Last Updated Date: June 1, 2022
Welcome to the Elektra Virtual Museum Platform, owned and operated by Association pour la création et la recherche électroacoustiques du Québec (ACREQ), doing business as Elektra (“Elektra” or “we” or “our” or “us”).
If you have any questions regarding the processing of your personal information, do not hesitate to reach out to us! You can e-mail us at [email protected], or reach us by mail at the following address:
Elektra - Attention: Privacy Officer
5445 de Gaspé Avenue
QC, Canada H2T 3B2
This Policy describes how we collect, use and disclose personal information about individuals (“you”, “User”) who are:
- navigating our public website https://www.elektramontreal.ca (the “Website”);
- using our online application available for download at [https://evm.elektramontreal.ca] and meant to access the Virtual Museum (the “Application”); and
- exchanging with us by e-mail, social media or otherwise.
In this Policy we use the term “Services” to refer to all of the above, and where there is no distinction to make between the different aspects of the Services.
This Policy also covers our use of tracking technologies such as cookies (as defined hereinafter).
In addition, this Policy covers the use of your personal information for interest-based advertising.
This Policy does not apply to third-party content accessible through the Services, or to the use of a third party for the purpose of connecting to the Service, as applicable.
2. What do we mean by “personal information”?
Personal information is information that relates to a natural person or allows for the identification of a natural person. Some information may not be personal on its own, but may become personal information if associated with personal information or if the sum of the information allows us to identify you. For the purposes of this Policy, we consider that your cookies are personal information, regardless of applicable laws.
The definition of what constitutes personal information is subject to the laws applicable in your jurisdiction, and this Policy shall be interpreted in accordance with applicable laws.
For the purposes of this Policy, we define personal information as any information which relates to a natural person and allows that person to be identified. For example, this means that we consider electronic identifiers, such as e-mails and passwords, as personal information. You should know that some laws do not include business contact information (ex. name, title, work email, etc.) and other employee’s personal information in the legal definition of personal information. However, to be transparent with our Users, we included such personal information in our own definition of personal information.
We include cookies in our definition of personal information, although some laws may not consider cookies as personal information. Cookies are messages that web services pass to your web browser when you navigate the Internet. Your browser stores each of these messages in a small file. Our definition of cookies also includes similar technologies, like pixel and web beacons that are installed on your devices. Cookies can track you across different websites and serve different purposes. There are various types of cookies: (1) essential; (2) functional; (3) marketing and (4) analytics. Some cookies remain installed only for the duration of your session on a website, others remain installed for several months or years.
3. What types of personal information do we collect, and why?
- IP address, mobile identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and language.
- This information is collected automatically by Us for our Services to function effectively, to fix bugs, or to improve the security of our Services. We also use this information for analytics purposes to know more about your use of our Services. These may be collected as part of cookies.
- Time spent on the Services, pages visited, links clicked, language preferences, pages that led or referred you to the Website.
- We collect this information for analytics purposes.
- Email addresses/ Identification data/ Publicly available information/ Emails content.
If you communicate with us by email, on social media, by subscribing to our services-related news communications on our Website, or by any other means, we collect the personal information that you share with us, such as your email address and the content of your communication. If you communicate with us using social media, we will have access to your publicly available information.
WEBSITE AND MARKETING ACTIVITIES
- Email/ Consent to receive e-mails.
- If you consent to receive our communications, we will send you e-mails about updates and specific app information. You can unsubscribe at any time directly in the emails or by contacting us.
- Publicly available information.
- If you follow us or interact with us on social media, we may process your personal information for marketing or advertising purposes, subject to applicable laws, including those on consent.
4. What cookies do you use and why?
- First party cookies are those that are issued by Us, and they can only be set or retrieved by Us. They are used for purposes specific to Us, such as to personalize the Website.
- Third party cookies are placed on our Website or Application by other entities, such as to create new functionalities or conduct advertising.
Cookies can also be categorized based on their roles. We collect cookies that are classified in each of these categories:
- Essential cookies are necessary to operate the core functions of our Services. These include login cookies, session ID cookies, language cookies as well as security cookies.
- Functional cookies are used to provide you with some functionalities and to remember preferences, consents and configurations.
- Analytics cookies are used to generate aggregated statistical data about the traffic and behaviour of Users when using our Services. For instance, we can determine how much time Users spend on a page, and how successful our advertising is. For instance, the cookie named _ga is used by Google Analytics to gather data about your behaviour on our Services.
- Marketing cookies are used to deliver relevant advertising which requires tracking and analyzing users’ behaviour across websites. Cookies help us to do so through our partners. For instance, _fbp and fr are cookies installed by Facebook to deliver targeted advertising, and bcookie is a Cookie installed by LinkedIn to track users for advertising purposes on our Services.
5. Do we use Google Analytics?
Yes, we do. We use Google Analytics as part of Analytics cookies on our Website. Google Analytics is Google’s analytical tool that helps us to understand how Users engage with our Website. The information we collect through Google Analytics is page views, time spent through the Services, number of visitors, the source where they come from, the pages they have visited, session and Website usage, all in a deidentified form. Google Analytics uses a set of cookies to collect such information and report site usage statistics without allowing us to identify individual Users.
6. Do we conduct interest-based advertising (IBA)?
Yes. We use targeting cookies as part of our marketing strategy. This is called interest-based advertising, which is also referred to as targeted advertising or behavioural advertising. Re-targeting means that the ads that you are being served are personalized based on your behaviour when browsing online. This is enabled through cookies and requires the processing of electronic data that is considered personal information under certain laws.
We collect your Mobile Advertising ID (also called Identifier for Advertisers in iOS operating systems and Android Advertising ID in Android operating systems). A Mobile Advertising ID is a user-resettable ID assigned to a specific device that enables us to associate activity on a device to that specific device and to track usage of applications. This tool lets us convert your email address to a unique number that advertisers use to match to unique numbers it generates from email addresses of its users as part of real-time bidding.
If you are not comfortable with this, you can opt-out of interest-based advertising by managing your cookies and other tracking technologies. You can also use WebChoices which is a browser-based tool for opting out of interest-based advertising. Mobile users can also download the DAA Choice App that provides additional solutions and explanations to control block and control cookies, as well as plug-ins to retain opt-out cookie preferences, even if you delete your cookies.
7. To whom do you disclose your personal information to?
We do not sell your personal information to data brokers. However, we do share your personal information with certain types of third parties to provide you with the Services, conduct marketing and as required by the law.
- Service providers are used to provide you with some functionalities that are outsourced to third parties.
IT Service Providers
- We use IT Service Providers to offer you the Services, to host the Services and your personal information.
- We use marketing partners to (1) serve you relevant ads; (2) analyze the performance of our advertising campaigns; (3) manage our leads and (4) provide you with marketing content. All these activities require the processing of your personal information, including through cookies.
Law enforcement and other authorities
- We may receive requests by authorities to access your personal information. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required by such law enforcement requests.
We may share your personal information with our financial and legal advisors or auditors if reasonably required, or in the event we would be required to do so to defend our rights and interests.
In the case of a merger or acquisition, sale of assets, corporate reorganization, bankruptcy filing, insolvency procedures or similar circumstances, your personal information would be considered our assets and property. In these circumstances, ownership of the personal information we collected may be transferred or we may have to share some of your personal information to conclude, negotiate or discuss with third parties. We will only share what we are required to share for these specific purposes.
8. Where do we store your personal information?
We store your personal information in servers that are located in Canada. However, our other suppliers and third-party service providers may process your personal information internationally. Some countries may not offer the same level of protection offered in your country for personal information.
9. How long do we retain your personal information?
We retain personal information for as long as necessary to provide you with the Services, to perform our marketing campaigns effectively or as required by applicable laws, whichever is longer. We use both persistent and session cookies. Session cookies are deleted once you close your browser, whereas persistent cookies remain active on your device for some time. For instance, Google Analytics cookies remain installed on your device for 2 years. This allows Google Analytics to track you for analytic purposes, as well as for marketing purposes, and to provide us with aggregated data on your behaviour.
10. How do we keep your personal information secure?
We strive to implement physical, organizational, contractual and technological security features that are proportional to the risks involved, taking into consideration factors such as the sensitivity of the personal information that we collect.
However, it is important to understand that we cannot guarantee the security of personal information on the Internet and that you must also take precautions, such as not sharing your credentials with anyone. No method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you are concerned that your account credentials are compromised), please contact us immediately using the contact information at the beginning of this Policy. If we learn of a security breach involving your personal information, we will inform you and the relevant authorities of the occurrence of the breach as required under applicable law.
11. Can you manage your Cookie preferences?
You can always manage your Cookie preferences. However, some functionalities may require Cookies to perform as expected, or for security purposes. You can control your Cookie preferences through your browser. Depending on the browser you use, different instructions are applicable. Click on your browser for more information:
Google Chrome (you can also browse on Incognito Mode while using Chrome)
Do you have any rights over your personal information?
Yes! These rights vary depending on where you are located.
You generally have the right to access your personal information and to correct your personal information if inaccurate, in certain circumstances.
If you want to exercise your rights, you can contact us using the contact information provided at the top of this Policy.
We will try our best to respond to your request within 30 days. If we cannot comply with your request, we will tell you why.
If you are located in Canada, note that the Office of the Privacy Commissioner of Canada drafted this FAQ to help you access your personal information when it is held by a business. You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:
9:00 am to 4:00 pm EST
Office of the Privacy Commissioner
30 Victoria Street
If you have any issue with how we collect, use or disclose your personal information, or how we responded to your request, please let us know by contacting us using the contact information above. We will do our best to improve our processes to make certain that it does not happen again. We will also provide you with additional information about our practices if you would like us to do so.
If you are still not satisfied, you can lodge a complaint to the Office of the Privacy Commissioner of Canada using this online form, or to your local privacy regulator.
12. What about our newsletter?
If you give us your consent, we may send you commercial electronic messages to provide you with information about our events, activities, promotions and related news. You can unsubscribe at any time, and we will stop sending you such messages within 48 hours after you have clicked the unsubscribe link at the bottom of our emails.
13. Can we change this Policy?