Q9 Networks

Privacy

Q9 NETWORKS INC.

PRIVACY POLICY
Your privacy is important to us.  Q9 Networks Inc. (“Q9”, “us”, “we”) is committed to maintaining the accuracy, security and privacy of the personal information it collects, uses and discloses in accordance with applicable legislation.  This privacy policy (the “Privacy Policy”) is a statement of principles and guidelines concerning the protection of personal information of our customers, suppliers and other individuals (“you”).

CONSENT
BY SUBMITTING PERSONAL INFORMATION TO Q9 OR ITS AGENTS, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, THE PRIVACY PREFERENCES YOU HAVE MADE KNOWN TO US AND AS PERMITTED OR REQUIRED BY LAW.
Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting us as set forth below.  If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information that may be of value to you.

What personal information do we collect?
Canadian privacy legislation defines personal information broadly as information about an “identifiable individual” or as information that allows an individual to be identified.  The types of personal information that we may collect from you from time to time include:

  • For representatives of our customers and visitors of our facilities: your name, address, telephone numbers, email addresses, government issued identification, ID check, biometric information, video and photo images and your photograph for access card purposes.
  • We do not collect, access or process any personal information that is stored by our customers in our data centres.

Why do we collect your personal information?
We collect your personal information for the purposes listed below:

  • For Representatives of Customers and Visitor
  • If you are a representative of our customers or a visitor of our facilities, we use your personal information for the following purposes: (i) identification, (ii) administration of access to our facilities, (iii) security and protection of our operations, and (iv) audits.
  • Other purposes

In addition, from time to time, we may use your personal information for the following purposes:

  • For the evaluation of the management and performance of our business, including audit compliance with our policies and  the performance of our contractual obligations;
  • To understand and respond to our customers and third party needs and preferences;
  • To meet legal and regulatory requirements; and
  • For any other purpose we may indicate to you from time to time.

To whom do we disclose your personal information?
In order to fulfill any of the purposes set forth in section 2 above, we may disclose your personal information to third parties in the following circumstances:

Disclosure in Business Transfers
We may be involved in the sale or transfer of some or all of our business. As part of that sale or transfer, we may disclose your personal information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.

Law Enforcement and Legal Disclosure
We may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to our legal counsel.

Where is your personal information stored?
Your personal information is stored in secured locations and on servers controlled by us, located solely within our offices and data centres within Canada. For access to your personal information, please contact our Privacy Officer (see “Contact Us” below).

In some cases we may use Salesforce to manage certain contact information. Salesforce is a cloud-based CRM solution that is certified to the TRUSTe privacy program and the US-EU Safe Harbour framework. Salesforce’s data centres may reside in the United States. For more information please see Salesforce’s privacy policy.

How can you access your personal information?
Upon written request, subject to certain exceptions, we will inform you of the existence, use, and disclosure of your personal information and will give you access to that information.  We keep your information for the time we are providing you with a service, and for a reasonable time thereafter.  Access requests should be sent to our Privacy Officer, using the contact information in the “Contact Us” section below.

How do we protect your personal information?
We make commercially reasonable efforts to protect against the loss, misuse, and alteration of personal information under our control. Our security policies are periodically reviewed and enhanced as necessary.

We employ administrative, contractual and technological safeguards to protect your information.  For example, only authorized employees and suppliers have access to personal information of representatives of our customers and visitors of our facilities. Where information is sent to a third party for processing, we make sure, through our contracts with them, that such service providers may only use the information for the limited purposes for which it was disclosed and are required to keep the information secure.  Moreover, we operate secure data networks protected by industry standard firewall and password protection systems.

Privacy and our Website
We may collect personal information through our website and online communications. In this section, we provide you with additional information regarding such collection.

Cookies
When an individual visitor accesses our website, we may use a browser feature called a ‘cookie’ to collect website information, user preferences and user data such as the type of Internet browser and operating system the visitor uses, the domain name of the website from which the visitor came and which the visitor visits after visiting our website, date and duration of the visit, number of visits, average time spent on our website and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from our website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of our website and to facilitate usage by a visitor.  This information may also be used to provide visitors with tailored marketing and help third parties improve their own products and services.  Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.

Online Communications
In order to provide our website visitors with a service or information, visitors may voluntarily submit personal information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, participating in a seminar or other event, and participating in contests and surveys. If you are known to us as a registered user of an online service, we may combine and store personal information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.

Links
Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than us, and that we have no responsibility for such third party websites.

Changes to the Privacy Policy
We reserve the right to modify or supplement this Privacy Policy at any time.  If we make a change to this Privacy Policy, we will notify you by publishing the revised policy on our website at https://www.q9.com/legal.  In addition, we will make the revised policy and changes available upon request to the Q9 Privacy Officer. However, we will obtain the necessary consents required under applicable Privacy Laws if we seek to collect, use or disclose an individual’s personal information for purposes other than those to which consent is obtained unless otherwise required or permitted by law.

Contact Us
Q9 has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable Privacy Laws.  For information on Q9’s privacy practices, please contact the Q9 Privacy Officer at:

Q9 Networks Inc.
c/o Privacy Officer
Suite 1100, PO Box 235
100 Wellington Street West
Toronto, Ontario
M5K 1J3
privacy@q9.com