Privacy Policy

GSoft Technologies Inc. offers tools and platform commercialised as “Officevibe” which provide the means to measure and increase employee commitment by giving them a voice within their organization (the “Officevibe Platform”). GSoft Technologies Inc. understands the importance of protecting Personal Information (as defined below). For this reason, GSoft Technologies Inc. strives to have business procedures and security safeguards in place to protect Personal Information under its control.

  1. Application and Scope

    This Privacy Policy describes our practices with respect to the collection, use and disclosure of Personal Information by GSoft Technologies Inc. and our affiliated entities in Canada, such as Groupe GSoft Inc. and Laboratoire d’Innovation Technologique GSoft Inc. (collectively, “Officevibe”).

    This Privacy Policy (this “Policy“) is intended to establish responsible and transparent practices for the management of Personal Information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Officevibe in respect of any Personal Information collected, accessed or processed by Officevibe in the course of its business operations and specifies the obligations of Officevibe that arise from Officevibe Terms of Service (available at https://officevibe.com/terms) (the “Terms”) entered into between Officevibe and its corporate customers (each, a “Customer”), whereby Officevibe might handle or have access to Personal Information.

    This Policy also governs Personal Information collected about Officevibe’s website Users (as defined in the Terms) and explains how Officevibe uses and discloses Personal Information collected from people who visit its website and otherwise interact with Officevibe through https://officevibe.com and its sister websites provided by Officevibe (including, https://help.officevibe.com) (collectively, the “website”). It also explains how Officevibe uses cookies and similar technologies. If you do not agree with this Policy, do not access or use the Officevibe Platform and any related services (the “Services”) or the website.

  2. Definition of Personal Information
    “Personal Information” is defined as any information about an identifiable individual. This may include, for example, email addresses and contact details and any similar information provided to Officevibe in the course of its business operations, or which Officevibe may receive from business inquiries. Personal Information that is aggregated and/or anonymized or that cannot be associated with an identifiable individual is no longer considered Personal Information.
  3. International Compliance

    Officevibe complies with: (i) data protection laws applicable to Officevibe; (ii) anti-spam legislation applicable to Officevibe; and (iii) applicable industry standards concerning data protection, confidentiality or information security. Officevibe has global operations and therefore, in some cases, information managed by Officevibe may be transferred, processed and stored to other countries, although at all times Officevibe will ensure that Personal Information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Officevibe itself.

    Officevibe complies with this Policy as well as applicable Canadian private sector data protection laws such as the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and substantially similar provincial laws pertaining to the collection, use and disclosure of Personal Information. PIPEDA provides for an adequate protection of Personal Information according to the European Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and the Council.

    Officevibe also complies with the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act 2018 and the GDPR as saved into United Kingdom law by virtue of Section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018. Where applicable, our commitment to such regulation may be found in our Data Processing Addendum. Officevibe (or third parties acting on Officevibe’s behalf) may transfer Personal Information that Officevibe collects to countries outside of the European Economic Area. Where such transfer occurs, Officevibe will take steps to ensure that Personal Information is protected. Officevibe will make such transfers only if at least one of the following conditions are present:

    1. Officevibe has entered into a contract based on the “Standard Contractual Clauses”, provided that such contract, combined with technical and organizational measures, offers appropriate safeguards for the rights of the individuals whose personal data is being transferred;
    2. Such transfer is governed by “Binding Corporate Rules”, which have been approved by data protection authorities; or
    3. Such transfer is covered by a European Union Commission “adequacy decision”. You can find out more about this here.
  4. Collection and Use of Personal Information through the Services
    When providing the Services, Officevibe only processes Personal Information in accordance with the Terms and applicable laws. Officevibe generally uses Personal Information from or about its Customers and Users for the following purposes:
    1. to create, establish and administer Customer’s account, to process payments, to respond to Customer’s inquiries related to its account and to contact Customer about Officevibe’s Services or account-related matters;
    2. to provide Services, including to provide Customer and its Users with access and use of the Officevibe Platform and customer support;
    3. to manage and develop Officevibe’s business and operations;
    4. to measure and analyze User behavior;
    5. to monitor, maintain and improve Officevibe’s Services or features;
    6. to understand how Users interact with Officevibe and ensure our services, products or features work correctly;
    7. to develop new services, products, features, programs and promotions;
    8. to understand Customers and Users’ needs and preferences and customize how we tailor and market products, programs and Services to our Customers and Users based on their interest;
    9. to meet legal and regulatory requirements and to allow Officevibe to meet contractual requirements relating to the Services provided to Customer;
    10. to conduct surveys on the quality of Officevibe’s Services or to collect feedbacks on the Services;
    11. to provide Customer with offers for additional services, features and products that Officevibe believes may be of interest to Customer;
    12. to conduct market or benchmarking research and data analytics by tracking and analyzing current or previously collected Personal Information; and
    13. to measure the effectiveness of our marketing.

    When possible, Officevibe will use Personal Information in an aggregated and/or anonymized format.

    Unless required or authorized by law, Officevibe will not use Personal Information for any other or new purpose without obtaining prior consent.

  5. Collection and Use of Personal Information through the Website
    Officevibe generally collects and uses Personal Information from or about its website Users as follows:
  6. Legal bases for processing Personal Information
    Pursuant to privacy laws applicable in the European Economic Area and in the United Kingdom, Officevibe collects and processes Personal Information about individuals under a variety of legal bases, depending on the reason for such collection or processing. Officevibe shall only collect, process or use Personal Information where:
    • Personal Information is required to provide the Officevibe Platform and all services ancillary to the proper functioning of the Officevibe Platform, such as support services, to provide a personalized experience, and to ensure the safety and security of the Officevibe Platform;
    • The Customer or User gave Officevibe consent to use Personal Information for a specific purpose (including for a purpose listed under section 4 hereof);
    • Processing of Personal Information is necessary to comply with a legal obligation;
    • Processing of Personal Information is warranted by a legitimate interest of Officevibe (which is not overridden by your data protection interests), such as the purposes listed in paragraphs (g), (h) and (i) of section 4 hereof, or to protect Officevibe’s legal rights and interests.
  7. Sharing of Personal Information
    Officevibe will not sell, rent or trade Personal Information to any third party. However, Officevibe may share Personal Information when authorized and/or required by law or as follows:
  8. Security of Personal Information
    Officevibe will store and process the Personal Information in a manner consistent with industry security standards. Officevibe has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal Information and to mitigate the risk of unauthorized access to or use of Personal Information, including: (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the Personal Information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized Users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with appropriate reasonable up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal Information that it manages; (iv) appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; and (v) permitting only authorized Users access to systems and applications, and all persons with authorized access to Personal Information must have a genuine business need-to-know prior to access (together, “Security Program”).
  9. Data Retention
    Officevibe will retain the Personal Information as necessary for the purposes described in this Policy, unless a longer retention is required by law or justified by a legitimate business interest of Officevibe, subject to applicable laws. Notwithstanding the foregoing, upon termination of the Terms, Officevibe shall retain the Personal Information stored in the Officevibe Platform until Customer instructs Officevibe to delete the Personal Information or until Customer’s access to the Services is terminated in accordance with the Terms, whichever occurs first.
  10. Training and Supervision
    Officevibe maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. Officevibe shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the Personal Information it manages.
  11. Data Incidents Involving Personal Information
    Officevibe shall promptly notify Customer of a data breach, of a loss of data or of a failure of Officevibe’s Security Program:
    1. which has resulted or is suspected to have resulted in the loss, unauthorised access, disclosure, use or acquisition of Personal Information (including hard copy records); and
    2. which, in Officevibe’s opinion, presents a real risk of significant harm to individuals whose Personal Information is impacted (“Data Incident”).
    While the initial notice may be in a summary form, a comprehensive written notice shall be given to Customer within the legally required timeframe, where applicable. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action taken or to be taken by Officevibe. Officevibe shall promptly take all necessary and advisable corrective actions, and shall cooperate with Customer in all reasonable efforts to mitigate the adverse effects of Data Incidents and to prevent their recurrence.
  12. Users Legal Rights Regarding Personal Information
    To the extent that Officevibe’s processing of Personal Information is subject to the General Data Protection Regulation (Regulation (EU) 2016/679) or to the Data Protection Act 2018 and the GDPR as saved into United Kingdom law by virtue of Section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018, Officevibe relies on the legal bases described under section 6 hereof to process Personal Information. Subject to applicable laws, all Users have the right to: (i) access and rectification or erasure of Personal Information, including erasure and deletion of their profile on the Officevibe Platform, except to the extent that Officevibe may need to retain certain Personal Information, including for record keeping purposes or to comply with legal obligations; (ii) restrict or object to Officevibe’s use of Personal Information (though, in some cases, this may mean no longer using the Services or the website) where Officevibe is relying on a legitimate interest (or those of a third party) and there is something about User’s particular situation which impacts on User’s fundamental rights and freedoms; (iii) lodge a complaint with their local data protection authority (contact details for data protection authorities in the European Economic Area are available here); and (iv) data portability. Users will not have to pay a fee to exercise such rights, however, Officevibe may charge a reasonable fee or refuse to comply if the request is unfounded, repetitive or excessive.
  13. How to Contact Us
    Any questions or complaints or requests regarding this Policy or Officevibe handling of Personal Information can be addressed by sending an email to [email protected]. A User who seeks to exercise its data protection rights referred to in Section 12, in respect of Personal Information stored or processed by us on behalf of a Customer (e.g. the employer), must direct his/her query to such Customer, as being the data controller. If Officevibe receives such User’s request to exercise its data protection rights referred to in Section 12 (including for access to or correction of Personal Information), Officevibe shall redirect the User to Customer and, upon request from Customer, shall assist Customer in responding to such request, if applicable.
  14. Change of Privacy Policy
    Officevibe will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. This Policy may therefore change from time to time. If Officevibe makes changes that materially alter Users privacy rights, Officevibe may provide additional notice, such as via email or through the Services or the website. If Users disagree with the terms of this Policy, their only remedy is to discontinue use of the websites and the Services.

This Policy was last updated on April 1st, 2022.

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