Personal information protection policy

Semences Prograin inc. and Prograin International Inc. (jointly referred to as “Prograin”) attach great importance to the confidentiality of your personal information. The goal of this Policy is to explain how we collect, use and communicate the personal information you might provide to us or that we might otherwise hold concerning you and to comply with the Canadian legislation relating to protection of personal information and, when applicable, to the General Data Protection Regulation (“GDPR”).

1.       Scope of this Policy

This Policy applies to the personal information that is in Prograin’s possession or under its control, including the information we may transfer to a third party for storage or processing purposes.

This Confidentiality Policy does not apply to information concerning the employees of Prograin’s suppliers.

2.       Acceptance

By using this website or any other Prograin website, you signify your acceptance of this Policy. Likewise, by submitting your personal information to us, you also accept that it be governed by this Policy.

Please note that this Policy applies only to our websites and not to the websites of other companies or organizations to which our websites may be linked. Prograin does not endorse and is not responsible for these linked websites.

Your consent may be withdrawn at any time, subject to legal and contractual restrictions and reasonable notice. Please note that if you choose to withdraw your consent, Prograin might not be able to provide you with certain services.

3.       Amendments to the Policy

We reserve the right to amend this Policy at any time by posting the amended conditions on our website. Please consult this Policy on a regular basis.

4.       Collection of Your Personal Information

Prograin only collects information you have consented to provide to us. We do not sell, lease or share information concerning you except in the manner described hereinafter.

Prograin limits the collection of your personal information to what is necessary for the purposes of the establishment, management and maintenance of our relationship with you. For example, personal information could be collected at the time of your registration, your subscription to receive our newsletter or our alerts, or the submission of questions, comments or suggestions, and could include, non-exhaustively, identification information such as your first name and your family name, your sex, your date of birth, your home address, your telephone number, your email address, your billing data, etc.

In general, we collect this personal information from you directly. However, we could also collect information concerning your from external sources with your consent or, when the law permits this, without your consent.

5.       Cookies

Your use of this website allows the Prograin to compile automatically certain information concerning your user profile, which may include the Internet protocol address (or IP address) of your computer, the operating system you use, the identity of your Internet service provider, the date and time when you accessed this website, the previous website you visited that provided you with a link to our website, and the content viewed and downloaded on our website.

To do this, our website, like most websites, uses cookies, which are saved on your computer when you visit it. We use this information to adapt our website to your preferences, including the advertising shown, and to compile statistics concerning the consultation and use of its website in order to improve it.

As with most Internet browsers, it is possible to delete cookies from your computer’s hard drive, block the creation of cookies or receive a warning before a cookie is saved. By doing this, however, your use of our website may be affected and it is possible you will no longer have access to all its functions. We invite you to consult the Ads Setting and Network Advertising Initiative website and the instructions or the Help section of your browser for more information.

6.       Use of Your Personal Information

Prograin could use your personal information for the following purposes:

Prograin might also use your personal information to compile statistics. However, these statistics will not allow you to be identified.

Your personal information will not be used for purposes other than those described above unless your consent is obtained or to the extent permitted or required by law.

7.       Communication of Your Personal Information

Prograin acknowledges that, except in the cases and on the conditions stated hereinafter, the communication of your personal information to a third party requires your consent.

Access to this information within Prograin does not require your consent, but is limited strictly to the persons for whom this information is necessary to the performance of their duties and tasks.

Prograin also could share information concerning you, without your consent, with agents, mandataries, data processors, service providers and other parties for whom this is necessary in the course of Prograin’s activities or to assist Prograin in the administration of our business relationship (assistance for promotions, providing technical support, etc.).

Prograin could also, without your consent, communicate information concerning you contained in a file it holds on you, as authorized or required by law.

In each situation where Prograin could communicate your personal information, the company will endeavour not to communicate more personal information than is necessary in the circumstances.

Please note that in the event the third party to whom Prograin communicates information concerning you is established in a foreign country, the local statutes might otherwise permit access to your personal information by third parties without your consent.

8.       Security Measures

Prograin applies reasonable security measures depending on the sensitivity of the information we hold. These measures seek to protect your personal information against theft or loss, and against any unauthorized consultation, communication, reproduction, use or modification.

We also take reasonable measures to ensure that the personal information we have collected is accurate and complete. However, it is incumbent on you to inform us of any change in your personal information.

9.       Processing of Personal Information of Persons Located in the European Economic Area (EEA)

This section applies exclusively to the processing of personal information in relation to the EEA, to the extent that this processing occurs when the persons concerned are located in this Area and when the processing activities are related to the offering of goods or services or monitoring of the behaviour of these persons which occurs within the EEA. The provisions of this section take precedence over those of this Policy, in case of conflict.

9.1     Consent

If your consent is provided in a written statement that pertains to other matters, Prograin will ensure that the request for consent concerning the processing of personal information is clearly distinct. Prograin will have to obtain your explicit consent to proceed with processing of sensitive personal data, as applicable.

9.2     Collection, Retention and Use of Personal Information

Prograin will not retain personal information longer than is necessary to implement the purposes for which it was collected, and Prograin will take reasonable measures to make known in advance the period during which this personal information may be retained or the criteria allowing this period to be determined.

9.3     Automated Individual Decision-Making

Prograin acknowledges that you have the right to know if your personal information is processed by an automated decision-making system. On request, Prograin will provide you with information on the functioning of this automated system. Unless this is required by law, you have the right to refuse that a decision based exclusively on an automated system be made in your regard, when this decision has legal consequences for you.

9.4     Impact Assessment Related to Protection of Personal Information

Prograin will proceed with an impact assessment related to protection of personal information before implementing new technologies that are very likely to infringe your rights and freedoms, including your right to privacy.

9.5     Right to Deletion

When the law prescribes it, you have the right to require Prograin to proceed with the removal and deletion of personal information, without delay.

9.6     Accuracy and Protection

Before collecting personal information, Prograin will implement appropriate technical and organizational measures to ensure protection of personal information, such as limitation of collection and pseudonymization.

Prograin will not share personal information with agents, mandataries, consultants, data processing enterprises or external service providers except when they ensure that appropriate measures have been deployed to protect personal information. Processing of personal data by agents, mandataries, consultants, data processing enterprises or external service providers is the object of a contact or another type of legal document.

9.7     Responsibility

Prograin ensures that it is responsible for protection of personal information and that it is able to prove its compliance with the GDPR when it processes personal information. For this purpose, it keeps a register of processing operations, when this is required, and trains its employees on protection of personal information.

9.8     Complaint Procedure, Right of Access or Correction

Prograin will take the necessary measures to facilitate the exercise of your right to access, correction or obtaining of personal information. You can always obtain confirmation from Prograin that personal information concerning you is the object of processing.

Any correction or deletion of personal information will be communicated to the third parties to whom this information will have been disclosed.

10.     Questions and Queries

Any question or concern regarding this Policy or relating to the collection, use and communication of your personal information, including requests for access or correction, shall be transmitted in writing to:

alexandre.beaudoin@prograin.qc.ca

You have the right to consult and obtain communication of information concerning you contained in a file held by Prograin. You may also request the correction of inaccurate, incomplete or equivocal information and obtain the deletion of information that is not justified regarding the objective sought by the file.

Prograin will respond to each request for access and correction within 30 days of receipt of the written request. In the event that Prograin cannot give you access to your personal information or correct it, it will inform you of the reasons for this impediment and will inform you of the possible remedies.