1. Introduction
Welcome to VIVRAI (the "Website").
This Privacy Policy explains how the Website operator ("Company", "we", "us", or "our") collects, uses, stores, discloses, and protects personal information when individuals visit or interact with our Website or use our products and services.
We are committed to respecting the privacy of our visitors, customers, and other individuals whose personal information we process.
Where applicable, we seek to comply with Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act ("PIPEDA") and relevant provincial privacy laws.
This Privacy Policy applies to:
- Visitors accessing our Website;
- Individuals contacting us through forms, email, or other communication channels;
- Registered users and customers, where registration or customer services are available;
- Individuals interacting with our products, services, or customer support;
- Other individuals whose personal information we process in connection with our operations.
By using our Website, you acknowledge that you have been provided with this Privacy Policy. Where required by applicable law, we will obtain your consent before collecting, using, or disclosing your personal information.
2. Personal Information We Collect
Personal information means information about an identifiable individual.
The categories of information described below apply only to the extent that they are actually collected through our Website or services.
When online messaging is available, submitting this form sends the details you enter to the contact service so we can respond. If the form cannot send your message, it displays an error and keeps your details on screen. You can also contact us by email or phone.
2.1 Information You Provide
Depending on your interactions with us, we may collect:
- Full name;
- Email address;
- Telephone number;
- Country or region of residence;
- Mailing or billing address;
- Account registration details, where applicable;
- Messages, inquiries, and support requests;
- Information voluntarily submitted through online forms;
- Other information reasonably necessary to provide requested services.
2.2 Account Information
If our Website supports user registration, we may process account-related information, including usernames, authentication information, account preferences, and records of account activity.
Passwords, where used, should be protected using appropriate security measures.
2.3 Technical and Usage Information
When visitors access our Website, certain technical information may be collected automatically by our hosting infrastructure or technologies used on the Website.
This may include:
- Internet Protocol (IP) address;
- Browser type and version;
- Device type;
- Operating system;
- Referring website;
- Pages visited;
- Dates and times of access;
- Website interactions;
- Diagnostic and security logs.
Such information may be used for Website functionality, troubleshooting, security, and performance analysis.
2.4 Cookies and Similar Technologies
Our Website may use cookies or similar technologies to support functionality, maintain preferences, measure performance, or provide additional features.
Depending on the technologies implemented, cookies may include:
- Strictly necessary cookies;
- Functional cookies;
- Analytics cookies;
- Advertising or marketing cookies.
Where required by applicable law, we will obtain consent before using non-essential cookies or tracking technologies.
Visitors may also manage cookies through their browser settings.
2.5 Information from Third Parties
We may receive personal information from third parties where reasonably necessary to provide our services and where permitted by applicable law.
Potential sources may include:
- Service providers;
- Business partners;
- Authentication providers;
- Payment processors;
- Technical support providers;
- Other parties authorized by the individual.
3. How We Use Personal Information
We collect, use, and process personal information only for identified, reasonable, and lawful purposes.
Depending on the services offered, these purposes may include:
- Operating and maintaining the Website;
- Providing requested products or services;
- Responding to inquiries and support requests;
- Managing customer relationships;
- Administering user accounts, where applicable;
- Improving Website performance and usability;
- Detecting and preventing fraud, abuse, and unauthorized access;
- Maintaining operational security;
- Complying with applicable legal and regulatory obligations;
- Sending service-related communications;
- Delivering promotional communications where permitted and, when required, with appropriate consent;
- Protecting the rights, property, and legitimate interests of the Company and its users.
We will not use personal information for materially different purposes without providing appropriate notice and obtaining additional consent where required.
4. Consent and Your Choices
Where Canadian privacy law requires consent, we will seek meaningful consent for the collection, use, or disclosure of personal information.
We aim to explain what information is collected, why it is needed, with whom it may be shared, and any material consequences of providing it.
Depending on the circumstances and sensitivity of the information, consent may be express or implied where legally permitted.
You may withdraw consent, subject to legal or contractual restrictions and reasonable notice, by contacting us through our Contact page.
Withdrawal of consent may affect our ability to provide certain services.
We will not make consent to unnecessary data processing a condition of receiving a service where prohibited by law.
5. Disclosure of Personal Information
We may disclose personal information to third parties only where reasonably necessary, authorized by the individual, or otherwise permitted or required by applicable law.
5.1 Service Providers
We may engage third-party service providers to perform functions on our behalf, potentially including:
- Website hosting;
- Technical maintenance;
- Cloud infrastructure;
- Customer support;
- Email delivery;
- Website analytics;
- Payment processing, if applicable;
- Cybersecurity and fraud prevention.
We seek to require service providers to handle personal information only for authorized purposes and with appropriate safeguards.
5.2 Legal and Regulatory Requirements
We may disclose personal information where required or permitted by applicable law, including in response to valid legal processes, court orders, or lawful requests from competent authorities.
We may also disclose information where legally permitted and reasonably necessary to investigate fraud, security incidents, or unlawful activities.
5.3 Business Transactions
In connection with a proposed or completed merger, acquisition, restructuring, financing, or sale of business assets, personal information may be disclosed or transferred subject to applicable legal requirements and appropriate safeguards.
5.4 No Unauthorized Disclosure
We do not authorize service providers to use personal information for purposes unrelated to the services they perform on our behalf.
6. International Data Transfers
Personal information may be processed or stored outside Canada if the Company or its service providers operate in other jurisdictions.
Where international transfers occur, we will take steps required by applicable law to protect personal information.
Information processed outside Canada may be subject to the laws of the jurisdiction in which it is processed, including lawful access requests by public authorities.
7. Data Security
We recognize the importance of protecting personal information against unauthorized access, loss, theft, misuse, alteration, and disclosure.
We aim to implement administrative, technical, and organizational safeguards appropriate to the sensitivity of the information and the risks associated with its processing.
Such safeguards may include, where implemented:
- Access controls;
- Secure authentication;
- Encryption;
- Security monitoring;
- Restricted access to personal information;
- Secure hosting and infrastructure;
- Incident-response procedures;
- Personnel confidentiality obligations.
No method of internet transmission or electronic storage is completely secure. We cannot guarantee absolute security.
8. Data Retention
We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, subject to applicable legal, contractual, and regulatory requirements.
Retention periods may depend on:
- The nature and sensitivity of the information;
- The purposes for which it was collected;
- Applicable legal requirements;
- Operational and security needs;
- The existence of unresolved disputes or legal claims.
When personal information is no longer required, we will take reasonable steps to securely delete, destroy, or anonymize it, as appropriate.
9. Your Privacy Rights
Subject to applicable Canadian privacy legislation and lawful exceptions, individuals may have the right to:
- Request access to personal information held about them;
- Request correction of inaccurate or incomplete information;
- Obtain information about how their personal information is used or disclosed;
- Withdraw consent where processing relies on consent;
- Challenge compliance with applicable privacy obligations;
- Submit a privacy-related complaint.
Additional rights may apply under provincial legislation, including in Quebec.
To exercise applicable privacy rights, please contact us through our Contact page.
We may request information reasonably necessary to verify your identity before processing a request.
We will respond within the time limits required by applicable law.
10. Marketing Communications
Where we send promotional emails or other commercial electronic messages, we will comply with applicable Canadian anti-spam requirements, including Canada's Anti-Spam Legislation ("CASL").
Where required, we will obtain appropriate consent before sending marketing communications.
Recipients will be provided with an appropriate means of unsubscribing from commercial electronic messages.
Opting out of marketing communications will not necessarily prevent us from sending essential administrative, security, or service-related communications.
11. Children's Privacy
Our Website is not intended to collect personal information from children without the consent or authorization required by applicable law.
If our services are directed toward minors or if we knowingly process children's personal information, additional safeguards and consent procedures may be required.
If we become aware that personal information has been collected from a child without legally required consent, we will take appropriate steps in accordance with applicable law.
12. Third-Party Websites and External Links
Our Website may contain links to websites, applications, or services operated by independent third parties.
We do not control the privacy practices of those third parties.
Visitors should review the applicable privacy policies before providing personal information to external websites or services.
This Privacy Policy applies only to personal information processed by the Company within the scope described in this document.
13. Automated Processing and Artificial Intelligence
If our Website uses automated decision-making systems, artificial intelligence, chatbots, or similar technologies to process personal information, we will provide information and obtain consent where required by applicable law.
Depending on the functionality involved, additional disclosures may be necessary concerning the purposes of automated processing and individuals' applicable rights.
14. Privacy Incidents and Data Breaches
We aim to maintain procedures for identifying, investigating, containing, and responding to incidents involving personal information.
Where a breach of security safeguards occurs, we will assess its impact and comply with applicable reporting, notification, and recordkeeping obligations.
Under PIPEDA, certain breaches creating a real risk of significant harm must be reported to the Office of the Privacy Commissioner of Canada, and affected individuals must be notified, subject to applicable legal requirements.
Additional obligations may apply under provincial privacy legislation.
15. Quebec and Other Provincial Privacy Requirements
Canadian privacy obligations may vary depending on the Company's operations, location, and the individuals whose information is processed.
Where applicable, we will comply with relevant provincial privacy laws, including Quebec's Act respecting the protection of personal information in the private sector, as amended.
Additional requirements may concern:
- Designation of a person responsible for privacy;
- Transparency regarding personal information processing;
- Privacy impact assessments;
- Transfers of personal information outside Quebec;
- Privacy incidents;
- Automated decision-making;
- Applicable rights to data portability or de-indexing.
16. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our services, information-handling practices, legal requirements, or operational procedures.
Where changes are material, we will provide additional notice and obtain consent where required by applicable law.
We encourage visitors to review this Privacy Policy periodically.
17. Additional Information for Canadian Residents
We are committed to providing clear information about the collection, use, disclosure, and protection of personal information.
Where PIPEDA applies, our privacy practices are intended to reflect its fair information principles, including accountability, consent, limiting collection, limiting use and retention, safeguards, openness, individual access, and the ability to challenge compliance.
This Privacy Policy does not limit any privacy rights that cannot lawfully be waived or restricted under applicable legislation.