Policy on the management of personal information

Last updated on 2019–03–13

(see the changes since the previous version)

SE2 Inc. (“SE2”, “us”, or “our”) has developed and operates a point of sale management platform known as Alice POS (the “Platform”).

As Platform operator, we collect and use personally identifiable information (“Personal Information”) on a daily basis, and we may disclose this personally identifiable information to the authorities upon request. The key to our success is the trust that you have in us and we believe that, in order to earn and maintain your trust, it is very important that we be transparent on the manner in which we collect, use, disclose, protect and store your Personal Information.

 

The objective of our privacy policy (the “Policy”) is to allow you understand how we collect, use, disclose, protect and store your Personal Information. Do not hesitate to reach out to us if you have any question or comments on our Policy or on the manner in which we collect, use, disclose, protect and store your Personal Information. Ro that effect, you will find our contact information in the section entitled “How to reach us?”.

By providing us your Personal Information, whether by using our website, sending us an email or otherwise, you consent that your Personal Information be handled pursuant to this Policy and all applicable laws. We will never use or disclose your Personal Information in a manner that is inconsistent with this Policy or applicable laws without having obtained your consent prior to such use or disclosure.

If you do not consent that we collect, use, disclose and/or store your Personal Information, we ask that you do not provide us with your Personal Information, in which case, it is possible that we may not be able to provide you with certain services.

 

1. Your Obligations As Merchant

The protection of your Personal Information and those of your clients are very important to us. When you use the Platform, you have the obligation to ensure that you comply with all applicable laws (including privacy laws) in your handling of your clients’ Personal Information.

This processing is not covered by our Policy and you must provide your clients with your own privacy policy. To that effect, you hereby undertake to have a privacy policy that applies to your clients’ Personal Information and to maintain the compliance of such privacy policy with all applicable laws.

If you are a client of one of our clients and want to exercise any right granted to you by applicable privacy laws we invite you to communicate directly with our client.

 

2. What Personnal Information Do We Collect?

2.1      When you use our website

2.1.1 When you access our website, we may collect and process Personal Information such as your IP address and the different pages you access.

2.1.2 When you submit information to us through the various forms available on our website, we collect the information you submit to us in addition to the information described in the preceding paragraph.

2.2      When you use the Platform

As part of the Platform’s operation, we can collect and process different types of Personal Information, including:

  • your contact information, such as your email address, IP address, phone number;
  • Biographical information, for example, the name of your employer and your employment title;
  • financial information, such as your billing address, your bank account information or payment details;
  • information about your account, such as your username and password
  • information about our services, such as the industry in which you operate and the type of subscription to the Platform;
  • Any other Personal Information you could provide us.

2.3      When we send you promotional emails

At no time and under no circumstances will we send you promotional messages without first obtaining your consent. As part of promotional activities related to the Platform or in connection with our website we use technologies that allow us to know if you interact with the emails we send you and how you interact with their content.

Learn more about the Personal Information we collect:

Generally speaking, the term ” Personal Information ” means any information about an identifiable person or any information that identifies a person.

The Personal Information we collect depends largely on the context in which it is submitted, the choices you make and the services to which you have subscribed.

Personal Information provided on a voluntary basis

We collect the Personal Information that you provide us via a form on our website, via email and/or via instant messaging.

Personal Information of third party

If you provide us with Personal Information about other persons, you must ensure that you have duly informed them that you would provide us with their Personal Information and that you have obtained their consent to such disclosure. By submitting Personal Information about a third party, you represent and warrant that you have informed that third party and obtained its consent prior to such disclosure.

Personal Information collected automatically

Some Personal Information is collected automatically when you interact with our website and/or the Platform. This Personal Information cannot, in itself, identify you and includes your IP address, browser, technical information about the type of device you use, your operating system, your language preferences, address of origin as well as the different sections of our website and/or Platform you access.

We may also use cookies and/or other similar technologies to determine your level of engagement with the promotional emails we send you (only if you have consented to us sending you such emails). In such cases, we may determine whether you have opened, transferred and/or interacted with the content of such promotional emails.

This information is primarily used for statistical purposes. However, we may use automated decisions to determine which type of promotional material is best for you.

3. How Are We Using Your Personal Information?

At no time and under no circumstances do we sell your Personal Information. In addition, we undertake not to disclose your Personal Information to third parties or otherwise use your Personal Information otherwise than in accordance with this Policy.

We may use your Personal Information for any purpose determined at the time of collection of your Personal Information including any of the following:

  • in order to provide you with access to the Platform, our other services as well as for the continuation of our operations;
  • in order to facilitate the use of our website and to ensure the relevance of its content, including in order to respond to requests sent to us via our website and ensure the effectiveness of the content, both in its presentation as well as in its meaning;
  • for marketing and business development purposes, such as through client testimonials and/or case studies, when you consent to our publishing such testimony and/or case study;
  • in order to comply our legal, regulatory and/or risk management obligations;
  • for the purposes of corporate transactions;
  • any other purpose for which we obtained your consent.

Learn more about how we use your Personal Information and have more information about how we may use your Personal Information for each of the purposes mentioned.

Here are more details on the different purposes for which we may use your Personal Information:

Example of purposes:

Access to the Platform, to our other services and for the continuation of our operations

  • to comply with our obligations under the access agreement to the Platform;
  • manage and conduct our business, including billing, account administration, collection and payment processing;
  • set up a trial version or normal account to use our services;
  • to communicate with you to ensure your satisfaction;
  • to provide customer support;

Facilitate the use of our website and ensure the relevance of its content

  • to respond to requests sent to us via our website;
  • to ensure the effectiveness of the content, both in its presentation and in its relevance and impact.
Marketing and Business Development
  • to provide new services;
  • to communicate with you for marketing purposes (only to the extent that you have consented to such communications), for example in order to send you communications or documents (such as offers, demonstrations, presentation documents, newsletters and marketing materials);
  • to follow your interactions with our promotional emails and adjust our campaigns according to your preferences and/or behaviors.
Comply with our legal, regulatory and/or risk management obligations
  • perform due diligence on you and your business;
  • to prevent cases of fraud;
  • to enforce our rights;
  • to comply with our legal or regulatory obligations regarding the communication of information;
  • to protect the rights of others;

Corporate Transactions

  • to disclose your Personal Information as part of a due diligence on our business, for example, in connection with a sale of our business to a third party and/or as part of a transfer to any entity resulting from a corporate reorganization (merger, or amalgamation);

4. Anonymised and Agreegate Data for Statistical Purposes

We reserve the right to generate aggregate and anonymized data from the different transactions that are made and processed within the Platform. In such case, we will make sure that it is impossible to trace the data back to you.

 

5. With Whom do we Share your Personal Information?

We may share your Personal Information with the following third parties:

  • third party service providers. These third parties may have access to your Personal Information as part of the services they provide us. We limit the information we provide to these service providers to only the information that is reasonably necessary to enable them to perform their services.
    • As part of the operation of the Platform, we use the services of third parties for hosting, development, maintenance and technical support related to the Platform;
    • As part of our marketing activities, we use the services of third parties in relation to (i) the management of our customers and our business opportunities (eg PipeDrive); (ii) send out promotional emails (eg MailChimp); (iii) perform analysis on our website; and/or (iv) analyze the effectiveness of our promotional emails;
    • As part of our operations, we use banking institutions to process electronic payments (eg Stripe and/or PayPal), bookkeeping services (eg Freshbooks) and/or collection agencies to make sure we get paid for the services we provide you.
  • government authorities and law enforcement agencies, when required by applicable law.
  • the purchaser, successor or assignee in connection with any merger, acquisition, sale of assets or any similar transaction, and in the event of insolvency, bankruptcy or other transaction involving the transfer of Personal Information as a commercial asset to one or more third parties.

Also, we may disclose your Personal Information and other information if we are required to do so by law or if we believe in good faith that such disclosure is necessary to comply with applicable laws, in response to an order of a court or subpoena or government search warrant, or otherwise to collaborate with such government authorities and law enforcement agencies;

 

6. How Long Will we Retain and Where Will we Store Your Personal Information?

We will retain your Personal Information for as long as you use the Platform and thereafter for a reasonable period of time to enable us to comply with our legal and regulatory obligations. For more information about how long we keep your Personal Information, please contact us as described in the section entitled “How to reach us?”.

We may also keep aggregate and anonymized information for statistical purposes and/or to improve the Platform and our other services.

It is possible that some of our third party providers be located outside the province of Quebec and/or outside of Canada, for example, in the United States. You consent to the transfer of your Personal Information in countries other than your country of residence, where applicable privacy laws may be different from those in force in the province of Quebec and/or Canada.

When information is stored outside your country of residence, it is subject to the laws of the country in which it is located, and may be disclosed to governments, courts or enforcement agencies of the country in question.

 

7. How do we Protect you Personal Information?

We maintain appropriate physical, technical and administrative safeguards to protect your Personal Information against accidental or unlawful destruction, accidental loss, modification, disclosure or unauthorized access, misuse or other illegal form processing of your Personal Information that we have in our possession.

No method of Internet transmission or electronic storage is 100% secure. We can not ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We also can not guarantee that such information will not be accessed, obtained, disclosed, modified or destroyed as a result of the violation of our physical, technical or administrative safeguards.

If you have reason to believe that Personal Information has been compromised, please contact us as described in the section entitled “How to reach us?”.

 

8. What are Your Rights With Respect to Your Personnal Information?

Under certain circumstances and pursuant to applicable privacy laws, you have the following rights:

Access: You have the right to ask us if we have Personal Information about you and if we do, you have the right to obtain a copy of all Personal Information that we have about you.

Rectification: You have the right to ask us that we rectify any incomplete or inaccurate Personal Information that we have about you.

Withdraw you consent: You have the right to withdraw your consent to our processing of your Personal Information.

To exercise any of these rights, please contact us as described in the section entitled “How to reach us?”.

 

9. How do we Use Cookies and Other Similar Technologies?

For detailed information on how we use cookies and other similar technologies, please consult our cookies policy, which is incorporated in our Policy by reference.

We will collect, use and store certain information on how you interact with each of our digital marketing campaigns, such as the date and time on which you opened our emails, the number of times you opened our emails, whether or not you clicked links contained in our emails as well as which link you clicked on, the frequency on which you clicked on links or otherwise interacted with our emails. We will use this information to generate statistical models and we might aggregate this information with other information we have about you in order to improve how we communicate with you. Each email that we will send you will contain instructions on how you may unsubscribe from our campaigns and to let us know that you no longer wish to receive our promotional emails.

 

10. Third Party Websites and/or Thirs Party Applications

Our Policy does not apply to third party websites even if they are accessible via our website or the Platform. Also, it does not apply to any third party applications that you can install in the Platform. We may not be held responsible for the handling of your Personal Information by such third parties.

If an application is not identified as being “made by Alice POS”, we may not be held responsible for and we have no control over the manner in which the third party collects, uses, discloses and/or stores your Personal Information. The use of any third party application is made at your own discretion and your use of such third party applications should be made only if the third party offers adequate safeguards for your Personal Information.

All third parties might have their own privacy policy, which should cover how the third party collects, uses, discloses and stores your Personal Information. We invite you to read the applicable third party privacy policies prior to providing your Personal Information.

 

11. How to Reach Us?

If you have any questions or comments about our Policy (including obtaining a list of all third parties with whom we shared or may share your Personal Information), to lodge a complaint and/or to exercise your rights with respect to the Personal Information that we have about you, we invite you to communicate with our privacy officer,

By email : privacy@se2.ca

By regular mail:

Alice POS
400 Marquette street
Sherbrooke, Quebec J1H 1M4 Canada

 

12. How Will the Policy be Updated?

Because privacy laws are constantly evolving, it is possible that we modify our Policy at any time. Please refer back to this page for changes. Your use of the Platform after the effective date of the proposed changes will be deemed as your consent to the proposed changes.