PRIVACY POLICY

KIWI is the software publisher behind STAGE+, the only internship management platform specifically designed for the health and social services. In the general framework of our activities, we can collect personal data from customers, system users, candidates for an internship, people who fill out forms on our website or on a website using our software (CI -At a "customer website"), or which have requested information on our products and services by other means, and those who wish to provide services to KIWI. In these situations, we are the "data controller" (that is to say the part which determines which data must be collected and how it will be used).

This privacy policy applies to KIWI as a data controller and covers the processing activities of all its legal entities and operating sites. For more information or contact KIWI, please consult the "Additional Information" section at the end of this policy for our contact points.
KIWI undertakes to protect and respect your privacy. When you visit our website, use our products and services or interact with KIWI, we can collect and process information about you ("personal data"). This privacy policy describes how KIWI processes your personal data and your rights on this data.

KIWI Technologies Inc. (« KIWI » ou « we ») are committed to protecting the privacy of individuals who visit the KIWI's websites (« Visitors »); the individuals who register to obtain a Demo or attend the webinaries of KIWI (« Participants »); and people who register to use services such as defined below or who use the services (« Customers »). This privacy policy (« Privacy Policy ») describes KIWI's privacy practices in relation to the use of KIWI's Websites(« website ») and related products and services offered by KIWI (« Services »). Customers, participants and visitors will all be signed as it is « you » in this Privacy Policy.

1. Non-Personal Information. We may collect « Non-Personal Information ». For the purposes of this Privacy Policy, “Non-Personal Information” means data in a form that does not directly identify a particular individual. Here are some examples of non-personal information we may collect and how we may use it:
1. We may collect information such as occupation, language, zip code, unique device identifier, location and time zone where a KIWI product is used in order to better understand customer behavior and improve our products, services and advertising.
2. We may also collect information about Customers' activities on our Website and our other products and Services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our Website, products and Services are of most interest. Aggregated data is considered Non-Personal Information for the purposes of this Privacy Policy.
2. Personal information. You may be required to provide « Personal information » to KIWI. For the purposes of this Privacy Policy, « Personal information » means data that can be used to identify or contact a specific natural person.
   1. Registration. Most of the time, You will browse the Website without registering or creating an online account. However, in order to access certain resources or services through the Website (purchase products, questions, services, etc.), You will need to register with us. In order to register and create an online account, we collect certain Personal Information about You, such as: your first and last name, your phone number, your permanent code, practice number or employee number, your email address, your professional function/title, your country, the name and size of your organization, your position, and whether or not you are acting on behalf of a current client.
   2. Navigation. When You visit our Website or use the Services, we automatically collect browsing and click data, HTTP protocol elements and search terms. We also collect information through the use of cookies.
   3. Customer data. Customers may electronically transmit data or information to the Services for hosting and processing purposes (“Customer Data”). KIWI will not interpret, share, distribute or reference any such Customer Data except as provided in the KIWI Customer Agreement or as required by law. Pursuant to the KIWI Customer Agreement, KIWI may access Customer Data solely for the purpose of providing the Services, improving the Services, or preventing or addressing technical or service issues or for any other purpose required by law. . When purchasing the Services, KIWI may require You to provide the Company with financial qualification and billing information, such as name and billing address and the number of employees within the organization that will use the Services. KIWI may also ask You to provide additional information, such as annual company revenues, number of employees or industry.
      Sensitive data.
3. Sensitive data.
   1. Personal Health Information. In the event that You submit to the Hosted Services or use the Hosted Services to collect any patient, medical or other health information regulated by HIPAA or any other similar federal or state law, rule or regulation, You acknowledge that that, KIWI is not acting as a business partner or contractor (as those terms are defined and used in HIPAA) and that the Services are not HIPAA compliant. “HIPAA” means the United States Health Insurance Portability and Accountability Act, as amended and supplemented.
   2. Payment Card Information. Unless otherwise agreed, You must not submit to KIWI (or use the Services to collect) any payment card information, account holder name, account number, service code, code/value/ card number, PIN or Block PIN, valid from and from dates and magnetic stripe data and information relating to a payment card transaction or any financial account number, with or without a code or password that would allow account access (such as bank account numbers and debit or credit card numbers), except as necessary for payment of your Order. You also acknowledge that, unless otherwise agreed, the Services do not comply with the Payment Card Industry Data Security Standard (“PCI DSS”).

The information we collect allows us to:

• Provide the Services;
• Keep you informed about the latest KIWI product announcements, software updates and upcoming events;
• Provide you with information, resources, products or services that your organization has requested from us;
• Send you communications related to customer service, including online services;
• To provide technical support to our Customers and to improve support and technical support services;
• Process communications You send to KIWI;
• Notify you of updates to our products;
• Collect your comments;
• To supplement and support current activity, Site and system administration, research and development and to improve the navigation and content of the Website;
• Help us develop, deliver and improve our products, Services, content, customer communications and advertising;
• To pursue internal purposes such as auditing, data analysis and research.

We may use, transfer and disclose Non-Personal Information for any purpose. If we combine Non-Personal Information with Personal Information, the combined information will be treated as Personal Information while it remains combined. KIWI may use this combined information to provide and improve its products, services, content and advertising.

The Website may use "cookies". These technologies help us better understand user behavior, tell us which parts of our Website people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies as Non-Personal Information. However, to the extent Internet Protocol (IP) addresses or similar identifiers are considered Personal Information by law, we also treat such identifiers as Personal Information. If You wish to disable cookies, consult your web browser provider for instructions on how to do so. Please note that some features of the Website may not be available once cookies are disabled. As with most websites, we collect information automatically and store it in log files. This information includes Internet Protocol addresses, browser type and language, Internet Service Provider (ISP), referring and exit pages, operating system, date and timestamp, and " navigation”. We use this information to understand and analyze trends, to administer the Website, to learn about user behavior on the site, and to gather demographic information about our user base as a whole. KIWI may use this information in its marketing and advertising services. In some of our email messages, we may use a "destination URL" linked to content on the Website. When You click on one of these URLs, You pass through a separate Web Server before arriving at the landing page on the Website. We track this clickable data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If You prefer not to be tracked in this way, You should not click on text or graphic links in email messages.

With affiliates. KIWI may share information about You with its affiliates in accordance with this Privacy Policy in order to work with them. For example, KIWI may need to share your Personal Information for customer relationship management purposes. We may also receive Personal and Non-Personal Information about individuals from our affiliates, business partners, resellers and other third party sources. This information is primarily used to supplement the information we already have about specific individuals, such as: updated business address information, purchase history and demographic information.

With business partners. From time to time, KIWI may partner with other companies to jointly offer products or services. If You purchase or expressly express an interest in a product or service jointly offered by KIWI, KIWI may share Data about KIWI customers collected in connection with your purchase or expression of interest with our promotional partners. KIWI does not control its business partners' use of your information and their use of the information will be in accordance with their own privacy policies. If You do not want Your information to be shared in this way, You can choose not to purchase or expressly express an interest in a jointly offered product or service.

With third parties. We may make certain Personal Information available to strategic partners in accordance with this Privacy Policy. Personal Information will only be shared to provide or improve our products, services and advertising; they will not be shared with third parties for marketing purposes. Upon request, KIWI will inform individuals of the type or identity of third parties to whom it discloses Personal Information.

KIWI takes precautions - including administrative, technical and physical measures - to protect your Personal Information against loss, theft and misuse, as well as against unauthorized access, disclosure, modification and destruction. KIWI uses robust security measures to protect your information stored in The Services, as described here. The Website uses Transport Layer Security (TLS) encryption on all websites where Personal Information may be collected. It is strongly recommended to use a TLS compatible browser. This protects the confidentiality of your Personal Information when it is transmitted over the Internet.

KIWI will retain your Personal Information for the period necessary for the purpose for which it was intended. KIWI will also retain your information for the purpose of performing or fulfilling a contractual obligation with your organization. Finally, we retain your information for as long as required by law.

You can request that we correct your information if it is inaccurate or that we delete it (if KIWI is not required by law to retain it). We may refuse to process your request if such request is excessively repetitive; requires disproportionate technical effort; jeopardizes the privacy of third parties; is impracticable or for which access is not required by law. You may make such a request or request access to your Personal Information in our possession by contacting: privacy[at]kiwi.ca.

The Website and Services may contain links to third party websites, products and services. Information collected by third parties may include location data or contact details and other generic usage information. This collection of data is governed by the privacy practices of these third parties. We encourage You to be aware of these practices. KIWI is not responsible for the content, operation or privacy practices of such sites. In particular, unless expressly stated, we are not agents of these sites or advertisers, and we are not authorized to make representations on their behalf. KIWI may disclose Personally Identifiable Information to these third party service providers for the sole purpose of providing services to You. KIWI may subcontract hosted services of your Personal and Non-Personal Information with KIWI's contracted service providers. KIWI does not share, sell, rent or trade any information with third parties for promotional purposes.

KIWI will promptly inform every concerned individual subject to the investigatory and enforcement powers of the Financial Consumer Agency of Canada or any other Canadian authorized statutory body. It may be necessary − by law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence, including to meet national security or law enforcement requirements − for KIWI to disclose your personal information. KIWI will inform concerned individuals about the requirements of such disclosure.

Questions regarding this Privacy Policy or the information practices of KIWI websites should be directed to François Léveillé, Vice President, our Chief Privacy Officer.

By email: privacy[at]kiwi.ca
By mail to: STAGE+ (Privacy), 206-3125 Flaubert, Quebec QC G2E 2J2 Canada

KIWI can update this privacy policy from time to time, without notice. Regularly check the updates.

Updated on: October 14, 2023