Privacy Policy

Scope and Application

This Privacy Policy (the "Policy") describes the practices regarding the collection, use, and disclosure of personal information at Centiva Inc. It also governs the personal information collected from users of the Centiva website (the "Users") and explains how Centiva uses and discloses personal information collected from individuals who visit or interact with Centiva on centiva.ca (the "Website"). It also explains how Centiva uses cookies and similar technologies.

International Compliance

Centiva complies with: (i) applicable data protection laws relevant to Centiva; and (ii) industry standards related to the protection, privacy, and security of information. Centiva ensures at all times that Personal Information is protected by security and confidentiality procedures and safeguards that are at least equivalent to those used by Centiva itself.

Centiva adheres to this Policy as well as private sector data protection laws, such as the Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial laws that govern the collection, use, and disclosure of Personal Information. PIPEDA provides adequate protection of Personal Information in accordance with the European Commission's decision of December 20, 2001, under Directive 95/46/EC of the European Parliament and the European Council.

Definition of Personal Information

The term "Personal Information" refers to any information about an identifiable individual. This may include, for example, email addresses and contact details, as well as any similar information provided to Centiva in the course of its business activities or received by Centiva through business inquiries. Such information is not considered Personal Information when it is aggregated and cannot be associated with an identifiable individual.

Collection and Use of Personal Information via the Website

4.1 Information Provided by Users. In many cases, Centiva collects Personal Information directly from Users when they visit or use the Website. For example, Centiva may collect the following types of information:

• Questions. Centiva may collect the User's name, contact details, email address, and any other information provided when the User makes an inquiry to Centiva or communicates with Centiva from the Website, downloads documentation or secure content from the Website, or registers for a webinar or Centiva's newsletter.

• Submission of a Job Application. Centiva may collect the name, contact details, email address, and any other information provided by a User who submits a job application for a position posted on the Website.

• Website Personalization. When Users visit the Website, they may occasionally be asked to provide information, such as their position or the size of their organization, to help Centiva personalize the User experience on the Website.

• Google Analytics: Centiva uses Google Analytics, which allows it to view information about User activities on the Website, including, but not limited to, pages visited, source, and time spent on the Website. This information is anonymized and presented in the form of numbers, meaning it is impossible to trace it back to the individuals concerned. Users can block Centiva's use of Google Analytics by visiting the Google Analytics Opt-Out page.

• Google AdWords: Centiva uses the "Remarketing" feature of Google AdWords to promote Centiva on the Internet and on third-party websites (including Google) to previous visitors of the Website. AdWords Remarketing will display ads to Users based on the parts of Centiva's website they have visited by placing a cookie on the Users' web browser. This means that Centiva could promote its website to previous visitors who did not complete a task on the website or display an advertisement on the Google search results page or on a site within the Google Display Network. This cookie does not in any way identify Users and does not grant access to Users' computers or mobile devices. This cookie is solely used to indicate to other websites that the User has visited a specific page on the website, so that ads shown to the User are related to that page. If Users do not wish to participate in Google AdWords Remarketing, they can disable it by visiting the Control your Google AdWords ad settings page.

• Interest-Based Advertising: Centiva may also allow a limited number of trusted third parties to install cookies from the Website. The Website may include third-party advertisements and links to other websites that may be used to generate personalized advertisements. Personalized advertisements, sometimes called interest-based or behavioral advertising, are advertisements based on information about Users, such as pages visited, information requested, or purchases made on the Website. Centiva does not provide Personal Information to advertisers or third-party sites that display interest-based advertising on the Website. However, advertisers and other third parties (including advertising networks, ad-serving companies, and other service providers they may use) may assume that Users who interact with a personalized advertisement and personalized content displayed on the Website or click on them are part of the targeted audience for the advertisement or content. Advertisers or advertising agencies working for Centiva may sometimes use technologies to send the advertisements that appear on the Website directly to the User's browser. They may also use cookies to measure the effectiveness of their advertisements and to personalize advertising content. Centiva does not have access to or control over the cookies and other features used by advertisers and third parties. The data handling practices of these advertisers and third-party websites are not subject to this Policy. Please contact them directly for more information about their privacy practices. Generally, Users can also opt out of personalized advertisements from third-party advertisers and advertising networks that are members of the Digital Advertising Alliance of Canada (DAAC). Please visit the DAAC Opt-Out Page for more information.

Sharing of Personal Information

Centiva will not sell or trade Personal Information to any third party. However, Centiva may share Personal Information when authorized, when required by law, or in the following cases:

5.1 Service Providers. Centiva may allow access to Personal Information by a third-party service provider in connection with the performance or improvement of its Website. Before sharing any Personal Information with one of its third-party service providers, Centiva will ensure that the third party adopts reasonable data management practices to maintain the confidentiality and security of Personal Information and to prevent any unauthorized access.

5.2 If Permitted or Required by Law. Centiva may disclose Personal Information when required by applicable law or a competent legal or governmental authority. Centiva may also disclose information to its accountants, auditors, agents, and attorneys in connection with the enforcement and protection of its rights. Centiva may also disclose certain Personal Information when it has reasonable grounds to believe that such disclosure is reasonably necessary to protect the rights, property, and safety of others and itself in accordance with the law. If Centiva receives a regulatory or governmental request regarding a User's Personal Information, it agrees to immediately notify the User, unless prohibited, so that the User may choose to defend themselves against such a request. Centiva commits to reasonably cooperate with the User in connection with such a defense.

5.3 Business Transaction. Centiva may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, a merger, a reorganization, or the financing of parts of the business. However, if a transaction is completed, the Personal Information will remain protected by applicable data protection laws. If the transaction is not completed, Centiva will require the other party not to use or disclose the received Personal Information in any way and to delete it.

Security of Personal Information

Centiva will store and process Personal Information in a manner that conforms to industry security standards. Centiva has implemented procedures, policies, and technical, organizational, and administrative systems to ensure the security, integrity, and confidentiality of Personal Information and to reduce the risk of unauthorized access to or unauthorized use of Personal Information, including:

i) administrative, technical, and physical safeguards and other security measures designed to ensure the security and confidentiality of Personal Information under its custody;

ii) a security approach aimed at preventing the compromise of its own information systems, computer networks, and data files through unauthorized access by Users, viruses, or malicious software programs;

iii) appropriate internal practices, including, but not limited to, data encryption in transit, the use of appropriate firewalls and antivirus software, maintaining operating system and application prevention measures with up-to-date virus definitions and security patches to avoid any impact on Personal Information under its custody;

iv) appropriate logging and alerts to monitor access controls and ensure data integrity and confidentiality, with access control to systems and applications permitted only to authorized users; and

v) measures allowing access to systems and data only to authorized Users, ensuring that individuals with authorization to access Personal Information genuinely need to know it (the "Security Program").

Training and Supervision

Centiva maintains adequate training programs to ensure that its employees and any other persons acting on its behalf are aware of and comply with the Security Program. Centiva is committed to exercising the necessary and appropriate control over its relevant employees to maintain the security and confidentiality of the Personal Information under its custody.

Data Breach Notification

Centiva is committed to immediately notifying the User regarding a data protection breach or a compromise or violation of its Security Program:

(a) that has resulted in or is suspected to have resulted in unauthorized loss, disclosure, use, or acquisition of Personal Information (including physical copies thereof) or unauthorized access to Personal Information; and

(b) that, in Centiva's opinion, presents a real risk of significant harm to the individuals whose Personal Information is involved (a "Data Incident").

Although the initial notice may be in the form of a summary, a detailed written notice will be sent to the User within the time frame prescribed by law, if applicable. The notice will reasonably describe the nature and scope of the Data Incident (including each category of data) and the corrective measures already taken or to be taken by Centiva. Centiva will promptly take all necessary and recommended corrective measures and fully cooperate with the User to make all reasonable efforts to mitigate the harmful effects of the Data Incident and to prevent its recurrence.

User Rights Regarding Personal Information

To the extent that Centiva's processing of Personal Information is subject to the application of the General Data Protection Regulation (Regulation (EU) 2016/679), Centiva relies on the legitimate interests described above, which are not overridden by the Users' data protection interests, in the processing of Personal Information. Subject to applicable law, Users have the right to:

(i) access, rectify, and request the deletion of their Personal Information, subject to Centiva's right to retain a copy of certain Personal Information for archival purposes or to comply with any applicable legal requirements;

(ii) restrict or object to the processing of Personal Information by Centiva (which, in some cases, may involve ceasing to access the Website) when Centiva relies on a legitimate interest (or that of a third party) and when the particular situation affects the User's fundamental rights and freedoms;

(iii) file a complaint with their local data protection authority (contact details for the European Economic Area data protection authorities are available here); and

(iv) benefit from data portability. Users may exercise their rights at no cost, but Centiva may impose reasonable fees or refuse to comply with a request if it is unfounded, repetitive, or excessive.

Contact Us

Any questions or complaints regarding this Policy or the handling of Personal Information by Centiva can be sent by email to: info@centiva.ca.

Centiva will review and update its policies and procedures as necessary to account for rules and regulations, new technologies, standards, and customer concerns. Consequently, this Policy may be amended from time to time.