its purpose, unless a minimum retention period is required by applicable law or regulation. Personal information used by Astek to make a decision about an individual must be retained for at least one year after the decision is made, or up to seven years after the end of the fiscal year in which the decision was made if the decision has tax implications (e.g. the circumstances of a termination of employment). At the end of the retention period or when the personal information is no longer needed, Astek will ensure to:
- destroy the information; or
- anonymize it in order to use it for a serious and legitimate purpose (i.e. permanently and irreversibly alter personal information making it impossible to identify an individual).
7. COMPLAINT HANDLING PROCESS
Any person wishing to make a complaint regarding the application of this Policy or, more generally, about the protection of their personal information, must do so in writing to the Privacy Officer using the contact details provided in section 8 of this Policy.
The individual must provide their name, contact information, including a telephone number, and the subject matter and reasons for the complaint in sufficient detail to allow Astek to assess the complaint. If the complaint is not specific enough, the Privacy Officer may request any additional information they deem necessary to assess the complaint.
Astek is committed to treating all complaints received in a confidential manner. Within 30 days of receiving the complaint or receiving any additional information deemed necessary and required by Astek’s Privacy Officer to process the complaint, the Privacy Officer must assess the complaint and provide a clear, written response to the complainant by email. The purpose of this assessment will be to determine if Astek’s handling of personal information complies with this Policy, any other policy and practice in place within the organization, and applicable legislation or regulations. If the complaint cannot
be processed within this period, the complainant must be informed of the reasons for the extension, the status of their complaint, and the reasonable time required to provide a final response.
Astek is required to maintain a separate file for each complaint received. Each file contains the complaint, the analysis and documentation supporting its assessment, and the response sent to the person who filed the complaint. You may also file a complaint with the Commission d’accès à l’information du Québec or any other privacy oversight office responsible for enforcing the law covering the complaint.
8. PROTECTION OF YOUR PERSONAL INFORMATION
We have adopted all the necessary measures to ensure the confidentiality of personal information and to protect it against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, considering, in particular, the sensitivity of the information and the purposes for which it is to be used.
Thus, Astek has implemented technical, organizational and administrative systems, policies and procedures to help ensure the security, integrity and confidentiality of personal information and to reduce the risk of unauthorized access to or use of personal information.
This Policy is approved by Astek’s Privacy Officer, whose business contact details are as follows:
606 Cathcart St.
Montreal, Quebec H3B 1K9
For any requests, questions or comments regarding this Policy, please contact
the Privacy Officer via email.