Privacy policy

Hub6 is a multidisciplinary firm offering legal, accounting, human resources and as such collect information on identifiable persons or permitting the identification of a person (hereinafter the “Personal Information”).

This privacy policy (hereinafter the "Policy") governs the practices of Hub6 Inc. (collectively hereinafter “we” or "Hub6 ") with respect to the collection, processing and use, disclosure and retention of Personal Information that you provide to Hub6.

Hub6 is firmly committed to protecting the privacy and security of your Personal Information that we collect, process and control. This present Policy is to inform you about how we collect Personal Information about you, how we use them and under what circumstances we may disclose or share them.

1. Who is it for?

The rights and obligations described in the Policy apply to all individuals, including our employees and professionals, customers, suppliers, collaborators, candidates, Internet users and users of the www.hub6.com Web site (hereinafter the "Web site") and to any third party, for which we obtain Personal Information (hereinafter collectively the "Users" ou "you").

We are responsible for the Personal Information entrusted to us by all Users.

2. Hub6’s commitments

We undertake to collect only the Personal Information necessary to accomplish the purpose for which you have requested our services, and to use such Personal Information in accordance with this purpose or as required by applicable laws, including without limitation rules of professional ethics.

Hub6 also undertakes not to sell your Personal Information and to protect it from unauthorized disclosure or access in accordance with its legal and professional obligations.

To the extent that we need to share your Personal Information, as part of a mandate, with an Hub6 authorized partner – for example, an international tax expert or a specialist in a particular field, we undertake to notify you and to ensure that your authorized partner understands and respects your rights. Such partner shall also comply with local privacy laws, if applicable, which may differ from those in force in your jurisdiction of residence.

We may also have to share your data with the courts or the government, if required by law.

3. Your consent

By providing your Personal Information, you consent to the use and disclosure of such information in accordance with this Policy. So, you authorize us to collect, to use and share the Personal Information you provide to us, so that it may be communicated or used in accordance with the purposes for which it was collected. We only collect Personal Information we need.

Subject to applicable laws, you may withdraw such consent in the manner provided herein. However, the withdrawal of consent does not affect the lawfulness of the processing of your Personal Information prior to the withdrawal of consent.

If you do not agree to this Policy, please do not disclose your Personal Information, do not use the Web site or, if applicable, send an e-mail or message to the Privacy Officer at Hub6 using the contact information provided in the “Information" section below.

4. What Personal Information do we collect?

In order to provide our services, we need to obtain and process information, including certain offline and online data, and in particular Personal Information.

The Personal Information we collect is primarily identification and authentication information, and may include:

• your name;
• your contact information, including your address, e-mail address and telephone number;
• documents and information to establish your identity;
• information about your organization’s members, including its employees, directors or officers, or any person related to the mandate entrusted to us;
• your payment information; and
• any other personal information you voluntarily provide to us.

In the case of employees or job applicants, Hub6 may also collect professional information, which may include:

• your company;
• your department;
• your position;
• your location;
• your curriculum vitae; and
• your references for all applications.

We do not collect any Personal Information about you, unless you provide it to us voluntarily or give us your consent to collect it by any other method.

In addition, Hub6 may automatically collect certain technical data about your visit to the Web site, including, but not limited to, certain traffic data, the type of device you use, the IP address and geographical location, the User's operating system, the Internet service provider, the type of Internet browser you use, the domain name, the access times, the duration of the visit, the referring URL, date and exit page marking (‘’cookies’’), as well as information about how you use the Web site ("Technical Data").

When you speak with us by phone, you may provide us with Personal Information during the call, and this Personal Information may be recorded in written notes.

5. How do we use your Personal Information?

Hub6 undertakes to use the Personal Information of any User in accordance with the purpose for which the Personal Information was communicated by the User in question. Only Hub6, its staff and authorized partners will have access to such information. Hub6 undertakes to ensure that its employees and authorized partners are informed of their obligation to guarantee the security and confidentiality of your Personal Information, in connection with the communication and/or consultation of Personal Information.

We may use and disclose Personal Information for the following purposes:

• Establish and verify your identity;
• Billing you for the services we provide;
• The delivery of our services;
• Keep our records in accordance with our professional obligations;
• Answering your questions;
• Better assess and respond to your needs and offer you a personalized experience based on informed analysis, conducted by us and our authorized partners, your usage and preferences;
• Promoting our own services for you;
• Host data with a cloud service provider;
• Respect our professional obligations and standards;
• To ensure security on our premises, via video surveillance cameras for example;
• Any purpose permitted or required by law; and
• Any other purpose disclosed to you and consented to by you.

We use Technical Data to compile reports on the Web site and to analyze usage trends. In addition, it allows us to detect problems with our server, manage the Web site, track the movements of users and use and collect general demographic information. See "Cookies" below for more information.

6. Retention, sharing and cross-border transfer of Personal Information

The Personal Information collected by Hub6 is kept only as long as necessary:

• for the purposes for which they were collected;
• for legitimate purposes; or
• to answer any questions that may arise at a later date.

When the Personal Information collected is no longer required for these purposes, Hub6 undertakes to destroy or anonymize it. While destruction is a process of definitive elimination, anonymization means that your Personal Information is modified so that it can no longer be used to identify you directly or indirectly. Destruction and anonymization are carried out safely and securely, in accordance with recognized best practices and the criteria and procedures determined by applicable laws.

When you provide Personal Information to Hub6, you agree that this information may be transferred electronically over the Internet to Hub6 and that Personal Information may also be transferred, stored, hosted and processed on behalf of Hub6, by a third party. Hub6 uses private cloud servers to store your Personal Information.

If we need to share Personal Information with third-party suppliers, in particular to ensure their safety and protection, Hub6 will ensure that the protection and confidentiality of such information comply with this Policy and will require such suppliers to comply with this Policy. Third-party suppliers are authorized to use Personal Information only for the purpose of providing their services to Hub6 and Personal Information may not be disclosed or transferred by such third party without the consent of Hub6.

Your Personal Information is usually hosted in Canada and/or the United States. In the event that Hub6 uses the services of a third-party supplier to host and store the Personal Information it collects, this third-party supplier may be located in another country. Therefore, you hereby consent to the transfer of Personal Information to countries other than Canada or the United States, where data protection rules may differ from those in your country of residence, and Hub6 will hold companies outside Canada or the United States responsible, under applicable law, of all Personal Information that may be transferred to them.

Under applicable law, we may be required to share Personal Information with a third party. For example, we may be required to disclose Personal Information pursuant to a court order, subpoena or warrant. In addition, subject to applicable laws, we may voluntarily provide information to assist law enforcement in an investigation or when disclosure is necessary to protect our systems, of our company or the rights of others, including for safety reasons.

We will share your Personal Information only in the ways described above and in accordance with applicable data protection laws.

7. Users' rights and applicable legislation

As the party responsible for processing your Personal Information, Hub6 undertakes to comply with all laws and regulations applicable to the protection of Personal Information according to the jurisdiction in which the User is located.

Hub6 will collect, process, store, disclose and dispose of the Personal Information you submit to us in accordance with the privacy laws applicable in the jurisdiction in which you are located, including without limitation, the laws applicable in the province of Quebec and the federal laws applicable of Canada therein, the laws applicable in the European Union and the United States. In particular, Hub6 undertakes to respect, depending on the User's jurisdiction of residence, the Personal Information Protection and Electronic Documents Act, the Act respecting the protection of personal information in the private sector, including updates made by the Act Modernizing Legislative Provisions on the Protection of personal information and the General Data Protection Regulation 2016/679 (GDPR).

You may exercise your rights under applicable law by writing to our Privacy Officer identified in the "Information" section below. You will then be contacted within a reasonable time to verify your identity before your request is processed.

8. Rights of access, correction, opposition and withdrawal

Hub6 undertakes to confirm the existence or non-existence of your Personal Information about you, to give you access to it, if applicable, and correct them according to your instructions, if necessary. It is your responsibility to provide us with true and accurate Personal Information, and you must inform us of any changes to this information.

You also have the right to object to and to withdraw your Personal Information, namely the possibility of requesting that your Personal Information no longer appear in a file for consultation, distribution or transmission, or withdrawing your consent at any time, as mentioned above.

Please note that we may, to the extent permitted by applicable law, not be able to respond to requests to delete your Personal Information if this is necessary to:

• Complete the mandate for which the Personal Information was collected, provide a service requested by you or reasonably expected in the context of our ongoing relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for such activity; or
• Comply with an existing legal obligation.

You may limit the use of your Personal Information and refuse to have your Personal Information used for certain purposes identified at the time of collection.

Finally, you can delete your customer account and associated information at any time.

In order to exercise these rights, we invite you to contact in writing our Privacy Officer identified in the section "Information" section below. To exercise your rights, you must first provide proof of your identity. In all cases, we will handle requests for access or modification in accordance with the applicable legislation.

9. Province of Quebec

Hub6 undertakes to respect all the rights and obligations stipulated by applicable laws and regulations regarding the protection of personal information in the collection and processing of your personal data. In particular, with respect to Users in the province of Quebec, Hub6 undertakes to:

1. In the event of a privacy incident involving Personal Information ("Incident"), take reasonable measures to reduce the risk of harm to the Users concerned and to prevent such an Incident from recurring;
2. Keep a register of Incidents, a copy of which may be requested, and must be provided on request, by the Commission d'accès à l'information ("Commission");
3. Notify the Commission and the Users concerned without delay in the event of an Incident presenting a serious risk of prejudice;
4. Conduct a Privacy Impact Assessment ("PIA") before disclosing Personal Information without consent for study, research or statistical purposes;
5. Conduct PIA before Personal Information is disclosed or communicated outside Quebec; and
6. Process and execute promptly any request for portability of Personal Information by the User.

10. Connection indicators (cookies)

The connection indicators or ‘’Cookies" are small, simple files which, as you navigate through the various pages of this Web site, are downloaded and stored by your browser on the hard disk of your computer or other device in order to memorize information about you, such as your language preference, for example. Cookies cannot be used to run programs or transmit viruses to your computer or device. Cookies are uniquely assigned to you and can only be read by a Web server in the domain that sent you the cookie.

The information stored there may be returned to our servers or to the servers of the third parties concerned during a subsequent visit, enabling us to improve and personalize your experience during your next visit.

We use cookies to understand your use of our Web site in order to improve its content. We may also use cookies to provide you services that match your interests, as identified through the Web site. If you choose to provide Personal Information through our Web site, this Personal Information may be linked to stored cookies and the information they contain.

One of the main purposes of cookies is to provide practical functionality to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Hub6 pages, or register with the Hub6 Web site or services, a cookie helps Hub6 to remember your specific information on subsequent visits. This simplifies the process of registering your personal information, such as billing addresses, delivery addresses, etc. When you return to the same Web site page, the information previously provided can be retrieved, so you can easily use the Hub6 features that you customized.

You have the option of managing the connection indicators on your computer, while you have the option of accepting or declining them. All major browsers automatically accept cookies, but allow you to block or delete them from your system; however, deactivating cookies may restrict your use of our Web site and/or some of its functionalities. To find out more about your ability to manage cookies, please consult your browser's privacy functions.

11. Minor children

We are committed to protecting children’s privacy of and encourage parents and guardians to play an active role in their children's online activities and look after their interests. We do not intentionally collect Personal Information from children under the age of fourteen (14) and do not target children under the age of fourteen (14) on our Web site.

If you are a parent and learn that your child has disclosed Personal Information to us, we invite you to contact the Privacy Officer at Hub6 using the contact information provided in the "Information" section, so that you can delete your child's Personal Information as soon as possible.

12. Safety

Hub6 will ensure that Personal Information is stored securely using up-to-date software and that appropriate measures are in place to guarantee the security of the information and prevent unauthorized sharing.

Where your personal information is transferred, stored, hosted and/or processed on Hub6's behalf by a third party, Hub6 seeks to apply the most secure means of transfer and storage. However, despite Hub6’s practices and procedures, no method of Internet transmission or electronic storage is fully secure, and we cannot ensure or warrant the security of any information you transmit to us or otherwise provide to us, Hub6 is only bound by an obligation of means. Therefore, you agree that Hub6 shall not be responsible or liable in any way for any damages that you or any third party may suffer as a result of any unauthorized access to Personal Information or data breach involving Personal Information.

In the event that an Incident occurs, we will notify any person affected by the Incident in accordance with the law and take all reasonable steps to reduce the risk of harm being caused in addition to taking reasonable steps to prevent further Incidents from occurring.

13. Modification

Hub6 reserves the right to modify this Policy at any time and for any reason it deems necessary. In the event of a change to this Policy, the updated version of the Policy will be published and made available without delay and will become effective immediately upon posting on the Web site. Your continued use of the Web site and/or available services following any such modifications shall constitute your: (a) acknowledgement of the Policy as modified; and (b) agreement to abide by and be bound by this Policy.

The version of this Policy applicable each time you access the Web site is the one in effect at the date and time the User accessed it, as posted on the Web site at that time.

14. Filing a complaint

If you feel that your rights have not been respected or that this Policy has not been applied, you may file a complaint with our Privacy Officer, identified below, or with the Commission.

15. Information

As the controller of your Personal Information, Hub6 has appointed a Privacy Officer who will be responsible for the application of this Policy and Hub6's ongoing compliance with the Policy. If you have any questions about this Policy or wish to exercise any of your rights under this Policy, please contact our Privacy Officer at the following address:

Anthony Quevillon
aquevillon@hub6.com
6000 boul. Rome, Suite 300
Brossard, Quebec, J4Y 0B6
© 2024, Hub6 inc.
Last update: May 10, 2024