Confidentiality and Privacy Policy

 1. General Information

(a) Introduction

Privacy is important to Twin Equipment Inc. (hereinafter “Entity”, “We”, “Us“, “Our”). For this reason, We have implemented safeguards and sound management practices for your Personal Information in accordance with the laws applicable in Quebec and Canada.

This privacy policy (the ” Policy “), which should be read in conjunction with our Terms and Conditions, describes our practices with respect to the collection, use, processing, disclosure and retention of Personal Information of our customers, visitors and users.

By using our https://www.twin.ca website  (the “Website“) or any of our services, you agree that We may collect, use, process, disclose and retain your Personal Information in accordance with the terms described herein. If you do not agree to abide by and be bound by this Policy, you are not permitted to visit, access or use Our Website or Services, or share your Personal Information with Us.

This Policy does not apply to the Personal Information of the Entity’s employees, representatives and consultants, or to any other person affiliated with the Entity, as well as to any information that does not constitute Personal Information as defined by the laws applicable in Quebec and Canada.

b) Privacy Officer

Questions, comments and complaints regarding the Entity’s Privacy Policy and practices may be directed to Our Privacy Officer at:

Telephone :        514-353-1190, ext. 2307

Email : rprp@twin.ca

Address :             10401 Parkway, Anjou, QC, H1J 1R4

2. Definitions

The following words and phrases, when they appear with a first letter in capital letters in the Policy, shall have the meanings ascribed to them below, unless otherwise implied or explicitly stated in the text:

“Service Provider” means any natural or legal person who processes Personal Information on behalf of the Entity. These are third-party companies or individuals employed by the Entity to facilitate the Services, provide the Services on behalf of the Entity, perform services related to the Services, or assist the Entity in analyzing the use of the Services.

“Personal information ” means any information that relates to a natural person and allows him or her to be identified, i.e. that directly or indirectly reveals something about the identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental capacities, character and behaviour of the person concerned) or activities, regardless of the nature of the medium and regardless of the extent of the information. the form in which the information is accessible (written, graphic, audio, visual, computerized or otherwise).

“Privacy Officer” means the person who is responsible for the application of this Policy and whose contact information is identified in Section 1 of this Policy.

“Services“: Services refers to the Website and our social media pages.

3. Handling of Personal Information

3.1Collection of Personal Information

In the course of our business, We may process different types of Personal Information including the information listed below:

  • Contact information, such as your first and last name, email address and telephone number;
  • information relating to products or services, such as information about the Services We have rendered to you;
  • information you choose to provide or provide to Us, for example, when you fill out a form;
  • information collected automatically when you use the Website and our Services, including:
    • login information and other information about your activities on the Website, such as your IP address, the pages you viewed, the time and date of your visits, the number of connections, the type of browser you use, the operating system of your device, and other hardware and software information;
    • Demographic and geolocation data, such as your IP address, a precise or approximate location determined from your IP address, or your mobile device’s GPS (depending on your device settings).

In each case, such Personal Information is processed in accordance with the legitimate and necessary purposes listed in section 3.2 below.

3.2 Use of Personal Information

We may use your Personal Information for the legitimate purposes described below:

  • operate, maintain, supervise, develop, improve and offer all features of Our Website;
  • present and/or provide Services to you;
  • To allow you to apply for job openings;
  • allow you to acquire our Services and complete transactions in connection with our Services;
  • carry out our contractual obligations to you;
  • developing, improving, and offering new Services;
  • send you messages, updates, security alerts;
  • for marketing and business development purposes, if you have previously consented to the processing of your Personal Information for those purposes;
  • answer your questions and provide you with assistance as needed;
  • collect reviews and feedback in connection with our Services;
  • conduct research, analysis and statistics in connection with Our business and Services;
  • detect and prevent fraud, errors, spam, abuse, security incidents, and other harmful activities;
  • for any other purpose permitted or required by law.

3.3 Disclosure of Personal Information

We may share your Personal Information with our employees (including marketing and sales departments), consultants, and other trusted third parties (collectively, “Service Providers“), who need the information to help Us operate Our Website, conduct our business activities, or serve you in accordance with applicable laws and Our Information Governance Program.

We do not sell, trade, or otherwise disclose your Personal Information to third parties.

3.3.1 Service Providers and Other Third Parties

Although We try to avoid sharing your Personal Information with third parties, We may use Service Providers to perform various services on Our behalf, such as IT management and security, marketing, and data analytics, hosting, and storage. We have defined below the cases in which such sharing may take place:

  • We use Google Analytics to analyse the Website’s audience, compile statistics and communicate with customers and prospects. Read their privacy policy ;
  • We use Google Ads to analyze the audience of Our Services, compile statistics and converse with customers and prospects. Check out their privacy policy. Check out their privacy policy;
  • We use Meta’s Facebook and Instagram to communicate about Our products and Services. Review their privacy policy.
  • We use LinkedIn to communicate about Our business, products and Services. Review their privacy policy.
  • We use Twitter to communicate about Our business, products and Services. Review their privacy policy.
  • We use KB Media’s services for the hosting of Our Website;
  • We use Metatracer to ensure Our compliance with the privacy laws that apply to Us. Review their privacy policy.

Before disclosing your Personal Information to Service Providers outside the province of Quebec or depending on the nature of the Personal Information disclosed, We conduct a Privacy Impact Assessment. When We disclose your Personal Information to Service Providers, We enter into written contracts with them before your Personal Information is disclosed to them and provide them with only the Personal Information necessary to carry out their mandate. As part of these contracts with our Service Providers, We are committed to adhering to the principles set out in this Policy, and these Service Providers are required to use Personal Information confidentially, as directed by us, and only for the purposes for which it was provided.  We provide sufficient assurances that adequate safeguards are in place that are commensurate with the sensitivity of the Personal Information processed or disclosed. When our Service Providers no longer need your Personal Information, We require them to destroy that data appropriately.

3.3.2 Complying with Legislation, Responding to Legal Requests, Preventing Harm, and Protecting Our Rights

We may disclose your Personal Information where We believe such disclosure is authorized, necessary or appropriate, including:

  • to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
  • to protect our business;
  • to comply with legal process;
  • to protect our rights, privacy, safety, property, yours or those of others;
  • to allow Us to pursue available remedies or limit the damages We may sustain; and
  • in accordance with applicable laws that are applicable, including laws outside your country of residence;

3.3.3 Business Transaction

We may share, transfer or communicate, in strict accordance with this Policy  and the provisions of the Act respecting the protection of personal information in the private sector, CQLR c P-39.1  (the “Private Sector Act  “) and  the Act to modernize legislative provisions as regards the protection of personal information, S.S. 2021, c 25 (the “Bill 25“) (assented to September 22, 2021), your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of the Entity or our assets (e.g., as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or other business transaction, including in connection with the negotiation of such transactions). In this case, We will notify you before your Personal Information is transferred and is governed by a different privacy policy.

3,4 Consent to Personal Information

To the extent possible, the Entity obtains consent directly from the individual to the collection, use and disclosure of the individual concerned. However, if you provide Personal Information about other individuals to Us, you must ensure that you have given them due notice that you are providing their information to Us in addition to obtaining their consent to such disclosure.

We will seek your express, manifest, free, informed and specific purpose consent before using or disclosing your Personal Information for purposes other than those set out herein. We will also seek your explicit consent whenever sensitive Personal Information is involved in any of the Entity’s processing activities. We will ask for your consent for each of the specific purposes in plain and clear terms, distinct from any other information that will be disclosed to you.

BY USING OUR WEBSITE, BY SUBMITTING YOUR PERSONAL INFORMATION BY EMAIL, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.

If You do not consent, please stop using the Website. Except where otherwise required by law, You may withdraw your consent at any time upon reasonable notice. Please note that if You choose to withdraw your consent to the collection, use or disclosure of Your Personal Information, certain features of our Website may no longer be available to You or we may no longer be able to offer You some of our services.

3.5 Retention of Personal Information

Subject to applicable law, We retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, unless you consent to your Personal Information being used or processed for another purpose. As an indication, the duration of certain information may extend up to 7 years following the end of the Services rendered by the Entity to you. In addition, our retention periods may be changed from time to time due to legitimate interests (e.g., to ensure the security of Personal Information, to prevent abuse and breaches, or to prosecute criminals)

For more information on the periods for which your Personal Information is retained, please contact our Privacy Officer using the contact information provided in section 1b) of this Policy.

4.  Your rights

As a data subject, you may exercise the rights set out below by contacting Our Privacy Officer in writing at the contact information provided in section 1b) of the Policy. Please note that We may ask you to verify your identity before responding to any of these requests.

  • You have the right to be informed of the Personal Information We hold about you, its use, disclosure, retention and destruction, subject to the exceptions provided by applicable law;
  • You have the right to access your Personal Information, to request a copy, including hard copy, of the documents containing your Personal Information, subject to the exceptions provided by applicable law, and to obtain, where applicable, additional details about how we use, disclose, retain and destroy it;
  • You have the right to have the Personal Information We hold about you corrected, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
  • You have the right to withdraw or modify your consent to the Entity’s collection, use, disclosure or retention of your Personal Information at any time, subject to applicable legal and contractual restrictions;
  • You have the right to ask Us to stop disseminating your Personal Information and to de-index any link to your name that provides access to that information if such disclosure would contravene the law or a court order;
  • You have the right to request that your Personal Information be disclosed to you or transferred to another organization in a structured and commonly used technological format;
  • The right to be notified of a privacy incident involving your Personal Information that may cause you serious harm. To this end, we maintain a register of all confidentiality incidents and assess the harm they may cause;
  • You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions set out in applicable law.

In order to comply with your request, you may be asked to provide appropriate identification or otherwise identify yourself.

5. Cookies and Other Tracking Technologies

We use cookies and other similar technologies (collectively, “Cookies“) to help us operate, protect and optimize the Website and Services we offer. Cookies are small text files that are stored on your device or browser. They collect certain information when you visit the Website, including your language preference, browser type and version, the type of device you are using, and your device’s unique identifier. While some of the Cookies we use are deleted after your browser session has ended, other cookies are stored on your device or browser to allow us to recognize your browser the next time you visit the Website. The Personal Information collected through these Cookies is not intended to identify you. In particular, they make it possible to ensure the functioning of the Website, to improve the browsing experience of users and to provide certain data that allows us to better understand the traffic and interactions that take place on Our Website as well as to detect certain types of fraud. Cookies do not cause any damage to your device and cannot be used to extract your Personal Information. We collect your IP address, information about your device and operating system or browser, your browsing history and your browsing history on Our Website as well as your queries, browsing preferences (the languages used), etc.

You can configure your browser so that you are informed about the setting of Cookies when you visit the Website, so that you can decide, in each case, whether to accept or refuse the use of some or all of the Cookies. Please note that disabling Cookies on your browser may adversely affect your browsing experience on the Website and prevent you from using some of its features.

To find out more about how we use Cookies, you can see our “Cookie Policy”.

6. Security measures

The Entity has implemented physical, technological and organizational security measures to adequately protect the confidentiality and security of your personal information against loss, theft or any unauthorized access, disclosure, copying, communication, use or modification. These measures include, but are not limited to:

On the administrative side, the adoption of a series of policies and procedures as part of the implementation of our information governance program, including:

  • regulate the access, communication, retention, de-identification, including anonymization and/or, where applicable, destruction of Personal Information;
  • determine the roles and responsibilities of our employees throughout the life cycle of Personal Information and documents;
  • establish procedures for responding to and responding to confidentiality incidents;
  • govern the process of requests and complaints relating to the protection and handling of Personal Information.

On the technical level, the use of several means such as:

  • the use of a secure server. All sensitive information provided is transmitted via Secure Socket Layer (SSL) technology and then encrypted in Our Payment Gateway Provider Database only to be accessed by authorized persons with special access rights to such systems, and are required to keep the information confidential;
  • the use of backup systems, network monitoring software, etc. ;
  • the use of encryption and segregation of duties, access controls and internal audits.

We have not exhaustively listed the set of measures we are putting in place given the public nature of this Policy.

Despite the measures described above, We cannot guarantee the absolute security of your Personal Information. If you have reason to believe that your Personal Information is no longer protected, please contact Our Privacy Officer immediately using the contact information provided in Section 1(b) above.

7. Changes to this Privacy Policy

We reserve the right to change this Policy at any time in accordance with applicable law. If we make any changes, We will post the revised Privacy Policy and update the updated date in the footer of the Privacy Policy. We will also notify you by email at least thirty (30) days prior to the effective date of the new version of our Policy. If you do not agree to the new terms of the Privacy Policy, please do not use Our Website and Services. If you continue to use Our Website or Services after the new version of our Policy comes into effect, then your use of Our Website and Services will be governed by that new version of the Policy.

8. Links to third-party websites

From time to time, We may include references or links to Our Facebook page, websites, products or services provided by third parties (the “Third-Party Services“) on Our Website. These Third-Party Services, which are not operated or controlled by the Entity, are governed by privacy policies that are entirely separate and independent from ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services offered by Us. The Policy does not extend to third-party services such as Our Facebook Page / Our Facebook and YouTube Pages.

9. Individuals under the age of 14

We do not knowingly collect or use Personal Information from anyone under the age of 14. If you are under the age of 14, you should not provide Us with your Personal Information without the consent of your parent or guardian. If you are a parent or guardian and you become aware that your child has provided Personal Information to Us without consent, please contact Us using the contact information provided in Section 1(b) above to request that We delete that child’s Personal Information from our systems.

10. Applicable Laws

The laws of Canada and Quebec, excluding its conflict of law rules, will govern this Agreement and your use of the Website. Your use of the Website may also be subject to other local, provincial, national or international laws.