Last update: October 1, 2024

INGENIARTS TECHNOLOGIES INC. (“UgoWork”, “our”, “we” or “us”) takes your privacy and the protection of your Personal Information seriously. This Privacy Policy (the “Policy”) describes our privacy practices, the types of Personal Information we may receive or collect from you and how we use, disclose, host and secure it, so that you can make wise and informed choices.

This Policy applies to our website available at https://ugowork.com/ and addresses associated therewith (the “Website”). However, we wish to draw your attention to the fact that the rights and obligations described in this Policy do not cover third-party websites that may be linked to or mentioned on the Website. These third-party websites have their own privacy policies, and we encourage you to read them carefully. 

1. PERSONAL INFORMATION

For the purposes of this Policy, “Personal Information” means any information about an identifiable individual, including information that can be used alone or in combination with other information to identify, contact or locate a single individual. In general, Personal information does not include business contact information, such as your name, title, or business contact information. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be Personal information.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

The Personal Information we collect may include, but is not limited to:

Any other Personal Information you have provided to us.

  • Your contact information, such as your first and last name and e-mail address and IP address in order to identify you and correspond with you;
  • Information about your use of our services such as type of service, date of use, duration of presence on the Website and pages clicked on;
  • Marketing information and your communication preferences, as well as your comments, feedback, requests, complaints or survey responses; and

3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Directly to you

Generally, we collect the Personal Information we need directly from you, for example (i) via our Website; (ii) when you complete an information request on our Website; or (iii) when you contact us. We may also collect information relating to your use of the Website, including technical information about your connection and access to the Website collected through cookies. For more information in this regard, please read the section “How do we use cookies?“.

With your consent

We generally collect your Personal Information with your consent, unless applicable law provides an exception to this principle (for example, to comply with our legal obligations, when necessary to establish, exercise or defend a legal claim or proceeding). 

Refusal of collection and withdrawal of your consent

You have the right, if you so choose, to refuse the collection, use and disclosure of your Personal Information. You may also, at any time, and subject to reasonable notice and any applicable legal or contractual restrictions, withdraw your consent (if any) to the processing of your Personal Information in our possession or under our control by contacting our Privacy Officer. You should be aware, however, that if you choose not to provide us with your Personal Information, this may prevent you, for example, from using and accessing some features and functionalities of the Website, if such information is essential to such access. Please note, however, that anonymized information, i.e., information that does not allow you to be identified, may be retained if you withdraw your consent. You can contact us as indicated in the “How to Contact Us” section if you have any questions on this subject.

4. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

For specific and limited purposes 

UgoWork generally collects your Personal Information for the following purposes:

  • To provide and maintain the services requested, such as providing you access to the Website;
  • To study trends and generate usage statistics in order to improve the use of our Website and your user experience; 
  • To maintain and improve the security of the Website, including for diagnosing technical problems or improving functionality, as long as the data collected is used for this purpose;
  • To respond to your requests for information or assistance;
  • As permitted or required by any applicable legal or regulatory obligation or provision, including responding to law enforcement or government requests; and
  • Any other purposes to which you have consented (collectively, the “Purposes”). 

To send you messages

If you have consented to receive such information, UgoWork may send you newsletters, electronic messages such as e-mails, news, updates and/or other written communications (“Messages”) about UgoWork’s services and/or the products and/or services of its partners. You may choose not to receive the Messages in the manner indicated in the “How to Contact Us” section or through the unsubscribe link included in the Messages. 

For secondary purposes

Depending on the circumstances, UgoWork may also aggregate and anonymize the Personal Information you have provided, to create statistical data that UgoWork may use for secondary purposes to improve the Website, examine trends and interests. This statistical data does not include any Personal Information.

5. HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?

UgoWork does not rent or sell any of your Personal Information to third parties and will not share it with third parties without your consent, unless required by law or for the reasons set out below.

With our employees

In the course of their work, our employees, directors and officers may need access to your Personal Information, for example, when you contact us, order a service or request assistance. Their access is limited to what is necessary for the performance of their duties.

With strategic partners

UgoWork may share your Personal Information with its partners in order to facilitate its activities, such as developers, analytics, newsletter and hosting service providers. Our service providers may have access to your Personal Information for a limited time in connection with their business activities. When UgoWork uses third parties to process your Personal Information, UgoWork endeavours to implement commercially reasonable contractual and technical protections, so that these third parties keep strictly confidential all Personal Information they process. Please note that these third parties may not be located in your geographical location. In this case, UgoWork takes commercially reasonable measures, as described below in the section “Where is your personal information hosted and transferred?”.

When required by applicable laws

We may also share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with the law; (ii) comply with an order of a competent judicial authority in any jurisdiction; (iii) comply with legal process served on UgoWork; (iv) protect and defend the rights or property of UgoWork; (v) enforce or verify your compliance with any agreement you have entered into with UgoWork, if applicable; (vi) prevent fraud or other illegal activity perpetrated through the Website; or (vii) act in urgent circumstances to protect the personal safety of users of the Website, or the general public.

Business transfers or during a commercial transaction

We may share your Personal Information without your consent when our business transactions require it (for example, in the event of a merger). In such circumstances, we may also share all or part of your Personal Information with relevant third parties (or their advisors) for the purposes of a due diligence process.

For other purposes, with your consent

Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific cases where additional conditions apply and through these, we make it clear that specific third parties are processing your Personal Information.

6. THIRD-PARTY SERVICES AND PLATFORMS

We may include links on the Website to third-party sites or services that we do not control, for example, if you use an integrated Google feature (e.g., Google Drive, etc.). These third parties may share certain information about you with us. If you click on one of these links, you will be directed to sites that we do not control. Please read the privacy policies of those sites, applications or platforms that may collect Personal Information to understand their privacy policies and Personal Information collection practices. This Policy applies only to Personal Information processed by or on behalf of UgoWork.

7. HOW DO WE USE COOKIES?

A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. Other tracking technologies, such as web beacons and tracking pixels, may be used for similar purposes. In this Policy, all such tracking technologies are collectively referred to as “Cookie(s)”. Any Personal Information collected using Cookies by or on behalf of UgoWork (if applicable) is treated with the same level of confidentiality as any other Personal Information held by UgoWork.

Essential Cookies

These Cookies are necessary for the operation of the Website and cannot be deactivated in our systems. Strictly necessary Cookies must be present in order for the Website to perform basic functions and may include logging in, adding new features and other services. They enable a user to navigate from one page to another without losing previous actions in the same session.

Non-essential Cookies

If you have consented to their use, UgoWork and/or its third-party partners may also use non-essential Cookies in connection with the Website, including the following:

  • Functionality Cookies: These Cookies are not essential to the provision of our services. They enable us to personalize and improve the user experience. For example, if you have consented to their use, these Cookies will store your communication preferences.
  • Analytical or Tracking Cookies. We may use analytical or tracking Cookies to better understand traffic patterns on the Website (e.g., Google Analytics, Hotjar, Hubspot), to help us measure and improve the effectiveness of the Website, or the Messages, to determine whether these Messages have been opened and whether the links they contain have been clicked. These Cookies are used for statistical purposes only. All information collected by these Cookies is aggregated. To refuse to be tracked by Google Analytics, consult this module: https://tools.google.com/dlpage/gaoptout?hl=fr. To refuse to be tracked by Hotjar Analytics, consult this module: https://www.hotjar.com/legal/support/dpa/. To refuse to be tracked by Hubspot, consult this module: https://legal.hubspot.com/dpa.  You can also refuse the use of analytics or tracking Cookies by following the instructions below.

Deactivation of Cookies to which you have consented

With the exception of essential Cookies, we will only place Cookies on your device with your consent, and these Cookies will be kept for a maximum period of thirteen (13) months from the moment they are installed on your device. At the end of this period, your consent will again be required. You can also manage your Cookies by changing the settings on your browser or device. For details on how to configure your browser, please consult the help center for Chrome, Safari, Firefox, Internet Explorer, Edge or Opera. However, if you choose to refuse Cookies, some pages or sections of our Website may not display correctly or some features may no longer be available. 

You can manage your Cookie preferences and modify your consent at all times by accessing our Cookie management tool (Consent Choice in the footer of https://ugowork.com/).

Cookies can also be managed and/or deactivated via your browser’s Cookie settings. If you would like more information on how to manage and/or disable non-essential Cookies, please visit https://allaboutcookies.org/ and https://optout.aboutads.info/?c=3&lang=en.

8. WHERE IS YOUR PERSONAL INFORMATION HOSTED AND TRANSFERRED?

Your Personal Information may be stored by UgoWork in regions other than your province, territory or country of residence, including in the United States. UgoWork may also subcontract the processing or share your Personal Information with third parties located elsewhere, in regions other than your province, territory or country of residence. In such cases, we endeavour to limit access to Personal Information by such third parties to that which is necessary to perform the tasks entrusted to them.  Please be aware that we also strive to put in place contractual arrangements with these agents and service providers to ensure the confidentiality and security of your personal information. This may include implementing robust and effective security measures. If you have additional questions about this, you may contact us. 

9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Personal information will be retained only as long as necessary for the fulfillment of the Purposes or as required by law. At the end of this period, we endeavour to destroy or anonymize such information. In determining the appropriate retention period for your Personal Information, we take into account the amount, nature and sensitivity of the Personal Information, the potential risk of harm arising from unauthorized use or disclosure of your Personal Information, the Purposes for which we process your Personal Information and the possibility of achieving those Purposes by other means, as well as applicable legal, regulatory, tax, accounting or other requirements. If you would like more information on this subject, please contact us as indicated in the “How to Contact Us” section.

10. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

With necessary and appropriate measures

UgoWork has implemented security measures to protect your Personal Information. The standard security measures we use depend on the type of information collected. However, UgoWork uses electronic, physical and procedural safeguards to protect your Personal Information. 

11. WHAT ARE YOUR RIGHTS?

Depending on applicable legislation, you may have various rights such as the right to request the deletion of your Personal Information, the right to access or rectify your Personal Information, the right to withdraw your consent (if any), the right to be informed of a decision based exclusively on automated processing, the right to de-index, or the right to data portability, i.e., the right to receive a copy of all Personal Information that UgoWork holds about you in a structured, commonly used and machine-readable format. To exercise any of these rights (to the extent they are available), please contact us as indicated in the “How to Contact Us” section. 

12. HOW TO CONTACT US

UgoWork has established procedures to receive complaints and inquiries regarding its policies and practices relating to the management of Personal Information, including the retention and destruction of Personal Information, the role and responsibilities of UgoWork’s employees, directors and officers and the handling of complaints relating to the protection of Personal Information. UgoWork’s employees, directors and officers and the handling of complaints regarding the protection of Personal Information. We will inform individuals who make inquiries or lodge complaints of the existence of the relevant procedures. UgoWork will investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices. If you have any questions about any aspect of this Policy, wish to send a comment, file a complaint or exercise any of the rights available to you under applicable law, please contact our Privacy Officer as follows:

Philippe BeauchampAddress: 1065 Lescarbot, Suite 200 Quebec, QC, Canada, G1N 1X6E-mail: philippe.beauchamp@ugowork.com  Phone number: +1-418-262-0126

Your request may be accepted or denied by UgoWork according to applicable laws. UgoWork will take prompt corrective action upon becoming aware of any breach of this Policy. UgoWork shall not be liable for any indirect, incidental, consequential or punitive damages related to this Policy. You may at any time file a complaint with the appropriate authority if you believe that UgoWork is not handling your Personal Information in a manner consistent with this Policy or applicable laws.

13. MODIFICATIONS AND UPDATES TO THE POLICY

UgoWork may, at its discretion, update, revise, modify or supplement this Policy from time to time. If material changes are made to the Policy, you will be notified when you log in and/or we will send you a link to the new version of the Policy. The Policy and any related documents, if any, will be posted on our Website. UgoWork asks its users to review and accept the revised Policy before continuing to use its Website.