Privacy Policy

Last updated: October 3, 2022

This Privacy Policy describes how We collect, use and disclose Your information when You use our Website and tells You about Your privacy rights and how the law protects You.

We use Your Personal Information to provide and improve Our Website. By accessing or using the Website, You agree to the collection, use and disclosure of Your Personal Information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Website or parts of our Website.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy) refers to Portage CyberTech, 85 Rue Victoria, Gatineau, QC J8X 2A3, Canada.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Canada

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Information is any information that relates to an identified or identifiable individual.

 Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals retained by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).

Website refers to Portage CyberTech Website, accessible from https://www.portagecybertech.com

You means the individual accessing or using the Website, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Information

Types of Data Collected

Personal Information

While using the Website, We may ask You to provide Us with certain Personal Information that can be used to contact or identify You. Personal Information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, Province, Postal code, City
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Website.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Website.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Website.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.

We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

Analytics

We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the website. These third- parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link:

https://tools.google.com/dlpage/gaoptout?hl=en

You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

https://policies.google.com/technologies/partner-sites and

https://support.google.com/analytics/topic/2919631

 

Pixels (also known as a "clear GIF" or "web beacon")

 

A “pixel tag” is a tiny image - typically just one -pixel - that can be placed on a web page or in an email to you, to tell us when you have displayed that page or opened that email and to analyze response rates.

Use of Your Personal Information

The Company may use Personal Information for the following purposes:

  • To provide and maintain our Website, including to monitor the usage of our Website.
  • To manage Your Account: to manage Your registration as a user of the Website. The Personal Information You provide can give You access to different functionalities of the Website that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Website. To also understand Your needs, the suitability of our products and services ,and assess future needs.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For Product and Business Development: To research, analyze, develop, manage, protect and improve Our business operations, Website, products and services, and to test new products and services.
  • To collect Debts and manage Our risk and operations: To collect a debt owed to us and to manage Our risks and operations.
  • For Security: To administer and protect the security of Our business, and Website and other services.
  • For Legal Purposes: To meet Our legal and regulatory obligations, including to enforce Our legal rights; and
  • For any other relevant purposes: To fulfil other purposes related to any of the above. [

We may share your Personal Information in the following situations:

  • With Service Providers: We may share Your Personal Information with Service Providers to monitor and analyze the use of our Website, to advertise third party websites to You after You visited our Website, to contact You. These Service Providers are contractually limited from using or disclosing Your Personal Information except as is necessary to provide services to us or to comply with legal requirements. Furthermore, we may disclose information about you where we are required or permitted by law to do so.
  • For Business transfers: We may share or transfer Your Personal Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates
  •  to meet our legal and compliance requirements and operational needs, in which case we will require those affiliates to honor this Privacy Policy. We may also share Your information with Our Affiliates to offer certain products, services or promotions. Affiliates include Our parent company (Converge Technology Solutions Corp.) and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • With Law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
  • Other: We may disclose Your Personal Information in other circumstances where We are permitted or required by law to do so. This may include disclosure to protect Our rights, to comply with Our legal and regulatory requirements, or in the event of an emergency. For example, We may disclose Your Personal Information on the good faith belief that such action is necessary to:
  • Comply with a legal obligation;
  • Protect and defend the rights or property of the Company;
  • Prevent or investigate possible wrongdoing in connection with the Website;
  • Protect the personal safety of Users of the Website or the public; or
  • Protect against legal liability.

Your Consent

We collect information when we have a lawful means to do so. As part of using Our Website, we may collect and process some details about You. When We do so, we will collect, use or share Your Personal Information with Your consent for the purposes identified or as otherwise permitted or required by law. In compliance with Our privacy obligations, We may obtain Your permission based on implied consent (including through this Privacy Policy) or through other means (such as express consent). However, in some situations, the law allows Us to collect, use or disclose Personal Information without Your consent.

You may withhold or withdraw Your consent for Us to collect, use or share your Personal Information, as long as there are no legal or contractual requirements for Us to process Your information. Depending on the circumstances, however, withdrawal of Your consent may impact Our ability to serve You.

Retention of Your Personal Information

The Company will retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Website, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Information

Your information, including Personal Information, is processed at the Company’s operating offices and in any other places where the parties involved in the processing (such as our service providers) are located, including in the United States. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. As a result, in certain circumstances, other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access Personal Information collected and held under Our control.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Information and other personal information.

Security of Your Personal Information

We maintain reasonable physical, technical and administrative safeguards to help protect against the unauthorized access, use and disclosure of Personal Information you provide to us.

The security of Your Personal Information is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security.

It should be noted that we cannot be held responsible for any Personal Information you share with other users or post on public spaces, such as our blogs. Such public spaces may be consulted or viewed by anyone visiting our Website and, as such, falls outside the scope of this Policy.

Third Party Websites

It's important to know that our Website may contain links to third party websites not controlled by Us or covered by this Privacy Policy. We recommend that you check the privacy statements of other websites you visit before providing any information.

Do-Not-Track

Our Website does not take any specific automated action in response to browser Do Not Track signals or other similar mechanisms (collectively, “DNT signals”). As specified in the Tracking Technologies and Cookies section above, there are actions that you can take to restrict or eliminate the use of tracking technologies via the Website. No actions are taken automatically in response to DNT signals on the Website, however.

Children’s Privacy

We do not knowingly collect or solicit personal information from children under the age of 13. By using the Website, you represent that you are at least 13 years old. If you are under 13, please do not attempt to send any Personal Information about yourself to us. If we become aware that we have inadvertently received or collected Personal Information from a user of the Website who is under the age of 13, we will attempt to immediately delete that information from our files and records. Furthermore, we encourage users of the Website that are minors that are 13 years of age or older to ask their parents or guardians for permission before sending any information about themselves over the Internet.

If you believe a child who is under the age of 13 has provided us with Personal Information, please contact using the information outlined below in the “Contact Information” section.

Your Rights

You have the right to access or correct Personal Information that is in Our custody or control and to withdraw your consent to the collection, use or disclosure of your Personal Information. You may also have additional rights, in specified circumstances to request the deletion of your personal information or to request a copy of the information you have provided to us be transferred to another person. In case of any such request, please send an email to connect@portagecybertech.com or write to the Company’s Chief Data Protection Office (Legal Department) Portage CyberTech Inc. 85 rue Victoria, Gatineau, Québec, Canada J8X 2A3.

To the extent permitted by applicable law, where the Company would not address properly your request, you have the right to lodge a complaint with the competent privacy authority.

Contact Information

If you have any questions or concerns about this Privacy Policy or Our processing of Your Personal Information, or to make a complaint, please do not hesitate to communicate in writing with the Company’s Chief Data Protection Office:

Changes to Our Privacy Policy

We may modify this notice from time to time and will post the most current version online. We encourage You to review this Privacy Policy often.