Privacy Policy

GENERAL
Information

ALTRUM®. (“ALTRUM®”, “we” or “us”) respects your expectation of privacy as you visit www.altrum.com and all related websites including www.altrumhonors.comwww.altrumrecognition.comwww.altrumreconnaissance.com, and www.dealtoys.com. The purpose of this Privacy Statement is to inform you about the types of Personal Information (as defined below) that ALTRUM® collects, uses and discloses. It explains how we use and disclose that Personal Information, the choices you have regarding such use and disclosure, and how you may correct that information. This Privacy Statement applies to the collection, use and disclosure of Personal Information by ALTRUM®.

Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, mailing address, telephone number, e-mail address, business facsimile number, age, and employment history. Personal Information, however, does not include your name, business title or business address and business telephone number in your capacity as an employee of an organization.

From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

We ensure that all third parties that are engaged to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Statement and our privacy practices.

We have implemented physical (ex.: locked safes, file cabinets and certain rooms), organizational, contractual, and technological security measures (ex.: firewall, network segmentation, privileged access management and event logs) to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees, who are granted access to your Personal Information, are those with a business ‘need-to-know’ or whose duties reasonably require such information. Each employee matching the criteria mentioned above participates in a yearly mandatory training about information technology security and personal information manipulation.

COLLECTION OF
PERSONAL INFORMATION

We will always collect your Personal Information by fair and lawful means (for example, when you enter information on ALTRUM®’s websites or in offline contacts ALTRUM® may have with you). We may collect Personal Information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law. As a result, information may be collected by your use of to the ALTRUM® websites, including but not limited to, sending us e-mails; completing surveys; and submitting employment applications.

Furthermore, when you browse ALTRUM®’s websites, you and your web browser may also transmit information that ALTRUM® automatically collects. This information may be combined with other Personal Information you have provided. The only other type of information automatically provided to ALTRUM® is the type of computer, operating system and browser you are using. This information is provided by your browser, which ALTRUM® may use to improve the performance of its website.

ALTRUM® may also place small data files, called “cookies,” in the browser file of your computer’s hard drive. These cookies automatically identify your browser to ALTRUM®’s server whenever you interact with ALTRUM®’s website. ALTRUM® uses the cookies to record website data. Most browsers automatically accept the cookies, but you usually can change your browser setting to prevent the acceptance of cookies. Please be aware that certain web pages may not function properly if you choose not to accept cookies.

We will keep the Personal Information that we collect either at the ALTRUM® offices or at the offices of a service provider in the Province of Quebec, Canada. In a timeframe that remains within reasonable and legal bounds, your personal information will be retained to carry out our regular activities and provide you with our services. If you have any questions regarding this timeframe, please refer to the Communicating with Us About Our Privacy Statement section at the bottom of our privacy policy.

CONSENT TO
COLLECTING PERSONAL INFORMATION

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances.

USE OF
PERSONAL INFORMATION

We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):

  • to respond to your inquiries;
  • to respond to product or service complaints, product claims or product information requests;
  • to collect your Personal Information in aggregate form to develop consumer profiles, perform sales analysis and identify marketing opportunities and strategies;
  • to advise you about new products and services that may be of interest to you;
  • to collect opinions and comments in regard to ALTRUM®’s operations;
  • to include you on ALTRUM®’s mailing list(s);
  • to recruit for positions at ALTRUM® and to process your application for employment and resume;
  • to administer our websites;
  • to investigate legal claims;
  • such purposes for which ALTRUM® may obtain consent from time to time; and
  • such other uses as may be permitted or required by applicable law.

DISCLOSURE OF
PERSONAL INFORMATION

We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. For example, we may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes.

Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquiror in connection with a transaction involving the sale of some or all of the business of ALTRUM® (in which case the use of your personal information by the new entity would continue to be limited by applicable law), or as otherwise permitted or required by law.

In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

ACCESSING/REVIEWING
YOUR PERSONAL INFORMATION

We may keep a record of your Personal Information, correspondence or comments, in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

We will not charge any costs for you to access your Personal Information in our records or to access our privacy practices without first providing you with an estimate of the approximate costs, if any.

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

COMMUNICATING WITH US
ABOUT OUR PRIVACY STATEMENT

If you have any questions, comments, concerns, or complaints regarding this privacy statement or our privacy protection practices, or if you have any requests related to your personal data, please feel free to contact us at the following address:

Privacy Officer
privacy@altrum.com

Mailing Address:
38 Avenue du Pont
Saint-Martin, QC
G0M1B0