• Privacy Policy

    PAULUX PRIVACY POLICY

     

    INTRODUCTION

     

    With the advent of new communication tools, it is necessary to pay particular attention to the protection of privacy. That is why we, PauLux Ltd (hereinafter “PAULUX” or the “Company”), is seriously concerned about the privacy of your personal information and we are committed to respecting of the information we collect.

     

    PAULUX undertakes to respect, in accordance with applicable laws, the obligations regarding the collection and processing of personal and confidential information obtained in the context of the operation of the application and the website (hereinafter the “Services") so that everyone can benefit from the respect of their private life.

     

    The hereby Privacy Policy (hereinafter the “Policy”) describes the information that PAULUX may collect from the user, that is to say the end user or the organisation you represent or you work for, subject to restrictions (hereinafter the “User” or “Users”), in connection with its activities, the purposes for which PAULUX collects it, the use it makes of it, and the circumstances under which it can pass them on to third parties. The terms “you” and “yours” are associated with the person who is using the Application (the User) and the terms “us” and “our” are associated with PAULUX.

     

    In addition, this Policy indicates the User’s rights regarding the collection, use and communication of its personal information. PAULUX agrees not to collect, use or disclose the User’s personal information otherwise than in accordance with this Policy and applicable laws in Canada.

     

    By using the Company’s Application you consent to this Policy and to the data practices described in it. If you do not agree with the data practices described in this Policy, you should not use our Services.

     

    We periodically update this Policy. The Company will notify the Users thirty (30) days prior to the coming into effect of the modification of the Privacy Policy of the Services by email at the email address provided by the User. If the User refuses these changes and wishes to no longer use the Application, he must cease all use of the Application and will have no later than thirty (30) days following the entry into force of the amendments to send a notice to PAULUX.

     

    All capitalized terms and definitions, not defined in this Policy, have the meaning prescribed to them in the PAULUX Terms of Use (https://cloud.PauLux.com/web/docs/PauLux_ca_term_en_fr.pdf ).

     

    SCOPE OF THIS POLICY

     

    When the User operates PAULUX’s Application, he agrees to the terms and conditions of this Policy.

     

    The User accepts and recognizes that PAULUX has the right to modify, change or update the Privacy Policy. The Company will notify the Users thirty (30) days prior to the coming into effect of the modification of the Privacy Policy of the Application by email at the email address provided by the User. If the User refuses these changes and wishes to no longer use the Application, he will have no later than thirty (30) days following the entry into force of the amendments to send a notice to PAULUX.

     

    The use of the Application by the User after such a modification means that the User consents to respect the Privacy Policy as modified and to be legally bound by them. The Company will inform the Users of any changes to the Privacy Policy thirty (30) days in advance.

     

    The information we collect is necessary when we provide the User a service that he has requested. By providing us this information, the User consents to its collection and use as defined in this Policy.

     

    This Policy has been developed for purposes of compliance with the Personal Information Protection and Electronic Document Act (PIPEDA) and shall serve as part of your initial customer relationship with us and our ongoing commitments to you.

     

    Without information about you, the Company may not be able to provide you the service or the support you request or require. Some of the information we obtain is collected to comply with applicable laws and regulations, including anti-money laundering laws.

     

    This Policy explains:

     

    a. Types of information we collect about you;

     

    b. How we use information about you;

     

    c. Types of information we disclose to third parties and the types of such third parties;

     

    d. How we protect your personally identifiable information; and

     

    e. How you may instruct us not to disclose certain information about you which we are otherwise permitted to disclose by law.

     

    By applying or signing up for our Application, the User authorizes and consents to us obtaining from, and disclosing to, third parties any information about him/her in connection with identity or account verification, fraud detection, or collection procedure, or as may otherwise be required by applicable law.

     

    COLLECTION OF PERSONAL INFORMATION

     

    The Company may obtain personal information from the User when he/she saves this personal information on the Application, or where appropriate, when he discloses this personal information otherwise, such as creating a User account and choosing a password, by logging in as a registered User to the Application, by launching a product search, by requesting a Service, by providing information in the account, by contacting us by phone, email or otherwise, or by completing a form to enter a contest, inventory request, promotion or survey.

     

    We collect the following User’s information, upon registration:

     

    - Identification information, such as your name, email address, home address, phone number, and date of birth, along with identification details of documents confirming his ID and address;

     

    - Financial information, including without limitation bank account and payment card numbers, bank statements, other;

     

    - Other information the User provides when he participates in contests or promotions offered by us or our partners, respond to our surveys or otherwise communicate with us;

     

    - Information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions;

     

    - Information about the location of your device and some other device specifics, including your hardware model, operating system and version, unique device identifier, mobile network information, and information about the device’s interaction with our Services. We may also identify other software running on the device for anti-fraud and malware-prevention purposes (but will not collect any content from such software);

     

    - Information about how he uses our Services, including his access time, browser type and language, and Internet Protocol (“IP”) address;

     

    - Information about him from third parties, including third-party verification services, credit bureaus, mailing list providers, and publicly available sources (where lawful, this information may include your government-issued identification number);

     

    - Information collected by Cookies and Web beacons (defined below), including using web beacons and sending cookies to his device (for more information on this please see below);

     

    - Pictures of his ID, utility bills, and other documents as may be requested by us and provided by you;

     

    - Employment information; and

     

    - Information contained in or relating to any communication that he sends to us with or without our request, including without limitation the communication content and metadata associated with the communication.

     

    USE OF INFORMATION

     

    The User’s personal information will not be retained beyond the purposes for which it was collected. The deletion of the data occurs once the User deletes his account. The User will then have thirty (30) days to recover his data, otherwise, PAULUX could delete them permanently.

     

    The Application is designed for use by adults only. PAULUX does not knowingly collect any personal information from anyone under the age of eighteen (18).

     

    PAULUX does not sell, exchange or give to any other person your information, whether public or private, for any reason whatsoever, without your consent, other than for the express purpose of providing our Services to you.

     

    The Company collects, processes, and uses Information for the following purposes:

     

    a. To provide the Services to you, including without limitation to process your transactions;

     

    b. To improve, personalize and facilitate your use of our Services. For example, when you sign up for the Application, we may associate certain information with your new account, such as information about prior transactions you made using our Services.;

     

    c. To measure, customize, and enhance our Services, including the design, content, and functionality of the Services, or to track and analyze trends and usage in connection with our Services;

     

    d. To analyze use of our Services;

     

    e. To improve our customer Services;

     

    f. To send periodic emails, news and information, or to conduct surveys and collect feedback, about our Services and to communicate with you about products, services, contests, promotions, discounts, incentives, and rewards offered by us and select partners, based on your communication preferences and applicable law, and the email address you provided for such communications;

     

    g. To administer our internal information processing and other IT systems;

     

    h. To operate our Services, including to ensure their security;

     

    i. To maintain back-ups of our databases and to keep the records in accordance with our internal policies and procedures and the applicable law;

     

    j. To communicate with you, including without limitation to deliver the information and support you request, including technical notices, security alerts, and support and administrative messages, to resolve disputes, collect fees, and provide assistance for problems with our Services;

     

    k. To establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure for the protection and assertion of our legal rights, your legal rights and the legal rights of others;

     

    l. To obtain or maintain insurance coverage, to manage risks, or obtain professional advice;

     

    m. To comply with our obligations either required by law or by written agreements with third parties;

     

    n. To display transactions history;

     

    o. To develop new products and Services; and

     

    p. In order to:

     

    i. protect our rights or property, or the security or integrity of our Services;

     

    ii. enforce the terms of our Terms and Conditions or other applicable agreements or policies;

     

    iii. verify your identity (e.g., some of the government-issued identification numbers we collect are used for this purpose);

     

    iv. investigate, detect, and prevent fraud, security breaches, and other potentially prohibited or illegal activities;

     

    v. comply with any applicable law, regulation, or legal process.

     

    The Company may use third-party service providers to process and store your information in Canada and other countries in our sole discretion.

     

    For more information on the protection of your personal information and your related rights, you may contact the following institutions.

     

    • Office of the Privacy Commissioner of Canada (www.privcom.gc.ca)

     

    FORMS AND INTERACTIONS

     

    The User’s personal information may be collected through forms, namely:

     

    - Registration to the Application Form;

     

    - Order Form;

     

    - Survey;

     

    - Resources download Form;

     

    - Contacts importation Form;

     

    - Authorization of the user to access his/her information;

     

    - Contact Form;

     

    - Assistance Form;

     

    - Ad submission Form;

     

    - Community discussion Form;

     

    - Contest;

     

    - Payment Forms.

     

    If the User has not subscribed to our newsletter, the User will not receive any emails from PAULUX, except in special cases (i.e. follow-up or expiry of its subscription, follow-up of its free trial, participation in a contest, changes in the Terms and Conditions, follow-up of the expiry of the identity document to update it, term of the Services etc.).

     

    ADVERTISING INFORMATION

     

    PAULUX will contact you only if you wish. If you prefer not to receive any advertising information from us or if you do not want us to use your personal information to enhance your customer experience, please let us know by contacting us at the contact listed in the section “Right of opposition and withdrawal”.

     

    Remember to include your full name and the email address you used when you registered or when you made a purchase from us. There may be a delay in processing time for a request sent by e-mail or mail and you may continue to receive communications from PAULUX in the meantime.

     

    THIRD-PARTY SERVICES

     

    PAULUX may use third-party services for the management of its business and its Application. In no event shall PAULUX be liable for any prejudice that may arise from such third-party services. PAULUX invites the User to consult these services’ respective website, in order to learn about their conditions of use.

     

    Disclosure of your information to third-party

     

    Any third-party that receives or has access to information is required to protect such information and uses it only to carry out the services they are performing for the User or for PAULUX, unless otherwise required or permitted by law. We shall ensure any such third party is aware of our obligations under this Policy and we enter into contracts with such third parties by which they are bound by terms no less protective of any Information disclosed to them than the obligations we undertake to you under this Policy or which are imposed on us under applicable data protection laws.

     

    We may disclose any and all information specified in Clause “Use of information” of this Policy to:

     

    a) our suppliers or subcontractors as reasonably necessary for providing our Services to you;

     

    b) our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds;

     

    c) our partners, governmental bodies and regulatory authorities, judicial bodies, our associates, agents, attorneys or other representatives for compliance with legal obligations to which we are subject or for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure;

     

    d) our group companies, including our affiliates, for rendering our Services, compliance with applicable laws and improving the quality of our Services;

     

    e) our business partners that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services;

     

    f) credit reference agencies and fraud prevention agencies, including without limitation to Equifax Group of Companies; please find more information about it at https://www.consumer.equifax.ca/ ; and

     

    g) other users of our Services with whom you interact through your own use of our Services. For example, we may share information when you make a Transaction.

     

    Third-party advertising and analytics

     

    We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services. These third parties may use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Services, webpages viewed, time spent on webpages, links clicked, and conversion information (e.g., transactions entered into). This information may be used by us and third-party service providers on our behalf to analyze and track usage of our Services, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand how you use our Services.

     

    The third-party service providers that we engage are bound by confidentiality obligations and applicable laws with respect to their use and collection of your information.

     

    This privacy policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.

     

    AUTOMATICALLY EXCHANGED DATA

     

    The Company collects certain information during exchanges between the User’s computer and our server. Cookies allow the User to connect to the Application.

     

    This information consists mainly of the following:

     

    - Domain name;

     

    - IP address;

     

    - Navigation history;

     

    - User language; and

     

    - Purchases habits.

     

    Most of the automatically exchanged data do not allow to identify the User. They are collected only because of the technological requirements inherent in browsing the Internet. Most browsers automatically accept cookies, but it is usually possible to modify this setting. However, if the User chooses to refuse cookies, he may not be able to identify himself or use certain features of our Application.

     

    The use of such information allows us to improve our Services, to personalize the User’s experience and to better track his requests and orders.

     

    This information is also used for :

     

    - Process user requests and orders and answer their questions;

     

    - Stay in contact with the User and provide him/her with a personalized service at all times;

     

    - Communicate with the user (by email, mail or otherwise) and send him or her advertising material or additional information about the products, services, surveys, contests, promotions and special offers;

     

    - Learn more about users’ purchasing preferences;

     

    - Conduct market and performance research to assess the user service, measure the performance, enhance the experience provided to the users and improve the products; and

     

    - Improve the users’ experience through the analysis of their behaviour.

     

    These cookies are multiple, some expire when the User closes his browser and have no effect while other can be maintained.

     

    INTERNATIONAL COMMUNICATIONS

     

    It is possible that in certain situations, the User’s information is transferred to servers outside of Canada. The User acknowledges that PAULUX is not liable for the consequences of such transfer.

     

    Without prejudice of this Policy, you should be aware that we transfer your information outside Canada to facilitate the services.

     

    SHARING PERSONAL INFORMATION

     

    PAULUX undertakes not to sell the collected personal data without the User’s explicit consent. Personal data can exclusively be sold in the context of a partial or total disposal of PAULUX’s business to a third party. In such situation, the disposed data is subject to the same warranties that those contained in this Confidentiality Policy.

     

    Unless otherwise stated in this Policy, the personal information the User provides will not be transmitted to third parties without his permission. However, we sometimes share this information with partners.

     

    If the User does not wish to have his personal information communicated to third parties or partners, he may opt out at any time, as mentioned in the following section.

     

    YOUR RIGHTS TO YOUR INFORMATION

     

    The User has the following rights with respect to your Information:

     

    a) Right to Confirmation - You have the right to confirm that we process your Information and to access such Information together with the details of the purposes of the processing, the categories of Information concerned and the recipients of your Information. You have a right to request and receive a copy of your Information that we have subject to compliance with the applicable laws. You can access your Information by logging into your Application and checking the relevant section in the Application interface.

     

    b) Right to Rectification - You have the right to rectify any inaccurate information about you and to complete any incomplete Information about you.

     

    c) Right to Erasure - You have the right to demand erasure of your Information with us if:

     

    i. the Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

     

    ii. you withdraw consent to consent-based processing;

     

    iii. you object to the processing of your Information under the applicable law;

     

    iv. the processing of your Information is done for direct marketing purposes only; and

     

    v. your Information have been unlawfully processed.

     

    We may refuse your demand if your Information is processed for exercising the right of freedom of expression and information, compliance with a legal obligation or establishment, exercise or defense of legal claims.

     

    d) Right to Restrict Processing - You have the right to restrict processing of your Information if:

     

    i. you contest the accuracy of the Information;

     

    ii. processing is unlawful, but you oppose erasure;

     

    iii. we no longer need the Information for the purposes of our processing, but you require Information for the establishment, exercise or defense of legal claims; and

     

    iv. you have objected to processing, pending the verification of that objection, in which case we may continue to store your Information, but we will only otherwise process it: (A) with your consent; (B) for the establishment, exercise or defense of legal claims; (C) for the protection of the rights of another natural or legal person; or (D) for reasons of important public interest.

     

    e) Right to Object to Processing - You have the right to object to our processing of your Information by any reason to the extent that the legal basis for the processing is the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. Please note, that we will cease processing your Information if such processing was done for direct marketing purposes. Otherwise, we may disregard your objection if we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

     

    f) Data Portability - to the extent that:

     

    i. the legal basis for our processing of your Information is your consent, a necessity to perform a contract to which you are party, or to satisfy your request prior to entering into a contract, and

     

    ii. such processing is carried out by automated means,

     

    You have the right to receive your Information from us in a structured, commonly used and machine-readable format. However, we may refuse to provide you with your Information if it would adversely affect the rights and freedoms of third parties.

     

    g) Right to Complain - If you consider that our processing of your Information violates applicable laws and regulations, you have a legal right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) (priv.gc.ca/en/report-a-concern/).

     

    h) Right to Withdraw Consent (as defined hereunder) - You may withdraw your consent to us processing your Information at any time, however such withdrawal will not affect the lawfulness of processing of your Information before it.

     

    The User may exercise any of those rights by sending an email at info@infocorpnow.com or by using technical tools and features of the interface of your Application. Please note, that some of your rights related to your Information are quite complex, and you are advised to read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

     

    WITHDRAWAL AND OPPOSITION RIGHTS

     

    The Company is committed to offering the User the right to oppose and withdraw of his personal information.

     

    The right of opposition is understood as the possibility offered to the Users to refuse to allow their personal information to be used for certain purposes mentioned during the collection.

     

    The right of withdrawal is also understood as the possibility offered to the Users to request that their personal information no longer appear, for example, in a mailing list.

     

    The User also has the right to request access to the personal information we have collected about him and to correct any information as needed by contacting the contact person whom information is listed in the section “Contact person” below.

     

    ANTI-SPAM LEGISLATION

     

    PAULUX complies with the dispositions of the Canadian Anti-Spam Legislation (CASL). To withdraw your consent or to stop receiving electronic information or communication, please contact us at the following e-mail address: gdpr@PauLux.com.

     

    SECURITY

     

    The personal information PAULUX collects is kept in a secure environment. PAULUX has taken appropriate measures to maintain the confidentiality of personal information and protect it against loss of theft, as well as unauthorized access, disclosure, copying, use or modification, taking into account, in particular, its sensitivity and the purposes it is used. In addition, PAULUX requires that each employee, proxy or representative of PAULUX complies with this Policy.

     

    The third-party service providers store and transmit personal information in compliance with this Policy and other appropriate confidentiality and security measures. Nevertheless, we cannot guarantee that unauthorized third-parties will never be able to defeat our security measures or use your personal information for improper purposes.

     

    In order to ensure the security of the User’s personal information, PAULUX uses the following measures:

     

    - SSL (Secure Sockets Layers) protocol;

     

    - Protected access to servers and computers;

     

    - Secured access to its premises;

     

    - Firewall;

     

    - Confidentiality agreements with its employees;

     

    - Privacy policies;

     

    - Procedures for the protection of personal information;

     

    - Use of password-protected data networks;

     

    - Current update of security measures;

     

    - Encrypted and secure electronic communications; and

     

    - Server in Canada and outside Canada.

     

    PAULUX is committed to maintain a high degree of confidentiality by incorporating the latest technological innovations to ensure the confidentiality of the User’s transactions in order to protect the User’s personal information and prevent it from being viewed, used of disclosed without authorization.

     

    However, since no mechanism provides maximum security, some risk is always present when communicating personal information via the Internet. If a password is used to protect the User’s account and his personal information, it is his responsibility to keep it confidential.

     

    In the event that any information in PAULUX’s possession or under its control is compromised as a result of a security breach, the Company will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

     

    OPT OUT AND DEACTIVATION OPTIONS

     

    If the User wishes to deactivate his Application, he may do so by contacting our User service. We may retain archived copies of the information and any transactions or Services in which he may have participated for a period of time that is consistent with applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, or legal process, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms and Conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law.

     

    If the User does not consent to the collection of the device location information, he may be unable to use our corresponding Services. The User can stop our collection of location information at any time by changing the preferences on his mobile device. If the User does so, some of our applications will no longer function. The User also may stop our collection of location information via the Application by following the standard uninstall process to remove our Application from his device.

     

    Some of the cookies used in the Services are set by the Company, and others are set by third parties who deliver services on our behalf. Most web and mobile device browsers are set to automatically accept cookies by default. However, the User can change his browser settings to prevent automatic acceptance of cookies, or to notify him each time a cookie is set.

     

    The User may opt out of receiving promotional messages from us by following the instructions in those messages or by changing his/her notification settings by logging into his/her Application. If the User decides to opt out, we may still send him non-promotional communications, such as digital receipts and messages about his Application activities.

     

    DATA RETENTION POLICY

     

    The Company will hold the User’s Information for seven (7) years from the date of his last use of our Services unless otherwise required by the applicable law. We do not retain or store the User’s bank card or bank account information, unless otherwise required by the applicable law.

     

    Notwithstanding the first Clause of this section, we may retain the User’s Information where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect his vital interests or the vital interests of another natural person.

     

    DATA PROTECTION OFFICER AND OUR CONTACT DETAILS

     

    PAULUX LTD is a private company, incorporated in Canada and an entity registered with Fintrac (MSB registration number M23641244).

     

    Any questions or concerns regarding this Policy or your rights related to protection of your personal information may be sent via email at info@infocorpnow.com.

     

    In order to ensure effective and legal handling of our customers’ Information we have appointed a Data Protection Officer. You can reach our Data Protection Officer by sending an email at: info@infocorpnow.com.

     

    FRENCH AND ENGLISH LANGUAGE

     

    If a problem of definition or interpretation arises between the English and French versions of this Policy, the English version shall prevail.

     

    CONTACT PERSON

     

    You may exercise your rights provided in this Policy or you may address any other question or complaint regarding PAULUX’s privacy practices by contacting us:

     

    Name: Anand Misir

     

    E-mail: info@infocorpnow.com

     

    AMENDMENT OF THIS POLICY

     

    The User accepts and recognizes that PAULUX has the right to modify, change or update the Privacy Policy. The Company will notify the Users thirty (30) days prior to the coming into effect of the modification of the Privacy Policy of the Application by email at the email address provided by the User. If the User refuses these changes and wishes to no longer use the Application, he will have no later than thirty (30) days following the entry into force of the amendments to send a notice to PAULUX.

     

    The use of the Application by the User after such a modification means that the User consents to respect the Privacy Policy as modified and to be legally bound by them. The Company will inform the Users of any changes to the Privacy Policy thirty (30) days in advance.

     

    The Company will take this notification as an instruction to close the User’s account. In the event that you close your account following rejection of the changes, we will still hold your personal data on file, to adhere to applicable law.

     

     Last update done 02-21-2024.

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