1. CONTEXT
2. SCOPE AND DEFINITIONS
3. COLLECTION, USE, AND DISCLOSURE
4. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
5. RESPONSIBILITIES OF CAMELEOH!
6. DATA SECURITY
7. RIGHTS OF ACCESS, CORRECTION, AND CONSENT WITHDRAWAL
8. COMPLAINTS HANDLING PROCESS RECEPTION
9. APPROVAL
10. MODIFICATIONS
In the course of its operations, Cameleoh! may collect various types of information for various purposes. The types of information that Cameleoh! might collect, their intended use, and the means by which they are collected are detailed in Annex A of this policy.
Cameleoh! will also inform the concerned individuals, at the time of collecting personal information, of any other information gathered, the purposes for which they are collected, and the means of collection, in addition to other mandatory information required by law.
Cameleoh! adheres to the following general principles regarding the collection, use, and disclosure of personal information:
Consent
Generally, Cameleoh! collects personal information directly from the concerned individual with their consent unless a legal exception applies. Consent may be implied in certain situations, for example, when an individual provides their personal information after being informed by this policy about its use and disclosure for the purposes specified herein
(refer to Annex A for more details). Therefore, the individual can review this policy and its contents at the time of data collection.
Typically, Cameleoh! must also seek the individual’s consent before collecting their personal information from third parties, disclosing it to third parties, or using it for secondary purposes. However, Cameleoh! can act without consent in specific cases allowed by law. Key situations where Cameleoh! may act without consent are highlighted in the relevant sections of this policy.
Collection
In all cases, Cameleoh! only collects information when there’s a valid reason and limits the collection to what’s necessary for the intended purpose.
Please note that Cameleoh!’s services and programs are not intended for minors, and generally, Cameleoh! does not intentionally collect personal information regarding minors. In such cases, the data can’t be gathered without consent from a parent or guardian.
Collection from third parties: Cameleoh! may collect personal information from third parties. Unless a legal exception applies, Cameleoh! will seek the individual’s consent before collecting personal information concerning them from a third party. If such information isn’t directly collected from the individual but from another organization, the individual can ask Cameleoh! about the source of the collected data.
In certain scenarios, Cameleoh! may also collect personal information from third parties without the individual’s consent if there’s a significant and legitimate interest, such as a) if collecting the data benefits the individual and can’t be obtained in a timely manner or b) if necessary to ensure the accuracy of the information.
Retention and Use
Cameleoh! ensures that the information it holds is up-to-date and accurate when making decisions related to the concerned individual.
Cameleoh! can only use an individual’s personal information for the reasons specified in this policy or any other reasons provided during collection. If Cameleoh! wishes to use this information for another purpose, new consent from the concerned individual must be obtained, expressly if it’s sensitive personal information. However, in certain legally permitted scenarios, Cameleoh! can use the information for secondary purposes without the individual’s consent, e.g., if clearly benefiting the individual, necessary for fraud prevention or detection, or necessary to evaluate or enhance security measures.
Limited Access: Cameleoh! must implement measures restricting access to personal information only to those within its organization who need to know it. Cameleoh! will seek the individual’s consent before granting access to anyone else.
Disclosure
Generally, unless an exception is noted in this policy or legally allowed, Cameleoh! will obtain the individual’s consent before disclosing their personal information to a third party. Additionally, when consent is required and it involves sensitive personal information, Cameleoh! will need explicit consent before disclosure.
However, sometimes disclosing personal information to third parties is necessary. Thus, personal information might be disclosed without the individual’s consent in specific cases, notably but not exclusively, in the following situations:
Cameleoh! can disclose personal information, without the individual’s consent, to a public entity (like the government) collecting it in its official capacity or for a program it oversees. Personal information might be shared with service providers who need the information, without the individual’s consent.
For example, these might be event organizers, Cameleoh!’s subcontractors, or cloud service providers. In such cases, Cameleoh! must have written contracts with these providers detailing measures to ensure data confidentiality, use of data only for contract fulfillment, and no retention of data post-contract expiration. Also, these contracts must stipulate that providers must notify Cameleoh!’s data protection officer (mentioned in this policy) of any breach or attempted breach of confidentiality obligations and allow audits for data confidentiality.
If necessary for a business transaction, Cameleoh! might also disclose personal information without the individual’s consent to another transaction party, subject to legal conditions.
Disclosure Outside of Quebec: Personal information held by Cameleoh! might be disclosed outside of Quebec, for example, when Cameleoh! uses cloud service providers with servers located outside Quebec or when working with subcontractors outside the province.
Additional Information on Used Technologies:
Use of Cookies Cookies are data files transmitted to a website visitor’s computer by their web browser when visiting the site and can serve various purposes.
Websites controlled by Cameleoh! use cookies to: Remember visitor settings and preferences, such as language choice and to track the current session. For statistical purposes to understand visitor behavior, viewed content, and improve the website. Websites controlled by Cameleoh! use the following types of cookies: Session cookies: Temporary cookies stored only for the website visit duration. Persistent cookies: Stored on the computer until they expire and are retrieved during the next site visit.
Some cookies might be disabled by default, and visitors can choose to enable these functions or not while browsing Cameleoh!’s websites.
Also, you can activate or deactivate cookie usage by adjusting browser settings.
Use of Google Analytics
Cameleoh!’s site uses Google Analytics for continuous improvement. Google Analytics primarily analyzes how a visitor interacts with a Cameleoh! website. Google Analytics uses cookies to generate statistical reports on visitor behavior and viewed content.
Information from Google Analytics won’t be shared by Cameleoh! with third parties.
It’s possible to install a browser add-on to disable Google Analytics.
Other Technological Means Used
Cameleoh! also collects personal information using technological means, such as embedded web forms on a Cameleoh!- controlled website (e.g., contact form). If Cameleoh! collects personal information by offering a technological product or service with privacy settings, it ensures these settings provide the highest level of default privacy (excluding cookies).
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