Effective Date: November 26, 2024
1. Introduction
At Sultran Ltd, and affiliates (Sultran Ltd., alone or, depending on the context, Sultran Ltd and its affiliates, are hereinafter referred to as “Sultran”, “us”, “our” or “our”), the protection of personal information is a priority.
This Privacy Policy (the “Policy”) describes how Sultran collects, uses, discloses and retains personal information about you, regardless of the nature of your relationship with Sultran (unless you are an employee), for example if you visit our website (collectively, the “Site”). This Policy also describes the rights you may have under privacy laws.
Our Site is not intended for children under the age of 14 and is not designed to attract the attention of children under the age of 14. If you are a parent or guardian and believe we have collected personal information about your child in error, please contact us immediately using the contact information at the end of this Policy, so that we can make reasonable efforts to promptly remove all personal information relating to the child from our systems.
2. Definition of “Personal Information”
In this Policy, the term “personal information” refers to any information (in any format) that relates to an individual and that directly or indirectly identifies the individual. Examples of personal information include your first and last name, address, phone number, email and date of birth. Personal information will not include any business contact information such as your name, title, professional phone number, postal or email address.
3. What Personal Information Does Sultran Collect?
We may collect the following personal information about you:
- Identifiers and contact information, such as your first and last name, address, phone number, social insurance number, and email. We may collect this information if you contact us on our Site, meet with our agents, or by other means, including when you apply for a job or for our services and products. Depending on the type of products or services you are applying to, we may also collect certain information on your dependent children, such as the name, age, passport number or birth certificate. This information will be collected through parental consent and legal guardians only.
- Information you provide to us through our social media accounts. Sultran is present on social media platforms, such as LinkedIn. When you interact with our social media accounts, for example, if you “like” our page or make comments, we may collect certain information about you, such as your name and profile picture. The information we collect depends on what these social media platforms share with us based on the privacy settings you have selected. We suggest you consult the privacy policies of these social media platforms to learn more.
- Geolocation and Technical information when you visit our Site. When you visit our Site, we may collect technical information electronically (through the use of cookies or the use of digital ID verification tools, for example) about your browser or device and your use of the Site. This information may include information about your visit to or use of our Site, including the IP address of your device or computer, user location, and the browser you used to access our Site. To learn how to limit the type of information we collect, use or disclose about you when you visit and/or use our Site, please visit What Are Your Privacy Rights?.
For example, we use Google Analytics, which allows us to obtain information about your online activities, including which pages you viewed, the source of your visit and the time spent on our Site. You can disable the use of Google Analytics by visiting the Google Analytics opt-out page.
- Other information about your interactions with us. We may collect information about any other interactions you may have with us (including any transactions, communications or requests you may have).
4. How Do We Use Personal Information?
We may use your personal information for the following purposes, or otherwise with your consent or as permitted or required by law:
- To ensure and improve our operations and the performance of our Site, for example, by analyzing your use of them, generating reports and ensuring their proper functioning.
- To manage our business activities, for example, to improve our business strategies or to detect fraud (or other illegal activities) and ensure the security of our IT systems.
- To communicate with you, for example, to respond to information requests or other inquiries, or to send you marketing communications and inform you about our products or send you personalized offers (e.g., newsletters, etc.).
- For other purposes permitted or required by law. We will not use personal information for any other purpose without your consent, unless we are legally permitted or required to do so by law, for example, to comply with a legal obligation or to protect the rights, including property rights, and interests of Sultran.
5. How Do We Share Personal Information?
Your personal information may be disclosed in the following contexts in order to achieve the purposes set out in this section:
- With our employees. Certain employees may have access to your personal information in the context of their functions and on a need-to-know basis only.
- Affiliates and Partners. We may share your personal information with Sultran’s affiliates for the purposes described in this Policy.
- Service providers. We hire companies and individuals to perform certain tasks on our behalf and/or to provide us with services. These service providers may fall into different categories such as accounting, financial, tax, accounting, marketing (including digital, behavioural advertisements, and commercial electronic messages) and legal consulting, website hosting, customer service, IT or software solutions. These service providers have access to the personal information necessary to fulfill their duties, but may not use this information for any other purpose.
- Protecting the interests of Sultran and third parties. We may disclose personal information when we believe it is appropriate for the purposes of complying with the law, enforcing our agreements, or protecting the rights, title deeds or safety of Sultran, its clients or other parties.
- Commercial transactions. We may disclose and transfer personal information in connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any part of our business, assets or shares (including in connection with bankruptcy or similar proceedings), but only to the extent that your personal information is necessary for such transactions, in which case we will comply with applicable legal requirements.
- Other situations. We may share your personal information in other situations, in which case we will inform you of such practices and obtain your prior consent (or as required or permitted by law).
6. What Kind of Cookies are used by Sultran ?
Cookies are small pieces of data (text file) that are saved on your computer or mobile when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. Cookies may be temporary (or “session”) cookies, which are only in use while you visit our Site and are deleted when you close your browser, or permanent cookies, which stay on your device’s permanent storage after you leave our Site until you delete them manually or your browser deletes them after a period of time. Cookies that are set by us are called first-party cookies. We also use third-party cookies, which are cookies from a domain different than the domain of the Site you are visiting.
Our Site primarily uses the following four types of cookies:
- Strictly necessary cookies: These cookies are necessary for our Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but that may cause some parts of the Site to not work.
- Functional cookies: These cookies are used to recognize and remember your preferences, sharing content of the website on social media platforms, collecting feedback and other third-party features. For example, functionality cookies may use information, such as your language preferences, to make sure that you arrive at a version of our Site that will provide you with a continuous experience.
- Analytics cookies: These cookies are used to understand how visitors interact with our Site. For example, analytics cookies will provide information on metrics such as the number of visitors, bounce rate, traffic sources among others. We use various tools for these purposes. For instance, we use Google Analytics to learn more about the visitors on our Site and their activities on our Site. To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to information regarding your visit (such as the pages you visit and length of your visit), information about your device (such as your IP address), how you got to the website, and other information about you. Google Analytics has developed an opt-out tool that will prevent Google Analytics from tracking you across all website, which is available here: https://tools.google.com/dlpage/gaoptout/.
- Performance cookies: These cookies are used to understand and analyze key performance indexes of our Site to help deliver a better user experience. For example, performance cookies tell us which pages are popular, monitor traffic to our Site and compile anonymous analytic information. Performance cookies can also be used to identify and remedy operational problems with the Site.
- Advertising Cookies: These cookies collect information about your browsing habits and are generally placed on our Site by our advertising partners, which include social media platforms. They may be used by those companies to build a profile of your interests, show you relevant advertisements on other websites and analyze the efficiency of the advertisement campaign.
When using our Site, you may be directed to other websites for such activities as surveys, and to view content hosted on those websites such as an embedded video or news article. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our Site.
7. What Are Your Privacy Choices?
By providing us with personal information when using our Site, you consent to the collection, use and disclosure of your personal information in accordance with this Policy. In some cases, your consent may be “implied”, meaning that your consent is presumed based on your action or inaction at the time of collection, use or sharing of your personal information. We usually obtain your consent when we want to use personal information for a new purpose or for a purpose other than those indicated at the time of collection in this Privacy Policy, in accordance with applicable privacy laws.
You can choose how we treat your personal information:
- Changing your browser settings. We use technologies such as cookies to improve your experience on our Site. Thanks to technologies such as cookies, our Site can recognize you when you use or return to them and can facilitate your experience (for example, memorizing the language of our Site). You can remove or disable some of these technologies at any time via your browser and the cookie banner. However, if you do, you may not be able to use some of the features of our Site.
Please refer to your browser’s instructions, help screen or cookie banner for information on how to block, delete and manage cookies on your computer or mobile device.
You can deactivate Google Analytics by downloading and installing the Google Analytics Deactivation Browser Add-on for your browser.
- Withdraw your consent. You may withdraw your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy at any time by sending us a request in accordance with the information provided in the Complaints and Questions section below, subject to legal or contractual restrictions. Withdrawal of your consent may affect the provision of the services you receive or would like to receive, as the continued use and disclosure of your personal information may be necessary to make the service available to you. In some circumstances, legal requirements may prevent you from withdrawing your consent.
8. What Are Your Privacy Rights?
The rights described above may be exercised in accordance with the requirements and restrictions provided by law:
- Your right of access: you have the right to ask us if we use or retain your personal information. You may also request copies of this personal information.
- Your right to rectification: you have the right to ask us to rectify personal information that you consider inaccurate or equivocal, and to complete information that you consider incomplete. You may also have the right to request rectification of your personal information if the collection, disclosure or retention of such information is not permitted by law.
To exercise your rights, you may make a request to that effect in your account or by contacting our Privacy Officer at the email address indicated in the Complaints and Questions section below.
9. Governance Rules and Other Privacy Measures
Sultran implements reasonable administrative, contractual, technical and physical safeguards to protect personal information in its custody or control from unauthorized access, use, modification and disclosure.
Sultran has adopted policies and practices that ensure the protection of your personal information, including:
- Internal policies and procedures that define the roles and responsibilities of our employees throughout the information lifecycle and that limit their access to information on a need-to-know basis;
- If the information is collected or stored electronically, the establishment of technical safeguards such as firewalls, passwords, anti-virus software, multi-factor authentication tools and other similar measures;
- Appointment of a Privacy Officer to ensure compliance with applicable privacy laws;
- Training of employees on privacy and information security;
- A process for handling privacy complaints and inquiries, including regarding any confidentiality incidents involving personal information; and
- Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate safeguards and security standards.
10. Retention of Your Personal Information
Sultran has processes and retention periods to ensure that we retain your personal information only for as long as is reasonably necessary for the purposes set out in this Policy or to comply with our legal obligations.
Sultran is committed to making reasonable efforts to maintain users’ personal information that is accurate, complete and up-to-date to the extent necessary to achieve the purposes for which it was collected and is to be used. Sultran may, from time to time, ask you to confirm the accuracy of your personal information for this purpose.
11. Transfer Of Your Personal Information to Countries Other Than Canada
Some of our external third-party service providers are based outside of your province or territory of residence, including without limitation Canada and the United States, and their processing of your personal information will therefore result in the transfer of information outside of Canada. Organizations based outside of Canada may not be subject to privacy laws that provide you with the same rights and protections as in Canada. As a result, your personal information may be subject to the laws of a foreign jurisdiction, including any law that permits or requires the disclosure of information to law enforcement or national security authorities upon request.
12. Complaints And Questions
Sultran has appointed a Privacy Officer. If you believe that your privacy question or request has been handled in violation of this Policy, or if you would like to receive more information about this Policy, you can submit a written request to the Privacy Officer at lindsayo@sultran.com.
13. Updates
We may review and update this Policy as necessary to stay current with laws and regulations, new technologies and standards. Please refer to the “Effective Date” at the top of this page to find out when this Policy was last revised. If the changes we make are material, we will highlight them when required by applicable law, including by posting a notice on the Site before the change comes into effect. We encourage you to check this page regularly for the latest information on our privacy practices.
By continuing to use our Site after the modified version of this Policy has been published, you agree to the changes made to this Policy.
