Direct B2B Privacy Policy

Privacy Policy

Groupe Accès Direct Marketing Inc.

Last updated on September 20, 2023

Groupe Accès Direct Marketing Inc. (“DIRECT B2B,” “our,” “we,” or “us”), a company specializing in direct marketing, is committed to respecting your privacy and safeguarding your personal information.

This Privacy Policy and Personal Data Protection Policy (the “Policy”) explains our practices regarding the protection of personal information, the types of personal information we may receive or collect from you, and how we use, disclose, retain, and protect it (collectively referred to as “Processing” or “Process,” including all conjugated forms). To provide quality services, we need to access certain personal information about you. Our employees handle this information with the utmost discretion, obligations, and necessary diligence.

1. About This Policy

This Policy describes why and how we process your personal information when you visit our website https://www.directb2b.ca/ (the “Site”). This Policy also explains why and how we process your personal information when you use our websites and applications, including social media pages and electronic messages (the “Services,” “Site”). It further informs you of your rights regarding your approval of our use of your personal information.

2. Definitions

The following definitions clarify the meanings, regardless of conjugation. Words with an initial capital letter have these specified meanings:

Personal Information: Any information related to an identifiable person, including information that can be used alone or with other information to identify, contact, or locate a single person. Examples of personal information include:

Identifiers, such as a real name, alias, mailing address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Information such as a signature, physical characteristics or description, phone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information.
Characteristics of protected classifications under applicable law.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchase or consumption histories or tendencies.
Biometric information.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
Geolocation data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Education information, defined as information not publicly available personally identifiable information.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
“Personal Data” does not include publicly available information. “Publicly available” means information legally made available by the individual or from federal, state, or local government records, or any associated conditions.
Account: A unique account created for you to access our service or portions of our service.

Affiliate: An entity that controls, is controlled by, or is under common control with a party, with “control” meaning ownership of 50% or more of shares, interests, or other securities giving the right to vote for election of directors or other management authorities.

Company (“DIRECT B2B,” “our,” “we,” “us,” “Company,” or “Corporation”): Refers to Groupe Accès Direct Marketing Inc. For the purposes of this Policy and GDPR standards, the company is the data controller.

Cookies: Unique identifiers transferred to your device to allow our systems to recognize your device and personalize it.

Country: Refers to Quebec, Canada.

Data Controller: For GDPR purposes, refers to the company as a legal person that determines the purposes and means of processing personal data, alone or jointly with others.

Device: Any device that can access the Services, such as a computer, mobile phone, or digital tablet.

GDPR: Refers to the European Union General Data Protection Regulation.

Service: Refers to the website or any service provided by DIRECT B2B.

Service Provider: Any natural or legal person who processes data on behalf of the Company. These are third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used. For GDPR purposes, service providers are considered data processors.

Usage Data: Data collected automatically, generated by the use of the service or from the service infrastructure itself (e.g., the duration of a page visit).

Site: Refers to https://www.directb2b.ca/ or any site under the domain directb2b.ca.

You: The person accessing or using the Service, or the company or other legal entity on whose behalf such person is accessing or using the Service, as applicable. Under GDPR, you may be referred to as the data subject or as the user, as you are the person using the service.

3. What Personal Information Do We Collect?
The personal information we collect when you use our Services may include, but is not limited to:

Contact details such as first name, last name, email address, or phone number.
Login information, such as a username and/or password.
Employment-related information, such as your resume, areas of expertise, and years of experience, when applying for a job.
The type of employment you are seeking (Regular, Temporary, Summer Employment, Internship, etc.) when applying for a position.
Any other personal information provided.
Additionally, we collect information related to platform, mobile application, or website usage, including technical information on visits or other data collected through cookies or similar tools. This information may include:

Number of visits
Conversion rate
Average visit duration
Actions taken on the Platform or Site
Pages viewed during the visit
Device type used during the visit
Web browser used during the visit
IP address used during the visit
Visit date and time
Visitor sources, such as the webpage visited before being redirected to the Platform or Site, etc.
Other diagnostic data.
4. Why Do We Collect and Use Your Personal Information?
Personal information collected when you use our Services will be used for the following purposes:

Establish and manage our relationship with you.
Enable you to apply for a job and manage your application.
Provide and maintain our Site.
Respond to your information requests.
Fulfill any contract we have with you, such as a DIRECT B2B partnership agreement.
Provide and maintain the Services, improve and develop new Services.
Facilitate, personalize, and improve your online experience.
Test and improve the performance of the Services.
Communicate with you about products, services, promotions, and events we think may interest you, with prior consent.
For our business purposes, such as data and trend analysis, audits, fraud prevention, and business expansion.
Monitor and keep records of our communications with you and our staff.
Conduct market research and create statistical analyses.
Enable business development and marketing to inform you about new offers, with prior consent.
As permitted or required to comply with any applicable legal or regulatory obligation.
These purposes are collectively referred to as the “Purposes.”

5. How Do We Collect Your Personal Information?

DIRECT B2B primarily collects your personal information directly from you.

5.1. Directly from You
In general, we collect the personal information we need directly from you, such as when you visit or browse our Site, use our tools, or communicate with us.

Information You Provide to Us: We collect personal information that you provide directly through our services. For example, personal data is collected when you use or register for the services, subscribe to notifications, post on the Services, participate in promotional activities, apply for a job, communicate with us through the Services, or use an application. De-identified Data: Once personal information has been “de-identified,” it may not be subject to this Privacy Policy. We and our service providers (defined below) may treat such de-identified information as non-personal information and use it without obligation to you, unless prohibited by applicable law.

Information We Collect Automatically When You Use the Services: We and our service providers collect information about the services you use and how you use them. This information includes IP addresses, device types, advertising identifiers, and information about your use of the services (“Usage Information”). If usage information qualifies as personal data under applicable law or is combined with personal data, we will treat it as such under this Privacy Policy.

Information Collected from Other Sources: We may also receive personal information from other sources, such as public databases, fraud prevention agencies, credit reference agencies, lenders, joint marketing partners, and social media platforms, which we combine with information we collect about you. If we combine third-party information with personal data collected directly from you, we will treat the combined information as personal data. We are not responsible for the accuracy of information obtained from third parties or their practices.

5.2. With Your Consent
The legal basis for processing your personal information is your consent, unless applicable law provides for another permissible legal basis (e.g., to comply with our legal obligations, when necessary to establish, exercise, or defend a legal claim or legal proceeding).

5.3. Refusal of Collection and Withdrawal of Consent
You have the right to refuse the processing of your personal information if you wish. You may also withdraw your consent (where applicable) to our processing of your personal information at any time, subject to reasonable notice and applicable legal or contractual restrictions, by contacting us. However, be aware that choosing not to provide personal information may prevent you from using certain features of our Site, as this information may be essential for its proper functioning. For requests in this regard, please use the contact information provided in the “Contact Us” section of this Policy.

6. With Whom Do We Share Your Personal Information?

DIRECT B2B does not rent or sell your personal information to third parties and will not share it with third parties without your consent unless required by law or necessary for the purposes outlined above. Your information is processed at the Company’s offices and at any other location where parties involved in the processing are located. This means that your information may be transferred to and stored on computers located outside your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to such transfers.

The Company will take all reasonably necessary measures to ensure that your data is treated securely and in accordance with this Privacy Policy and that no transfer of your personal data to an organization or country will occur unless there are adequate controls in place, including the security of your data and other personal information.

6.1. With Our Employees
Our employees may need access to your personal information as part of their job duties, such as when you contact us, submit an application, or request technical support on our Site. Their access is limited to what is necessary to perform their duties.

6.2. With Our Service Providers
We may share your personal information with our agents, vendors, consultants, marketing service providers, and other service providers (collectively, “Service Providers”) to facilitate their work on our behalf. These Service Providers are prohibited from using your personal data for purposes other than providing this assistance, although we may permit them to use de-identified or aggregated data that does not personally identify you or any other users of the Services.

6.3. With Our Affiliates
For business purposes, such as processing orders, fulfilling requests, customer service, and product improvement. In this case, we require these affiliates to comply with this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies we control or are under common control with us.

6.4. When Required by Applicable Laws
DIRECT B2B may also share your personal information if required by law or if it believes in good faith that such action is necessary to: (i) comply with the law; (ii) comply with a court order from a competent authority, regardless of jurisdiction; (iii) comply with any legal process served on DIRECT B2B; (iv) protect and defend the rights or property of DIRECT B2B; (v) enforce or verify your compliance with any agreements with DIRECT B2B if applicable; (vi) prevent fraud or other illegal activity conducted through our Site; or (vii) act in urgent circumstances to protect the personal safety of the public.

6.5. In the Event of a Business Transfer
We may share your personal information without your consent when required by our business operations (e.g., in the case of a merger, acquisition, bankruptcy, or sale of assets).

In such circumstances, we may also share all or part of your personal information with the relevant third party (or their advisors) for due diligence purposes.

6.6. For Other Purposes, With Your Consent
With your express consent, your personal information may be shared with other third parties. For example, there may be specific instances where additional terms apply, and we clearly indicate through those terms that specific third parties are processing your personal information.

7. How Long Do We Retain Your Personal Information?
When you use our Services or submit an application, we retain your personal information only as long as necessary to achieve the purposes for which it was collected or to comply with applicable legislative, tax, or regulatory requirements. Personal information held by DIRECT B2B and obtained from our Services will then be destroyed, deleted, or anonymized. If you would like more information about this, please contact us using the information provided in the “Contact Us” section.

8. How Do We Protect Your Personal Information?

8.1. With Necessary and Appropriate Security Measures
DIRECT B2B has implemented security measures to protect your personal information. The security measures we employ depend on the type of information collected. DIRECT B2B uses current physical, electronic, and procedural safeguards to protect your personal information. We adopt security measures to guard against unauthorized access, modification, disclosure, or destruction of your personal data and transaction information.

The security of your personal data is important to us, but remember that no transmission method over the Internet or electronic storage is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

8.2. Children’s Privacy
Our Site is designed for individuals over the age of 13. DIRECT B2B does not knowingly process the personal information of children under 13. If you believe that personal information has been collected from children under 13, or if you are a parent or legal guardian and believe that your child under 13 has provided us with personal information, you may contact us as indicated in the “Contact Us” section.

9.2. Analytics
We may use third-party service providers to monitor and analyze the use of our service. In some cases, we may use these services as follows:

To perform analytics on our Site’s audience, we use tools such as Cloudflare Web Analytics. This solution does not rely on any client-side state (such as “cookies” or “localStorage,” for example) to collect usage statistics. Cloudflare may collect analytics data related to our Site through a JavaScript tag or at Cloudflare’s edge servers. For more details on the technologies used for our Site’s analytics, please visit: Cloudflare Web Analytics.

Google Analytics is a web analytics service provided by Google that allows us to track and report website traffic. Google uses the data collected to track and monitor the use of our service, and this data may be shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can prevent your activity on the Service from being available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activities.

For more information on Google’s privacy practices, please visit Google Privacy & Terms.

 

9.3. Email Marketing
We may use your personal data to send you newsletters, marketing materials, or other promotional information that may interest you. You can opt out of receiving any or all of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.

We may use third-party service providers to manage and send emails. We also use automated email services such as:

HubSpot and its affiliated companies are committed to protecting your privacy. Their privacy policy applies to the information and personal data collected by HubSpot when you interact with their websites, products, and services, as well as any other website or service related to this privacy policy. This includes:

Interacting with us on our websites or via other channels (e.g., by communicating with us or attending one of our events);
Using our products and services (including the HubSpot subscription service);
Using other websites or services linked to this privacy policy (e.g., our other brands like Hustle, Trends, and Connect.com).
For more information on their policy: https://legal.hubspot.com/privacy-policy.

10. WHERE IS YOUR PERSONAL INFORMATION HOSTED AND TRANSFERRED?

Your Personal Information may be hosted by DIRECT B2B in locations other than your province, territory, state or country of residence, including in Canada (including in the province of Quebec). DIRECT B2B may also subcontract Processing or share your Personal Information with third parties located elsewhere, including in locations other than your province, territory, state or country of residence. In this case, DIRECT B2B will ensure that your Personal Information is adequately protected by technical, organizational, contractual or other appropriate legal means. If you would like further information about these security measures, please contact DIRECT B2B as indicated in the “Contact Us” section.

11. WHAT ARE YOUR RIGHTS?  

Depending on applicable laws, you may have the following rights with respect to your personal information:

• Right of access: you can obtain information regarding the processing of your Personal Information as well as a copy of this Information.
• Right to rectification: if you believe that your Personal Information is inaccurate or incomplete, you may request that this Personal Information be modified or corrected accordingly.
• Right to withdraw your consent: you can withdraw your consent to the processing of your Personal Information.
• Right to portability of your data: when you have given your consent to the use of Personal Information, you have the right to have this information transmitted directly to another data controller if this is technically possible or, in Quebec, to receive a copy of all Personal Information that DIRECT B2B has about you in a structured, commonly used and machine-readable format.

To exercise these rights, we invite you to communicate in writing with our Personal Information Protection Officer as indicated in the “Contact Us” section below. We will process your requests in accordance with applicable law.

When we receive personal information about you from customers or third parties, we encourage you to contact them directly (for example, your employer or service provider) if you have any questions about how they manage your personal information.

12. LINKS TO THIRD PARTY WEBSITES 

It is important to understand that this Policy does not apply to other third-party websites that may be accessed from links on our Site. We are in no way responsible for these third party sites, their content or their access. Consequently, any Personal Information that you transmit through these sites is subject to their privacy policies. It is your responsibility to read it in order to ensure the protection of your Personal Information.

13. GDPR PRIVACY

13.1. Legal basis for processing personal data under the GDPR

We may process personal data under the following conditions:

• Consent: You have given your consent to the processing of personal data for one or more specific purposes.
• Performance of a contract: the provision of personal data is necessary for the performance of a contract with you and/or any pre-contractual obligations relating thereto.
• Legal obligations: The processing of personal data is necessary to comply with a legal obligation to which the company is subject.
• Vital interests: The processing of personal data is necessary to protect your vital interests or those of another natural person.
• Public interests: The processing of personal data is related to a task carried out in the public interest or in the exercise of official authority vested in the company.
• Legitimate interests: The processing of personal data is necessary for the purposes of the legitimate interests pursued by the company.

In any case, the Company will be happy to help clarify the specific legal basis which applies to the processing, and in particular whether the provision of personal data is a legal or contractual requirement, or a requirement necessary to the conclusion of a contract.

 

13.2. Your rights under the GDPR

The Company undertakes to respect the confidentiality of your personal data and to guarantee you the exercise of your rights.

You have the right under this Privacy Policy and the law if you are in the EU to:

• Request access to your personal data. The right to access, update or delete information we hold about you. Where possible, you can access, update or request deletion of your personal data directly in the settings section of your account. If you are unable to perform these actions yourself, please contact us to assist you. This also allows you to receive a copy of the personal data we hold about you.

• Request correction of the personal data we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to the processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation which prompts you to object to the processing of your personal data for this purpose.
• Request erasure of your personal data. You have the right to ask us to erase or delete personal data where there is no good reason for us continuing to process it.
• Request the transfer of your personal data. We will provide you, or a third party chosen by you, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to automated information that you have initially consented to us using or where we have used that information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent to the use of your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific features of the Service.

13.3. Exercising your data protection rights under the GDPR

You can exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will do our best to respond to you as soon as possible.

You have the right to lodge a complaint with a data protection authority regarding our collection and use of your personal data. For further information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

14. POLICY CHANGES AND UPDATE

DIRECT B2B may, at its discretion, update, revise, modify or supplement this Policy from time to time. If a material change is made to the Policy, we will notify you by email and/or a prominent notice on our Service, prior to the change becoming effective, and we will update the date of the “last “updated” at the top of this privacy policy. DIRECT B2B asks its users to consult the modified Policy before continuing to use DIRECT B2B its services.

Continued use of the services provided by DIRECT B2B, after the modified Policy comes into force, corresponds to consent to this modified Policy.

15. HOW TO FILE A COMPLAINT?

DIRECT B2B has established procedures for receiving complaints and requests for information regarding its policies and practices for managing Personal Information. The company will inform persons who make an inquiry or complaint of the existence of relevant procedures. DIRECT B2B will investigate all complaints. If a complaint is found to be founded, the company will take appropriate action, including, if necessary, changing its policies and practices. If you wish to make a complaint, we invite you to contact us as indicated in the “Contact Us” section.

16. CONTACT US

For any other questions, requests for information, comments or complaints regarding your Personal Information, we invite you to contact our Personal Information Protection Officer by:

Email: privacy@directb2b.ca

Telephone: +514 990 9670

Our team makes it a point to communicate with you within a maximum of 30 working days following receipt of your communication.