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PRIVACY POLICY

AWAKENING TOUCH (“AWAKENING TOUCH”, “we”, “us” or “our”) is committed to respecting your privacy and protecting your personal information, which is why we have implemented a privacy program and appointed a Privacy Officer.

The purpose of this Privacy Policy (hereinafter the “Policy”) is to inform you of how AWAKENING TOUCH collects, uses, discloses, retains, shares and protects your personal information.

To provide you with quality services, we need to have access to certain personal information about you. We make sure that our employees manage this information with all the necessary discretion and diligence in compliance with the legal and regulatory requirements in force.

PERSONAL INFORMATION

We define “personal information” as any information about an identifiable individual, or that taken alone or combined with other data, allows an individual to be identified. Personal information does not include business contact information such as your name, title, business address or telephone number.

COLLECTION OF PERSONAL INFORMATION

During our interactions with you, whether it be while providing services or during our business activities, we must collect certain personal information about you. The personal information we collect is necessary to provide you with the requested services. This includes, but is not limited to:

  • Your contact information such as name, address, email, or phone number,
  • Identification and other background check information, such as a copy of a passport, driver’s licence, utility bill, proof of beneficial ownership or source of funds,
  • Information provided by or on behalf of our customers or information produced while providing our service that could be understood as personal information,
  • Billing information such as billing address, banking information or payment system data,
  • Marketing information and communication preferences such as comments, or survey responses,
  • Information related to the use of our website including technical information about visits or other information collected through cookies or similar tools,
  • Recruitment-related information such as resumes, information about your professional or academic background, or other information relevant to potential recruitment,
  • Historical information such as names of previous employers, job titles, digital content such as photos, videos, or audio files,
  • Any other personal information provided.

PURPOSES OF PERSONAL INFORMATION COLLECTION

AWAKENING TOUCH collects, uses, and discloses personal information for the purposes identified at the time of collection or as permitted or required by regulations. This includes, but is not limited to, the following purposes:

  • Establishing and managing relationships with our clients,
  • Providing legal and other services as well as for the conduct of our business,
  • Sharing personal information with third parties during our legal representation or services (adverse parties, interested parties, foreign lawyers or counsel, courts, experts, witnesses),
  • To establish commercial relationships with our clients, more precisely to manage billing, and client accounts, collect, and process payments, limit the risk of non-payment, and collect payments due,
  • Fulfilling legal, regulatory or risk management obligations towards our clients, including, due diligence with respect to a client, obtaining necessary information, detecting risks in terms of anti-corruption, and conflicts of interest,
  • Preventing fraud and/or conducting any background checks required by applicable laws or regulations,
  • To facilitate the use of our website and ensure its applicability, to monitor the use of our website, to answer questions submitted through our website,
  • To enable business development and marketing, more precisely to inform our current and future clients about our new services, to provide information on recent developments and to provide invitations to events with the prior consent of the person concerned,
  • To conduct development and research to ensure that we maintain the highest standard of security, to understand our clients’ requirements and to improve our service offer,
  • Recruit staff, process applications and evaluate the candidate’s profile in relation to the requirements of the position,
  • As permitted or required by any applicable legal or regulatory obligations or provisions,
  • Any other purpose to which you have consented.

LIMIT TO COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

AWAKENING TOUCH strives to limit the collection of personal information to what is strictly required to fulfill the purposes for which it is collected. Rest assured that we will not disclose or use your personal information for any other purpose unless you consent to such or as required by law.

In addition, as you will see in the Security Safeguards for Personal Information section, we limit access to your personal information only to those individuals who have the authority and need to access it for a specific purpose.

Please note that we do not voluntarily collect information from persons under the age of 16.

CONSENT

Generally, AWAKENING TOUCH will obtain the necessary personal information directly from you, with your consent, subject to the exceptions provided by law.

We may also collect personal information from third parties or from publicly available records as permitted by law or where we have obtained consent.

AWAKENING TOUCH will not collect, use, or disclose personal information without your consent unless it is authorized or required to do so by applicable regulations. For example, AWAKENING TOUCH may need to do so without your consent for the following reasons:

  • When we obtain personal information from a third party by our client while providing services,
  • For security, medical or legal reasons, where we are unable to obtain your consent,
  • For fraud detection, prevention, or law enforcement purposes, seeking consent would defeat the purpose of the procedure.

Please note that you have the right to refuse to provide us with personal information. You also have the right, subject to reasonable notice and applicable legal or contractual restrictions, to withdraw your consent regarding the use of your personal information already collected by contacting our Privacy Officer. The refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide you with some of our services.

AWAKENING TOUCH may also ask for your consent for secondary purposes, for example to invite you to an event or training sessions, to conduct market studies or to populate its databases. As mentioned above, we will ask for your consent in this regard. In addition, your consent for secondary purposes may be withdrawn at any time, without affecting the rendering of our services to you.

PERSONAL INFORMATION SHARING

To provide you with our services, we may share the personal information we collect with certain third parties.

During its activities, AWAKENING TOUCH may disclose your information to third parties, which includes but is not limited to:

  • Third parties in connection with our services,
  • Third-party service providers, including but not limited to services related to our website (hosting, security, etc.). The personal information provided is then limited to only the information required to enable them to carry out their services and these suppliers are obliged to maintain the confidentiality of this information,
  • Governmental public authorities and law enforcement agencies when required by applicable laws or when necessary for the rendering of our service.

AWAKENING TOUCH will never, by any means, sell or exchange your personal information for payment.

PERSONAL INFORMATION RETENTION

Personal information is retained for as long as necessary for the purposes set out in this Policy and to ensure that we comply with our legal, tax or regulatory obligations. After such time, any personal information held by AWAKENING TOUCH will be destroyed, deleted, or made anonymous.

In addition, and as mentioned in the previous section, your personal information may be kept in Canada or abroad. Of course, we ensure that we have the necessary security measures in place, as well as the relevant contractual agreements, to protect your personal information.

If you wish to learn more about how long we keep your personal information, we invite you to contact our Privacy Officer, whose contact information is provided below.

PRIVACY SAFEGUARDS

AWAKENING TOUCH has security measures in place to protect your personal information. We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the personal information in its possession. The standard security measures we use will depend on the type of information collected. In doing so, we follow generally accepted industry standards. The personal information we hold is therefore accessible only to persons who are qualified to have access to it and who consult it only when necessary in the performance of their duties.

Appropriate physical, technical, and/or administrative safeguards and security measures have been put in place and are maintained to prevent:

  • Any accidental or unlawful destruction,
  • Accidental loss,
  • Unauthorized disclosure,
  • Unauthorized modification,
  • Unauthorized access,
  • Any illegal treatment.

AWAKENING TOUCH will make its employees aware of the importance of maintaining the confidentiality of personal information, and care will be used in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the personal information. Moreover, we make sure that access to our offices and computer equipment is restricted, that our staff is trained and that our agents and suppliers of goods and services with access to personal information are required to sign confidentiality agreements and implement security measures deemed equivalent.

It should be noted, however, that no method of transmission over the Internet, nor any means of electronic storage is completely secure. Thus, we encourage you to be cautious when using the Internet.

If you believe that your personal information has been compromised, we invite you to contact us using the contact information listed in the “Contact Us” section of this Policy.

YOUR RIGHTS

Depending on applicable laws, you might have the right to obtain access to, rectification or erasure of your personal information, the right to withdraw your consent (if any), the right to be informed of a decision based exclusively on an automated processing automated decision (if any), the right not to be discriminated against, the right to restrict and to object to the use and processing of your personal information by AWAKENING TOUCH, or the right to data portability by, namely, receiving a copy of all personal information that AWAKENING TOUCH has about you in a structured, commonly used and machine-readable format.

To exercise any of these rights (to the extent available), please submit your request to us by writing to the Privacy Officer as set forth in the Section “Contact Us”. Depending on the right being exercised, we will inform you of the procedure to follow, the processing time (delay of response) and the information needed.

PERSONAL INFORMATION MANAGEMENT PROGRAM

In order to protect your personal information, we have put in place policies, practices and procedures relating to the management of the personal information we hold.

These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance. These policies and practices also provide the framework for the implementation of privacy impact assessments, as well as the prevention of and response to potential privacy incidents.

PRIVACY OFFICER

AWAKENING TOUCH senior management has delegated the management of the privacy program to the Privacy Officer. The Privacy Officer is responsible for the internal management and oversight of AWAKENING TOUCH privacy program.

The Privacy Officer is responsible for approving and implementing privacy policies and procedures, ensuring that they are functioning properly, and reporting to AWAKENING TOUCH senior management on the effectiveness of the program.

It is also the responsibility of the Privacy Officer to provide you with the necessary support in the event of a question, complaint or request relating to the protection of personal information.

DETAILS ON THE COLLECTION, USE AND DISCLOSURE OF DATA ON THE AWAKENING TOUCH WEBSITE

 

Why do we collect personal information on the website?

The personal information we collect about you on www.AWAKENING TOUCH.ca is collected in order to respond to your request, for example, when you provide your name, email address or telephone number on the form provided in the Contact Us section of the website.

Use of cookies

A cookie is a small data file created by your browser and placed on your computer, mobile device, tablet or other device when you use your browser to visit an online service. Cookies allow websites to store certain information about you to facilitate your access and browsing of the Internet within our sites. Cookies can only be read by the website that sends them to your computer.

We use certain cookies on the company site, specifically to:

  • Store your settings and preferences. Cookies tell us your preferences for example, your province or language,
  • Produce statistical compilations. Among other things, we use cookies to determine the popularity of our site pages, the average number of pages visited, and the average time each user has spent on the site in order to improve our services,
  • Analyze our performance in order to, among other things, learn more about the functions that our users appreciate and those that may require some modification.

Please note that the use of cookies only identifies you as a user and does not recognize you by name or address.

Google Analytics

AWAKENING TOUCH uses Google Analytics to analyze the browsing behaviour of visitors to its website. It is a tool for analyzing website traffic and website use, which is provided by Google Inc. (Google). By using this tool, AWAKENING TOUCH can obtain, among other things, the following information:

  • the number of visitors to the site,
  • the type of browser, language, and operating system they are using,
  • screen resolution,
  • the name of the service provider,
  • date, time, and duration of visits,
  • the country/province from which the site is being accessed,
  • age/gender,
  • pages visited,
  • the source (origin) of the traffic, either organic/direct/reference/social media
  • centres of interest,
  • search terms within the website (search fields).

The information collected by Google Analytics is used to analyze the use of AWAKENING TOUCH’s website and to produce statistical reports on visitor activity. More information about Google Analytics can be found here.

Deactivation of Cookies

It is possible to prevent the personalization functions of our site by disabling cookies on your browser. You can do this by changing the settings in your browser or mobile device.

However, if you choose to decline cookies, certain pages or sections of our website may not display properly or certain features may not be available.

USE OF RECAPTCHA in OUR WEB FORM

We use the reCAPTCHA service from Google Inc. (Google) to protect form entries on our website. Google reCAPTCHA is used to check whether the data entered on our website (contact form) has been entered by a human or by an automated program. In other words, this service allows us to distinguish between humans and computers, so that robots are unable to maliciously fill in forms.

For more information, we invite you to visit the Google reCAPTCHA website and review their privacy policy.

By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out in their policies.

LINKS TO SITES

It is important to understand that this Policy does not apply to other third-party websites that may be accessed through links on our website. We are not responsible for those third-party sites, their content or access. Therefore, any personal information you transmit through these sites is subject to the privacy policies of those sites. It is your responsibility to review their privacy policies to ensure the protection of your personal information.

CONTACT US

You may contact us to exercise your rights, or if you have questions about our privacy practices or need assistance with exercising or understanding your privacy choices.

For inquiries, please contact us via our Contact page.

AWAKENING TOUCH is committed to responding promptly and accurately to all your questions and concerns about the privacy and security of your personal information and our privacy policies and procedures.

In the event that you have a complaint regarding the exercise of your rights under this Privacy Notice, your file will be handled by AWAKENING TOUCH Privacy Officer, who will inform you of the procedures to follow. Each complaint will be investigated. If the complaint is justified, the specific situation will be corrected, and you will be informed.

UPDATING THIS POLICY

AWAKENING TOUCH frequently revises this Privacy Notice to keep it up to date with applicable legislation and its operations. If material changes are made to the Privacy Notice, then update notices (such as online notices or emails) may be used to alert you of such changes. Otherwise, the posting of the revised Privacy Notice on the Site shall be considered sufficient notice to you, and by continuing to use the Site or by submitting Personal Information to us, you are consenting to any changes to our Privacy Notice.

Of all the translated versions of this policy, the French version shall prevail in the event of any dispute.