At Nomadis, we are committed to providing our clients and users with exceptional service. As providing this service involves the collection, use, transfer, and disclosure of some personal information about our clients and users, protecting their personal information is one of our highest priorities.
We will inform our clients and users of why and how we collect, use, transfer and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy outlines the principles and practices we will follow in protecting personal information of our clients and users. Our privacy commitment includes ensuring the confidentiality and security of the personal information we collect and allowing our clients and users to , correction of, or deletion by obfuscation of their personal information.
Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect information that is necessary to fulfill the following purposes:
- To verify identity;
- To open and manage an account, such as a User account or a business Client account;
- To deliver requested products and services, namely to provide cloud software services in support of Human Logistics, Travel Management and related activities of our Clients;
- To ensure a high standard of service to our Clients and Users;
- To meet regulatory requirements;
- To diagnose issues related to our services and systems;
- To conduct research and perform analytics on the usage of our software solutions;
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided electronically, by the user or by proxy through an authorized representative, or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a Client or User is given notice and a reasonable opportunity to opt-out of his or her personal information being used in providing the Services, or for informative communications such as the marketing of new services or products, and the client does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Nomadis Inc. to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client, in making the decision.
2.5 We may collect, use or disclose personal information without the knowledge or consent of the client or user, in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate a possible data breach or other information security incident;
- To investigate an anticipated breach of an agreement or a contravention of law.
Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection, or for a purpose reasonably related to those purposes such as:
- To conduct client or user surveys in order to enhance the provision of our services;
- To contact our clients and users directly about products and services that may be of interest;
3.2 We will not use or disclose client or user personal information for any additional purpose, unless we obtain consent to do so.
3.3 We will never sell personal information to other parties.
Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client we will retain that personal information for at least one year so that the client, customer, member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
5.2 Clients or Users may request correction to their personal information in order to ensure its accuracy and completeness. Corrections must be done by the Client or User themselves using the systems put at their disposal by Nomadis. Should there be a case where it is not possible for the Client or User to modify their personal information using the systems provided by Nomadis, a request to correct personal information must be made in writing, providing sufficient details to identify the personal information and the correction being sought, and submitted using the standard support channels offered by Nomadis.
Securing Personal Information
6.1 We are committed to ensuring the security of personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 Nomadis has implemented and maintains administrative, physical and technical safeguards and measures designed to protect against unauthorized access to the personal information of its Clients and Users. Such security program is described in the most recent Service Organization Control 2 (SOC 2 Type II) report.
6.3 We will use appropriate security measures when destroying personal information of Clients or Users, such as permanently obfuscating or deleting personal information stored electronically (on media or within databases).
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security. As such we are committed to SOC 2 Type II recertification on an annual basis.
Providing Clients and Users Access to their Personal Information
7.1 Clients and Users have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made using the functionalities of the systems provided by Nomadis, such as obtaining access via the built-in system functionalities, recovering lost credentials, or other functionalities offered to recover personal information. If the Client or User is not able to obtain the personal information using the functionalities within the systems provided by Nomadis, a request must be made in writing, providing sufficient detail to identify the personal information being sought, and submitted using the standard support channels offered by Nomadis.
7.3 Upon request, we will also tell Clients and Users how we use their personal information and, to the extent possible, to whom it has been disclosed, if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to detailed personal information, for example transactional or audit trail data. Where a fee may apply, we will inform the Client of the cost and request further direction from the Client on whether we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the Client in writing, providing the reasons for refusal and the recourse available to the Client.
Questions and Complaints: The Role of the Privacy Officer or designated individual
9.1 The Privacy Officer is responsible for ensuring compliance with this policy and the applicable privacy laws.
9.2 Clients should direct any complaints, concerns or questions regarding compliance issues in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the Client may also write to the Information and Privacy Commissioner of the Province of Quebec, Canada.
Contact information for Nomadis:
General Enquiries and Support: firstname.lastname@example.org
Privacy and Security Concerns and Complaints: email@example.com