This Privacy Policy describes how we – ComUnik by MCJ Conseil (9149-6695 Québec Inc.), (together with its affiliates – "comunik.ca", "we", "us" or "our") collect, store, use and disclose personal data about individuals ("you") who: (i) visit or otherwise interact with our website available at www.comunik.ca, or any other website, webpage (including broadcast tables or forms generated by our service), email, text message or digital advertising under our control (collectively, the "Sites"); (ii) use our ComUnik cloud-based communications platform via the Sites, integrations, addons or extensions (« Utilisateurs » ; et ensemble avec les Sites – le « Service »).

Specifically, this Privacy Policy describes our practices regarding:

  • Data collection
  • Use of data
  • Location and retention of data
  • Data Sharing
  • Cookies and tracking technologies
  • Communications
  • Data security
  • Rights of data subjects
  • Data Controller / Data Processor
  • Jurisdiction

Your privacy is important to us, and we are committed to making our practices regarding your personal data fair and transparent.

Contact details

If you have any questions about this privacy policy, you can contact our Data Privacy Officer in the following ways:

Full Name of Legal Entity: ComUnik

Name of Data Privacy Officer: Isabelle Pouliot

Email Address of Officer:

Postal Address: 1200, St-Jean-Baptiste avenue, 105 desk, Quebec, QC  G2E 5E8

Please read this Privacy Policy carefully and ensure that you fully understand it. You are not legally required to provide us with your personal data, and you may do so (or avoid doing so) at your own discretion. If you do not wish to provide us with your personal data, or have it processed by us or one of our service providers, simply do not visit or interact with our Sites, or use our Service. You can also choose not to provide us with "optional" personal data, but keep in mind that without it, we will not be able to provide you with the full range of our services or the best user experience when using our Service.

This Privacy Policy relates to ComUnik's practices as a "data controller", where we determine the means and purposes of the processing of personal data. When we process data on behalf of our business customers ("Customers"), we are acting as a "data processor" in accordance with our agreement with them (as further explained in section 9 below). If you are a user of the Service on behalf of one of our customers, we suggest that you contact your account administrator ("Account Administrator") with any questions or requests relating to the personal data we process on behalf of that customer.

Any capitalized term not defined in this Privacy Policy shall have the meanings given to it in our Terms of Service. Conditions »).

1-            Data collection

We collect technical data, profile data, content, and other data as you, your organization, and other third-party sources.

We collect and control several types of personal data about our Users and visitors to our Sites. This data is collected and generated through your interaction with us or our Service, by automatic means, or directly from you, other Users, our Customers, or other third parties (including our Service Providers, as defined below).

Specifically, we collect the following categories of data (which, insofar as they relate to an identified or identifiable person, are considered " personal data " ) :

Data Collected or Automatically Generated: When you visit, interact with, or use our Service, we may collect, record, or generate certain technical data about you. We do this independently or with the assistance of third party service providers (as defined in Section 4 below), including through the use of "cookies" and other tracking technologies (as detailed in Section 5 below).

This data consists of aggregated connectivity data, technical data and usage data, such as IP addresses and general locations, device and application data (such as type, operating system, mobile device or application identifier, browser version, location and language settings used), the date and time of use, cookies and relevant pixels installed on or interacted upon through said device and recorded activity (sessions, clicks, feature usage and other interactions) of visitors and Users in connection with our Service. In addition, telephone calls (e.g. with our customer service or product consultants) may be automatically recorded, tracked and analyzed, including for the purposes of analysis, monitoring and improvement of service, operational and business quality, training, and record keeping.

Data received users on your part: when you contact us, register for the Service and create your individual profile (User Profile), or register for an event that we host, organize or sponsor, you provide us with personal data. This typically includes your name, place of work and job title, contact information (such as your email address, phone number, and address), account login details (email address and passwords that are automatically hashed), and any other data you choose to provide when using our Service, that you contact us or interact with others through our Service.

You may also send us a "Contact Us" request or support request, or provide us with comments, reviews or responses to our surveys or promotions, including by submitting an online form on our Service or social media, posting on one of our online public forums or communities, by sending an email to one of our designated addresses, or any other form of communication. This data may include details about a problem you are experiencing, contact information and any other documentation, screen recording, screenshots or other information.

Our customers may provide us with additional data such as their billing details, business needs and preferences. To the extent that this data relates to a non-human entity (for example, the bank account of a company or company), it will not be considered personal data in most countries.

Data received users of our Customers and Users: Customers and Users may provide us with the contact details of potential Users, such as employees, collaborators and colleagues, so that we can contact, invite or register them as Users of our Service (including by using single sign-on tools). This data typically includes the names, business phone numbers, and email addresses of these individuals, but additional data may be provided at the discretion of those providing it. For the purposes of this Privacy Policy, this data is also considered user data.

Data received from other third parties: We may receive personal data about you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your personal data from its organizers. We may also receive your contact and business data (e.g. name, company, position, contact details and work experience, preferences and interests) from our Partners (defined below), our service providers, and through the use of tools and channels commonly used for connecting companies and individual professionals to explore potential business and employment opportunities, such as LinkedIn.

Data Obtained Using Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Services. Analytics tools collect data such as how often Users and visitors visit or use the Sites or Services, the pages they visit and when, which website, advertisement or email brought them there, and how they interact with and use our Service and its various features.

2-            Use of data

We use personal data as described in this section (e.g. to provide, improve, and secure our Service; for analytics, marketing, and sales purposes; to comply with applicable laws; and to support our legitimate interests).

We use personal data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Service, for example by understanding the use of our Service and performance of our campaigns, and by obtaining information that helps us focus our resources and efforts more effectively; in marketing, advertising and selling our Service to you and others; providing customer service and technical support; and protecting and securing our Users, Customers, visitors, ourselves and our Service.

If you reside in or use the Service (i) in a territory governed by privacy laws that determine that "consent" is the only or most appropriate legal basis for processing personal data (in general, or specifically with respect to the types of personal data you choose to share through the Service), your acceptance of our Terms and this Privacy Policy will be deemed your consent to the processing of your personal data for all the purposes detailed in this Privacy Policy, as permitted by law. If you wish to revoke this consent, please contact us by email at support@comunik.ca.

Specifically, we use personal data for the following purposes:

  • Facilitate, operate and provide our Service;
  • Authenticate the identity of our Users and allow them to access our Service;
  • Fournir à nos visiteurs, utilisateurs et clients une assistance et un soutien ;
  • Pour mieux comprendre comment les visiteurs et les utilisateurs évaluent, utilisent et interagissent avec notre Service, et comment nous pouvons améliorer leur expérience utilisateur et celle des autres, et continuer à améliorer nos produits, nos offres et les performances globales de notre Service ;
  • To facilitate and optimize our marketing campaigns, ad management and sales operations, and to more effectively manage and serve ads for our products and services, including on other websites and applications. These activities allow us to highlight the benefits of using our Service, thereby increasing your engagement and overall satisfaction with our Service. This includes contextual, behavioral and interest-based advertising, based on activity, preferences or other data held by us or our service providers and business partners.
  • To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences, including through partnerships with local distributors, resellers, business partners and professional service providers related to our Service ("Our Partners ", as described in more detail in section 4 below);
  • To contact our visitors, users and customers (existing or potential) with general or personalized messages related to the Service, as well as promotional messages that may be of specific interest to them (as further described in Section 6 below);
  • Facilitate, sponsor and offer certain events, contests and promotions;
  • To post your comments and submissions on our sites, public forums and blogs;
  • Support and improve our data security measures, including to prevent and mitigate the risk of fraud, error or any illegal or prohibited activity;
  • To create aggregated statistical data, inferred from non-personal data or anonymized or pseudonymized (rendered non-personal), which we or others may use to provide and improve our respective services, or for any other commercial purpose; and
  • Comply with applicable laws and regulations.

3-            Data localization and conservation

We store your data in Canada, for as long as necessary, in accordance with our reasonable business needs (as necessary for the performance of our Service or to support and exercise our legitimate interests) and in accordance with our legal obligations.

Data Localization: We and our Authorized Service Providers (defined below) store, store and process personal data in Canada and other countries reasonably necessary for the proper performance and provision of our Service, or as required by applicable law.

Although privacy laws vary from jurisdiction to jurisdiction, ComUnik, its affiliates and service providers are all committed to protecting personal data in accordance with this Privacy Policy, customary and reasonable industry standards, as well as appropriate legal mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

Data retention: we may retain your personal data for as long as reasonably required in order to maintain and extend our relationship and provide you with our Service and offerings; to comply with our legal and contractual obligations; or to protect us from potential litigation (i.e. in accordance with applicable journaling, records and bookkeeping laws, and in order to have proof and proof of our relationship, in the event of a legal issue following your interruption of use).

4-            Data sharing

We share your data with our Service Providers; your organization (our Client); within our group; in accordance with legal compliance requirements; and between Users on your shared boards.

Legal compliance: In exceptional circumstances, we may disclose or authorize government and law enforcement authorities to access your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally required to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is necessary to protect the security or integrity of our products and services.

Service Providers: We engage selected third-party companies and individuals to provide services complementary to ours. These service providers include third-party service providers (as defined in the Terms & Conditions), server hosting and colocation services, communication and content delivery networks (CDNs), data security and cybersecurity services, billing and payment processing services, fraud detection, investigation and prevention services, web and mobile analytics services, email and communications distribution and monitoring services, session or activity recording services, remote access services, performance measurement services, data optimization and marketing services, social networks and marketing, content providers, emails, voice messages, customer relationship management systems, and our legal advisors and auditors, financial and compliance (collectively, "Service Providers").

These service providers may have access to your personal data, depending on their specific roles and purposes in facilitating and improving our service, and may only use it for limited purposes as determined in our agreements with them.

Partnerships : We engage select channel and business partners, resellers, distributors and professional service providers related to our service, who enable us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our potential and existing customers and users. In such cases, we may share contact information, business information and usage data with the relevant partner, in order to enable them to contact these customers and users for these purposes. If you engage directly with one of our partners, please note that any aspect of this commitment that is not directly related to the Service and directed by ComUnik is beyond the scope of the Terms and Conditions and ComUnik's Privacy Policy, and may therefore be governed by the Terms and the Partner's Privacy Policy.

Service Integrations : You or your Account Administrator may choose to integrate your Account into the Service with a third-party service (provided that such integration is supported by our Service). The provider of this integrated third-party service may receive certain relevant data regarding your Account on the Service or share certain relevant data from that account on the third-party provider's service with our Service, depending on the nature and purpose of such integration. This may include your User Data. Note that we don't receive or store your passwords for any of these third-party services (but they usually require your API key to integrate with them). If you do not want your data to be shared with this third party service(s), please contact your Account Administrator.

Comments or Recommendations: If you submit a review or public comment, please note that we may (at our discretion) store and present your review to other visitors and Users of our Sites and Services (including other Customers). If you wish to remove your public notice, please contact us at support@comunik.ca. If you choose to send others an email or message inviting them to use the Service, we may use the contact information you provide to automatically send us such email or invitation message on your behalf. Your name and email address may be included in the email or invitation message.

Protection of rights and safety: We may share your personal data with others if we believe in good faith that doing so will help protect the rights, property, or personal safety of ComUnik, any of our users or customers, or any member of the general public.

ComUnik Subsidiaries and Affiliates: We share personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, ComUnik or any of its corporate groups are subject to any change in control, including through a merger, acquisition, or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event. If we believe that this change of control may materially impact your important personal data with us, we will notify you of this event and the choices you may have by email or by means of a prominent notice on our Service.

For the avoidance of doubt, ComUnik may share your personal data by other means, in accordance with your explicit approval, or if we are legally required to do so, or if we have made such data non-personal and anonymous.

5-            Cookies and tracking technologies

We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes.

Our sites and our service (including some of our service providers) use "cookies", anonymous identifiers, pixels, container tags and other technologies so that we can provide our service and ensure that it is works properly, to analyze our performance and marketing activities, and to personalize your experience. These cookies and similar files or beacons may also be temporarily placed on your device. Some cookies and other technologies are used to remember personal data, such as an IP address, previously provided by a user.

Please note that we do not change our practices in response to a "Do Not Track" signal in the HTTP header from a browser or mobile application. However, most browsers allow you to control cookies, including whether or not you accept them and how to delete them. You can configure most browsers to notify you if you receive a cookie or to block or completely delete cookies.

You can enable some or all cookies by changing your cookie preferences in your browser settings or directly on the pop-up window that will appear when using the Website or Services. However, please note that if you choose to configure your browser in this way, some areas of our site and/or Services may not function properly.

6-            Communications

We carry out service and promotional communications, by email, telephone, SMS and notifications.

Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (by any means available to us) about changes or updates to our service, billing issues, service changes, login attempts, or service reset notices. password etc Our Customers and other Users on the same Account may also send you notifications, messages and other updates regarding their use of the Service or your use of the Service. You can control your communication and notification settings from your User Profile settings. However, please note that you will not be able to opt out of receiving certain service-related communications that are integral to your use (such as password resets or billing notices).

Promotional Communications: We may also notify you of new features, additional offers, special events and opportunities or any other information that we believe may be useful to our Users. We may provide such information through any of the means of contact available to us (for example, telephone, mobile or email), through the Service, or through our marketing campaigns on any other site or platform. If you do not wish to receive such promotional communications, you may notify ComUnik at any time by emailing support@comunik.ca

7-            Data security

We secure your personal data using standard physical, procedural and technical measures.

In order to protect your personal data held with us, we use industry-standard physical, procedural and technical security measures, including encryption, where applicable. However, please note that, regardless of the security measures used, we cannot and do not guarantee the absolute protection of personal data stored with us or with third parties as described in section 4 above.

8-            Rights of data subjects

Individuals have rights regarding their personal data. For all such personal data that we process as a Data Controller (listed in section 1), you may exercise your rights by contacting us using the method set out below.   

Please note that once you have contacted us, we may advise you how to respond to your request independently through your user profile settings; may refer you to your account administrator; or may request additional information and documents, including certain personal data, in order to authenticate and validate your identity and process your request. This additional data will then be retained by us for legal purposes (for example, as proof of the identity of the person submitting the request), in accordance with section 3 above.

9-            Data Controller / Data Processor

ComUnik is the controller of the personal data of our visitors and Customers and certain types of user data; We are the processor of personal data submitted to our service (i.e. in boards of directors and elements), and data Processed users on behalf of our client.

Our role as data controller : ComUnik is the "data controller" of the personal data of its visitors and customers, as well as user data including profile and contact information, usage, preferences, engagement data and analysis, as well as the data detailed in Section 1 above. With respect to such data, ComUnik assumes the responsibilities of data controller (only to the extent applicable under law), as set out in this Privacy Policy.

10 – Jurisdiction

The Parties expressly agree that any dispute, dispute, disagreement, dispute or disagreement arising directly or indirectly from this Privacy Policy, including concerning the interpretation, execution or violation of the Privacy Policy, shall be submitted to the competent courts of common law in the judicial district of Quebec, Quebec, Canada.

Updates and Changes: We reserve the right to update and change this Privacy Policy from time to time by posting a modified version on our Service. The modified version will be effective on the date of its publication. When we make material changes to this Privacy Policy, we will notify Users as appropriate in the circumstances, such as by posting a prominent notice on the Service or by sending an email. If you continue to use the Service after the changes have been implemented, you accept those changes.

Last updated: January 23, 2023