LaunchLeap Personal Information Protection policy

Last Modified: 09-08-2016

The Personal Information Protection Policy of 9310-9056 QUÉBEC INC. doing business as LAUNCHLEAP (“LaunchLeap”) is modeled after the principles set out in the national standard of Canada entitled “Model code for the protection of personal information” (CAN/CSA-Q830-96).

Nothing in this Personal Information Protection Policy (the “Policy”) has the effect of creating obligations for LaunchLeap beyond those imposed by applicable laws and regulations pertaining to protection of personal information.

In this policy:

This Policy covers the following aspects of Personal Information protection:

  1. Accountability
  2. Purposes
  3. Consent
  4. Limited collection
  5. Limited use, disclosure and retention
  6. Accuracy
  7. Safeguards
  8. Openness
  9. Individual access
  10. Challenging compliance

Summary of the policy
  1. Accountability: LaunchLeap has designated an individual or individuals accountable for LaunchLeap’s compliance with this Policy.

  2. Purposes: The purposes for which Personal Information is collected will generally be identified by LaunchLeap at or before the time the information is collected.

  3. Consent: Your knowledge and consent are required for the collection, use, or disclosure of your Personal Information, except where inappropriate.

  4. Limited collection: The collection of Personal Information will be limited to that which is necessary for the purposes identified by LaunchLeap. Information will be collected by fair and lawful means.

  5. Limited use, disclosure and retention: Personal Information will not be kept, used or disclosed for purposes other than those for which it was collected, except with your consent or as required by law. Personal Information will be retained only as long as necessary for the fulfilment of those purposes.

  6. Accuracy: Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

  7. Safeguards: Personal Information will be protected by security safeguards appropriate to the sensitivity of the information.

  8. Openness: LaunchLeap will make readily available to you specific information about its policies and practices relating to the management of Personal Information.

  9. Individual access: Upon request, you will be informed of the existence, use and disclosure of your Personal Information and will be given access to that information. You will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

  10. Challenging compliance: You may address a challenge concerning LaunchLeap’s compliance with this Policy to the designated individual or individuals accountable for such compliance.

You should read this Policy carefully prior to creating a registered participant account through the website at launchleap.com (the “LaunchLeap Website”) prior to communicating Personal Information to LaunchLeap. Your participation as a visitor or a registered participant to activities offered through the Launchleap Website is entirely voluntary. If you do not consent to the way in which LaunchLeap collects, uses or communicates your Personal Information, you should not communicate Personal Information to LaunchLeap.


Details of the policy
  1. ACCOUNTABILITY

    What can you expect FROM LAUNCHLEAP in terms of protection of your privacy and your Personal Information?

    LaunchLeap’s Policy is based on applicable laws. LaunchLeap abides by the principles provided for in the Personal Information Protection and Electronic Documents Act of Canada and the provisions of the Act respecting the protection of personal information in the private sector of the province of Québec.

    When you participate in LaunchLeap’s feedback campaigns, your Personal Information will be protected.

    LaunchLeap has designated an individual or individuals accountable for LaunchLeap’s compliance with the following Policy. Accountability for LaunchLeap’s compliance with this Policy rests with the designated individual(s), even though other individuals within LaunchLeap may be responsible for the day-to-day collection and processing of Personal Information. Other individuals within LaunchLeap may be delegated to act on your behalf.

    The identity of the individual(s) designated by LaunchLeap to oversee LaunchLeap’s compliance with this Policy will be made known upon request.

  2. PURPOSES

    Why is LaunchLeap collecting your Personal Information?

    LaunchLeap will document the purposes for which Personal Information is collected. Depending upon the way in which the information is collected, this can be done orally or in writing. An online application form or notes related thereto, for example, may give notice of the purposes.

    Identifying the purposes for which Personal Information is collected at or before the time of collection allows LaunchLeap to determine the information it needs to collect to fulfil these purposes. LaunchLeap will collect only the information necessary for the purposes that have been identified.

    In the context of the operation of its business, LaunchLeap collects your Personal Information so as to understand your needs and better serve you, and in particular for the purpose of:

    1. allowing for your subscription and use of the LaunchLeap Website and its online feedback campaign feature;
    2. enabling you, upon request, to partake in LaunchLeap’s various promotional contests, LaunchLeap’s newsletter, LaunchLeap’s loyalty program;
    3. making it possible to deliver rewards, special offers and targeted benefits, to organize promotional events and to communicate with the winners of promotional contests, as well as to verify the identity of LaunchLeap’s loyalty program members;
    4. creating and maintaining LaunchLeap’s relationship with you;
    5. recommending specific campaigns or products tailored to your needs and preferences;
    6. allowing you to voice your opinion about products;
    7. generating statistics and study groups;
    8. creating user profiles and statistics;
    9. developing and setting-up marketing or advertising campaigns that suit your preferences;
    10. processing complaints; and/or
    11. communicating with you.

    When Personal Information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified and documented prior to use. Unless the new purpose is required by law, your consent will be requested before information can be used for that purpose.

  3. CONSENT

    LaunchLeap will not collect your Personal Information without informing you of the purposes of its collection, the use which LaunchLeap will make of it, the categories of persons who will have access to it, and the place where it will be kept.

    Consent to the collection, communication or use of Personal Information will be manifest, free and enlightened, and will be given for specific purposes. Such consent will be valid only for the length of time needed to achieve the purposes for which it was requested.

    Typically, LaunchLeap will seek consent for the use or disclosure of the information at or before the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when LaunchLeap wants to use information for a purpose not previously identified).

    To make the consent meaningful, the purposes for which the information will be used will be stated in such a manner that you can reasonably understand how the information may be used or disclosed.

    The way in which LaunchLeap seeks consent may vary, depending on the circumstances and the type of information collected. LaunchLeap will generally seek express consent when the information is likely to be considered sensitive. Implied consent may generally be appropriate when the information is less sensitive. Consent can also be given by an authorized representative (such as a legal guardian or a person having power of attorney). Consent will not be obtained through deception.

    You can give consent in many ways. For example:

    1. an online application form may be used to seek consent, collect information and inform you of the use that will be made of the information. By completing and sending the form, you are giving consent to the collection and the specified uses;
    2. a checkbox may be used to allow you to agree that your name and address be given to other organizations;
    3. consent may be given orally when information is collected over the telephone; or
    4. consent may be given at the time that you use a product or service.

    You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

    Consent to the communication of Personal Information from a third person may be given by you to LaunchLeap in order to collect the information from the third person.

    LaunchLeap will collect Personal Information only from you, unless you consent to collection from third persons. However, LaunchLeap may, without your consent, collect Personal Information from a third person if the law so authorizes. It may also do so if it has a serious and legitimate reason and either of the following conditions is fulfilled:

    the information is collected in your interest and cannot be collected from you in due time;

    collection from a third person is necessary to ensure the accuracy of the information.

  4. LIMITED COLLECTION

    LaunchLeap will only collect the information necessary for the purposes identified by LaunchLeap, and will collect it by fair and lawful means.

    WHICH Personal Information does LaunchLeap collect?

    LaunchLeap may collect any Personal Information relevant to its market research business, including any Personal Information resulting from answers to market research questions such as:

    1. name and last name;
    2. full mailing address, including your postal code;
    3. email address;
    4. telephone number;
    5. gender;
    6. date of birth;
    7. opinions and preferences on products and services, among a choice submitted by LaunchLeap, or not;
    8. information on your satisfaction as a user of LaunchLeap services or as a customer of any third-party; and
    9. interests and hobbies.

    LaunchLeap may establish a file on you. LaunchLeap, when establishing such a file on you or recording Personal Information in such a file, will make an entry indicating the source of any Personal Information collected from a third person when the third person is a person carrying on an enterprise. The entry is part of your file.

    LaunchLeap may not refuse to respond to a request for goods or services or to a request relating to employment by reason of the applicant's refusal to disclose Personal Information except where:

    • collection of that information is necessary for the conclusion or performance of a contract;
    • collection of that information is authorized by law; or
    • there are reasonable grounds to believe that the request is not lawful.

    when does LaunchLeap collect your Personal Information?

    LaunchLeap collects Personal Information when you create an account on the LaunchLeap Website, when you respond to one of LaunchLeap’s campaigns on the LaunchLeap Website and when you participate to one of LaunchLeap’s contests or promotions. LaunchLeap can also receive Personal Information from partners using the LaunchLeap Website for their campaigns.


    HOW DOES LAUNCHLEAP COLLECT YOUR PERSONAL INFORMATION?

    LaunchLeap collects Personal Information through your account and your interactions on the LaunchLeap Website, LaunchLeap’s social media and LaunchLeap’s customer service, specifically from LaunchLeap’s:

    1. Account subscription form;
    2. Opinion campaigns and surveys;
    3. Contests;
    4. Contact form;
    5. Social media, such as Facebook, Twitter, Google +, Pinterest and Instagram; and
    6. Customer service.
  5. LIMITED USE, DISCLOSURE AND RETENTION

    Occasionally, LaunchLeap may contact again you to validate your responses or to validate your interests in future campaigns, products or contests.

    Does LaunchLeap share your Personal Information?

    LaunchLeap will not communicate your Personal Information unless you authorise LaunchLeap to do so or such communication or use is provided for by law.

    For instance, in the carrying on of its enterprise, LaunchLeap’s authorized employees, mandataries or agents or any supplier in to a contract with LaunchLeap for work or services may have access to Personal Information without your consent if the information is needed for the performance of their duties or the carrying out of their mandates or contracts.

    LaunchLeap may, without your consent, communicate Personal Information contained in a file to an archival agency if the archival agency is a person whose object is the acquisition and preservation of documents for their general informational value and if the information is communicated as part of the transfer or deposit of the archives of LaunchLeap.

    Personal Information may also be communicated without your consent for research purposes if the documents containing the information are not structured so as to allow retrieval by reference to your name or identifying code or symbol and the information cannot be retrieved by means of such a reference.

    If you consent to such communication, LaunchLeap may communicate your Personal Information collected in compliance with the Policy with its affiliated companies or third parties for the purposes for which it was collected and meant to be used.

    How long will LaunchLeap store your Personal Information?

    LaunchLeap stores your Personal Information for as long as needed for the purposes for which it collected and used.

    Your decisions about participating in responding to specific questions, or discontinuing participation will always be respected.

    can you object to use of your Personal Information?

    LaunchLeap pledges to offer you objection and withdrawal rights with regards to your Personal Information. The objection right means the possibility for you to refuse that your Personal Information be used for certain purposes mentioned upon collection. The withdrawal right means the possibility for you to ask LaunchLeap to destroy your Personal Information or to remove you from some of the LaunchLeap Website’s features such as, for example, LaunchLeap’s newsletter and communications.

  6. ACCURACY

    As per the accuracy of the information LaunchLeap collect, LaunchLeap will always rely on the Personal Information that you provide to LaunchLeap. When you create a profile on the LaunchLeap Website or otherwise provide Personal Information to LaunchLeap, be it through the LaunchLeap Website or any other means of communication, you undertake to provide up-to-date, complete and truthful information.

  7. SAFEGUARDS

    how does launchleap ensure the Security of your Personal Information?

    LaunchLeap will take the security measures necessary to ensure the protection of the Personal Information collected, used, communicated, kept or destroyed and that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored.

    The security safeguards of LaunchLeap will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

    The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information and the method of storage.

    The methods of protection includes:

    • physical measures (such as restricted access to offices);
    • organizational measures (such as security clearances); and
    • technological measures (such as the use of passwords).

    LaunchLeap will make its employees aware of the importance of maintaining the confidentiality of Personal Information, and care will be used in the disposal or destruction of Personal Information, to prevent unauthorized parties from gaining access to the information.

    Personal Information that LaunchLeap collects is stored in a secured environment. The LaunchLeap site is secured with https connection, along with:

    • SHA256 with RSA signature;
    • 3 way certificate;
    • TLS 1.0 and later supported (SSL2/3 deprecated);
    • Secure renegotiation;
    • Downgrade attack prevention;
    • Forward Secrecy;
    • Strict Transport Security.

    The LaunchLeap site has maintained an A+ rating on the SSLLabs server test at www.ssllabs.com/ssltest, where security features can be viewed.

    In addition, LaunchLeap has implemented several additional security elements To ensure the safety of your Personal Information that further complimented best practices, such as:

    • SSH connection other than default port with root login disabled;
    • Daily encrypted backups;
    • Backups storage with restricted server accepting only inbound traffic;
    • ECC memory used to prevent data corruption or memory hack attempt;
    • Passwordless login on the platform;
    • Random cryptographic key generation for every device using the platform, thereby eliminating password stealing/phishing or social engineering abuse;
    • Cryptographic data check.

    LaunchLeap is committed to deploying all reasonable efforts to maintain a high level of confidentiality by integrating the latest technological innovations known and proven to ensure confidentiality. However, since it is impossible to eliminate all risks, there will always remain some form of risk when using the Internet to share Personal Information. In this regard, LaunchLeap offers no warranty, express or implied, as to the safeguarding of the confidentiality of data you provided to LaunchLeap, or as to the LaunchLeap Website safety.

    what about the password for your account?

    It is your responsibility to maintain the confidentiality of the password you use to access the sections of the LaunchLeap Website that are protected by password. Consequently, you are responsible for all activity that will take place from your account or with your password.

    Should you believe that the confidentiality of your account or password has been compromised in any way whatsoever, you must contact LaunchLeap immediately at contact@launchleap.com

    Despite the above, LaunchLeap will be entitled to rely on the authority of anyone having access to an account or making use of a password and in no case can LaunchLeap be held liable for any fee, liability or damage resulting from: (i) an action or omission on LaunchLeap’s part with regards to this disposition; (ii) the compromise of an account or password’s confidentiality; and (iii) the unauthorised access to an account or unauthorised use of a password.

    Although LaunchLeap put a lot of efforts into making the LaunchLeap Website safe and preventing unauthorised third parties from accessing an account, LaunchLeap offers no warranty, express or implied, that the confidentiality of the data provided to LaunchLeap will be preserved, or as to the LaunchLeap Website safety. It is possible that a third party may intercept or modify communications between a member and the LaunchLeap Website

    Your security and the security of all LaunchLeap’s members and of the LaunchLeap website are extremely important to LaunchLeap. LaunchLeap therefore reserve the right to take any necessary or reasonable measure to ensure the security of the LaunchLeap Website or of an account. This includes the right to suspend or terminate an account, modify a password or require that some information be provided prior to authorising operations on an account.

  8. OPENNESS

    LaunchLeap will make readily available to you specific information about its policies and practices relating to the management of Personal Information.

    LaunchLeap is open about its policies and practices with respect to the management of Personal Information. You will be able to acquire information about LaunchLeap’s policies and practices without unreasonable effort. This information will be made available in a form that is generally understandable.

    The information made available includes:

    • the name or title and the address, of the person who is accountable for LaunchLeap’s policies and practices and to whom complaints or inquiries can be forwarded;
    • the means of gaining access to Personal Information held by LaunchLeap;
    • a description of the type of Personal Information held by LaunchLeap, including a general account of its use; and
    • what Personal Information is made available to related organizations (e.g. affiliates such as subsidiaries and parent organizations).
  9. INDIVIDUAL ACCESS

    can you Access the Personal Information collected?

    You will have a right to access, rectify and delete any Personal Information about you in LaunchLeap’s possession as provided by this Policy.

    You may be required to provide sufficient information to permit LaunchLeap to provide an account of the existence, use and disclosure of Personal Information.

    LaunchLeap, when holding a file that is the subject of a request for access, rectification or deletion by an Individual, will respond to that request within a reasonable time after receipt of the request.

    No request for access, rectification or deletion may be considered unless it is made in writing by you when you prove that you are the person concerned.

    To exercise these rights, you may contact LaunchLeap at contact@launchleap.com. A reasonable charge may be required from your requesting the transcription, reproduction or transmission of Personal Information.

    In certain situations, LaunchLeap may not be able to provide access to all the Personal Information it holds about you. Exceptions to the access requirement are meant to be limited and specific. The reasons for denying access will be provided to you upon request.

    Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons and information that is subject to solicitor-client or litigation privilege.

    LaunchLeap may refuse to communicate Personal Information to you where disclosure of the information would be likely to hinder an inquiry the purpose of which is the prevention, detection or repression of crime or statutory offences.

  10. CHALLENGING COMPLIANCE

    LaunchLeap has put procedures in place to receive and respond to complaints or inquiries about their policies and practices relating to the handling of Personal Information. The complaint procedures will be easily accessible and simple to use.

    LaunchLeap will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures.

    LaunchLeap will investigate all complaints. If a complaint is found to be justified, LaunchLeap will take appropriate measures, including, if necessary, amending its policies and practices.

    When a challenge is not resolved to the your satisfaction of the Individual, the substance of the unresolved challenge will be recorded by LaunchLeap.