Accolades Marketing Inc.

Privacy Policy

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1. Purpose

This policy applies to all processing of personal data carried out by Accolades Marketing Inc. and aims to inform the user about how Accolades Marketing Inc. processes personal data (including details on the type of personal data collected and the purpose of processing) and about the user's rights in relation to their personal data.

2. Contact - How can I get in touch?

If you have any questions regarding the privacy policy, you can contact Accolades Marketing Inc. by the following means:

• The headquarters is located at: 21-3 Boulevard Queen-Victoria, Sherbrooke, Qc, Canada J1H3P4
• The contact phone number is: 438 389-2996

The user can establish direct and effective communication with Accolades Marketing Inc. in writing by sending a communication to the address indicated or by sending an email to: jonathan@lesaccolades.com Furthermore, the information of the person responsible for processing your personal data is as follows:

• Name: Accolades Marketing Inc.
• Identity of the responsible party: Accolades Marketing Inc.
• Address: 21-3 Boulevard Queen-Victoria, Sherbrooke, Qc, Canada J1H3P4
• Email: jonathan@lesaccolades.com

3. Identification of Processing - How do we collect personal data?

In accordance with current regulations on the protection of personal data, in particular,

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, "GDPR"),
• Argentine Law No. 25.326 on the protection of personal data, its regulatory decree 1558/01 and its supplementary norms (the "Argentine LPDP"),
• The General Data Protection Law of Brazil, Law No. 13.709, (the "LGPD")
• The California Consumer Privacy Act (CCPA), Bill No. 375
• Canadian Anti-Spam Legislation (CASL) and Personal Information Protection and Electronic Documents Act (PIPEDA).
• Virginia Consumer Data Protection Act (VCDPA).
• Australian Privacy Act No. 1988 (APA)

Accolades Marketing Inc. collects personal data in its possession when the user:

• (i). Fills out forms at www.lesaccolades.com ("Site");
• (ii). Subscribes to the newsletter;
• (iii). Responds to a survey or fills out an online form;
• (iv). Fills out a printed form;
• (v). Sends an email or communicates by phone, which are then uploaded into the corresponding forms;

4. Personal Data Collected - What personal data do we collect?

Accolades Marketing Inc. collects information when visiting their web page, primarily through completing its registration forms.

The following data is collected: full name, email, and phone number.

Generally, when personal data is required to use a service or access certain content, its provision will not be mandatory, except in cases where it is specifically indicated that it is a required data for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.

The user declares and guarantees that all data provided by him are true and accurate and commits to updating them. Changes can be communicated to the Data Protection Officer or at the address indicated in paragraph 2 above.

Similarly, the user acknowledges that the data required by Accolades Marketing Inc. are necessary, adequate, and not excessive to achieve the purposes expressed in paragraph 5 above, which would be impossible to achieve if these data are not provided.

Any false or inaccurate statement that results from the information and data provided, as well as the damages that such information could cause, will be the responsibility of the user.

5. Purpose - What are the personal data we collect used for?

The personal data requested from the user will be used for the following purposes:

• In the case of a contract for services offered on the site, to create and maintain the commercial relationship and to carry out the activities and provide the services of Accolades Marketing Inc. (including, without limitation, management, administration, provision, and improvement of services).
• To send newsletters, as well as commercial communications, promotions and/or advertisements from Accolades Marketing Inc., either occasionally or periodically. Consequently, the email address that the user provides when completing the form on the site may be used to send information and updates on the service request, as well as news about Accolades Marketing Inc. (either occasionally or periodically), updates, information about related products or services, among others. This processing is based on our legitimate interest in promoting our products and services.
• To conduct a survey or organize a contest.
• To personalize the user experience, increasing our ability to respond to their needs.
• To improve the site and the service offering of Accolades Marketing Inc., relying on the legitimate interest of Accolades Marketing Inc. to constantly improve its products and services.
• To process transactions and comply with legal obligations to which Accolades Marketing Inc. is subject, such as tax obligations. The data submitted for processing will not be used for purposes other than those mentioned above and which motivated their collection. Notwithstanding the foregoing, it is specified that the recorded data may be used, in addition to the purposes for which they were expressly collected, for statistical purposes, incident management, or market studies. However, in case of processing of personal data for purposes other than those initially specified at the time of collection of these data, a compatibility analysis will be carried out by Accolades Marketing Inc. in accordance with applicable regulations. Processing will only be authorized if the initial purpose is compatible with the new purpose or authorized in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or the legal justification for the processing of their data. We remind the user that they can oppose the sending of commercial communications (unsubscribe) and no longer receive emails from Accolades Marketing Inc., by reliably informing Accolades Marketing Inc., who will proceed to the interruption as soon as possible after receiving such communication. To this end, they can send an email to the address indicated in section 2, a postal letter to the address indicated in section 2 above, or directly follow the unsubscribe instructions detailed at the end of each email from Accolades Marketing Inc.

6. How do we use your information?

We will use the information we collect about you for the following purposes:

• Administration Information
• Testimonials
• Customer Feedback Collection
• Enforcement of Terms and Conditions
• Support
• Targeted Advertising
• Administration Information
• Site Protection
• Dispute Resolution

If we want to use your information for other purposes, we will ask for your consent and will only use your information when you have given your consent and only for the purpose (or purposes) for which you have given your consent, unless we are required to do otherwise by law.

We will keep your personal information with us for 14 months after user accounts are no longer active or for the duration necessary to fulfill the purposes for which they were collected, as indicated in this privacy policy.

7. Consent

By providing personal data to Accolades Marketing Inc., the user declares to accept their processing fully and unreservedly by Accolades Marketing Inc. The user hereby grants their free, express, and informed consent to Accolades Marketing Inc. to use the data collected for the purposes indicated in section 5 above, as well as their incorporation into a database of Accolades Marketing Inc.

Accolades Marketing Inc. performs the processing of the user's data legitimized by: (i) the conclusion of a service contract with Accolades Marketing Inc. by the user, according to the terms and conditions that are made available to the user at the end of the completion of the service request form (before a possible hiring) and that the user (after having read them), and if they agree, can accept by checking the box that has been included for this purpose; and (ii) the free, informed, and unequivocal consent of the user, given after having reviewed this privacy policy where Accolades Marketing Inc. informs the processing it will carry out with your data, and if you agree, by checking the box that has been included for this purpose in the service request form. The processing of data that is not covered by one of the legal bases indicated above, will be carried out if Accolades Marketing Inc. deems it necessary to protect a legitimate interest and only if they do not infringe on the fundamental rights and freedoms of the user.

8. Expiration - How long do we keep them?

The data will be destroyed or archived when they are no longer strictly necessary or relevant for the purposes detailed in section 5 above. In particular, personal data will be kept as long as the commercial relationship is in force (and to the extent that the user has not previously requested their deletion) and for the period during which obligations, compensations, and/or responsibilities may arise in the context of the commercial relationship or for the services provided. Accolades Marketing Inc. informs that it will keep the essential information to identify the origin of the stored data for the duration of the client relationship with Accolades Marketing Inc. and/or the revocation of the user's consent in accordance with the information contained in section 5 of this privacy policy and/or the duration required by applicable law.

9. Confidentiality / Assignment / International Transfer - Do we disclose data to third parties?

Accolades Marketing Inc. will keep the personal data collected privately and confidentially and will not use them for purposes other than those established in section 5 above. Accolades Marketing Inc. requires the signing of confidentiality agreements and personal data processing by its employees and third parties who provide services that access the content of the databases (or include such obligations in the service agreements it signs with such providers as indicated in the following paragraph).

The user's personal data collected by Accolades Marketing Inc. will not be transferred, sold, exchanged, transmitted, and/or communicated to third parties outside of Accolades Marketing Inc. without the user's consent, except for legal obligation and/or for the purpose of providing services to the user. This does not include certain employees and service providers who enable Accolades Marketing Inc. to maintain the site operational, to comply with the purposes established in section 5 above and/or to provide services to the user, who have assumed the obligation to maintain the confidentiality of the data provided and commit to comply with the applicable regulations on personal data protection, at the time of hiring. The contracts with service providers stipulate the purpose, scope, content, duration, nature, and purpose of data processing, the type of personal data, the categories of data owners, and the obligations and responsibilities of Accolades Marketing Inc. and the contractual third parties.

In particular: Accolades Marketing Inc. may share the personal information provided with controlling companies, subsidiaries, affiliated companies, related companies, and/or intermediaries related to Accolades Marketing Inc.

Accolades Marketing Inc. may share certain personal information provided by the user internally within Accolades Marketing Inc., with certain departments, such as administration, marketing, or IT.

**- In some cases, Accolades Marketing Inc. transfers personal data based on a legitimate interest and the economic and technical benefits associated with the use of specialized suppliers. In this regard: - Maps. Accolades Marketing Inc. uses Google Maps to include maps on the site. Integration with Google Maps allows Google to collect the user's IP address. The user can consult the privacy policy and other legal aspects of said company at the following address: http://www.google.com/intl/fr/policies/privacy/. - YouTube. The Site contains links to YouTube in connection with videos related to the services of Accolades Marketing Inc. As indicated in Section 13 above, by using these links, the user leaves the Site and is redirected to the YouTube page. The user can consult the privacy policy and other legal aspects of YouTube through the following link: https://policies.google.com/privacy - Facebook. Accolades Marketing Inc. has integrated Facebook components on the Site. In particular, Accolades Marketing Inc. uses the Facebook advertising platform. The company operating Facebook services is Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The user can consult the privacy policy and other legal aspects of said company through the following link: https://en-en.facebook.com/about/privacy/. - Instagram. The Site contains links to Instagram. As indicated in Section 13 above, by using these links, the user leaves the Site and is redirected to Instagram. The user can consult the privacy policy and other legal aspects of Instagram through the following link: https://help.instagram.com/155833707900388. - Linkedin. The Site contains links to Linkedin. As indicated in Section 13 above, by using these links, the user leaves the Site and is redirected to Linkedin. The user can consult the privacy policy and other legal aspects of Linkedin through the following link: https://www.linkedin.com/legal/privacy-policy. - Twitter. The Site has links to Twitter. As indicated in Section 13 hereof, by using these links the user leaves the Site and is redirected to Twitter. The user can consult the privacy policy and other legal aspects of Twitter at the following link: https://twitter.com/privacy ** **- Social networks. Accolades Marketing Inc. also uses social networks, such as Facebook or Instagram, and has integrated functions of these networks into its services. The user can only use these social networks to the extent that they are registered and have accessed the corresponding social network with their user. These social networks have their own privacy policies and their own general conditions, over which Accolades Marketing Inc. has no interference or control. **

Finally, the user should know that Accolades Marketing Inc. may (and that Accolades Marketing Inc. reserves the right to) disclose its information in the following cases: (i) if required by a judicial or administrative authority; (ii) if necessary to exercise your rights under the general conditions of Accolades Marketing Inc. and this privacy policy; (iii) if necessary to comply with the law; (iv) if such data could be useful for the protection of the rights of third parties; (v) when they are useful for the protection of the rights, property, or safety of Accolades Marketing Inc., its controllers, its subsidiaries, its affiliates, its officers, its employees, users, or the general public; and (vi) when there are founded reasons in matters of public safety, national defense, or public health.

10. Security - How do we ensure data security?

Accolades Marketing Inc. declares its intention to adopt the necessary technical and organizational measures to guarantee the security, integrity, and confidentiality of data in accordance with the provisions of the GDPR, Argentine LPDP, LGPD, CCPA, PIPEDA-CASL, VCDPA, and APA to prevent their alteration, loss, unauthorized consultation, or processing.

Accolades Marketing Inc. does not guarantee absolute privacy in the use of the site, as it cannot be excluded that unauthorized third parties may become aware of it. The user acknowledges that the existing technical security means are not impregnable and that even when adopting all reasonable security precautions, manipulation, destruction, and/or loss of information is possible. In the event of detecting a security incident involving a significant risk to the data owner, this event will be communicated without delay to the competent control authority, as well as the corrective and palliative measures implemented and/or to be implemented.

Accolades Marketing Inc. is not responsible for the loss or deletion of data by users. Similarly, Accolades Marketing Inc. accepts no responsibility for any possible damage caused by computer viruses.

Finally, the user must also take measures to protect their information. Accolades Marketing Inc. insists that you take all precautions to protect your personal information when you are on the Internet. At a minimum, it is advised to change your password periodically, using a combination of letters and numbers, and to ensure that you are using a secure browser.

11. Data Owner's Rights and Procedures for Responding to Their Exercise - What rights do I have as a data owner?

The user who owns the data may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality, and deletion concerning their personal data, in accordance with the provisions of articles 15 and following of the GDPR, the provisions of the Argentine LPDP, the provisions of the LGPD, the provisions of the CCPA, the provisions of the PIPEDA-CASL, the provisions of the VCDPA, the provisions of the APA, as applicable. The exercise of these rights can be carried out by the user themselves by email to jonathan@lesaccolades.com, or by written communication addressed to the data protection delegate at the following address jonathan@lesaccolades.com, or by any of the means provided for by the applicable regulations mentioned above. Accolades Marketing Inc. may request the necessary data to validate the identification of the data owner.

The deletion of certain data will not be carried out when it could cause harm to the rights or legitimate interests of third parties, or when there is a legal obligation to retain the data.

12. Appointment of a Data Protection Delegate

Accolades Marketing Inc. has appointed a delegate for the application and control of this privacy policy as well as for the relationship with the regulatory authority, Jonathan Boisvert, who can be contacted by the following means:

• Email: jonathan@lesaccolades.com
• Phone: 4383892996

13. Training - Do we train?

The staff of Accolades Marketing Inc. whose functions are related to the processing of personal data are trained to ensure better protection of personal data and the rights of their holders.

14. Links to Third Parties - Does Our Site contain links to other sites?

The site may contain links to third-party sites, with or without advertising content, whose privacy policies are foreign to Accolades Marketing Inc. The linked sites are not related to Accolades Marketing Inc. and their existence does not imply any suggestion, invitation, or recommendation to visit the destination places or any link or association between Accolades Marketing Inc. and these sites. Accolades Marketing Inc. is not responsible or liable for the content, use, and activities of these linked sites, nor for the damages, whether current or potential, material or moral, direct or indirect, suffered by users and derived from the information contained in these sites or from the relationship that users may establish with third parties whose services have been published on the site. Nevertheless, any comment on these linked sites will be useful for Accolades Marketing Inc. to improve services and/or ensure the integrity of the site. Accolades Marketing Inc. commits to doing everything possible to prevent the existence on its site of links to sites with illegal content.

15. Cookies - Do we use cookies?

When the user enters the site, Accolades Marketing Inc. may store information on their computer in the form of a "cookie" or similar file. The site uses cookies to (i) track advertising, (ii) collect data on site traffic, and (iii) improve the user experience when using the site.

The user should know that to navigate the site, it is not necessary for the user to authorize the installation of cookies sent by the site. This may only be required for certain services. The user can delete cookies from their hard drive, prevent access to their computer either through their browser or by choosing the corresponding option when asked if they wish to use cookies for these purposes and in accordance with the cookie policy of Accolades Marketing Inc.

Cookies are information files that the site or the provider of certain services of the site transfers to the user's computer hard drive via the browser program. Cookies themselves cannot personally identify the user (although they may contain the user's IP address) but they allow the user's browser to be recognized and capture and store certain data (user's operating system, domain name of the website from which the site was linked, among others). Accolades Marketing Inc. reserves the right to contract the services of third parties to analyze and understand the users of the site, who may not use the information collected for purposes other than to improve the services of Accolades Marketing Inc.

16. Approval

The user's use of the site implies full and complete knowledge and approval of Accolades Marketing Inc.'s privacy policy and general conditions, where applicable. Similarly, the user accepts Accolades Marketing Inc.'s privacy policy and general conditions by completing the service request form.

17. Modifications - Is this the most recent version?

This is the current version of Accolades Marketing Inc.'s privacy policy, updated on August 2, 2023.

Accolades Marketing Inc. may at any time and without notice, modify this privacy policy. These modifications will be operational from their publication on the site or when they are communicated to users by any means, whichever occurs first. The user must stay informed of the terms included here by entering periodically.

18. Information for California Consumers

This part of the document is integrated and complements the information contained in the rest of the privacy policy and is provided by the company that manages this application and, where applicable, by its parent company, subsidiaries, and affiliates (for the purposes of this section, collectively referred to as "we", "us", "our").

The provisions contained in this section apply to all Users who are consumers residing in the State of California, United States of America, in accordance with "The California Consumer Privacy Act of 2018" (Users hereinafter simply referred to as "you", "your", "yours"), and, for these consumers, these provisions supersede any other possibly divergent or contradictory provisions contained in the privacy policy.

This part of the document uses the term "personal information" as defined in The California Consumer Privacy Act (CCPA).

Categories of Personal Information Collected, Disclosed, or Sold

We summarize here the categories of personal information that we have collected, disclosed, or sold and the associated purposes. You can learn more about these activities in detail in the section entitled "Detailed Information on the Processing of Personal Data" of this document.

Information We Collect: The Categories of Personal Information We Collect

We have collected the following categories of personal information about you: internet information.

We will not collect additional categories of personal information without notifying you.

How We Collect Information: What are the sources of the personal information we collect?

We collect the categories of personal information mentioned above, directly or indirectly, from you when you use this application.

For example, you directly provide your personal information when you submit requests via any form on this application. You also provide personal information indirectly when you navigate this application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the service or with the operation of this application and its features.

How We Use the Information We Collect: Sharing and Disclosure of Your Personal Information with Third Parties for Business Purposes

We may disclose the personal information we collect to a third party for business purposes. In this case, we enter into a written agreement with the third party that requires the recipient to keep the personal information confidential and not use it for any purpose other than those necessary for the execution of the agreement.

We may also disclose your personal information to third parties when you ask us or explicitly authorize us to do so, in order to provide you with our service. For more information about the purposes of processing, please refer to the relevant section of this document.

Sale of Your Personal Information

For our purposes, the word "sale" means any "sale, rental, release, disclosure, dissemination, making available, transfer, or other communication, orally, in writing, or by electronic means, of a consumer's personal information by a business to another business or to a third party, for monetary or other valuable consideration."

Your Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your personal information. This means that whenever you ask us to stop selling your data, we will respect your request. Such requests can be made freely, at any time, without submitting a verifiable request, simply by following the instructions below.

Instructions to Opt-Out of the Sale of Personal Information

If you want to learn more or exercise your right to opt-out concerning all the sales made by this application, both online and offline, you can contact us for more information using the contact details provided in this document.