PRIVACY POLICY

Last update: 2022-06-01

Elo Mentoring (“Elo”, “we”, “us”, “our“), a company offering a mentoring platform for professionals, values your privacy and the protection of your personal information. This Privacy Policy (the “Policy”) describes the personal information we may receive or collect from you and how we use, disclose, store and secure it. This way, you can make informed choices. 

This Policy applies to our website elomentorat.com as well as our web and mobile application currently referred to as “ELO” (collectively, our “Platform”). However, we would like to draw your attention to the fact that the rights and obligations described in this Policy do not cover third party platforms that may be listed on the Platform. These third party platforms have their own privacy policies and we encourage you to read them carefully.

1.PERSONAL INFORMATION

For the purposes of this Policy, “Personal Information” means any information about an individual that identifies the individual or that, individually or in combination with other information, identifies an individual.

2.HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

With your consent

As a general rule, we will obtain the Personal Information we need directly from you with your consent, subject to any applicable legislative or regulatory exceptions. For example, Elo may need to proceed without your consent where, for fraud detection or prevention purposes, seeking your consent would defeat the purpose.

Elo collects your Personal Information primarily from you, such as when you contact us, register for our services or use our Platform. Your Personal Information may also be collected through cookies, through publicly available records, or from third parties as permitted by applicable law or if we have obtained necessary consent.

Refusal of collection and withdrawal of your consent

You have the right, if you wish, to refuse the collection, use and disclosure of your Personal Information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of Personal Information in our possession by contacting us. You should be aware, however, that if you choose not to provide us with your Personal Information, this may prevent you from, for example, accessing mentoring or other services with us, as this information is essential to the provision of the requested service.

We would also like to inform you that anonymized information, which does not identify you, may continue to be used even if you withdraw your consent.

Use for secondary purposes

Depending on the circumstances, Elo may also ask for your consent to use your Personal Information for secondary purposes, such as market research or to populate its databases. Your consent for secondary purposes may be withdrawn at any time by contacting us, without affecting the provision of our services to you.

3. WHAT PERSONAL INFORMATION DO WE COLLECT?

In the course of our business and provision of services, Personal Information collected may include, but is not limited to:

  • Your contact information, if any (e.g., your name, e-mail address, mailing address or telephone number), for identification and correspondence purposes; 
  • Your login details such as your email address and password;
  • Demographic information such as your gender and age; 
  • Information about where you live and work, such as the name of your employer and the province and region where you live;
  • Your communication preferences; 
  • Your comments or survey answers, if any;
  • Any other Personal Information you have provided to us.

Elo also collects information related to the use of its Platform including technical information about your visits, your IP address when you last logged on, or any other information collected through cookies or similar tools. For more information in this regard, please read the “Cookies and Similar Tools” section.

4.WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

Personal Information collected by or on behalf of Elo may be used for the following purposes:

  • To communicate with you and assist you in the delivery of our services;
  • Provide and maintain the services requested;
  • For research and development, statistical purposes and to improve the use of our Platform and your customer experience. In other words, we want to make sure you enjoy your digital experience and that our services are what you need;
  • Respond to your requests for information and technical support. In other words, if you need help, we’ll do our best to be there for you;
  • To inform you of our new offers and to communicate other information of a commercial nature, if you give us your consent or if the law allows us to do so;
  • As permitted or required by any applicable legal or regulatory obligation or provision;
  • Any other purpose to which you have consented.

Via automated processes

When you use our Platform, we obtain certain information through automated processes, such as the pages you have visited. This information helps us to better tailor our Platform to your needs in order to optimize its functionality and provide you with the best possible experience. We collect this information through a variety of means, including the use of cookies or other similar tools. For more information, please read the “Cookies and Similar Tools” section.

5. COOKIES AND OTHER SIMILAR TOOLS

As mentioned in the previous sections, we may use various tools to improve your experience on our Platform and to better understand our customers’ behavior, particularly in connection with our marketing strategies. The following section is intended to give you more information about how we use these tools and how we profile, if at all.

Cookies and web beacons

We may make use of cookies as well as web beacons. Generally speaking, cookies are small data files that are commonly stored on your device when you use websites and online services. Web beacons are tiny images that may be placed on web pages or in emails. They can be used, for example, to anonymously obtain the number of times a particular page has been visited by an Internet user or confirmation that an e-mail has been read. As the name implies, web beacons are invisible and any part of our Platform may contain web beacons. Unlike cookies, web beacons are not placed on your computer. For the purposes of this Policy, we refer to cookies and web beacons collectively as “cookies”.

The cookies we use

Elo may use various types of cookies. As described below, some of these cookies are strictly necessary for the proper functioning of the Platform, while others will be used for functional, performance or targeting purposes, or to share content on social networks:

  • Strictly necessary cookies. We use strictly necessary cookies to enable the proper functioning of our Platform, our security measures and those of third parties. Without these cookies, the services you have requested cannot be provided.
  • Functional cookies (also known as “preference cookies”). These cookies are not essential to the provision of our services. These cookies help personalize and improve the user experience. For example, they store your communication and language preferences.
  • Performance cookies (also known as “statistical cookies” or “analytical cookies”). These cookies are not essential to the provision of our services. If you have consented, we use performance cookies to understand how you interact with our Platform. Our partners may also use these cookies to analyze your use of our Platform and provide us with information about it. These cookies only produce statistics. For more information on our use of these cookies, see the “Analytics Tools” section.
  • Advertising cookies. These cookies are not essential to the provision of our services. If you have consented, we may use advertising cookies to show you relevant advertising content, including on social networks. Also, our partners may use these cookies to determine whether our advertisements were displayed to you and, if so, whether you interacted with them. In such cases, our partners share data with us, including statistics about the performance of our ads. 
  • Sharing cookies. Our Platform includes social networking features such as the Facebook, LinkedIn or Twitter sharing button. If you use these features, they collect your IP address and the page you visit on our Platform and create a cookie to allow content viewed on our Platform to be linked to your user account on these social networks, if applicable. These features may be hosted by a third party or directly on our Platform.

Analytical tools

If you consent, Elo uses analytics tools to analyze the browsing behavior of visitors to our Platform, which are website traffic and usage analysis tools. In addition, we use the Google Analytics tool offered by Google LLC (“Google“) to collect information about how you navigate our Platform. You can get more information about Google Analytics here.

Targeted advertising

Elo also works with third-party advertising companies such as Google Ads that collect and use information about your visits to our Platform in order to show you advertising that may be of interest to you. Elo does not share any personally identifiable information with these advertising companies.

Elo may also use Facebook’s Custom Audience feature to target advertising to the interests of our current and potential customers. We encourage you to check your Facebook privacy settings if you wish to manage your advertising settings. You can find more information here.

Deactivation of cookies to which you have consented

With the exception of strictly necessary cookies, we will only place cookies on your device with your consent, and these will be retained for a maximum of thirteen months from the time they are placed on your device. At the end of this period, your consent will again be required. 

 

You may manage your cookie settings at any time by following the instructions below. However, if you choose to decline cookies, some pages or sections of our Platform may not display properly or some features may not be available. Also, even if you choose not to receive ads targeted to your interests, it will still be possible to see ads from Elo, but in this case the ads will simply not be tailored to your interests and may be displayed more frequently.

 

  • Set your choices on your browser. You can manage your cookie settings by changing the settings on your browser or mobile device. For details on how to set your browser, please consult the help center for Chrome, Safari, Firefox, Internet Explorer, Edge or Opera

 

  • Set your choices on social networks. If you want to change your settings for sharing cookies via social networks, we invite you to go directly to the sites of these social networks:

 

Disable analytics. You can disable Google Analytics by installing this add-on.

6. HOW DO WE SHARE YOUR PERSONAL INFORMATION?

In the course of our business, we may need to share your Personal Information with various stakeholders. However, we endeavour to share your Personal Information only in the ways described below:

 

  • Our Employees. In the course of their work, our employees may need to access your Personal Information, for example when you contact us for technical support. Their access is limited to what is necessary to perform their duties.

 

  • Our Agents and Service Providers. From time to time, we may need to share your Personal Information with agents or service providers to help us make available features of our Platform (for example: maintenance, analysis, legal requirements, fraud detection, marketing and development). For more information on the transfer of Personal Information, see “Do we transfer your Personal Information outside of Canada? 

 

  • When required by applicable law, to enforce compliance or to protect the property or safety of our rights or those of others. For example, we may disclose Personal Information to legal or regulatory authorities where we suspect money laundering, insider trading, manipulative or deceptive business practices or other criminal activity, to detect and prevent fraud, or to comply with legal or regulatory requirements of governmental authorities, regulatory bodies or other self-regulatory organizations. We may also need to disclose Personal Information to comply with a legal obligation (e.g., court order) or to protect our assets (e.g., to collect overdue accounts).

 

  • Transfer of business. In the course of developing our business, we may sell or buy businesses or services. In such transactions, Personal Information generally becomes part of the transferred business assets, but remains subject to the promises made in any pre-existing privacy policy (unless, of course, the individual consents otherwise). 

Anonymously. Anonymized Personal Information may be shared with third parties. For example, we may anonymize Personal Information in order to determine trends or statistics.

7. DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE OF CANADA?

The Personal Information we collect is stored in secure systems hosted in the United States on servers that meet the highest standards of data security.

We also retain agents and service providers who may be located outside of Canada. However, we strive to protect the Personal Information in our custody, including Personal Information in the custody of an agent or service provider, whether they are located in Canada, the United States or other jurisdictions or countries. In particular, we endeavour to limit their access to Personal Information to that which is necessary to perform their assigned functions. Please be aware that we also strive to put in place contractual arrangements with these agents and service providers to ensure the confidentiality and security of your Personal Information. This may include implementing robust and effective security measures.

If you have any additional questions on this subject, you can contact us.

8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Your Personal Information will be retained only as long as necessary for the fulfillment of the identified purposes or to meet the requirements of any applicable law regarding retention periods. Thus, the length of time we retain your Personal Information will vary depending on the purpose for which it is to be used. At the end of this period, we will endeavour to destroy or anonymize such information. If you would like more information on this subject, please contact us.

At any time, you may request that your account be deleted or your data suppressed by sending a request by completing this form.

9. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the Personal Information in our possession. To do so, we follow generally accepted industry standards, including encryption, firewalls and security protocols. The Personal Information in our possession is therefore only accessible to those persons who have the authority to access it and who consult it only when necessary for the performance of their duties.

Appropriate physical, technical and administrative safeguards and security measures have been put in place and are maintained to minimize the risk of security incidents. If you believe that the security of your Personal Information has been compromised, we invite you to contact us.

10. WHAT ARE YOUR RIGHTS?

Depending on the applicable law, you may have certain rights, such as the following:

  • Protecting the privacy of your Personal Information; 
  • Access to your Personal Information;
  • Correction of your Personal Information if it is incomplete, inaccurate or misleading, or if its collection, disclosure or retention is not permitted by any applicable law;
  • Removal of your email address from our newsletter mailing list, if applicable;
  • Withdrawing your consent to the disclosure, use and communication of your Personal Information, if applicable.

If you have any questions about this, please contact us.

11. DELETION OF ACCOUNT AND PERSONAL DATA

At any time, you may request the deletion of your Elo account and all associated data. To do so, simply send us an email at support@elomentorat.com. or complete this form.

12. CHANGES AND UPDATES TO THE POLICY

Elo reserves the right to change this document at any time and for any reason, in which case the most current version of the Policy will be posted on the Platform. You are responsible for complying with posted updates to the Policy, if any. Your continued use of the Platform after the posting of the amended Policy indicates your full acceptance of the Policy. The date of the last update to the Policy is indicated at the top of the Policy.

13. HOW TO REACH US?

Elo has established procedures for receiving complaints and inquiries about its Personal Information management policies and practices. We will inform individuals who make inquiries or lodge complaints of the existence of the relevant procedures.

Elo will make every effort to investigate all complaints submitted to us. If a complaint is found to be justified, we will take appropriate action, including, if necessary, amending our policies and practices.

Please feel free to contact us with any questions, inquiries, comments or complaints about your Personal Information. To do so, we invite you to contact us at the coordinates found on the Contact Us page.

SPECIAL CONDITIONS FOR USERS OF THE UNIVERSITÉ DU QUÉBEC À TROIS-RIVIÈRES (UQTR) ZONE

Users must provide Elo with consent prior to any disclosure of their data for research purposes.

Users agree that data held by Elo may be hosted in the United States.

SPECIAL CONDITIONS FOR USERS OF THE MEDTRONIC CEMA ZONE

DATA SUBJECT RIGHTS

Depending on your jurisdiction, you may have certain data subject rights, such as Access, Correction, Erasure and Objection rights. To send a request in relation to any of these rights please contact support@elomentorat.com