Welcome!

Here are the key elements of this Policy so that you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your personal data. By submitting personal data to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy. 

Before we get started with the details, here are a few terms we think you should know as you read this Policy.

“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. Ubiweb Media is committed to adhering to all applicable Data Protection Laws, which include:

1. The “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; 
2. The “UK GDPR” which applies to our activities in the United Kingdom; please note that when this Policy refers only to the “GDPR”, this includes the UK GDPR, as applicable;
3. “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada; and
4. Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (the “Quebec Privacy Act”), as amended by Law 25, that applies to our activities in Quebec. 

“Personal data” – this is information that we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA, the Quebec Privacy Act and the CCPA, the equivalent concept is “personal information”, which is roughly the same. For example, the Quebec Privacy Act defines “personal information” as “any information which relates to a natural person and allows that person to be identified either directly or indirectly.” Any mention of “personal data” in this Policy will also mean personal information. 

Ubiweb Media Inc. (“Ubiweb Media”), which owns and operates the Website, is a Quebec corporation located in the province of Quebec, Canada, with an office at the address listed below. Where this Policy refers to “Ubiweb Media”, it may refer to Ubiweb Media and/or its affiliates, and their respective officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to Ubiweb Media. In this Policy, a Website visitor may be referred to as “you” or “your”. 

Under the GDPR, Ubiweb Media is generally a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.

Under the GDPR, Ubiweb Media is generally a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.

If you want to ask us anything about this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can contact:

Ubiweb Media Privacy and Data Protection Officer

privacy@ubiweb.ca 

or:

Ubiweb Media Privacy and Data Protection Officer 

800-2000 de l’Éclipse Street

Brossard, Québec, J4Z0S2

Canada

You have the following rights regarding your personal data held by Ubiweb Media, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting any prices or costs charged by Ubiweb Media, if any. Please note that exercising certain of these rights may affect your ability to access or benefit from certain parts of the Website. 

• The right to withdraw your consent for Ubiweb Media to process your personal data at any time;
• The right to have your personal data erased from Ubiweb Media’s records, and to have your name de-indexed if we link to any information about you (which we currently do not);
• The right to access your personal data and any relevant information around its processing and use; 
• The right to have a copy of your personal data given to you in an easy-to-read format so that you can transfer it to any data controller or data processor or other third party;
• The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
• The right to opt out of marketing communications we send you, at any time;
• The right to know whether Ubiweb Media shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy and Data Protection Officer if you need additional information or clarification;
• The right to demand that Ubiweb Media not sell your personal data. Please note that Ubiweb Media does not sell your personal data;
• The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law; and 
• The right to refuse any marketing or advertising targeted at you by Ubiweb Media.

If you wish to exercise any of these rights, please contact our Privacy and Data Protection Officer at the contact information above or refer to certain relevant sections further in this Policy.

Ubiweb Media limits the amount of personal data we collect to what is necessary and appropriate for the identified purposes. We will not use or disclose your personal data for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.

In the table below, please find all the personal data we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA and the Quebec Privacy Act, the legal basis is your informed consent, and by submitting this personal data you acknowledge having granted this consent to Ubiweb Media.

We do not collect any personal data about you from third parties, except to the extent that advertising and analytics identifiers are generated from third parties. Such identifiers may be considered personal data collected from third parties and you can find details about those further below in this Policy. 

We only share some of your personal data with third parties who are identified in the table below in this section, along with what they do with it. 

We will share personal data with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (2) we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person; (3) we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website infrastructure or the internet in general (such as voluminous spamming or denial of service attacks); or (4) we are required to under any applicable law.

We may also share personal data: (1) to a parent company, subsidiaries, joint ventures, or other companies under common control with Ubiweb Media (in which case we will require such entities to honour this Policy); (2) if Ubiweb Media merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case, we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).

Some of these third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area or the U.K., please see the “Transfer of Your Personal Data Outside of the European Economic Area” section further down in this Policy for more information, including on how we safeguard your personal data when this occurs. If you are in Quebec, please see the “Transfer of Your Personal Data Outside of Quebec” section further down in this Policy for information on how we safeguard your personal data when this occurs.

We will never share your personal data with other third parties, except under these circumstances. We do not sell or rent your personal data to any third party for direct marketing purposes or any other purpose. 

We do not collect any of what the Data Protection Laws consider sensitive personal information from you when you visit the Website, unless you voluntarily submit it to us, which we encourage you not to do. 

Ubiweb Media uses Gmail via the Google Workspace (the “Email Service Provider”) to manage our mailing list, to send out our newsletter and to help us send you emails in response to your inquiries. Personal data is transferred to the Email Service Provider in order to facilitate our email communications and for the emails to be sent out properly. Your email address is only used to send out emails; the Email Service Provider does not use this personal data for any other purpose and will not transfer or sell your personal data to any other third party. For more information, please refer to Google's Privacy Policy. 

You may unsubscribe from Ubiweb Media’s mailing list at any time by following the link at the bottom of our newsletter. Other types of emails, such as transactional, relational, and other emails related to our Services will not have an opt-out option as they include necessary information on the Services.

Ubiweb Media’s email practices are designed to be strictly compliant with anti-spam laws, including but not limited to the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23) and the American CAN-SPAM Act of 2003. If you believe you have received email in violation of these laws, please contact our Privacy and Data Protection Officer using the contact information further up in this Policy.

Ubiweb Media is continuously evaluating and modifying our use of various advertising networks, which may change from time to time. In this section you will find the advertising networks that Ubiweb Media currently uses and instructions for opting out of them. You may also opt out or decline such advertising by refusing or deleting the appropriate cookie, as described further in this Policy. We will always update this Policy if we use additional advertising networks. 

Generally, these ad networks work by delivering you advertisements that will be of particular interest to you when you use their websites, apps, or services, based on your browsing and activity history interacting with the Website. Certain advertising networks use your email address that you submit to us to match your profile in order to better target the advertising to your preferences, called email retargeting. 

The table blow identifies the advertising networks we currently use, as well as links and instructions on opting out. By visiting the Website or submitting your email address to us, you consent to our advertising to you in this manner, understanding that you can opt out any time, or refuse or delete the cookie (as described below) which will prevent such advertising.

Ubiweb Media automatically collects certain information using the “Third-Party Analytics Programs” Hubspot and Google Analytics to help us understand more about our Website visitors and how they use the Website, but none of this information identifies you personally, except via an alphanumeric string. For example, each time you visit the Website, we automatically collect (as applicable) your IP address, browser and computer or device type, access times, the web page from which you came, the web page(s) or content you access, and other related information. We use information collected in this manner only to better understand your needs and the needs of Website visitors in the aggregate. Ubiweb Media also makes use of information gathered for statistical purposes to keep track of the number of visits to the Website and the specific pages visited on the Website, with a view to introducing improvements to the Website. 

Your IP address and other relevant information we collect using the Third-Party Analytics Programs may be used in order to trace any fraudulent or criminal activity.

Ubiweb Media uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website. Cookies are small text files placed on your computer or device when you visit a website, in order to track use of the site and to improve the user experience by storing certain data on your computer. By visiting or using the Website, you agree to their use, but only if you explicitly consent to such use, according to the cookie banner presented to you when you visit the Website. 

Specifically, we use cookies and related technologies for the following functions:

• to facilitate online advertising, as described above in this Policy; 
• to provide general internal and user analytics and to conduct research to improve the content of the Website, and to monitor its performance using the Third-Party Analytics Programs, as described above in this Policy; 
• to track information about emails you receive, for example whether you opened it or clicked on any links in it; and
• to assist in identifying possible fraudulent activities.

Your browser can be set to refuse cookies or delete them after they have been accepted and stored. You can refer to your browser’s help section for instructions, but here are instructions for the most commonly used browsers and operating systems:

• Google Chrome
• Mozilla Firefox
• Microsoft Edge
• Opera
• Apple Safari
• iOS
• Android

You can also adjust your Ubiweb Media cookie settings at any time by clicking on the checkmark icon in the bottom right-hand corner of the Website. Clicking on that icon will also give you a full list of the cookies used on the Website and allow you to customize your cookie settings.

Please note that deleting or refusing cookies may reduce your user experience on the Website. Furthermore, deleting cookies may prevent certain functions from working at all. 

We have implemented strict technical and organizational procedures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost or used or accessed in any unauthorized way.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.

Ubiweb Media uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Ubiweb Media uses Amazon Web Services (AWS), a recognized leader in secure data, for hosting of the Website, and all related data, which has a robust security program that you can read about here. 

Finally, all information, including personal data, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for internet data transfer and transactions. You can use your browser to check Ubiweb Media’s valid SSL security certificates on the Website.

In addition to the measures to protect your personal data described in the previous section, we have drafted and implemented certain internal procedures and policies regarding personal data, including the following:

• A framework for the keeping and destruction of personal data, including where we may keep anonymized data;
• Defining and describing the roles and responsibilities of the members of Ubiweb Media personnel throughout the life cycle of the personal data; and
• A process for dealing with individual complaints and requests for personal data and exercising of an individual’s rights under Data Protection Laws.

For our European users, we endeavour to keep your personal data inside the EEA or the U.K. (as applicable). 

Certain of our data processors (and Ubiweb Media) are in other countries where your personal data may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:

• Canada. We transfer personal data to our operations in Canada, but Canada has been determined to have an “adequate level of protection” for your personal data under European data protection law. 
• The United States. Your personal data is only transferred to companies in the United States that: (1) have signed agreements with us or have informed us that they are GDPR-compliant; and (2) have concluded the Standard Contractual Clauses for the transfer of personal data outside the EEA and the U.K.

That’s it! You have the right, however, to refuse to have your data transferred outside the EEA or the U.K. Please contact our Privacy and Data Protection Officer to make that request. Please note that making this request may prevent you from being able to use certain portions of the Website.

For our Quebec Website visitors, we endeavour to keep your personal data in Quebec. However, certain of our third-party service providers are in other provinces or countries where your personal data may be transferred. When this happens, we do the following to safeguard your personal data:

1. We will perform what the Quebec Privacy Act calls an “Assessment of the privacy-related factors” (what is generally called a “Privacy Impact Assessment,” or “PIA”) prior to the personal data leaving Quebec. If the PIA does not meet our standards and the standards required by the Quebec Privacy Act, we will not transfer your personal data to such a service provider; and
2. If the PIA allows us to transfer the personal data to such a service provider outside Quebec, we will sign what is generally called a “Data Processing Agreement,” or DPA, with the service provider, which protects the person data transferred to them and limits their use of it to what we have contracted with them to do. This DPA will adhere to the requirements of the Quebec Privacy Act. 

If you are in the EEA or the U.K., under the GDPR, you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy and Data Protection Officer, or if you would like to make a complaint directly about Ubiweb Media’s data practices, we invite you to contact the supervisory authority in your country.

If you are in the U.K., you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF). If you are in France, you should contact the Commission Nationale de l'Informatique et des Libertés which is the supervisory authority there. Their contact information can be found here. 

The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here. 

If you are in Canada and you are not satisfied with the response received or the actions taken by our Privacy and Data Protection Officer, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website. If you are in Québec, you can make a complaint to the Commission d’accès à l’information, with the instructions for contacting them on their website.

Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. 

We may have to keep your data for a longer period of time to satisfy our requirements under any applicable law, including anti-spam laws, or to protect our legal interests. In some cases, where permitted by the Data Protection Laws, we may keep personal data that has been anonymized, for our legitimate business purposes. 

Ubiweb Media does not use any automated decision-making processes with regard to your personal data in providing the Website.

The Website (and our Services) are only intended for persons who have reached the age of majority in their respective jurisdictions.

The Data Protection Laws have various age limits as to the minimum age required for us to hold personal data about an individual. We do not knowingly collect any personal data from a child under those minimum ages. If we become aware that we have inadvertently received personal data from a person under the minimum ages through the Website, we will delete such information from our records.

The date at the top of this page indicates when this Policy was last updated. Because Data Protection Laws are constantly evolving, every now and then we will have to update this Policy. You can always find the most updated version at this URL. We will post a prominent notice on the Website if we make significant changes to the Policy.

Thanks for reading! Please keep your personal data safe; we promise to do the same. 

© Ubiweb Media Inc., 2023