Privacy & Data Policy

Context

​

The purpose of this policy is to ensure the protection of personal information and to govern the way Solutions Web Gen-X Inc. (hereinafter referred to as "Gen-X") collects, uses, communicates, retains and destroys it or otherwise manages it. In addition, it is intended to inform all interested parties of the way Gen-X handles sensitive data. It also covers the processing of personal information collected by Gen-X through technological means.

​

 

Canadian Industry Standards Compliance

​

At Gen-X, we attach the utmost importance to protecting the privacy and personal and professional information of our visitors and clients. This includes the confidentiality of documents from client mandates, which are treated with the utmost rigour and respect for security standards. To elaborate, we abide by OTTIAQ's (Ordre des traducteurs, terminologues et interprètes agréés du Québec) Code of Ethics and professional Code of Conduct. We also abide by the National Standard of Canada for Translation Services developed by the CGSB (Canadian General Standards Board) CAN/CGSB-131.10-2017, a government agency within Public Services and Procurement Canada. A standard developed by an SCC (Standards Council of Canada) accredited Standards Development Organization (SDO) and approved by SCC, as per SCC’s: Requirements and Guidance-Accreditation for Standards Development Organizations and Requirements and Guidance Approval of National Standards of Canada Designation. We respect the secrecy of all confidential information obtained in our profession, and we take measures to ensure that the information or documents protected by professional secrecy are never disclosed.

​

Intellectual property rights

Gen-X Web Solutions Inc. owns the intellectual property rights of all posted content on its website, translation and content writing projects, and constructed TMs and TBs. Copyrights for Created Content, Translations, TMs, and TBs, are assigned to our clients upon final payment of invoices. All new clients are required to sign a contract agreement for all services offered by Gen-X Web Solutions Inc. 

​

Policy Application and Definitions

 

This policy applies to Gen-X, including, without limitation, its directors, employees, consultants, volunteers and any person who otherwise provides services on behalf of Gen-X. It also applies to Gen-X's website, as well as all websites controlled and maintained by Gen-X.

 

It applies to all types of personal information managed by Gen-X, whether it be information about its customers, potential or actual, its consultants, its employees, its members or any other person (such as website visitors or other).

 

For the purposes of this Privacy and Data Policy, personal information is any information about someone that directly or indirectly allows that person to be identified. Examples include name, address, e-mail address, telephone number, gender, banking information, health information, ethnic origin, language, etc.

 

Sensitive data is information pertaining to a high reasonable expectation of privacy, e.g., health information, banking information, biometric information, sexual orientation, ethnic origin, political opinions, religious or philosophical beliefs, etc. Sensitive personal information is information about which there is a high reasonable expectation of privacy.

 

Generally speaking, an individual's professional or business contact information does not constitute personal information, such as an individual's name, title, address, e-mail address or business telephone number. More specifically, under Quebec's Act respecting the protection of personal information in the private sector, and as of September 22, 2023, the collection, use, and communication, retention and destruction, and data security, do not apply to an individual's information relating to the exercise of a function within an enterprise, such as name, title, function, as well as address, e-mail address and telephone number at work. This information does not apply to personal information that is public by law, as of the effective date of this policy.

​

Data Collection, Use, and Sharing

​

We are the sole proprietors of the information collected on this website. We only collect data voluntarily provided by site visitors, and we never sell or share this information with any third parties without informed consent. 

​

Consent

 

In general, Gen-X collects personal information directly from the person concerned and with his or her consent, unless an exception is provided for by law. Consent may be implied in certain situations, for example, when the individual decides to provide his or her personal information after having been informed by this policy of the use and disclosure for the purposes indicated herein. Thus, this policy and the information it contains will be available to the person concerned at the time personal information is collected.

 

Normally, Gen-X must also obtain the consent of the person concerned before collecting his or her personal information from third parties, before communicating it to third parties or for any secondary use thereof. However, Gen-X may act without consent in certain cases provided for by law and under the conditions set forth therein. The main situations in which Gen-X may act without consent are indicated in the relevant sections of this policy.

​

Right of Access and Withdrawal of Consent

 

To exercise his or her right of access, rectification or withdrawal of consent, the person concerned must submit a written request to that effect to Gen-X's Privacy Officer, at the e-mail address indicated in the "Approval" section below.

 

Subject to certain legal restrictions, individuals may request access to, and correction of their personal information held by Gen-X if it is inaccurate, incomplete or equivocal. They may also request that Gen-X cease disseminating personal information about them, or de-index any hyperlink attached to their name allowing access to this information by a technological means, when the dissemination of this information contravenes the law or a court order. They may do the same or require that the hyperlink providing access to this information be reindexed, when certain conditions provided for by law are met.

 

Gen-X's Privacy Officer must respond to such requests in writing within 30 days of receipt of the request. Any refusal must be substantiated and accompanied by the legal provision justifying the refusal. In such cases, the response must indicate the remedies available under the law and the deadline for exercising them. If necessary, the person in charge must help the applicant understand the refusal. Subject to applicable legal and contractual restrictions, data subjects may withdraw their consent to the disclosure or use of the information collected. They may also ask Gen-X what personal information is collected from them, what categories of people at Gen-X have access to it and how long it is kept.

​

Data Collection

 

In all cases, Gen-X will only collect information if it has a valid reason to do so. In addition, data collection will be limited to that which is necessary to fulfill the purpose for which it is collected. Please note that Gen-X's services and programs are not intended for minors, and more generally, Gen-X does not intentionally obtain personal information about minors (in such cases, information cannot be collected from them without the consent of a parent or guardian).

 

Collection from third parties: Gen-X may collect personal information from third parties. Unless an exception is provided for by law, Gen-X will seek the consent of the individual concerned before collecting personal information about him or her from a third party. If such information is not collected directly from the individual, but from another organization, the individual may request the source of the information collected from Gen-X.

 

In certain situations, Gen-X may also collect personal information from third parties, without the consent of the person concerned, if it has a serious and legitimate interest in doing so and a) if the collection is in the interest of the person and it is not possible to collect it from him or her in a timely manner, or b) if such collection is necessary to ensure that the information is accurate.

 

Gen-X may also collect personal information indirectly, in particular by using Wix to design the website, which has its own terms, conditions, and privacy policy, which can be consulted for further information. This collection through third parties may be necessary to use certain services or programs, or to otherwise do business with Gen-X. Where required, Gen-X will obtain consent at the appropriate time.

​

Control Over Data

​

You are free to contact us at any time to inquire about what information we hold about you, to change any of your details which need to be corrected or updated, or to express any concerns you may have regarding our use of your data.

​

Gen-X may only use an individual's personal information for the purposes identified herein or for any other purposes provided at the time of collection. If Gen-X wishes to use this information for another reason or purpose, a new consent must be obtained from the person concerned, which must be obtained expressly if the information is sensitive personal information. However, in certain cases provided by law, Gen-X may use the information for secondary purposes without the individual's consent, e.g.:

​

• When such use is clearly for the benefit of that person.

• When necessary to prevent or detect fraud.

• When necessary to evaluate or improve protection and safety measures.

 

Limited access: Gen-X shall implement measures to limit access to personal information only to the employees and individuals within Gen-X's organization who have a right to know the information and for whom the information is necessary in the performance of their duties. Gen-X will seek the consent of the individual before granting access to any other person.

​

Communications

Generally, and unless an exception is indicated in this policy or otherwise provided for by law, Gen-X will obtain the consent of the person concerned before disclosing his or her personal information to a third party. In addition, where consent is required and where sensitive personal information is involved, Gen-X will obtain the individual's express consent prior to disclosing the information.

 

However, disclosure of personal information to third parties is sometimes necessary. Thus, personal information may be communicated to third parties without the consent of the person concerned in certain cases, including, but not limited to, the following:

 

Gen-X may communicate personal information, without the consent of the person concerned, to a public body (such as the government) which, through one of its representatives, collects it in the exercise of its powers or the implementation of a program under its management.

 

Personal information may be transmitted to service providers to whom it is necessary to communicate the information, without the consent of the individual. For example, these service providers may be event organizers, Gen-X's subcontractors designated to carry out mandates in Gen-X-administered programs, and cloud service providers. In these cases, Gen-X must have written contracts with these suppliers that specify the measures they must take to ensure the confidentiality of the personal information communicated that the use of this information is made only within the framework of the execution of the contract and that they may not retain this information after its expiry. In addition, these contracts must provide that suppliers must notify Gen-X's Privacy Officer (indicated in this policy) of any breach or attempted breach of confidentiality obligations concerning the personal information communicated and must allow this officer to carry out any verification relating to this confidentiality.

 

If necessary for the purpose of concluding a commercial transaction, Gen-X may also communicate personal information, without the consent of the person concerned, to the other party to the transaction and subject to the conditions provided by law.

 

Disclosure outside Quebec: It is possible that personal information held by Gen-X may be disclosed outside Quebec, for example, when [company name] uses cloud service providers whose server(s) are located outside Quebec or when Gen-X deals with subcontractors located outside the province.

​

Additional Information on the Technologies Used

 

Cookies are data files sent to the visitor's computer by their Web browser when they visit a website and can be used for several purposes. The websites controlled by Gen-X use cookies, in particular:

 

• To memorize visitors' settings and preferences, e.g., for language selection, and to enable tracking of the current session.

• For statistical purposes, to track visitors’ behaviour and content, and to help improve the website.

 

The websites controlled by Gen-X use the following types of cookies:

 

• Session cookies: These are temporary cookies that are stored only for the duration of your visit to the website.

• Persistent cookies: These are kept on the computer until they expire and are retrieved the next time the site is visited.

• Some cookies may be disabled by default and visitors may choose whether to enable these functions when visiting Gen-X's websites.

 

It is also possible to activate and deactivate the use of cookies by changing the preferences in the settings of the browser used.

​

Google Analytics

 

Gen-X's website may use Google Analytics to allow its continuous improvement. Google Analytics makes it possible to analyze how a visitor interacts with a website. Google Analytics uses cookies to generate statistical reports on the behaviour of visitors to these websites and the content consulted. Information from Google Analytics will never be shared by Gen-X with third parties. You can install an Opt-out browser add-on to deactivate Google Analytics.

 

Retention and Destruction of Personal Information

 

Unless a minimum retention period is required by applicable law or regulation, Gen-X will retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected. Personal information used by Gen-X to decide about an individual must be kept for a period of at least one year following the decision in question or even seven years after the end of the fiscal year in which the decision was made if it has tax implications, for example, the circumstances of a termination of employment.

 

At the end of the retention period or when personal information is no longer required, Gen-X will ensure to destroy it or anonymize it (i.e., the data no longer irreversibly identify the individual and it is no longer possible to establish a link between the individual and their personal information) and use it for serious and legitimate purposes.

 

The destruction of information by Gen-X will be done in a secure manner to ensure the protection of this information. This section may be supplemented by any policies or procedures adopted by Gen-X regarding the retention and destruction of personal information, if any. Please contact Gen-X's Privacy Officer (identified in this policy) for further information.

 

Gen-X's Responsibilities

 

In general, Gen-X is responsible for protecting the personal information it holds. Gen-X's Privacy Officer is the organization's President. In general, he or she is responsible for ensuring compliance with applicable legislation concerning the protection of personal information. The person in charge must approve the policies and practices governing the governance of personal information. More specifically, this person is responsible for implementing this policy and ensuring that it is known, understood and applied. In the event of the absence or inability to act of the Privacy Officer, the President of Gen-X will assume the duties of the Privacy Officer.

 

Gen-X employees who have access to personal information or are otherwise involved in its management must ensure its protection and comply with this policy. The roles and responsibilities of Gen-X's employees throughout the life cycle of personal information may be specified by any other Gen-X policy in this regard, if applicable.

 

Data Security

 

Gen-X is committed to implementing reasonable security measures to ensure the protection of personal information under its control. The security measures in place correspond, among other things, to the purpose, quantity, distribution, medium and sensitivity of the information. This means that information that may be considered sensitive will require more stringent security measures and greater protection. In particular, and in line with what was mentioned above concerning limited access to personal information, Gen-X takes necessary measures to impose constraints on the rights of use of its information systems so that only employees who need to have access to them are authorized to do so.

 

Complaints Handling Process

 

Any person who wishes to make a complaint regarding the application of this policy or, more generally, regarding the protection of his or her personal information by Gen-X, must do so in writing by contacting Gen-X's Privacy Officer at the e-mail address indicated in the "Approval" section.

 

The individual will be asked to provide his or her name, contact information, including a telephone number, as well as the subject and reasons for the complaint, in sufficient detail to enable Gen-X to assess the complaint. If the complaint is not sufficiently precise, the Privacy Officer may request any additional information he or she deems necessary to assess the complaint.

 

Processing

 

Gen-X undertakes to process all complaints received confidentially. Within 30 days following receipt of the complaint or following receipt of all additional information deemed necessary and required by Gen-X's Privacy Officer to process it, the latter shall evaluate it and deliver a reasonable written response by e-mail to the complainant. The purpose of this assessment will be to determine whether Gen-X's handling of personal information complies with this policy, any other policies and practices in place within the organization, and applicable legislation or regulations.

 

If the complaint cannot be processed within this timeframe, the complainant must be informed of the reasons for the extension, the progress made in processing the complaint and the reasonable time required to provide a definitive response. Gen-X must keep a separate file for each complaint it receives. Each file contains the complaint, the analysis and documentation supporting its assessment, as well as the response sent to the person who filed the complaint.

 

You may also file a complaint with the Commission d'accès à l'information du Québec or any other privacy oversight body responsible for the application of the law concerned by the subject of the complaint. However, Gen-X invites any interested party to first contact its Privacy Officer and wait until Gen-X has completed its processing.

 

Approval

 

This policy is approved by Gen-X's Privacy Officer, whose business contact information is as follows:

 

Responsible for the protection of personal information:

 

Natasha Tatta

625, rue Joncas

Laval, Quebec H7X 2R2

info@genxtranslationservices.com

Tel: 514-358-1378

​

For all requests, questions or comments regarding this policy, please contact the person in charge by e-mail.

 

Publication and modifications

 

This policy is published on Gen-X's website, as well as on all websites controlled and maintained by Gen-X, to which this policy applies, with respect to the personal information collected therein. This policy is also disseminated by any means suitable for reaching the people concerned.

 

Gen-X must also do the same for all amendments to the present policy, which must also be notified to the people concerned.​​​