Privacy Policy

Effective date: January 1, 2024

This Privacy Policy applies to all websites including those websites known as spc-cpf.com, ela-sve.com, antoinebcarriere.com, findingcareerfit.com and gabcm.ca (collectively the “Site”), all products, and all services of GABCM Inc. and its affiliates or subsidiaries, including Strengths Performance Centre and Centre des points forts (hereinafter collectively referred to as “GABCM”). GABCM is committed to protecting User privacy and providing a safe and secure online experience for its Users.

  

QUESTIONS & ACCESS TO INFORMATION 

If You have any questions about this Privacy Policy, or an Access to Information request for Your Personal Information, please contact Us by email at:

[email protected]

 Any requests for access to Personal Information must be in writing and will be addressed within 30 calendar days of receipt, as required by law. GABCM will use reasonable efforts to respond to any and all requests for access to Personal Information as quickly and as thoroughly as possible. 

Users have the right at all times to lodge a complaint with the relevant regulatory authority respecting GABCM’s handling of Personal Information.

 

DEFINITIONS

“Content” means the comments, documents, work done and other inputs by the User or Trial User.

“Personal Information” means information about an identifiable individual, as defined by the federal Personal Information Protection and Electronic Documents Act, SC 2000 c 5 (“PIPEDA”), and as amended from time to time, and also includes “Personal Data” as it is defined and used in the European Union’s General Data Protection Regulation, being Regulation (EU) 2016/679 (“GDPR”).

“Product” means, and is a reference to, any document or file which is the core content creation target within the Service, and is the result of the use of the Service, or is made available by GABCM in relation to the Service.

“Service” means the online service that is provided on the Site, located at https://gabcm.ca and https://spc-cpf.com, or any alternate website as may be designated by GABCM from time to time.

“Team” means a group of Users from the same client organization or group, between whom certain Products are shared.

“User” means any person, whether in an individual, company, partnership or other person or entity, that accesses the Service.

“We”, “Us” or “Our” means GABCM, the company who provides the Site and with whom You are accepting this User Agreement.

“Client Portal” is an account on the Service which contains Users, documents, and Products. Typically, a company or organization will register and invite Users to the Service (resulting in a Product).

“You” or “Your” means, capitalized or not, yourself personally, or the company or other entity for which You are accepting the terms of this Privacy Policy, and any subsidiaries or affiliates of that company or entity.

  

PRIVACY POLICY TERMS

USER PRIVACY POLICY AGREEMENT

By using the Site, You consent to the collection, storage, use and disclosure of Your Personal Information as described in this Privacy Policy. If You do not agree to the practices in this Privacy Policy, You should not use this Site. Each time You use this Site, the current version of the Privacy Policy will govern Your use. Accordingly, when You use this Site, You should check the date of this Privacy Policy (which appears at the top) and review any changes since the last version.

CONSENT

The way in which GABCM seeks consent, including whether it is express or implied, may vary depending upon the sensitivity of the information, the circumstances and the reasonable expectations of the User. We seek express consent when the information is likely to be considered sensitive. We rely on implied consent when the information is less sensitive. Should GABCM ever decide to use Personal Information for a purpose other than that for which the Personal Information was collected, GABCM will contact Users prior to engaging in such use to inform Users and obtain updated consent or provide Users with the opportunity to withdraw consent prior to such use.

An individual can withdraw consent at any time, subject to legal or contractual restrictions. We will inform individuals of any implications of withdrawing consent.

As a visitor to the Site there is no obligation on You to provide any Personal Information to GABCM. If You do not consent to Our Privacy Policy then You must discontinue Your access to, and use of, the Site. As a visitor, there are no repercussions to either not providing or withdrawing consent.

For all Users, consent is a contractual requirement to access and use both the Site and Service. If a User does not provide the necessary Personal Information, they will not be able to properly access the Site and/or use the Service.

COLLECTION, USE, AND RETENTION OF PERSONAL INFORMATION

When using the Site a User may transmit Personal Information, such as, but not limited to, name, email, company name, billing name and other billing information, avatar, “bio,” job title, country, state or province, city, and language preference. When using the Site a User may view web pages, click links and perform other actions such as select a preferred language interface; such usage information is also collected. GABCM collects Personal Information using common Personal Information collection tools such as “Cookies.” GABCM may collect other Personal Information regarding Your use of the Site, such as the name of the Internet service provider and the Internet Protocol address through which You access the Internet, the time You access the Service, and the Internet address of any referring website and the Internet address of the website from which You linked directly to any GABCM website. GABCM also retains comments and information sent between Users using the Service and Product for the purpose of providing the Service, but in no way monitors the type of information exchanged within the Service and does not use any such information except for the sole purpose of providing the Service.

GABCM uses all collected information, Personal or otherwise, to operate, support, and improve the Service and if You have opted-in to receive communications from GABCM, to send to You communications about GABCM and its services. Personal Information submitted to GABCM may also be used by GABCM to contact the User, including but not limited to, for updates respecting changes to GABCM’s Privacy Policy.

GABCM limits the amount and type of Personal Information collected to that which is necessary for identified purposes, and will only collect Personal Information by fair and lawful means.

GABCM does not sell or trade Your Personal Information to third parties, and uses such Personal Information solely for its own purposes.

GABCM will retain Personal Information only as long as necessary for the fulfilment of Our identified purposes. Personal Information will be destroyed, erased or made anonymous when it is no longer required to fulfill Our identified purposes.

DISCLOSURE AND STORAGE OF PERSONAL INFORMATION 

This Privacy Policy only applies to Personal Information that is collected through the Site and does not apply to any Personal Information that may be collected by other Users, such as through email or Service communications between You and another User.

When using the Site, You may transmit Personal Information and any other content to areas of the Site where such Personal Information may be viewed, collected, stored or used by other Users that also have permission to such areas of the Site. GABCM is not responsible for any Personal Information You transmit to such areas of the Site and is similarly not responsible for any actions taken or not taken by other Users to such areas of the Site. If You disclose Your Personal Information to other Users, different rules may apply to their use or disclosure of Your Personal Information. GABCM does not guarantee the privacy or security of the Personal Information You provide to others. We therefore encourage You to evaluate the privacy and security policies of the other Site User before sharing Your Personal Information.

Personal Information may be shared with other Users within a Product between the members of a Team as needed by the nature of the Service. Such Personal Information disclosure is limited to that which is necessary for identified purposes of the Product. 

Unless You share Your Personal Information with other Users on the Site, or unless You instruct, or permit, GABCM to share Your Personal Information with other Users on the Site, GABCM does not share, sell or trade Your Personal Information with other Users.

GABCM reserves the right to disclose User Personal Information in circumstances allowed by federal and provincial or state privacy laws, which includes but is not limited to, (i) complying with lawful government requests and court orders, (ii) disclosing to necessary employees and service providers, (iii) collecting a debt owed by the User to GABCM, or (iv) enforcing GABCM’s rights pursuant to a breach of the Digital Content Terms and Conditions and/or Services Agreement.

GABCM may also store Your Personal Information outside Canada, including but not limited to the United States of America and the European Union. All Personal Information stored outside of Canada will be subject to Personal Information protection and disclosure laws of the country where such data is stored. Regardless, GABCM will not voluntarily disclose Your Personal Information unless for the purposes outlined in this Privacy Policy or as required to by domestic or foreign privacy laws.

USER PRIVACY CONTROLS

Users can opt-out of receiving emails about new features, changes to the Service, and other marketing materials. Notwithstanding any such communications preferences indicated by You, GABCM may send to You necessary service emails regarding necessary maintenance events or modifications to the functionality or delivery of the Site and/or Service.

Further, notwithstanding any communications preferences indicated by You, some emails related to the Service are initiated by Users and accordingly even though You may have opted-out from receiving communications from GABCM, such other Users may nevertheless cause Service-related emails to be sent to You, and vice-versa.

User has the legal right to request GABCM send all Personal Information held by GABCM to the User upon written request. Furthermore, User has the legal right to require that any incorrect Personal Information be corrected. If at any point You wish to have Your Personal Information deleted, You must send Us a written request. Contact information and response timelines are set out above in the “Questions & Access to Information” section. Users requesting Personal Information will first be required to prove their identity prior to having such Personal Information released, corrected, or deleted by GABCM.

Users have the choice to configure their web browser to enable or disable Cookies. However, disabling Cookies will cause the private aspects of the Site not to function – i.e. a User will not be able to log in nor work on any Products or documents.

USER INFORMATION REMOVAL 

A User may remove Personal Information from the Site which they upload in the course of using the Service, including Personal Information in the User’s profile, in the User’s Products and in the User’s Workspace. Though such Personal Information is stored by GABCM so that the User’s Content and Product remain from session to session, the User has control of such Personal Information and can delete such Personal Information at any time, by sending a request to Us in accordance with the “Questions & Access to Information” section, above. When a User removes such Personal Information, other Users will not be able to see the removed Personal Information, unless it is Personal Information that remains visible in the system due to the availability of certain historical information (for example, older versions of a Product). If a User has distributed or shared Personal Information with other Users, the shared Personal Information is stored with the other User’s workspace meaning the Personal Information shared with another User may be viewable by other Users even after the User has removed their own Personal Information.

GABCM stores User Personal Information in case a User requests account reactivation by maintaining back-up copies of all Personal Information in the system. Personal Information stored in backup copies is not available to Users. Users have the legal right to request that GABCM permanently delete any such stored Personal Information.

SECURITY

GABCM will at all times take reasonable precautions to protect Users’ Personal Information from unauthorized access, use or disclosure. To help protect User Personal Information, the Site uses Secure Socket Layer technology (“SSL”) using both server authentication and data encryption. SSL helps to ensure User Personal Information is secure and accessible only to the User to whom the Personal Information belongs and those to whom the User has agreed to provide access. GABCM has implemented additional technical safeguards and procedures to protect communications between User and Site including communication of Personal Information.

As mentioned above, GABCM provides access to User’s Personal Information to GABCM employees and to service providers who need to manage such Personal Information. To help ensure appropriate access and management of User Personal Information, GABCM employees and service providers are bound by confidentiality and information management agreements. Furthermore, GABCM requires that any third party service providers sign agreements agreeing and demonstrating that their data collection, protection, retention, and use meet minimum legal requirements for each of Canada, the United States of America, and the European Union.

Notwithstanding these precautions and security measures, the security of communications sent over the Internet (including by email) and online information storage is subject to many factors outside of GABCM’s control and, as a result, GABCM cannot and does not guarantee the security or privacy of such communications and data storage.

For Non-Canadian Resident Users, You agree and acknowledge that Information collected through the Site or in connection with the Site may be transferred across national boundaries and stored and processed in any of the countries around the world in which GABCM maintains a presence, including but not limited to Canada, the United States of America, and the European Union. In any event, GABCM will ensure that appropriate security safeguards are in place as those required by Canadian, American, or European Union privacy laws, as applicable. Where such assurances cannot be contractually guaranteed, We will seek Your explicit consent prior to transferring any such Personal Information. 

BREACHES OF SECURITY SAFEGUARDS

If a security breach occurs involving Personal Information under GABCM’s control, for which it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to an individual, or in the EU result in a high risk to the rights and freedoms of natural persons, GABCM will, as applicable:

1. report the breach to the Canadian Privacy Commissioner in the manner prescribed by PIPEDA;
2. unless otherwise prohibited by law, notify the individual in accordance with provisions of PIPEDA;
3. report the breach to the relevant EU Supervisory Authority as prescribed by the GDPR;
4. as and when required, notify the affected person(s) in accordance with the GDPR; and
5. notify any other organization, a government institution or a part of a government institution of the breach if We believe that the other organization or the government institution or part concerned may be able to reduce the risk of harm that could result from the breach or mitigate that harm, or if any other prescribed conditions are satisfied. 

PIPEDA defines “significant harm” as including bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.

COMMUNICATIONS AMONGST USERS

You shall have sole responsibility for any and all communications You initiate with other Users and accordingly GABCM shall have no responsibility in connection with any such User to User communications. It is Your sole obligation to comply with all data protection and privacy laws and rules applicable to other Users within the Service. 

USE OF COOKIES

The Site uses two different kinds of cookies. If a User turns off the “allow cookies” setting in their internet browser settings, then any such User would be unable to use the private portions of the Site – i.e. they would not be able to log in.

The first type of cookie is called a “session cookie” to keep track of authenticated Users and their preferences. Without this cookie the User would need to login on every request made by the User. For example when a User clicks a button or link, then the User would have to login for each request. Thus, the session cookie stores who the User is and the fact that the User is already authenticated with the Site, preventing the need for repeated authentications. In addition, the session cookie usefully tracks language, Product, and Client Portal settings. The session cookie exists only for the session the User is in and when the User logs out or closes their internet browser, then the session cookie is deleted.

The second type of cookie is for the “Remember Me” feature available to Users on the login page. This cookie is only activated and used if the User clicks the “Remember Me” checkbox. This cookie stores a special code that is associated with the User’s account and allows a previously authenticated User to re-access the Site even after closing their internet browser and re-opening it. If a “Remember Me” User deletes this cookie, then the User would have to login again the next time they want to access the Site. Unless the User turns off cookies, this would be a permanent cookie and exist across sessions in the Site.

THIRD-PARTY WEBSITE LINKS

The Service may include links to third-party websites (such as but not limited to Gallup Access, LinkedIn, Youtube, Facebook, etc.); You may redirect to such third-party websites as a User of this software. The third-party websites are not under control of GABCM and GABCM is not responsible for the content of any third-party website and/or any links contained in the third-party websites. GABCM is providing these links to the third-party websites to You only for Your convenience and GABCM is not responsible for any kind of loss/damage arising out of it. Your access, use, and reliance upon such content, products, or services are at your own risk. When linking to those third-party websites, You are subject to the terms posted by those third-party websites, including any privacy policy. We are not responsible for, nor do we control, the content, products, or services provided by any third-party website. We do not endorse or guarantee the products, information, services, or recommendations provided by third-party websites and are not liable for any failure of products or services advertised on those websites. In addition, each third-party website may provide less security than GABCM does and may have substantively different privacy policy. You should review the security and privacy policies of such third-party websites.

PRIVACY POLICY CHANGES

GABCM may change its Privacy Policy from time to time. GABCM will post Privacy Policy changes on this web page including the date of the latest change (at the top of the Privacy Policy). Copies of past Privacy Policy documents are available by contacting GABCM at the address above.

GOVERNING LAW & STANDARDS 

This Privacy Policy is developed in accordance with the principles of PIPEDA and the EU GDPR, which governs GABCM’s privacy requirements in Canada and the EU. Accordingly, this Privacy Policy and the standards developed and adhered to herein meet applicable Canadian and European Union privacy laws. These standards do not necessarily meet the standards established and required in other countries outside of Canada or the European Union, and GABCM neither claims nor purports that such other standards are met.

Any Non-Canadian and Non-EU Users hereby agree that this Privacy Policy shall be interpreted and construed in accordance with the appropriate Canadian and EU laws, as applicable, excluding any principles of the conflicts of laws that would apply a different body of law. Any such Users submit and attorn to the exclusive jurisdiction of the courts in Ottawa, Ontario with respect to all matters arising from or related to this Privacy Policy, except for EU Users who have the legal right to pursue judicial remedies in the courts of their EU Member State.

CONTACT US

If you have any questions, concerns or complaints about this Privacy Policy, please contact us:

• By email: [email protected]
• By phone number: (+001) 613.421.47.22 
• By mail: 17001-1937 Portobello Blvd, Ottawa, ON Canada K4A4W8