PROTECTION OF PERSONAL INFORMATION POLICY
9527-4270 QUÉBEC INC. (“Naos FitClub”, “us” or “we”) is aware of the need to protect the Personal Information provided to us, including while making use of our Site, and is committed to maintain the privacy and security of Personal Information.
This Policy describes our practice with respect to the Collection, Use or Disclosure of Personal Information. The application of this Policy remains subject to applicable legislation, including the Act respecting the protection of personal information in the private sector.
DEFINITIONS
“Collection” means the collection or acquisition of Personal Information, including from a Third Party; the term “Collecting” and its variations have a similar meaning.
“Cookie” means a small text file or piece of data that is downloaded to and stored on a computer or device while visiting a website.
“Data Subject” means an individual about whom we hold Personal Information.
“Disclosure” means the disclosure of Personal Information to a Third Party; the term “Disclosing” and its variations have a similar meaning.
“Personal Information” means any information which relates to a natural person and allows that person to be identified, including, but not limited to, names, addresses, email addresses and dates of birth.
“Policy” means this Protection of Personal Information policy.
“Site” means our https://naosfitclub.ca/ website, as well as any other similar platform or mobile application belonging to Naos FitClub.
"Third Party" means a person (natural or legal) other than you, a Data Subject or Naos FitClub. “Third-party” has a similar meaning.
"Tracking Pixel" means very small graphic element with a unique identifier that can be used on a website to measure am individual interactions with said a website and the services offered therein.
“Use” means the processing, handling, storage and management of Personal Information by Naos FitClub; the term “Using” and its variations have a similar meaning.
OUR COMMITMENT
We undertake, at all times, to protect all Personal Information we hold and to respect their confidentiality. The Collection, Use and Disclosure of Personal Information will be performed at all times in accordance with applicable laws and the following guidelines:
- personal Information is only gathered with the Data Subject consent, unless exempted by law;
- personal Information is kept strictly confidential and secure;
- personal Information is only Used for the identified purposes;
- personal Information will be destroyed, de-identified or anonymized when they are no longer needed for the identified purposes or required by law; and
- a Data Subject may at any time request that Personal Information concerning them be made available to them, corrected or destroyed.
HOW DO WE COLLECT PERSONAL INFORMATION
We may collect Personal Information as follows:
- Directly: An individual may provide us with Personal Information by email, by telephone, through a Site or in any other direct manner.
- through a Site: We can collect certain Personal Information through interactions with a Site or our media accounts, including through technologies such as Cookies.
- From other sources: We may collect Personal Information from other sources, including a Third Party, with the consent of the Data Subject, unless permitted or required by law.
- Using technology in our establishments: When a person visits our establishment, we may collect audio or video information.
A client of Naos FitClub (a “Client”) may Disclose to Naos FitClub the Personal Information of the users of its products and services pursuant to the terms of a contract of enterprise or for services between the Client and Naos FitClub (a “Mandate”). In this specific context, Naos FitClub undertakes to (i) use the Personal Information so disclosed only in accordance with the terms of the Mandate, this Policy and the applicable laws; and (ii) destroy the Personal Information so disclosed after the expiration or termination of the Mandate without the Client having to make a request to this effect. For the purposes of clarity, Naos FitClub’s role is limited to the provision of services to the Client in accordance with the terms of the Mandate, in particular the hosting of said Personal Information, and any question regarding the Collection, Use or Disclosure of Personal Information by a Client must be transmitted to the latter, Naos FitClub is not responsible for the Client’s internal practices.
CONSENT
Unless exempted by law, we will inform you and obtain your consent to the Collection, Use or Disclosure of your Personal Information. Such consent may be implied, meaning that it will be inferred from your actions or inaction at the time of Collection, Use or Disclosure.
When we wish to use of a Data Subject’s Personal Information for purposes other than those specified at the time of its Collection, we will seek the consent of the individual concerned.
Consent may be withdrawn at any time, except in limited circumstances, including where withdrawal of consent is limited by legal or regulatory requirements, or due to the Data Subject’s contractual obligations to Naos FitClub.
If you choose (i) not to provide us with certain Personal Information; or (ii) to withdraw your consent, where it is possible to do so, it may be impossible for us to provide you with our products or services.
PERSONAL INFORMATION COLLECTED
In the course of its interactions with us, we may Collect, Use or Disclose an individual’s Personal Information to provide products or services to such person, to communicate with them, to improve our product or service offering, and for other operational, legal and compliance purposes. The Personal Information Collected may include:
| Categories | Examples |
| Identification information | Name, first name, postal address, email address, telephone number |
| Technical or digital information | IP address, date and time of connection, pages visited, actions taken on our Site, geolocation data |
| Transactional or commercial information, | Products or services purchased or considered for purchase |
| Recruitment information | Curriculum vitae, professional or academic history |
| Financial information | Salary, payment information, credit report |
| Audio-visual information | Audio or video recording during a call or during a visit to a service point |
| Demographic information | Age, gender, ethnicity, nationality, place of residence |
| Health information | Weight, health history, lifestyle habits, medication use |
| Biometric information | Fingerprints, shape of the face, hand or iris of the eye, voice print |
| Inferences or preferences | Information we learn or infer |
We may also process a person’s account credentials, passwords, profile information and other Personal Information it provided to facilitate the use of the Site.
We do not Collect sensitive information, such as political or religious beliefs, ethnic background, sexual preference, health or any other sensitive information.
We do not seek to Collect information about minors and if you believe your child may have shared its Personal Information with us, please contact us by contacting our Responsable de la protection des renseignements personnels as set forth below.
HOW WE USE PERSONAL INFORMATION
Except where allowed or required by law, we only Use the Personal Information provided to us for the identified purposes for their Collection and we will not Use them for any other purpose without the consent of the Data Subject.
COOKIES AND TRACKING PIXELS
By using our Site, you consent to our use of Cookies and Tracking Pixels which enable us, among other things, to recognize you when you visit the Site so as to customize your browsing experience based on your preferences and provide a customized offering of services and products on our Site. Most browsers are initially set to accept Cookies and Tracking Pixels. You can usually change your browser settings to (i) refuse Cookies or Tracking Pixels or to indicate when a Cookie or Tracking Pixel is being sent; or (ii) remove or block browser Cookies or Tracking Pixels, but that may impact your ability to use the Site as it may not work well or at all.
HOW WE SAFEGUARD PERSONAL INFORMATION
We take reasonable steps to protect Personal Informations against loss or theft and unauthorized access, Disclosure, copying, Use, modification or destruction and use safeguards appropriate at all times.
Any person we authorized who has access to Personal Informations must respect their confidentiality.
We will destroy, de-identify or anonymize any Personal Information no longer needed for the identified purposes or required by law according to its established internal controls, schedules and practices.
From time to time, we may ask other members of our group, or Third-party service providers, to help us manage our information technology systems used to process Personal Information.
We will only Disclose Personal Information to a Third-party service provider where we are satisfied that (i) adequate levels of protection are in place to protect the integrity and security of any Personal Information being processed; and (i) compliance with applicable Personal Information protection legislation is achieved. These measures include use of standard contractual clauses stating the confidentiality of the Personal Information and the identified purposes.
The Internet is not a secure means of communication and that we make no representations or warranties as to the absolute security of Personal Information so provided. You acknowledge that the transmission of Personal Information via the Internet is at your own risk.
SHARING AND DISCLOSURE
We do not sell or rent any Personal Information to any Third Party except as provided herein. We may have to Disclose Personal Information in response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
YOUR RIGHTS REGARDING THE PERSONAL INFORMATION PROVIDED TO US
If you would like us to delete or correct your Personal Information from our records, please contact us using the contact details below and we will respond within a reasonable time. Please note that we may be required to retain certain information by law or for our own legitimate business purpose.
If you wish to access the Personal Information we hold about you, please contact us using the contact details below and we will respond within a reasonable time. Your Personal Information will be made available to you in a clear manner and reasonable fees may be charged. In certain situations, in accordance with current legislation, Naos FitClub reserves the right to refuse, in whole or in part, access to the Personal Information requested.
If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
OUR RESPONSIBILITY FOR EXTERNAL LINKS
We may provide links to external elements or Third-party websites, including, but not limited to social media sites such as Facebook. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices. Furthermore, we can have no responsibility for the information Collected by any Third Party under those circumstances and we cannot be responsible for Collection, Usage and protection of any information which you may so provide.
CONTACT US
All comments, inquiries or complaints regarding our privacy practices or your Personal Information can be addressed to our Responsable de la protection des renseignements personnels at:
| 520, St-Hubert Street, Montréal (Québec) H2Y 0C1 | |
| Attention to: | Responsable de la protection des renseignements personnels |
| E-mail: | vieuxport@naosfitclub.ca |
| Phone: | 514-281-1019 |