Privacy Policies
Updated: January 26, 2024
Below is the complete English translation of the provided privacy policy text:
Propulsion Technologies Inc. (“Propulsion”, “we”, “our”) takes the protection of your privacy and personal information very seriously. This Privacy Policy (the “Policy”) is intended to explain how we collect, use, disclose, store, and safeguard your personal information. It also outlines the various ways to contact us, including how to exercise your rights under this Policy and obtain further information when needed.
This Policy applies to visitors of our website, namely: www.propulsionsport.com (the “Site”), and to users of our Propulsion platform (the “Platform”). The Site and the Platform are collectively referred to as our “Services” for the purposes of this Policy. If you follow hyperlinks from our Site to another website, please note that we are not responsible for, and have no control over, their privacy policies and practices, which we strongly encourage you to review.
By using our Services or providing us with your personal information, you consent to its collection, use, disclosure, and retention in accordance with the terms set forth herein. We advise you to read this Policy carefully. If you do not agree with it, please do not disclose your personal information to us and discontinue your use of the Services.
1 - Personal Information
This Policy applies to the personal information collected, used, disclosed, and retained by Propulsion.
For the purposes of this Policy, “Personal Information” means any information about an identifiable person, including any data that can directly or indirectly identify that person. Generally, we do not consider business contact details as Personal Information when they are used to contact you in your professional capacity or regarding your company.
This Policy does not apply to the Personal Information of Propulsion’s employees, consultants, or other individuals associated with Propulsion.
2 - Personal Information Protection Program
To protect your Personal Information, we have established policies, practices, and procedures regarding the management of the Personal Information we hold.
These internal policies and procedures govern the collection, use, disclosure, retention, and destruction of personal information, as well as the handling of complaints, information security, and data governance at Propulsion. They also provide the framework for conducting privacy impact assessments when necessary, as well as for preventing and responding to potential privacy incidents. All of these policies and practices have been approved by our Privacy Officer.
The collection of your Personal Information through our Services complies with the requirements of this program.
Privacy Officer
The highest-ranking person in our organization has delegated the management of the Personal Information Protection Program to our Privacy Officer. Their responsibilities include managing and monitoring Propulsion’s internal personal information protection program.
The Privacy Officer approves and implements the policies and procedures for personal information protection, ensures their proper operation, and reports to Propulsion’s senior management on the effectiveness of the program.
The Privacy Officer is also responsible for providing you with the necessary support in the event of a question, complaint, or request regarding the protection of Personal Information:
Azaria Chavannes
President and Privacy Officer
Propulsion Technologies Inc.
410, Rue de Marika,
Québec, QC,
G3G 1L6
support@propulsionsport.com
We are committed to responding promptly to your requests.
Upon receiving a complaint, the Privacy Officer will conduct an investigation. If the complaint is justified, the situation will be remedied. Regardless of our findings, we will keep you informed.
3 - Basis for the Collection of Personal Information
Propulsion must collect and process certain Personal Information so that you can use our Services.
When we collect your Personal Information, we ensure that we only gather the information necessary to achieve one of our previously disclosed objectives (for example, as set out in this Policy). We use Personal Information in accordance with the privacy laws applicable to our activities.
Below is a description of the basis for the collection and processing of your Personal Information by Propulsion:
With your consent
As required by applicable privacy laws, Propulsion collects most of your Personal Information based on your voluntary consent, favoring direct collection from you.
Propulsion is committed to obtaining your explicit consent for the collection of any sensitive personal information.
Because our Services are intended for corporate clients, we do not have a direct business relationship with the end user of the Platform. This is why we require our clients to ensure that they have obtained all mandatory consents from the end users of the Platform when necessary. In particular, the end users should have been informed that their Personal Information may be transferred to service providers, such as Propulsion.
We also ask our clients to provide the legally required notices to the end users of the Platform and to ensure that the use, collection, or disclosure of Personal Information between Propulsion and the client is permitted.
Other permitted legal basis, such as contract implementation
As permitted by applicable privacy laws, Propulsion may collect Personal Information without your explicit consent, for example, to comply with legal obligations or to fulfill our contractual obligations.
4 - Personal Information We Collect
We collect Personal Information when you interact with our Services, including when you:
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Create an account or update your profile information.
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Use our Platform or our Site.
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Subscribe to our Services.
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Communicate with our customer service or support team.
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Participate in surveys, contests, or promotions.
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Submit feedback, reviews, or other content.
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Interact with our advertisements and promotional content.
The Personal Information we collect may include, but is not limited to, your name, email address, phone number, communication preferences, IP address, device information, location data, activity data, payment information, and information regarding your use of our Services.
Automatically Collected Data
When you use our Services, we may automatically collect and store the following information:
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Date and time of visits;
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Location (with your consent);
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IP address of connection;
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Hardware and software details, such as mobile device type, unique identifier, operating system, and, if applicable, mobile identifiers like Apple’s IDFA or Google Android’s AAID;
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Clicked links;
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Duration of your visit on the Site; and
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Content viewed.
Non-Automatically Collected Data
We may also collect the following information when you perform certain functions on our Services, such as completing a form or creating your account and using the Platform:
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First and last name;
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Email address;
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Phone number;
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Mailing address;
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Activity data, such as your step count, active minutes, type of workout performed, as well as the time and duration of workouts.
Personal Information We Collect
We only collect the Personal Information that helps us achieve the objectives set out in this Policy. We do not collect any additional information without informing you beforehand.
5 - How We Use Your Personal Information
We use your Personal Information for the following purposes:
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To provide, update, and improve our Services.
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To personalize your experience and tailor the content we display.
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To inform you of updates, changes to our terms, conditions, and policies, special offers, promotions, or newsletters.
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To communicate with you, including to respond to your questions, inquiries, comments, complaints, and support requests.
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To analyze the usage of our Services, including identifying usage trends, the effectiveness of our promotional campaigns, and business activities.
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To comply with any applicable law or regulation, or to act in accordance with it, including, but not limited to:
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Responding to requests from public or governmental authorities (including authorities outside your country of residence);
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Protecting our operations and legitimate interests or those of our subsidiaries;
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Enabling us to pursue available remedies or limit any damages we might incur, etc.
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For any other purpose for which you have provided consent.
If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will obtain appropriate consent or inform you of the change, as permitted by law.
6 - Sharing of Personal Information
Your Personal Information will not be sold to third parties. We will share your Personal Information with third parties in the following cases:
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When it is necessary to provide our Services or respond to your request.
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If required by law, court order, or to protect our legal rights.
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To fulfill tasks assigned to us by contract from our clients.
Most of the time, you have already consented to such sharing. In some cases, applicable laws also allow us to share your Personal Information with third parties without your consent.
More specifically, we may need to share your Personal Information, sometimes without your consent:
With our employees:
In the course of their work, our employees and managers may need to access your Personal Information, for example when you contact us. Their access is limited to what is necessary to perform their tasks.
With our service providers:
Our business partners may sometimes need to access or receive certain Personal Information to perform their services (such as payment processors, cloud data hosting providers, maintenance, analytics, fraud detection, and development). In such cases, we implement reasonable contractual and technical safeguards, including privacy impact assessments, to ensure that these third parties keep all Personal Information they process strictly confidential.
Please note that these third parties may be located outside your country, province, or territory of residence. We have contractual agreements with these third parties and service providers to ensure that your Personal Information is processed in accordance with the applicable laws. Where applicable, we conduct privacy impact assessments before transferring Personal Information to another jurisdiction (for example, outside Quebec).
With authorities or persons authorized by law:
We may share your Personal Information if required by law or if we believe in good faith that such action is necessary to:
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Comply with the law;
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Comply with the order of a competent judicial authority in any jurisdiction;
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Comply with a judicial process;
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Protect and defend the rights or property of Propulsion;
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Enforce or verify your compliance with any part of the contracts you have entered into with us, if applicable;
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Prevent fraud or any other illegal activity carried out through our Services; or
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Act in urgent circumstances to protect the personal safety of users of our Services or the general public.
With potential buyers of our company:
We may be required to share your Personal Information without your consent in the event of a merger, acquisition, or sale of all or part of the company (for example, during due diligence). In such cases, we will limit the sharing to what is necessary to assess the feasibility or opportunity of the transaction.
7 - Retention of Personal Information
Propulsion will retain your Personal Information only for as long as necessary to achieve the purposes for which it was collected, in accordance with our internal document retention policies, and to comply with applicable legal, tax, or regulatory requirements, until you request its destruction or for a period of seven (7) years. After such a period, any Personal Information held by Propulsion will be destroyed, deleted, or anonymized.
You may also request the deletion of your account by sending an email to support@propulsionsport.com.
8 - Security of Personal Information
We take technical, administrative, and physical protection measures to safeguard your Personal Information against loss, unauthorized access, disclosure, alteration, misuse, or destruction. These protection measures vary according to the sensitivity of the data in our possession and are based on industry best practices. Unfortunately, no system for data transmission or storage can be guaranteed to be 100% secure.
How We Protect Your Personal Data
Your Personal Information is hosted by our service providers, who commit to using reasonable security measures to preserve the integrity and confidentiality of your Personal Information.
To protect your security, we use the most robust browser encryption available and store all our data on servers in secure facilities.
Our employees and providers are informed of the confidential nature of the Personal Information collected and are trained on appropriate security measures to prevent unauthorized access to Personal Information.
If you have any questions regarding the security of your interactions with us (for example, if you believe the security of any account you may have with us has been compromised), you can contact us at support@propulsionsport.com.
Children
We do not knowingly collect or use Personal Information from children under the age of 14. If we learn that we have collected Personal Information from a child under the age of 14, it will be deleted as soon as possible. If a child under the age of 14 has provided us with Personal Information, their parent or guardian may contact our Privacy Officer.
9 - Your Choices and Rights
Depending on the applicable laws, where you reside, and how you interact with the Services, you may be granted certain rights regarding the Personal Information we hold about you.
You may have the right to:
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Access your Personal Information and correct it if it is inaccurate or incomplete.
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Request the deletion of your Personal Information.
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Obtain additional information, for example, about the categories of third parties with whom we share your Personal Information.
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Object to the processing of your Personal Information based on our legitimate interests and ask us to restrict the processing of your Personal Information.
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Request the portability of your Personal Information in a structured, commonly used, and machine-readable format.
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Refuse to receive marketing communications from Propulsion.
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Withdraw your consent at any time if we have collected and processed your Personal Information based on your consent. The withdrawal of your consent will not affect the legality of the processing carried out before your withdrawal, nor the processing of your personal information carried out based on legitimate grounds other than consent.
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Lodge a complaint with a supervisory authority for the protection of personal information, for example with a privacy commissioner or the Commission d’accès à l’information.
How to Exercise Your Rights
You can review, correct, update, modify, or delete the Personal Information you have provided us by using your account. Simply log in to your account and make the necessary changes.
You may also exercise your rights listed above by submitting a written request to our Privacy Officer. They will assist you with your request if needed.
For your protection, we will only process requests to exercise rights if they come from the same email address you use to log in to your account. We may also need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time, and any required information, as applicable. We strive to respond to requests promptly, usually within 30 days.
For the processing activities covered by this Policy, Propulsion does not make decisions solely based on automated processing that produce legal effects or similarly significant effects.
Lodging a Complaint
You may file a complaint with Propulsion’s Privacy Officer if you are dissatisfied with our handling of your Personal Information or our compliance with this Policy.
You are also entitled by law to file a complaint with a privacy commissioner or any other competent supervisory authority for the protection of personal information.
Your Choices Regarding the Use and Disclosure of Your Personal Information
The information you provide may be used by Propulsion for marketing purposes, including, but not limited to, one-off promotional emails, direct mailings, and business contacts. We offer you several options regarding our use and disclosure of your Personal Information for marketing, location data, Cookies, or online advertising. You may disable:
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Our electronic marketing communications: You can refuse to receive these emails by sending a removal request to support@propulsionsport.com. You may unsubscribe from our mailing lists at any time. If you request this, we will no longer use your contact details for marketing purposes.
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Certain location data: You can disable the use of certain location data on your device.
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Non-essential Cookies: You can disable these Cookies according to the procedure mentioned in the “Cookies” section below.
Cookies
A cookie is a small text file stored in a designated location on your computer, mobile device, tablet, or any other device when you use your browser to visit an online service. This Policy includes within the term “Cookie” other tracking technologies, including web beacons and tracking pixels. These tracking technologies are not necessarily stored on your computer or device. All Personal Information we collect via Cookies or on our behalf is processed with the same level of confidentiality as all other Personal Information we hold.
Essential Cookies
These Cookies are necessary for the operation of the Site and provide basic functions, and may include maintaining your session and preventing security threats. We cannot disable these Cookies in our systems without affecting the functionality of the Site. However, if you wish, you can block or delete them by modifying your browser settings to block all Cookies on the Site.
Non-Essential Cookies
Non-essential Cookies provide certain non-essential functionalities on our Site for functional, analytical, or advertising purposes. We will ask for your consent before using these Cookies.
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Functional Cookies: We use these Cookies to facilitate non-essential features of our Site, such as embedding content like videos or sharing Site content on social media.
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Advertising Cookies: Our Site displays advertisements. These Cookies help us track the effectiveness of our advertising campaigns and personalize our ads so that they are relevant to you.
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Analytical Cookies: These Cookies store information such as the number of visitors on our Site or which pages they visited. They help us understand and analyze the performance of our Site and potential improvements.
Managing Cookies
You can manage and disable Cookies through your browser’s cookie settings and your mobile device’s advertising settings. However, if you refuse Cookies, you may not be able to use all the features of the Site, and you will continue to receive advertising, but it may no longer be as relevant to you.
Your Choices Regarding Online Advertising
We may collect your Personal Information to present you with advertisements for goods and services and may work with online advertising companies to display relevant and useful ads to you.
We may also use your mobile advertising identifier to target and measure the effectiveness of advertising campaigns. On iOS, this identifier is called the “IDFA” (Identifier for Advertising); on Android (Google Play), it is called the “AAID” (Android Advertising ID).
You can control the collection and use of your Personal Information for online advertising by expressing your preferences on your mobile devices. You may also control the use of your mobile advertising identifier by resetting the IDFA or AAID or by limiting its use in your mobile device settings.
Social Media Features
Our Site includes social media features such as LinkedIn, Facebook, or Instagram share buttons, or interactive mini-programs that operate on our Site. If you use these features, they may collect your IP address, the page you visit on our Site, and create a Cookie to allow these features to function properly. These features may be hosted by a third party or directly on our Site.
Modifications
This Policy may be amended from time to time to remain compliant with applicable laws and to reflect any changes to our data collection processes. When we make significant changes to this Policy, we will notify you by posting an announcement on our Site or by email. In all other circumstances, posting a new version of the Policy on our Site or your continued use of the Services will constitute sufficient notice and acceptance of the changes.
Technical Support
For any questions related to technical issues with our Services regarding your access or use of their features, please contact us at: support@propulsionsport.com
This translation is provided for your convenience. In the event of any discrepancy between this translation and the original French version, the French version shall prevail.