Attestra
Privacy Policy for Traces Québec Transport Mobile Application
We respect
your privacy and are committed to protecting it through our compliance with
this privacy policy (“Policy”). This Policy describes the types of information
we may collect from you or that you may provide (“Personal Information”) in the
Traces Québec Transport mobile application (“Mobile Application” or “Service”)
and any of its related products and services (collectively, “Services”), and
our practices for collecting, using, maintaining, protecting, and disclosing
that Personal Information. It also describes the choices available to you
regarding our use of your Personal Information and how you can access and
update it.
This Policy
is a legally binding agreement between you (“User”, “you” or “your”) and this
Mobile Application developer (“Operator”, “we”, “us” or “our”). If you are
entering into this agreement on behalf of a business or other legal entity, you
represent that you have the authority to bind such entity to this agreement, in
which case the terms “User”, “you” or “your” shall
refer to such entity. If you do not have such authority, or if you do not agree
with the terms of this agreement, you must not accept this agreement and may
not access and use the Mobile Application and Services. By accessing and using
the Mobile Application and Services, you acknowledge that you have read,
understood, and agree to be bound by the terms of this Policy. This Policy does
not apply to the practices of companies that we do not own or control, or to
individuals that we do not employ or manage.
Collection
of personal information
You can
access and use the Mobile Application and Services without telling us who you
are or revealing any information by which someone could identify you as a
specific, identifiable individual. If, however, you wish to use some of the
features offered in the Mobile Application, you may be asked to provide certain
Personal Information (for example, your account name and password).
We receive
and store any information you knowingly provide to us when you create an account, or fill any forms in the Mobile Application. When
required, this information may include the following:
You can choose not to provide us with your Personal Information,
but then you may not be able to take advantage of some of the features in the
Mobile Application. Users who are uncertain about what information is mandatory
are welcome to contact us.
Privacy
of children
We do not
knowingly collect any Personal Information from children under the age of 18.
If you are under the age of 18, please do not submit any Personal Information
through the Mobile Application and Services. If you have reason to believe that
a child under the age of 18 has provided Personal Information to us through the
Mobile Application and Services, please contact us to request that we delete
that child’s Personal Information from our Services.
We
encourage parents and legal guardians to monitor their children’s Internet
usage and to help enforce this Policy by instructing their children never to
provide Personal Information through the Mobile Application and Services
without their permission. We also ask that all parents and legal guardians
overseeing the care of children take the necessary precautions to ensure that
their children are instructed to never give out Personal Information when
online without their permission.
Use and
processing of collected information
We act as a
data controller and a data processor when handling Personal Information, unless
we have entered into a data processing agreement with you in which case you
would be the data controller and we would be the data
processor.
Our role
may also differ depending on the specific situation involving Personal
Information. We act in the capacity of a data controller when we ask you to
submit your Personal Information that is necessary to ensure your access and
use of the Mobile Application and Services. In such instances, we are a data
controller because we determine the purposes and means of the processing of
Personal Information.
We act in
the capacity of a data processor in situations when you submit Personal
Information through the Mobile Application and Services. We do not own,
control, or make decisions about the submitted Personal Information, and such
Personal Information is processed only in accordance with your instructions. In
such instances, the User providing Personal Information acts as a data
controller.
In order to
make the Mobile Application and Services available to you, or to meet a legal
obligation, we may need to collect and use certain Personal Information. If you
do not provide the information that we request, we may not be able to provide
you with the requested products or services. Any of the information we collect
from you may be used for the following purposes:
Processing
your Personal Information depends on how you interact with the Mobile
Application and Services, where you are located in the world and if one of the
following applies: (i) you have given your consent for one or more specific
purposes; (ii) provision of information is necessary for the performance of an
agreement with you and/or for any pre-contractual obligations thereof; (iii)
processing is necessary for compliance with a legal obligation to which you are
subject; (iv) processing is related to a task that is carried out in the public
interest or in the exercise of official authority vested in us; (v) processing
is necessary for the purposes of the legitimate interests pursued by us or by a
third party.
Note that
under some legislations we may be allowed to process information until you
object to such processing by opting out, without having to rely on consent or
any other of the legal bases. In any case, we will be happy to clarify the
specific legal basis that applies to the processing, and in
particular whether the provision of Personal Information is a statutory
or contractual requirement, or a requirement necessary to enter into a
contract.
Disclosure
of information
To maintain
the highest level of privacy and to protect your Personal Information to the
full extent, we do not share your Personal Information with anyone and for any
reason.
Retention
of information
We will
retain and use your Personal Information for the period necessary to comply
with our legal obligations, to enforce our agreements, resolve disputes, and
unless a longer retention period is required or permitted by law.
We may use
any aggregated data derived from or incorporating your Personal Information
after you update or delete it, but not in a manner that would identify you
personally. Once the retention period expires, Personal Information shall be
deleted. Therefore, the right to access, the right to erasure, the right to
rectification, and the right to data portability cannot be enforced after the
expiration of the retention period.
Links to
other resources
The Mobile
Application and Services contain links to other resources that are not owned or
controlled by us. Please be aware that we are not responsible for the privacy
practices of such other resources or third parties. We
encourage you to be aware when you leave the Mobile Application and Services
and to read the privacy statements of each and every
resource that may collect Personal Information.
Information
security
We secure
information you provide on computer servers in a controlled, secure
environment, protected from unauthorized access, use, or disclosure. We
maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use,
modification, and disclosure of Personal Information in our control and
custody. However, no data transmission over the Internet or wireless network
can be guaranteed.
Therefore,
while we strive to protect your Personal Information, you acknowledge that (i)
there are security and privacy limitations of the Internet which are beyond our
control; (ii) the security, integrity, and privacy of any and all information
and data exchanged between you and the Mobile Application and Services cannot
be guaranteed; and (iii) any such information and data may be viewed or
tampered with in transit by a third party, despite best efforts.
As the
security of Personal Information depends in part on the security of the device
you use to communicate with us and the security you use to protect your
credentials, please take appropriate measures to protect this information.
Data
breach
In the
event we become aware that the security of the Mobile Application and Services
has been compromised or Users’ Personal Information has been disclosed to
unrelated third parties as a result of external activity, including, but not
limited to, security attacks or fraud, we reserve the right to take reasonably
appropriate measures, including, but not limited to, investigation and
reporting, as well as notification to and cooperation with law enforcement
authorities. In the event of a data breach, we will make reasonable efforts to
notify affected individuals if we believe that there is a reasonable risk of
harm to the User as a result of the breach or if
notice is otherwise required by law. When we do, we will send you an email, get
in touch with you over the phone.
Changes
and amendments
We reserve
the right to modify this Policy or its terms related
to the Mobile Application and Services at any time at our discretion. When we
do, we will revise the updated date at the bottom of this page. We may also
provide notice to you in other ways at our discretion, such as through the contact
information you have provided.
An updated
version of this Policy will be effective immediately upon the posting of the
revised Policy unless otherwise specified. Your continued use of the Mobile
Application and Services after the effective date of the revised Policy (or
such other act specified at that time) will constitute your consent to those
changes. However, we will not, without your consent, use your Personal
Information in a manner materially different than what
was stated at the time your Personal Information was collected.
Acceptance
of this policy
You
acknowledge that you have read this Policy and agree to all its terms and
conditions. By accessing and using the Mobile Application and Services and
submitting your information you agree to be bound by this Policy. If you do not
agree to abide by the terms of this Policy, you are not authorized to access or
use the Mobile Application and Services.
Contacting
us
If you have
any questions, concerns, or complaints regarding this Policy, the information
we hold about you, or if you wish to exercise your rights, we encourage you to
contact us using the details below:
We will
attempt to resolve complaints and disputes and make every reasonable effort to
honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by
applicable data protection laws.
This
document was last updated on February 20, 2023