Privacy Policy

Protecting your privacy is important to Technologies Altee Inc. ("Altee" or "we"), which is why we take the confidentiality of our users' personal information and compliance with applicable laws very seriously.
This Privacy Policy (the "Policy") aims to explain and describe how we collect, use, and disclose your personal information. The Policy is designed to comply with Quebec and Canadian laws regarding personal information protection and, where applicable, the General Data Protection Regulation ("GDPR") applicable to individuals in the European Union ("EU").

1. Scope of the Policy

The Policy applies to personal information we hold or control, including information collected when you use our Altee online platform and services or browse Altee's website (the "Web Services"). The Policy also applies to information received from third parties about you in connection with our service delivery.

2. Acceptance

The use of the Web Services is also subject to our Terms of Use, which are available on Altee's website and were made available to you when you subscribed to Altee's Web Services, if applicable. By accessing our Web Services, you agree to be bound by the terms and conditions contained in the Policy. If you do not agree to be bound by these terms and conditions, please do not access or use the features of our Web Services.

3. Policy Modifications

We occasionally update this Policy and reserve the right to modify its content at any time. Any changes made will appear on our website. The date of the latest version of this Policy appears at the bottom of the page. We recommend that you print a copy of this Policy for your records and review this section of our Web Services periodically.

4. Consent

Altee acknowledges that your consent to the collection, use, and disclosure of your personal information must be manifest, free, and informed. Your consent must be given for specific purposes. Depending on the nature and sensitivity of the personal information, your consent may be explicit (such consent may be given verbally, in writing, or electronically) or implicit (for example, when you voluntarily provide us with personal information). Generally, Altee will seek your consent at the time of collection of the information, unless we are required or otherwise authorized by law to do so.
You may withdraw your consent at any time, subject to applicable legal restrictions and the provision of reasonable notice. Please note that if you choose to withdraw your consent to the collection, use, or disclosure of your personal information, our Web Services may no longer be accessible to you, and Altee may no longer be able to provide you with certain services.

5. Collection of Personal Information

Altee only collects personal information about you that is necessary to establish, manage, and maintain its relationship with you. As part of your use of the Web Services, you may also add and store personal information of third parties on our online platform, such as that of your employees or potential candidates.
For example, without limitation, personal information may be collected when you enter information into our Web Services as part of their use (about yourself, your employees, individuals applying for a job at your company, etc.), register to access your online account, sign up to receive our newsletter, or participate in other interactive online activities. The personal information collected may include, among other things and without limitation:

Non-personally identifiable information may also be collected to enable us to offer you personalized services.

6. Collection of Personal Information via Third Parties

Generally, we obtain information directly from you. However, we may also collect personal information about you from external sources, with your consent or without your consent, if permitted by law.
To provide its online human resources management software services, Altee will also collect information directly from your employer for which you have given authorization. This personal information will be stored, in particular, in your employee file on our platform.

7. Use of Your Personal Information

The purposes for which Altee collects your personal information are determined before or at the time of collection. Altee may use your personal information for the following purposes:

• identify you as a user of our Web Services and allow you to access your account;
• provide you with our Web Services;
• establish and maintain our business relationship, whether as a supplier, partner, client, or otherwise;
• improve our range of services, including the use of Web Services or any other online service, and support our research and development efforts;
• communicate with you when you submit questions, comments, and suggestions;
• provide you with information about our financial services and products that may be of interest to you;
• prevent errors and fraud;
• comply with legal requirements.

Altee may also use your personal information to compile statistics. However, these statistics do not identify you and have been de-identified. Your personal information will not be used for purposes other than those described above, unless we have obtained your consent, or if required or permitted by law.

8. Automated Decision-Making

Your personal information may be used by Altee to make automated decisions about services that may be of interest or relevant to you. This automated decision-making will have no legal effect on you, but is simply intended to automatically generate recommendations based on your personal and financial information. Upon request, Altee will provide you with information on how this automated system works.

9. Disclosure of Your Personal Information to Third Parties in Quebec

Altee recognizes that, except in the cases and subject to the conditions described below or when authorized by law, the disclosure of your personal information to third parties requires your consent.
Access to your personal information within our company does not require your consent, but is strictly limited to individuals for whom such information is necessary for the performance of their duties and responsibilities.
Altee may share your personal information, without your consent, with its agents, service providers, or consultants who need this information in connection with Altee's activities or to help Altee administer its Web Services. These agents, service providers, and consultants will contractually guarantee that they will use the personal information disclosed to them solely to provide specific services and that they will respect its confidential nature in accordance with this Policy.
Where applicable, you understand that your employer may have access to certain information you add to the Altee platform.

Altee may also, without your consent, disclose your personal information when authorized or required by law, for example, to prevent fraud or a risk of serious physical harm to any person. Whenever Altee must disclose personal information about you, it will endeavor not to disclose more information than is required under the circumstances.

10. Disclosure of Your Personal Information Outside the Province Where You Usually Reside

Altee may occasionally disclose your information outside the province where you usually reside (to another province or outside Canada) as part of the execution of a service contract or business contract, for example, for data hosting or processing. If applicable, we will take all measures to ensure that the third-party service provider will protect your personal information with the same protection standards as those in force at Altee and that your personal information will not be used for purposes other than those authorized by the collection or by law. If we disclose sensitive personal information about you outside Canada, we will obtain your express consent. You have the right to know, upon request, to whom your personal information is disclosed and the circumstances that led to its disclosure, and you will find the contact information for the person to make such a request in Section 15 of the Policy.

11. Cookies

Your use of the Web Services allows Altee to automatically compile certain information about your user profile, which may include your computer's Internet Protocol address (or IP address), your geolocation area, the operating system you use, the identity of your Internet service provider, the date and time you accessed this website, the previous website you visited that provided a link to our website, as well as the content viewed and downloaded on our site.
To do this, our website, like most websites, uses cookies, which are small data files that are stored on your computer when you visit it. Altee and its service providers use this information to tailor the website to your preferences and to compile statistics about the consultation and use of its website to improve it.
As with most Internet browsers, it is possible to delete cookies from your computer's hard drive, block the creation of cookies, or receive a warning before a cookie is stored. However, doing so may affect your use of our Web Services, and you may no longer have access to all its functions. We invite you to consult the Ads Setting and Network Advertising Initiative websites, as well as your browser's instructions or help section for more information on cookies.

12. Security Measures

Altee has implemented a series of security measures aimed at protecting your personal information against loss or theft, as well as unauthorized access, disclosure, reproduction, use, and modification, taking into account, in particular, its sensitivity and the purposes for which it is used.
These security measures include:

• physical measures (for example, employee office access cards, visitor registration, data backup and archiving using an external system, etc.);
• administrative or organizational measures (for example, restricting access to what is strictly necessary, restricting modifications based on the principle of least privilege);
• and technological measures (such as depersonalization of your personal information, use of passwords, use of a firewall, data encryption, use of the SSL protocol, etc.) that are reasonable given the sensitivity of the information, its use, quantity, distribution, and medium.

Altee also takes the necessary steps to ensure that all its employees are informed about the content of the Policy and educated on personal information protection practices.
However, as no mechanism offers flawless security, some risk is always present. It is also your responsibility, if you create an account on our Web Services, to protect the confidentiality of your password and to change it regularly.
If a personal information security incident occurs, Altee will disclose, when required by law, to the Commission d'accès à l'information du Québec, the Office of the Privacy Commissioner of Canada, and the affected individuals the occurrence of such an incident and will take measures to mitigate the impacts of this security incident on the affected individuals. Altee will also investigate the security incident and adopt methods to reduce the risk of a similar or identical security incident occurring again. Altee maintains a register of all security incidents related to personal information and, upon request and when required by law, will communicate this register to the competent personal information protection authorities.

13. Accuracy

Altee recognizes the importance of personal information being accurate, complete, and up-to-date, and takes reasonable steps to ensure the accuracy and completeness of the information it uses or discloses. However, it is your responsibility to inform Altee of any significant changes to your personal information that may occur and to ensure that all personal information in your account is accurate.
It is also your responsibility to ensure that your information is up-to-date with your employer, considering that much of the personal information about you residing on the Altee platform may have been added and maintained by your employer.
Altee retains your personal information only for the period necessary to fulfill the purpose for which it was collected, to meet legal retention requirements, and for the period necessary to protect its legitimate business interests.

14. Processing of Personal Information of Individuals Located in the European Economic Area (EEA) and/or the EU

Altee complies with the provisions of the GDPR, where applicable. Section 14 of the Policy applies exclusively to the processing of personal information in connection with the EEA and the EU, insofar as such processing takes place while the data subjects are located in the EU or the EEA and when the processing activities are related to the offering of goods or services or the monitoring of their behaviour, insofar as such behaviour takes place within the EEA or the EU. In case of conflict between this Section 14 and the rest of the policy, the provisions of this section shall take precedence, only when the processing takes place while the data subjects are located in the EU or the EEA and when the processing activities are related to the offering of goods or services or the monitoring of their behaviour, insofar as such behaviour takes place within the EEA or the EU.

14.1 Consent

If your consent is provided in a written declaration that addresses other matters, Altee will ensure that the request for consent regarding the processing of your personal information is clearly distinct.

14.2 Collection, Retention, and Use of Personal Information

Altee will not retain personal information longer than necessary to fulfill the purposes for which it was collected, and Altee will take reasonable steps to make known in advance the period during which this personal information may be retained or the criteria used to determine this period.

14.3 Automated Individual Decision-Making

Altee acknowledges that you have the right to know if your personal information is processed by an automated decision-making system. Upon request, Altee will provide you with information on how this automated system operates. Unless required or authorized by law, you have the right to refuse that a decision based solely on an automated system be made concerning you, when this decision has legal consequences for you.

14.4 Privacy Impact Assessment

Altee will conduct a privacy impact assessment before implementing new technologies that are highly likely to affect your rights and freedoms, including your right to privacy.

14.5 Right to Erasure

Where provided by law, you have the right to request that Altee withdraw and erase personal information without undue delay.

14.6 Accuracy and Protection

Before collecting personal information, Altee will implement appropriate technical and organizational measures to ensure its protection. Altee will only share personal information with agents, representatives, consultants, data processing companies, or external service providers when they assure that appropriate measures have been put in place to protect personal information.

14.7 Accountability

Altee acknowledges its responsibility for protecting personal information and its ability to demonstrate compliance with the GDPR when processing personal information.

14.8 Complaint Procedure, Right of Access or Rectification

Altee takes all necessary measures to facilitate the exercise of your right to access, rectify, or obtain your personal information. You can always obtain confirmation from us that personal information is being processed. Any rectification or erasure of your personal information will be communicated to third parties to whom this information has been disclosed.

15. Access and Rectification Requests

All questions or concerns regarding the Policy or the collection, use, or disclosure of your personal information, including requests for access or rectification, must be submitted in writing and addressed to the following contact person:
Charles Ceelen-Brasseur Privacy Officer legal@altee.com
You have the right to request to consult and access the personal information Altee holds about you. You also have the right to obtain confirmation that we hold personal information about you. We will provide your personal information, when collected electronically, in a structured and commonly used technological format. You may also request that your personal information be rectified if it is inaccurate, incomplete, or ambiguous, or if its collection, disclosure, or retention is not authorized by law.
Altee will respond to any access or rectification request within 30 days of receiving the written request. If we refuse to provide or correct the information, Altee will provide you with the reasons for its refusal and the applicable legal provisions supporting its refusal, subject to the restrictions provided by law, and will inform you of your recourses.
If Altee refuses to rectify your personal information, we will allow you to add written comments to your file regarding the personal information that was the subject of the refusal to rectify. Altee will also retain personal information that has been the subject of an access request for as long as necessary to allow you to exhaust the remedies provided by law.
For more information on the protection of your personal information and your rights, you may contact the enforcement authorities:

• In Canada: Office of the Privacy Commissioner of Canada www.priv.gc.ca
• In the European Union: National Commission for Data Protection and Liberties www.cnil.fr
  Policy updated April 28, 2023.-