“Personal Information” means any information pertaining to a natural person which directly or indirectly allows the person to be identified.

We collect only the Personal Information about you that is necessary to establish, manage and maintain our relationship with you. This collection is limited, in most cases, to the following Personal Information:

• Last name, First name;
• E-mail address, mailing address, phone numbers;
• Banking information, if applicable;
• As well as cookies (see Section Cookies of this Policy for more details).

We may collect Personal Information via email, telephone or in-person interactions with us.

We may also collect Personal Information directly on the Website, either automatically via cookies or through an online registration form.

These forms are notably used in connection with contests we run. First, please note that participants in such contests may be required to acknowledge their awareness of this Policy and sign an express consent form. Secondly, we would also like to advise you that payment information from these contests may be processed by third party payment providers.

Therefore, it is important that you read the rules of each contest and payment services privacy policies, which are available at the following links:

Participation rules
Privacy Paypal

Your consent to the collection, use or disclosure of your Personal Information must be freely given, unambiguous, and informed. It must be given for the specific purposes and objectives identified in this Policy.

Depending on the nature and sensitivity of your Personal Information, your consent may be explicit and expressly manifested (such consent may be given verbally, in writing or electronically) or implied (when you voluntarily provide Personal Information, for instance). Where Personal Information is sensitive, UMENCIA will ensure that your consent is expressly given.

BY USING THE WEBSITE, YOU CONSENT TO THE COLLECTION, USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY. PLEASE READ IT CAREFULLY.

If you do not consent, please stop using the Website. Except where otherwise provided by law, you may withdraw your consent at any time upon reasonable notice. Please note that if you choose to withdraw your consent to the collection, use or disclosure of your Personal Information, certain features of our Website may no longer be available to you or we may no longer be able to provide you with certain services.

Cybersecurity is a priority for us. As such, we have put in place physical and technological measures that are reasonable in light of the sensitivity of the Personal Information, its use, amount, distribution and medium.

Personal Information of the Website users is used only for the following purposes:

• provide the Website and ensure its security and optimal operation;
• obtain statistics on the usage of the Website;
• identify a Website user and ensure the authenticity of the identification;
• send you information and promotional offers when appropriate.

We only use Personal Information for the purposes stated above except where we are permitted by law, in very limited circumstances, to do so without your consent.

·      To whom?

We may disclose Personal Information to third parties in specific circumstances permitted by law. The following table summarizes these circumstances and the steps we take to protect such information.

·      Where?

We do not communicate your Personal Information outside of Quebec. If we are required to do so on an exceptional basis, we will first conduct a privacy impact assessment that takes into account:

• The sensitivity of the Personal Information;
• The purposes for which it will be used;
• The safeguards that will be provided; and
• The applicable legislation in the jurisdiction where the Personal Information will be disclosed.

Such disclosures will only be made if the assessment demonstrates that the Personal Information will be adequately protected, with respect to the generally accepted privacy principles. In addition, such disclosure will be subject to a written agreement that is based on all the findings of the assessment.

We retain Personal Information about you only as long as necessary to fulfill the purpose for which it was collected, to comply with legal retention requirements, and as long as necessary to protect our legitimate business interests. We reserve the right to establish Personal Information destruction policies from time to time. Upon request, we can inform you how long we will retain your Personal Information.

For Website users, you have the following rights:

• The right to be informed about their use, disclosure, retention, and destruction of your Personal Information. This is what this Policy is meant to achieve;
• The right to access your Personal Information and to obtain, where appropriate, further details on how we use, disclose, store and destroy it;
• In some cases, you may object to, restrict or withdraw your consent to such operations by giving reasonable notice to the e-mail address provided at the end of this Policy;
• The right to have your Personal Information corrected if it is inaccurate or misleading and to have it completed if it is incomplete;
• The right to have your Personal Information deleted when it is obsolete or when the purposes for which it was collected are fulfilled subject to our legal obligations; and
• The right to be informed of a confidentiality incident involving your Personal Information that may cause you serious harm. We maintain a register of all confidentiality incidents and assess the harm they may cause.

You may exercise these rights by sending an e-mail to the e-mail address provided at the end of this Policy. We will respond to your requests within 30 days of receipt, except where the law permits an extension.

Any correction or deletion of Personal Information will be communicated to the third parties to whom the information has been disclosed.

Subject to legal restrictions, if we refuse to provide or correct your information, we will provide you with the reasons for the refusal, information about your recourse and the applicable sections of the law.

If we refuse to rectify your Personal Information, we will allow you to place comments in your file in respect of the Personal Information for which rectification has been refused. We will also retain the Personal Information that has been the subject of an access request for as long as necessary to allow you to exhaust any recourse provided by law.

Your use of the Website allows us to automatically compile certain information, known as cookies, which may include:

• the Internet Protocol (IP) address of your computer
• your geo-location area;
• the operating system you are using;
• your language preference;
• the identity of your Internet service provider;
• the date and time you access the Website
• the content viewed and downloaded from our Website or the number of visits.

If you wish, you can set your browser to notify you when you receive a cookie or to refuse cookies. It is possible to erase cookies from your computer hard drive, block the creation of cookies, or receive a warning before a cookie is stored.

However, doing so may affect your use of our Website and you may not have access to all of its features. We invite you to consult
Ads Setting and Network Advertising Initiative Initiative and your browser’s instructions or help section for more information on cookies.

This section applies exclusively to Personal Information about EEA residents where UMENCIA collects such information or where such information is otherwise subject to the GDPR (as defined below). With respect to such information, this section takes precedence over other sections of the Policy that address the same subject matter where there is a conflict. Where this section is silent on a subject, the provisions of the Policy continue to apply.

For the purposes of this section, the following definitions apply:

• “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;.
• “GDPR“: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) [2016] JO, L 119.
• For the purposes of this section, Personal Information is equivalent to Personal Data under the GDPR.

If your consent is provided in a written statement that addresses other matters, UMENCIA will ensure that the request for consent to process Personal Information is clearly separate. In addition, UMENCIA will require your express consent to process Personal Information relating to ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, and health information, genetic or biometric information.

As noted above, UMENCIA will not retain personal information longer than is necessary to fulfill the purposes for which it was collected. In addition, UMENCIA will take reasonable steps to identify in advance the time frame for which such personal information may be retained or the criteria for determining that time frame.

UMENCIA will only share Personal Information with external agents, mandataries, consultants, data processors or service providers when they comply with the mandatory content of the subcontractor agreements as set forth in Section 6 hereof. In addition, where Personal Information is subject to this section, UMENCIA will require a Personal Information Processing Agreement as required by the GDPR.

UMENCIA ensures that it is responsible for the protection of Personal Information and that it is able to demonstrate its compliance with the GDPR when processing Personal Information. To this end, it keeps a record of the processing, where required, and trains its employees in the protection of personal information.

The Privacy Officer at UMENCIA is Christine Giroux.

If you have any questions or requests regarding the Policy, you can send an e-mail to the following address: info@umencia.com

UMENCIA reserves the right to change the content of this policy at any time. Any changes will be posted on our Website and brought to your attention when you log in. We recommend that you print a copy of this policy for your records and review this section of our Platform periodically.

This Privacy Policy was last amended on March 29, 2023.