Privacy Policy

DATED 2024-05-06 · VERSION 20240710_rev01 · COMPARED WITH 20240602_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20240602_rev01 to 20240710_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 The purpose of this privacy policy (the "**Privacy Policy**") is to inform you about our privacy practices, including how we collect, use and disclose your Personal Information (as defined herein). We respect your privacy and we are committed to safeguarding your privacy while online at our websites, together with any other websites, applications and services offered by Valnet (collectively, the "**Sites**" and individually, a "**Site**") and as such, the following further discloses the information gathering and dissemination practices for the Sites.
 This Privacy Policy was last updated on May 6, 2024.
+##### Privacy Policy Updates
+##### PRIVACY POLICY UPDATES
 This Privacy Policy is current as of the "updated" date which appears at the top of this page. We may modify this Privacy Policy from time to time. When changes are made to this Privacy Policy, they will become immediately effective when published in a revised Privacy Policy posted on the Sites, unless otherwise noted. We may also communicate the changes through our services or by other means we deem appropriate, so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
 Please review this Privacy Policy carefully. By submitting your Personal Information to us, by registering for or using any of the services we offer, by using our Sites, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your Personal Information as set out in this Privacy Policy, as revised from time to time.
+##### Definition of Personal Information
+##### DEFINITION OF PERSONAL INFORMATION
 "**Personal Information**" means information about an identifiable individual. This information may include, without limitation, your name, mailing address (including postal code or zip code), e-mail address, telephone number and payment information.
 Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as, without limitation, your name, position name or title, work address, work telephone number, work fax number or work electronic address.
 Personal Information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.
+##### Legal Ownership
+##### LEGAL OWNERSHIP
 The Sites are owned and operated by Valnet Inc. ("**Valnet**", "**us**" or "**we**"), a corporation incorporated under the laws of Canada, having its head office at 7405 Transcanada Highway, Suite 100, Saint-Laurent, Quebec H4T 1Z2, and/or its subsidiaries.
+##### Your Consent to Collection, Use and Disclosure
+##### YOUR CONSENT TO COLLECTION, USE AND DISCLOSURE
 We collect, use and disclose your Personal Information with your consent or as permitted or required by applicable privacy laws. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the Personal Information in question.
 If you choose to provide Personal Information to us, we assume that you consent to the collection, use and disclosure of that Personal Information as outlined in this Privacy Policy, as we deem appropriate.
 If you wish to withdraw your consent to our collection, use or disclosure of your Personal Information, please contact us at [data@valnetinc.com](mailto:data@valnetinc.com). However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.
 If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy under all applicable circumstances.
+##### Personal Information Collected
+##### PERSONAL INFORMATION COLLECTED
 When you visit our Sites, we collect certain information related to your device, such as your internet protocol ("**IP**") address, what pages you visit on our Sites, whether you were referred to our Sites by another website, and at what time you accessed our Sites. We will not collect any information without your prior explicit consent.
 We do not collect any other type of Personal Information. If you are accessing our Sites through a social media account, please refer to the social media provider's privacy policy for information regarding their data collection.
 We track and store data about how you visit and use our Sites. More specifically, the Personal Information we collect includes, but is not limited to:
 - Your browser language;
 - The URLs of any pages you visit on our Sites and apps; and
 - Other usage information.
 We combine this data with other information we collect about you. If your browser does not accept our cookies, you cannot access certain parts or sections of our Sites (e.g., your account(s) on our Sites).
+##### Accessing, Amending and Deleting your Information
+##### ACCESSING, AMENDING AND DELETING YOUR INFORMATION
 You have the right to request information regarding the data we have on file for you, and to request corrections and/or deletions of your Personal Information. Please contact us at [data@valnetinc.com](mailto:data@valnetinc.com), for any inquiries or requests regarding your information.
 Please note that we comply with the following ID partners' privacy terms:
 - LiveRamp's country-specific terms when it comes to the collection, use, and disclosure of user information. If you have any questions about the extent of the information collected, please visit: [https://liveramp.com/authenticated-traffic-solution-country-specific-terms/](https://liveramp.com/authenticated-traffic-solution-country-specific-terms/).
     If you would like to opt out, please visit: [https://liveramp.com/opt\_out](https://liveramp.com/opt_out) or [https://youradchoices.com/token](https://youradchoices.com/token)
 - ID5's country-specific terms relating to the collection, processing, and transferring of user personal data. If you have any questions about the nature and extent of the information collected, please consult: [https://www.id5.io/privacy-policy](https://www.id5.io/privacy-policy)
 - Criteo's privacy terms, which can be accessed here: [https://www.criteo.com/privacy/](https://www.criteo.com/privacy/)
+##### Log Files
+##### LOG FILES
 Like most standard website servers, we use log files. This includes logging the following information: IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/timestamp, and number of clicks to analyze trends, administer our Sites, track user's movement in the aggregate, and gather broad demographic information for aggregate use.
+##### Cookies
+##### COOKIES
 A cookie is a piece of data stored on the user's computer tied to information about the user. We and some of our business partners (for example, advertisers) use cookies on our Sites. These cookies track usage of our Sites for security, analytics and targeted advertising purposes.
 - **Essential Cookies:** These cookies are essential to the provision of our Sites.
 - **Functionality Cookies:** These cookies help us remember choices you have made while on our Sites, remember your preferences, and personalize your experience on our Sites.
 - **Analytics and Performance Cookies:** These cookies help us collect statistical and analytical usage to help us analyze your usage of our Sites.
 - **Social Media Cookies:** These cookies allow you to interact with content on certain social media platforms, such as "liking" our articles. Depending on your social media setting, the social media network will have record of this and may display your name or identifier in relation to this action.
 - **Advertising and Targeted Advertising Cookies:** These cookies track your browsing habits and location to provide you with advertising in line with your interests. Please see our "Advertisers" section below for further details.
 - **Shared ID Cookies:** These cookies store a unique user id in the first party domain and is accessible to our ad partners. This simple ID can be utilized to improve user matching, especially for delivering ads to iOS and MacOS browsers. Users can opt out of the Shared ID tracking cookie by clicking [here](https://prebid.org/product-suite/sharedid/).
 If you wish to disable cookies, you may do so through your individual browser options. For further information regarding cookies and how to manage them, please see [https://allaboutcookies.org/](https://allaboutcookies.org/).
+##### Pixel Tags
+##### PIXEL TAGS
 We use pixel tags, which are small graphic files that allow us and our trusted third-party partners to track your usage of our Sites and collect usage data, including the number of pages you visit, the time you spend on each page, what you click on next, and other information about your visit to the Sites.
+##### Advertisers
+##### ADVERTISERS
 We use third-party advertising companies to serve ads when you visit our Sites. These companies may use information (such information does not include your name, address, email address or telephone number) about your visits to our Sites and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, [click here.](http://www.networkadvertising.org/managing/opt_out.asp)
 Advertisers, as third-party vendors, use cookies to collect usage and demographic data in order to serve ads on our Sites. For example, Google's use of the DART cookie enables it to serve ads to our users based on their visit to our Sites and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.
+##### Advertising Partners
+##### ADVERTISING PARTNERS
 We have used commercially reasonable efforts to review our advertising partners' policies to ensure that they comply with applicable data privacy laws and recommended data security practices.
 We use the following advertisers:
 - Google Ad Exchange: [https://policies.google.com/privacy](https://policies.google.com/privacy)
 - Conversant: [https://www.conversant.com/privacy-policy/](https://www.conversant.com/privacy-policy/)
 - Fluct: [https://en.fluct.jp/#about](https://en.fluct.jp/)
 - Equativ: [https://equativ.com/about-us/](https://equativ.com/about-us/)
 - Teads: [https://www.teads.com/ad-policies/](https://www.teads.com/ad-policies/)
 - One Tag: [https://www.onetag.com/](https://www.onetag.com/)
+##### Service Providers
+##### SERVICE PROVIDERS
 We rely on third-party services providers to perform a variety of services on our behalf, such as, without limitation, e-commerce providers, payment card processors, telephone and technical support providers, hosting, data storage and processing service providers, and research and analytics providers. Our partners, including ad partners, may collect data in relation to your usage of our Sites as disclosed herein. All such data will only be collected with your prior explicit consent. If we provide your information to service providers, then we require that the service providers keep your Personal Information secure, and only handle it for limited purposes for which it is provided. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes.Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; and (f) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your Personal Information and other information to a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.
 If we otherwise intend to disclose your Personal Information to a third-party, we will identify that third-party and the purpose for the disclosure, and obtain your consent.
+##### Links to Other Websites
+##### LINKS TO OTHER WEBSITES
 Our Sites may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage our users to be aware when they leave our Sites, and to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by our Sites.
+##### Purpose of Information Collection
+##### PURPOSE OF INFORMATION COLLECTION
 We use the information we collect in order to:
 - Administer our Sites, including troubleshooting, and statistical or data analysis;
 - To improve our Sites and enhance user experience by ensuring you have access to personalized content in line with your interests;
 - Analyze user use and optimize our services;
 - To ensure that our Sites remain secure and are not subject to any hacking or fraud; and
 - Share information with our partners to provide targeted advertising and social media features.
 We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law. We may use the information we collect to advertise third-party products and services or targeted advertising of our Sites' products and services across third-party websites or service offerings.
+##### How Your Information is Stored
+##### HOW YOUR INFORMATION IS STORED
 All information collected through our Sites is stored on servers located in the United States. Our servers are certified under the EU-U.S. Data Privacy Framework.
 IP address and user agent string data from all visitors is stored in rotating log files on Amazon servers for up to seven (7) days. All of our employees, agents and partners are committed to keeping your data confidential.
+##### Consent under Applicable Laws
+##### CONSENT UNDER APPLICABLE LAWS
 If you are based in the European Economic Area (the "**EEA**"), a consent window will appear when accessing our Sites. If you have clicked "yes", your consent will be stored on our servers for twelve (12) months and your data will be processed as disclosed in this Privacy Policy. After twelve (12) months, you will be asked to provide consent again.
 We comply with the IAB Europe Transparency & Consent Framework.
 You can withdraw consent at any time. Withdrawing consent may impede your ability to access certain services and will not allow us to provide the personalized Site experience.
+##### Data Security
+##### DATA SECURITY
 Our servers comply with ISO 27018, a code of practice that focuses on protection of Personal Information in the cloud. We comply with all reasonable precautions in order to ensure your information's safety.
 In the event that we become aware of any data security breach, alteration, unauthorized access or disclosure of any Personal Information, we will take all reasonable precautions to protect your information and will notify you as required by all applicable laws.
 We have implemented physical, organizational, contractual and technological security measures with a view of protecting your Personal Information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your Personal Information are those with a business 'need-to-know' or whose duties reasonably require such information.Despite the measures outlined above, no method of information transmission or information storage is absolutely secure or error-free, and as such, we cannot guarantee absolute security.
 - Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them); and
 - Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).
 Rather than delete your information, we might de-identify it by removing identifying details.
+##### Sensitive Personal Information
+##### SENSITIVE PERSONAL INFORMATION
 Our Sites do not intentionally collect any sensitive Personal Information, including:
 - Your social security number;
 - Your racial or ethnic origin;
 - Your political opinions;
 - Your health, biometric or genetic characteristics;
 - Any trade union membership; and
 - Any criminal background.
 There are rare situations when we request this information (e.g., a reader survey asks about your political leanings), but you can decline to answer. Outside those situations we would prefer you never share that information with us.
+##### Age
+##### AGE
 Our Sites do not target people below the age of sixteen (16). By visiting our Sites, you hereby warrant that you are sixteen (16) years of age or older or are visiting our Sites under parental supervision.
+##### Legal Disclaimer
+##### LEGAL DISCLAIMER
 Though we make every effort to preserve user privacy, we may need to disclose Personal Information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on us or any of our Sites.
+##### Online Accounts and Services
+##### ONLINE ACCOUNTS AND SERVICES
 If you choose to participate in, register or access any of our services including, but not limited to, online accounts or online content, such as community forums, commenting features, surveys, or newsletters, we will request and receive Personal Information such as your name, email address, postal address, telephone number, login details, including username and password or other contact details you may provide, as required. This Personal Information will then be held by us in accordance with this Privacy Policy, as it is necessary for us to carry out the services for which you registered. We may also use this information to improve the function of our Sites, online accounts and services and to prevent any abuse to our Sites.
 You can choose to opt-out or unsubscribe from a newsletter or other emails you may receive from us by utilizing the "unsubscribe" link or mechanism noted in such emails, at any time. For forum account deletion requests, where applicable on our Sites, you may use the Forums Data Deletion Request Form. You can also submit a request to access or erase your data, or any other request to exercise your rights under applicable privacy legislation by contacting us at [data@valnetinc.com](mailto:data@valnetinc.com). Should you have multiple email addresses subscribed or registered with us, you may continue to receive newsletters and/or communications until you unsubscribe each email address provided and/or delete your account(s).
+##### Contact Information
+##### CONTACT INFORMATION
 If users have any questions or suggestions regarding our Privacy Policy, please contact us at [data@valnetinc.com](mailto:data@valnetinc.com) or by mail at the postal address listed above, attention: Data Compliance Department.