Latest modification: September 8, 2021

Ingeniarts Technologies Inc. (“Ingeniarts”, “we” or “us”), owner and operator of the website available at www.ugowork.com and addresses associated therewith (collectively, the “Platform”), places particular importance on the protection of your Personal Information and wishes to offer its users a secure environment that respects their privacy. That is why we are committed to ensure the accuracy, security and confidentiality of the Personal Information collected about you through the rigorous application of this Privacy Policy (the “Policy”) and in accordance with applicable laws. 

This Policy defines how we collect, use, disclose and retain your Personal Information and is intended to help you understand our practices. This Policy also explains how you can ask questions and make suggestions about our privacy practices and review or update your Personal Information. 

This Policy does not apply to third-party websites and software that may be accessed through the Platform. Be aware that if you click on a link to a third-party site, you will be taken to websites we do not control. 

For the purposes of this Policy, “Personal Information” means any information about an identifiable individual or that, taken alone or in combination with other data, allows an individual to be identified. Generally speaking, personal information does not include business contact information such as your name, title, business address or telephone number. 

We have appointed a Chief Privacy Officer (“CPO”). If you have any questions, comments or complaints about this Policy, please contact the following email: legal@ugowork.com.  

1. THE PERSONAL INFORMATION WE COLLECT

In the course of our business and service provision, the Personal Information collected may include, but is not limited to:

  • Your contact information, including your name, username, email address, residential address and IP address;
  • Your use of the Platforms and other technical information related to your browsing behavior;
  • Marketing information and communication preferences such as comments, survey responses; and
  • Any other Personal Information provided by you.

Please note that this Personal Information may also be linked or processed with technical data collected by our battery systems and other equipment.

Our Platform is not intended for individuals under the age of majority in the jurisdiction of their domicile, and in any case, we do not knowingly collect Personal Information from children under 16. If we learn that we have accidentally collected Personal Information from a child under age 16 without verification of parental consent, we will delete that information.  If you believe that we might have any information from or about a child under 16, please notify our CPO at the email address mentioned above.

2. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

Ingeniarts collects your Personal Information from you, third parties, through cookies and web analytics services such as Google Analytics or Hubspot. 

  1. From you

You provide us directly with Personal Information when, among other things, you create or use an account on the Platform, you click on an advertisement that we have placed on a third-party website (e. g. Google, Facebook, etc.), you contact us, complete a training program or fill out an online form on the Platform. 

  1. From third parties

We may also collect Personal Information from third parties, or from publicly available records as permitted by law or where we have obtained the necessary consent.

  1. Cookies and other social media features

Cookies, or similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) are small files that a site or its service providers transfers to your computer’s hard drive through your Web browser (collectively, “Cookies”). They are used for the efficient operation of websites and can provide information and assist in the customization of services. Ingeniarts collects Personal Information provided by Cookies.

More specifically, Ingeniarts uses different types of Cookies:

  • Performance and functionality Cookies: These Cookies are not essential to the provision of our services. They facilitate the personalization and enhancement of the user experience. For example, they may remember your preferences and avoid having to re-enter information more than once or remember your credentials, so they don’t have to enter them each time you use them. They allow us to understand your behavior in order to improve the Platform.
  • Cookies for advertising purposes: These Cookies are not essential to the provision of our services. They use information about your visit to the Platform, such as the pages visited or the response to advertisements, to help provide the best user experience for your situation.

Note that these Cookies may be temporary (i.e., they may be stored on your devices for the duration of your visit to the Platform, after which they are deleted) or persistent (i.e., they may be stored on your devices until they expire or are deleted and can be retrieved the next time you visit the Platform). The duration of our Persistent Cookies varies depending on their purpose.

If you wish to disable the use of Cookies, you can do so from your browser’s preference menu. You may disable Cookies or use private browsing mode when accessing the Platform.

Our services may also include social media features (e.g. the Facebook share button) accessible through the Platform. If you use those features, they will collect your IP address, which page you are visiting on the Platform, and set a Cookie to enable those features to function properly. These features may be hosted by a third party or hosted directly on the Platform. Your interaction with these features is governed by the privacy policy of the company providing the feature and not by this Policy.

  1. Web analytics services

We use web analytics services (such as Google Analytics or Hubspot) to analyze the browsing behavior of visitors to the Platform. These tools may allow us to obtain information such as the number of visitors to the Platform; the type of browser, language and operating system you use; your screen resolution; the name of your Internet service provider; the date, time and duration of your visits; the country or province from which you access the Platform; the pages visited; the source (origin) of the traffic, whether organic / direct / referrals / social media, etc. and search terms used the Platform.

3. HOW WE USE YOUR PERSONAL INFORMATION

The Personal Information collected by Ingeniarts will be used for the following purposes:

  • To provide, maintain and promote our products and services to you through the Platform;
  • Enable us to perform internal operations related to our products and services; 
  • Customize and improve our products, services and the Platform; and
  • Send or facilitate communications between Ingeniarts and you in connection with the services offered through the Platform.

Except as already provided by applicable privacy legislation, we will obtain your consent before using your Personal Information for any purpose not previously identified.

4. TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION

In the course of its business, we may disclose your information to third parties, including but not limited to:

  • Third party service providers, including but not limited to Platform services (hosting, security, etc.). The Personal Information provided is then limited to only the Personal Information necessary to enable them to perform their services; and
  • Governmental public authorities and law enforcement agencies where required by applicable law or where necessary for the provision of our products or services. 

Except as set out above, Ingeniarts will not disclose your Personal Information to third parties without your prior consent. In addition, prior to disclosing your Personal Information to third parties, such third parties must agree to comply with strict contractual conditions requiring them to (i) maintain the confidentiality of the Personal Information disclosed to them; (ii) retain and use such Personal Information only for the purposes set out herein; and (iii) destroy such Personal Information once it has been used for the authorized purposes.

Finally, Ingeniarts will disclose your Personal Information if we are required to do so by law or by an order made by a court or authority with jurisdiction to compel us to disclose such Personal Information, or to protect or defend a legal interest.

5. YOUR CONSENT TO THE COLLECTION AND USE

Your consent to the collection, use and disclosure of your Personal Information is required, except where inappropriate (for example, for legal or security reasons, it may be impossible or impractical to obtain consent).

BY ACCESSING THE PLATFORM OR OTHERWISE USING Ingeniarts’S SERVICES, YOU EXPRESSLY PROVIDE US WITH YOUR CONSENT TO COLLECT, PROCESS AND USE YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PROVISIONS OF THIS POLICY.

You represent that you are aware of the purposes for which Ingeniarts collects, processes and uses your Personal Information, how it will be collected and how we protect the confidentiality of the Personal Information.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Refusal to disclose Personal Information or withdrawal of your consent may prevent us from providing or continuing to provide you with some of our products or services.

6. RETENTION OF PERSONAL INFORMATION

Personal Information will be retained as long as necessary for the fulfillment of the identified purposes or for compliance with legal requirements regarding retention periods.

Any user may request that their account be deleted by sending a request to Ingeniarts by email at legal@ugowork.com.

7. OUR SECURITY MEASURES

We implement industry-standard, state-of-the-art security measures to protect our customers from unauthorized access or use, alteration, unlawful or accidental destruction or loss of their Personal Information.

Unfortunately, it is impossible for us to guarantee the absolute security of the Personal Information collected or transmitted through the Platform. 

You therefore understand and agree that (i) there are limits to the security and confidentiality of the Personal Information we collect that are beyond the control of Ingeniarts; and (ii) the security, integrity and confidentiality of all Personal Information and data exchanged between you and Ingeniarts through the Platform cannot be guaranteed; and (iii) such Personal Information may be viewed or altered by a third party at the time of transfer. For these reasons, Ingeniarts cannot be held responsible for any loss, capture or alteration of Personal Information. 

8. ACCESS AND MODIFICATION OF PERSONAL INFORMATION

You may have access to some of your Personal Information through your user account on the Platform, if applicable. You can correct and update it from this access.

You may obtain a copy of your Personal Information or have it corrected, if it is incorrect, by sending us a written request by email. 

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 individual concerned (or the representative, heir or successor of that individual, or the liquidator of the succession, a beneficiary of life insurance, as applicable). 

When we receive a request for access, correction or removal, we will attempt to respond within a reasonable timeframe after receipt of the request.

In certain situations, Ingeniarts 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.

A reasonable fee may be charged for the transcription, reproduction or transmission of Personal Information.

9. POLICY CHANGE AND UPDATE

Ingeniarts may, at its discretion, update, revise, modify or supplement this Policy from time to time. If a change is made to the Policy, you will be notified when you log in to your account and/or we will send you a link to the new version of the Policy. The Policy and any related agreements, if any, will be posted on the Platform. Ingeniarts will request that its users review the amended Policy before continuing to use the Platform.

The continued use of the Platform, after the amended Policy comes into effect, constitutes consent to such amended Policy.

10. EUROPEAN UNION DATA

This Section 10 only applies to Personal Information that is collected or processed on an individual located in the territory of the European Union at the time of such collection. 

  1. Right to erasure 

With some restrictions applicable, in accordance with the international application of the General Data Protection Regulation, you will be entitled to obtain from Ingeniarts the prompt deletion of your Personal Information and Ingeniarts is required to delete such Personal Information as soon as possible, where any of the reasons provided in the General Data Protection Regulation applies.

Where Ingeniarts has made the Personal Information public and is required to delete it, Ingeniarts, taking into account the available technologies and the costs of implementation, will take reasonable steps, including technical measures, to inform the data controller who process such Personal Information that you have requested that such data controller delete any link to or copy or reproduce such Personal Information.

This right of erasure shall not apply insofar as the Processing is necessary, in particular (i) for the exercise of the right to freedom of expression and information, (ii) for scientific research or statistical purposes, insofar as the right of erasure is likely to render impossible or seriously jeopardize the achievement of the purposes of the Processing; or (iii) for the establishment, exercise or defence of legal claims.

  1. Right to restrict processing

You will be entitled to obtain from Ingeniarts a restriction to process when any of the following applies (i) for a period of time that allows Ingeniarts to verify the accuracy of the personal data while you dispute the accuracy of the Personal Information; (ii) the processing is unlawful and you object to the deletion of Personal Information and instead require a restriction to process by limiting the Personal Information use; (iii) Ingeniarts no longer requires the Personal Information for the purposes of the processing, but it is still necessary for you to establish, exercise or defend legal rights; or (iv) you object to the processing during a verification as to whether the legitimate grounds pursued by Ingeniarts prevail over your own.

  1. Right to Data Portability

You will be entitled to receive the Personal Information you have provided to Ingeniarts, in a structured, commonly used and machine-readable format, and you will be entitled to transmit such Personal Information to a third party without Ingeniarts impeding it where the processing is based on your consent and the processing is carried out using automated processes.

  1. Right to Object

You may object, at any time, for reasons relating to your particular situation, to the processing of your Personal Information which is necessary for the legitimate interests pursued by Ingeniarts or by a third party or for the performance of a task carried out in the public interest or in the exercise of a public authority vested in Ingeniarts, including profiling. Ingeniarts will no longer process Personal Information unless we demonstrate that there are compelling legitimate reasons for the processing that prevail over your interests, rights and freedoms or for the establishment, exercise or defence of legal rights.

  1. Automated Individual Decision-Making, Including Profiling

You may not be the subject of a decision based exclusively on automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar manner, unless the decision is (i) necessary for the conclusion or performance of a contract between you and Ingeniarts; (ii) authorized by the law to which Ingeniarts is subject and which also provides for appropriate measures to safeguard your rights, freedoms and legitimate interests; or (iii) based on your explicit consent.

11. CONTACT US

To contact us, ask questions about this Policy, provide us with your comments, submit a request for access or correction, exercise any applicable rights, file a complaint or obtain information about our practices or policies, we invite you to contact our CPO at legal@ugowork.com.