SHIFT GROUP INC. PRIVACY POLICY

This privacy policy (hereinafter the “Policy”) is intended to help you understand the practices of Shift Group Inc. (hereinafter “Shift”) concerning the collection, processing, use, disclosure, and retention of personal information that you provide to Shift, including personal information that identifies you (hereinafter “Personal Information”).

1. Scope

The rights and obligations described in this Policy apply to all individuals (hereinafter collectively referred to as “Users”), including but not limited to our employees, our customers, Users of the websites https://groupeshift.ca/en/ and https://gemba-walk.com/en/ (hereinafter the “Website”), Users of Shift’s Gemba-Walk application (hereinafter the “Software”), and third parties. Shift, its employees, and its customers must comply with the policies, procedures, and practices described in this Policy.

2. Consent

By providing your Personal Information, you consent to the use and disclosure of said information as indicated in this Policy. You authorize us to collect, use, and share the Personal Information you provide to us via email, phone, on our Website, or on our Software, including when you create a user account or when your employer creates a user account for you (hereinafter the “Organization”), as applicable, or when you make an online purchase of the Software, so that it may be disclosed or used in accordance with the purposes for which it was collected. We only collect the Personal Information that is necessary.

You have the right to withdraw your consent to the disclosure or use of the information collected at any time. However, the withdrawal of consent does not affect the lawfulness of the processing of your Personal Information before such withdrawal. If you do not consent to this Policy, please do not disclose your Personal Information, do not use the Software, or, if applicable, send an email or message to Shift’s data protection officer using the contact information provided in the “Contact Information” section. Shift will take the necessary steps to have your Personal Information deleted or anonymized as soon as you exercise your right to withdraw or object as defined below.

3. Collection of Personal Information

For the purposes of this Policy, Personal Information that may be collected includes identification and authentication information, such as your name, email address, and password, as well as information related to Software purchases, such as payment information and purchase history.

In addition, Shift may automatically collect certain information, including but not limited to the type of device you use, IP address, user operating system, internet browser type, domain name, access times, visit duration, referral URL, Software information, date and time stamp, and login cookies, as well as information about how you use the Software and/or the Website.

4. Use of Personal Information

The Software contains various features and functionalities. To access and use the Software, as well as its features and functionalities, you may need to enter Personal Information into the Software.

Personal Information is collected when you use our services or our Software, when you log in to your user account when you access the Software to identify yourself or when you purchase the Software.

When you provide us with your Personal Information, Shift employees and employees of our subsidiaries who need access to the Personal Information to provide you with Software-related services, technical support, or similar services will have access to your Personal Information. Shift is committed to ensuring that its employees are informed of their obligation to ensure the security and confidentiality of your Personal Information when communicating and/or consulting Personal Information. Additionally, your Personal Information will be provided to cloud service providers, web hosting providers, data processing providers, and third-party providers of Shift such as payment platforms and financial institutions.

However, the Personal Information provided may be used to compile statistics and data from the use of the Software in a manner that does not allow anyone to directly identify you, and we are committed to minimizing the risk of anyone identifying you from de-identified information.

Personal Information may also be used for purposes compatible with the purposes for which it was collected and for your benefit, including but not limited to dissemination, correspondence, information, or to personalize your experience on the Software, answer your questions, understand your needs, inform you of our offers and promotions if you have consented, and manage fraud and theft cases, if applicable. If the purpose of processing Personal Information changes later, you will be informed of the changes by email at the email address provided to Shift, and these changes will be published on the Software and the Website.

5. Retention, Protection, and Sharing of Personal Information

Shift securely and confidentially retains your Personal Information in accordance with the requirements of the law to ensure the integrity and confidentiality of your Personal Information.

When you provide Personal Information to Shift, you agree that this information may be electronically transferred to Shift via the internet, and that Personal Information may also be transferred, stored, hosted, and processed on behalf of Shift by a third party. Shift uses private cloud servers for the storage of your Personal Information.

If we need to share Personal Information with third-party providers, especially for security and protection purposes, Shift will ensure that the protection and confidentiality of this information comply with this Policy and will require these providers to comply with it. Third-party providers are only authorized to use Personal Information for the purpose of providing services to Shift, and Personal Information may not be disclosed or transferred by such third party without Shift’s consent.

Your Personal Information is typically hosted in Canada and/or the United States, but we may use providers located in other countries. Therefore, you consent to the transfer of information to countries other than Canada, where data protection rules may differ from those of your country of residence, and Shift will hold companies outside of Canada accountable, under Canadian law, for any Personal Information that may be transferred to them.

However, despite Shift’s practices and procedures for protecting Personal Information, please note that no method of transmitting data over the Internet or storing data is completely secure, and no security measure can prevent all potential security breaches. Therefore, you agree that Shift cannot be held responsible for breaches of confidentiality or security that result from the unauthorized access of Personal Information.

6. Cookies and Web Beacons

Shift may use cookies and web beacons (also known as clear gifs) to collect and store information about your visits to the Website and your interactions with emails we send to you. Cookies are small files that are stored on your computer’s hard drive and are used for a variety of purposes, including to determine preferences, let you navigate between pages efficiently, and generally improve your experience on our Website. Web beacons are tiny graphics with a unique identifier that are embedded invisibly on web pages or in emails. They are used to track the online movements of website users.

We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. Persistent cookies can be removed by following your browser’s help file directions.

If you choose to disable cookies, some areas of our Website may not work properly or at all.

7. Children’s Privacy

The Website is not directed to individuals under the age of 18, and we do not knowingly collect Personal Information from individuals under 18. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact us using the contact information provided in the “Contact Information” section.

8. Links to Third-Party Websites

The Software and the Website may contain links to third-party websites. Please be aware that Shift is not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects Personal Information.

9. Changes to this Privacy Policy

Shift reserves the right to update or modify this Policy at any time without prior notice. We will do so by posting an updated or revised version of the Policy on the Software and the Website, with the “Last Updated” date at the top of this Policy indicating the date of the latest revision. Your continued use of the Software and the Website following the posting of changes to this Policy will mean you accept those changes.

10. Contact Information

If you have any questions about this Policy, please contact us at:

Francis Rondeau
info@groupeshift.ca
16997 boulevard des Acadiens
Bécancour (Québec) G9H 0N8
© 2022, Le groupe Shift inc.
Dernière mise à jour : Octobre 2022