Personal Information Protection Policy
The National Optics Institute (“INO”, “our”, “us”, “we”), one of the largest centres of expertise in optics-photonics in Canada, is committed to respecting your privacy and protecting your Personal Information.
This Privacy Policy (the “Policy”) describes our practices for protecting Personal Information, the types of Personal Information we may receive or collect from you, and how we use, disclose, maintain and protect your personal Information (“Process” or “Processing”, including its conjugated versions). In order to offer you quality services, we need to have access to certain Personal Information about you. Our employees manage this information with all the necessary discretion and diligence.
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ABOUT THIS POLICY
This Policy describes why and how we Process your Personal Information when you visit our websites www.ino.ca and www.quantino.ca (the “Sites”), including through cookies (the “Cookies”). For detailed information on our use of Cookies, please see the “How do we use cookies?” section. When INO Processes your Personal Information obtained from the Sites, it acts as the data controller with respect to such Personal Information.
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WHAT CONSTITUTES PERSONAL INFORMATION?
For the purposes of this Policy, “Personal Information(s)” means any information about an identifiable individual, including information that may be used alone or with other information to identify, contact or locate a person. Depending on applicable law, Personal Information may or may not include your business contact information, such as your name, title or business contact information.
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WHAT PERSONAL INFORMATION DO WE COLLECT?
The Personal Information we collect when you use the Sites may include, but is not limited to the following information:
- Your contact information, such as your first name, last name, address, postal code, province, state, email or mobile phone number;
- Information relating to your work status such as your title or position within the company for which you work and the name of such company;
- Information relating to your previous employment such as your curriculum vitae, when you apply for a job;
- Information relating to marketing and communication preferences such as comments or responses to surveys;
- Information relating to the use of the Sites including technical information on visits or any other information collected through Cookies or other similar tools. This information includes in particular:
- The number of visits;
- The conversion rate;
- The average duration of your visit;
- The date and time of your visit;
- Actions taken on our Sites;
- The pages consulted during your visit;
- The type of device used during your visit;
- The web browser used during your visit;
- The IP address used during your visit;
- The origin of visitors, i.e. the web page you visited before being redirected to our Sites;
- Any other personal information provided.
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WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?
4.1 Specific and limited purposes
The Personal Information collected by INO when you use our Sites will be used for the following purposes:
- Developing and managing our relationship with you;
- Evaluating the application of an “incubatee”, when you use the Quantino website;
- Providing our Sites, as well as maintaining them;
- For research and development or statistical purposes and to improve the use of our Sites and your browsing experience;
- Replying to your requests for information;
- Replying to your support requests;
- Allowing business development and marketing, in particular to inform you about our new offers, upon prior agreement;
(collectively, the “Purposes”).
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HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
INO collects your Personal Information primarily from you, but also from third parties or through Cookies when you use our Sites.
5.1 Directly from you
In general, we collect the Personal Information we need directly from you, for example when you visit and/or browse our Sites or when you communicate with us. We may also collect information that is generated by your mobile and/or computing devices (for example, mobile advertising identifiers, location information and IP address). For more information, please see “How do we provide online advertising?”.
5.2 With your consent
The legal basis for Processing your Personal Information is obtaining your consent, unless applicable law provides another legal basis (for example, to comply with our legal obligations, as the case may be, to commence, exercise or defend a legal action or proceeding.
5.3 Refusing collection and withdrawing your consent
You have the right, if you wish, to object to the Processing of your Personal Information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent (if any) to the Processing of your Personal Information in our possession by contacting us. However, you should be aware that if you choose not to provide your Personal Information, this may prevent you from accessing certain features associated with our Sites, as this information may be essential to their proper functioning. To submit any queries to us in this regard, please use the contact information indicated in the “Contact Us" section of this Policy.
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WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
INO does not lease or sell any of your Personal Information to third parties and will not share it with third parties without your consent, unless required by law or if necessary for the Purposes set out above.
6.1 With our employees
In the performance of their work, our employees may need access to your Personal Information, for example when you contact us, submit an application, or request technical support for our Sites. Their access is limited to what is necessary for the exercise of their duties.
6.2 With strategic partners or service providers
INO may call on third parties to facilitate its activities, namely when you use the Sites. As part of these activities, INO’s service providers may have access to your Personal Information for a limited period. When INO uses third parties for the Processing of any Personal Information, INO implements reasonable contractual and technical protection measures so that these third parties keep all Personal Information that they Process strictly confidential. Please note that these third parties may be located elsewhere than where you are, in which case, appropriate measures are taken by INO, as indicated below in the section “Where is your Personal Information hosted and transferred?".
6.3 When required by applicable laws
INO may also share your Personal Information if required to do so by law or if it believes in good faith that such disclosure is necessary to: (i) comply with the law; (ii) comply with an order of a competent judicial authority in any jurisdiction; (iii) comply with any legal procedure served to INO; (iv) protect and defend the proprietary rights of INO; (v) apply or verify your compliance with the agreements entered into with INO, if applicable; (vi) prevent fraud or other illegal activity perpetrated through our Sites; or (vii) act in urgent circumstances to protect the personal safety of the general public.
6.4 In the context of a business transfer
We may share your Personal Information without your consent when our operations require it (for example, in the event of a merger, acquisition, bankruptcy or sale of assets).
In such circumstances, we may also share some or all your Personal Information with the relevant third party (or its advisers) for the purposes of a due diligence process.
6.5 For other purposes, with your consent
Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific instances where additional terms apply and through these, we make it clear that specific third parties Process your Personal Information.
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HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
7.1 Personal information from your interaction with our Sites
When you visit our Sites, or submit an application, we will 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. The Personal Information held by INO and resulting from your interaction with our Sites will then be destroyed, deleted or made anonymous. If you wish to obtain more information on this subject, we invite you to communicate with us using the contact information indicated in the “ Contact Us" section of this Policy.
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HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
8.1 Necessary and appropriate security measures
INO has implemented security measures to protect your Personal Information. The security measures we employ depend on the type of information collected. INO uses physical, electronic and procedural security measures to protect your Personal Information.
8.2 Children’s privacy
Our Sites are intended for persons 13 years of age or older. INO does not knowingly Process the Personal Information of children under the age of 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 using the contact information indicated in the “Contact Us" section of this Policy.
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HOW DO WE USE COOKIES?
As mentioned above, we may use various tools to improve your experience on our Sites and to better understand their visitors. The following sections are intended to provide you with more information on our use of these tools and how we perform profiling, as the case may be.
A cookie is a small text file that is stored in a dedicated location on your computer, mobile, tablet or other device when you use your browser to visit an online service. Other tracking technologies, such as web beacons and tracking pixels, may be used for similar purposes. In this Policy, all such tracking technologies are collectively referred to as “Cookie(s)”. Any Personal Information collected using Cookies by INO, or on its behalf, is treated with the same level of confidentiality as any other Personal Information held by INO.
INO uses Cookies whose retention period may vary:
- Session Cookie: This type of Cookie is active for the duration of your visit on our Sites, after which it is erased from your device. It allows you to be identified and is subsequently deleted when you leave our Sites.
- Persistent Cookie: This Cookie is stored on your device until it expires, or is deleted by you, and will be retrieved when you next visit our Site. Our persistent Cookies therefore have a variable duration, but which does not exceed 2 years.
9.1 Strictly necessary Cookies
These Cookies are necessary and essential for the operation of the Sites and cannot be disabled in our systems. Strictly necessary Cookies must be present for our Sites to provide basic functionality. They also allow a user to navigate from page to page without losing previous actions in the same session.
9.2 Other Cookies
We also use other types of Cookies on our Sites, which have different functions:
- Performance Cookies: These Cookies allow us to understand how you use the INO Sites, in order to improve the performance of the Sites. These Cookies provide information on usage trends and habits that may be used for business analysis, improving INO Sites, and implementing performance measures.
- Feature or selection Cookies: These Cookies allow us to remember the choices you make while browsing our Sites.
- Advertising Cookies: These Cookies collect information about your devices in order to show you advertisements based on relevant topics that may be of interest to you. If you would like more information on how to manage and/or disable advertising Cookies, visit https://www.youronlinechoices.eu/. You can also refuse the use of these Cookies by following the instructions indicated below. This category also includes social network Cookies, in order to provide you with personalized offers, to measure, optimize and develop audiences for advertising campaigns broadcast on social network platforms.
- Analytical Cookies: We may use analytical Cookies to better understand traffic patterns on our Sites, to help us measure and improve the effectiveness of our Sites, and to determine whether our emails have been opened as well as the links they contain. These Cookies are only used for statistical purposes. Any information these Cookies collect is aggregated and anonymous. INO uses Google Analytics, which is provided by Google Inc. (Google). To refuse to be tracked by Google Analytics, see this module: https://tools.google.com/dlpage/gaoptout?hl=en. You can also opt out of the use of analytical Cookies by following the instructions below.
9.3 How to manage Cookies
With the exception of strictly necessary Cookies, non-essential Cookies may be managed and/or disabled through your browser’s Cookies settings and your mobile device’s advertising settings. Social network cookies (“plugins”) may also be managed by consulting the policies of the following networks (to the extent that they are applicable):
If you would like more information on how to manage and/or disable non-essential Cookies, please visit https://www.allaboutcookies.org/en/ and https://optout.aboutads.info/?c=3&lang=en.
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HOW DO WE OFFER ONLINE ADVERTISING (TARGETED ADVERTISING)?
10.1 Through Cookies or mobile advertising IDs
INO may collect your Personal Information in order to provide you with advertisements about services and may work with online advertising companies to present you relevant and useful advertisements. These may be presented on our Sites or on the websites of other companies. This Personal Information is collected: (i) with social network Cookies and/or advertising Cookies, as indicated above in the section “How do we use Cookies?”; or (ii) directly from you when you reply to a survey, complete a questionnaire or consent to receive emails.
Depending on the preferences you have expressed on your mobile devices, INO and its advertising partners may also use your mobile advertising ID to target and measure the effectiveness of their advertising campaigns. In iOS, this identifier is called “IDFA” (“ID for Advertising”); in Android (“Google Play”), this identifier is called “AAID” (“Android Advertising ID”). You may access and reset your mobile advertising ID or limit its use through your mobile device settings.
Under no circumstances will we allow advertising to children when we know the user is under the age of 13.
Please note that, even if you choose not to receive targeted advertisements relating to your areas of interest, you may still see advertisements from INO. In this case, these will simply not be adapted to your real needs and could be displayed more frequently. To learn more about our advertising practices, please use the contact information indicated in the “Contact Us” section of this Policy.
10.2 “Do Not Track”
Internet browsers may transmit “Do Not Track” (“DNT”) signals that indicate that a user does not want their activity tracked across time and across different websites. Currently, there is no universally accepted standard on how to interpret these signals, although work to build consensus is underway. Therefore, we do not respond to these DNT signals.
10.3 Facebook custom audiences
INO also uses Facebook’s custom audience function to target advertising related to the interests of its current and potential clients. We invite you to verify your Facebook privacy settings if you want to manage your advertising settings. You may get more information here.
10.4 Social media features
Our Sites include social media features such as Facebook, LinkedIn and Twitter share button. If you use these features, they will collect certain information about you, including the page you are visiting on our Sites. Your interaction with these features is governed by the privacy policy of the company that provides the feature and not this Policy.
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WHERE IS YOUR PERSONAL INFORMATION HOSTED AND TRANSFERRED?
Your Personal Information may be hosted by INO in places other than your province, territory, state or country of residence, including in Canada (including in the province of Quebec). INO may also subcontract the Processing of your Personal Information or share your Personal Information with third parties located elsewhere, including in places other than your province, territory, state or country of residence. In this case, INO will ensure that your Personal Information is adequately protected by technical, organizational, contractual or other appropriate legal means. If you wish to obtain further information on these security measures, please use the contact information indicated in the “Contact Us” section of this Policy.
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WHAT ARE YOUR RIGHTS?
Depending on applicable laws, you may have the right to obtain access to or to rectify your Personal Information, the right to withdraw your consent (if applicable), the right not to be discriminated against, the right to restrict and oppose the use and Processing of your Personal Information by INO, or the right to data portability, i.e. the right to receive a copy of all Personal Information that INO 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 privacy officer as indicated in the “Contact Us” section below. We will process your requests in accordance with applicable law.
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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 Sites. We are not responsible for these third-party websites, their content or access to them. Consequently, any Personal Information that you transmit through these websites is subject to the privacy policy of these websites. It is your responsibility to read them to ensure the protection of your Personal Information.
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CHANGES AND UPDATE OF THIS POLICY
INO 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 send you a link to the new version of the Policy or a notice will be posted on the Policy posting page on our Sites. INO asks its users to consult the modified Policy before continuing to use its services.
The continued use of the services provided by INO after the publication of the modified Policy will indicate consent to this modified Policy.
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HOW TO SUBMIT A COMPLAINT?
INO has implemented procedures to receive complaints and inquiries regarding its policies and practices for managing Personal Information. INO will inform persons who submit a request for information or file a complaint of the existence of the relevant procedures. INO will investigate all complaints. If a complaint is deemed justified, INO will take the appropriate measures, including, if necessary, modifying its policies and practices. If you wish to make a complaint, please contact us using the information indicated in the “Contact Us” section of this Policy.
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CONTACT US
For any other question, request for information, comment or complaint relating to your Personal Information, we invite you to contact our privacy officer at the following address: service.juridique@ino.ca.