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Introduction
Megalexis Communications Inc. (Megalexis) is committed to preserving the integrity, security and privacy of Personal Information in accordance with applicable legislation. This Privacy Policy outlines the principles and guidelines concerning the protection of Personal Information of our clients, service providers, employees, and other individuals. It also describes the types of Personal Information that Megalexis collects, uses and discloses, and the principles we follow concerning the collection, use and disclosure of such information.
1. Personal Information
"Personal Information" is information about an identifiable individual or information that allows an individual to be identified. This includes, but is not limited to, your mailing address, telephone number, email address, Internet Protocol (“IP”) address, age, gender, marital status, health information and credit card information.
Your business title, business address, business e-mail address or business telephone number in your capacity as a professional, officer of a corporation, or employee of an organization, are not considered Personal Information under Canadian and Québec legislation.
2. Consent
By submitting Personal Information to Megalexis, whether via our website or secure portal, by email, in person, or over the phone, you explicitly agree that we may collect, use and disclose such information in accordance with this Privacy Policy and as permitted or required by law.
Where consent has not already been provided, we will use our best efforts to obtain explicit consent for any action that involves Personal Information.
You may at any time refuse or withdraw your consent by contacting Megalexis. However, should you refuse or withdraw your consent, Megalexis may not be able to provide you, or continue to provide you, with information or services which may be of value to you.
When you provide Megalexis with Personal Information of another individual, you represent that you have the authority and have obtained express consent from such individual.
3. Collection and Use of Personal Information
Megalexis will only collect the Personal Information that we require in order to render professional language services, and about our prospective and current service providers, as well as individual applicants for employment with Megalexis for the purposes of evaluating their application and deciding whether to establish business, contractual or employment relationships. We may also collect Personal Information for sales and marketing purposes.
Privacy is not only important to us in the context of our relationships with clients, but it is also a legal requirement. We therefore manage all information, especially Personal Information, in accordance with the highest standards and the applicable legal and regulatory framework.
4. Protection of Personal Information
Megalexis employs administrative protocols and technological safeguards to control and restrict user access and enforce authentication controls to preserve the confidentiality of your Personal Information. Multifactor authentication is enabled across all platforms we use.
Where the need arises to share Personal Information with a third party, we ensure, through our contracts with them, that all Personal Information is kept private and secure. We also operate secure data networks protected by firewall and password protection systems.
No method of transmission of information over the Internet, or method of electronic storage, is 100% secure. Therefore, notwithstanding our best efforts, we cannot ensure or warrant the security of any information you transmit or provide to us, and you do so at your own risk.
We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any safeguards we have in place. If you believe personal information has been compromised, please contact us.
5. Threat Monitoring Protocols
We have monitoring protocols in place to detect attempts to compromise the security or integrity of our information or information technology systems, including malware detection software within our network environment, as well as on systems that are at risk for infection.
6. Cookies, Log Files and Web Beacons
Megalexis does not generally record or collect cookies, except in the case of website visitors using their browsers to autofill forms with personal data that is cached.
7. Links to Third-Party Websites
Our website may contain links to other websites which are provided for convenience only. Visitors are advised that third-party websites may have privacy policies and practices different from Megalexis’, and that Megalexis has neither control over, nor does it assume responsibility for the protection of Personal Information collected, used, or kept by such third-party websites.
8. Disclosure of Personal Information
Megalexis will only disclose Personal Information with your express consent to such persons that require it for the purpose of providing you with professional language services. Megalexis will identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your express consent to such disclosure.
9. Storage of Personal Information
Personal Information provided to us is stored on servers in Canada. However, except where restricted by contractual arrangements or legal requirements applicable to specific clients, Megalexis may also employ the services of select service providers. Personal Information not subject to such restrictions that is "in the cloud" may be stored on multiple servers in several locations around the world. Information transmitted to other countries may be subject to the laws and lawful disclosure requirements of the jurisdiction(s) where the information is stored.
10. Cross Border Transfers
Megalexis only carries on business and contracts services with entities and individuals based in jurisdictions with a strong rule of law. In the exceptional cases when Personal Information is stored and processed in any country other than Canada where we engage third-party service providers, we will request your consent to the transfer of information to such country, which may have a legal and regulatory framework for data and Personal Information different than Canada's.
11. Retention of Personal Information
Megalexis will keep your Personal Information for as long as necessary to fulfill the purposes for which it was collected, or as permitted or required by law.
12. Secure Disposal of Personal Information
Megalexis will dispose of your Personal Information securely and irreversibly, so that it cannot be reconstructed or recovered in any way. Our disposal protocols include all associated physical and electronic copies as well as backup files.
13. Accuracy of Personal Information
Megalexis will make every reasonable effort to ensure that the Personal Information we collect and use is accurate and complete.
14. Right to Access and Rectification
Individuals providing Personal Information to Megalexis will have the opportunity to access such information, and on written request by the owner of such information, make changes to rectify it when inaccurate, incomplete or equivocal.
15. Data Portability
Individuals providing Personal Information to Megalexis can request and receive a copy of such information in a structured way, and in a commonly used format, except when such a request raises serious and practical difficulties for our company.
16. Privacy Impact Assessments
Megalexis conducts Privacy Impact Assessments (PIA) if an activity is anticipated to possibly have an impact on the Personal Information of individuals, and promptly communicates relevant information to the affected individuals.
17. Complaints and Requests Concerning Personal Information
Megalexis has designated a Person in Charge of Personal Information (“PCPI”) within the company. Our PCPI will handle complaints and requests concerning Personal Information in accordance with the timelines and requirements prescribed by the applicable legal and regulatory framework.
18. Privacy Incident Reporting
In case of a breach or major attempt to breach the privacy of Personal Information we hold, Megalexis will notify the affected parties without delay, and provide sufficient information to enable them to determine whether the incident presents a risk of serious injury to trigger official notification requirements to government authorities.
Megalexis will document the incident and take prompt and reasonable measures to reduce the risk of injury, and to prevent new incidents of the same nature from reoccurring.
Megalexis will also comply with the legal requirement to report the incident to the competent government authorities as applicable.
19. Cyber Security Incident Management
The Privacy Incidents referred to in the previous paragraph may arise as a result of a cyber security incident, i.e., a breach or major attempt to breach the security of our information technology equipment and systems.
In case of a cyber security incident, Megalexis will notify the affected parties without delay, and provide sufficient information to enable them to assess the risk to trigger official notification requirements to government authorities.
Megalexis will document the incident, including the facts surrounding an intrusion, infection, or system compromise, as well as the circumstances that led to the discovery of the incident, actions taken, names of persons involved in investigating the incident, detailed notes about the incident, damage inflicted to what hardware, software and information.
Megalexis will take prompt and reasonable measures to mitigate risk, and to prevent new incidents of the same nature from reoccurring. Megalexis will also promptly notify the competent government authorities, as required under the applicable legal and regulatory framework.
20. Training and Awareness
Megalexis has cyber and information security training in place to ensure that all users of information understand how to protect the company's information technology assets, including information and information resources and comply with our cyber security policy.
Megalexis provides cyber and information security training as part of new employee onboarding. We also hold monthly email phishing awareness and exercise campaigns involving all active users, with follow-up training as required.
21. Changes to this Policy
Megalexis may change this Policy, our website and how we use cookies from time to time in the future. We therefore encourage you to this Policy from time to time to stay informed of how we are processing Personal Information.
22. Person in Charge of Personal Information (PCPI)
Megalexis has appointed Michel Frégeau as the Person in Charge of Personal Information (“PCPI”) within the company. He can be contacted via email at privacy@megalexis.com, telephone (514) 861-4999, extension 2560, or by mail addressed to our office:
Megalexis Communications Inc.
c/o PCPI and Privacy Officer
666 Sherbrooke Street West, Suite 602
Montreal, Quebec H3A 1E7