Website Privacy Policy

This Website Privacy Policy applies to: InitiateProtection.com

Last update: November 1, 2023

The respect of your private life is of the utmost importance for Paymt.net LLC, who is responsible for this website.

This Privacy Policy aims to lay out:

  • the way your personal information is collected and processed. "Personal information" means any information that could identify you, such as your name, your mailing address, your email address, your location and your IP address. "Personal information" is a synonym for "personal data" within the meaning of the Regulation 2016/679 of the European Union (General Data Protection Regulation);
  • your rights regarding your personal information;
  • who is responsible for the processing of the collected information;
  • to whom the information is transmitted;
  • if applicable, the website's policy regarding cookies.

This Privacy Policy complements the Terms and Conditions that you may find at the following address:

https://initiateprotection.com/terms

1. COLLECTION OF PERSONAL INFORMATION

We collect the following personal information:

  • Last Name
  • First name
  • Postal code
  • Email address

The personal information we collect is collected through the collection methods described in the following section.

2. FORMS AND METHODS OF COLLECTION

Your personal information is collected through the following methods:

  • Website registration form
  • Order form

We use the collected data for the following purposes:

  • Order tracking
  • Special offers
  • Contact
  • Managing the website

3. COOKIES AND LOG FILES

We collect information through log files and cookies. These allow us to process statistics and information about traffic on the Website, to ease navigation, and to improve your experience for your comfort.

Under the General Data Protection Regulation (European Regulation 2016/679), the use of cookies and log files that involve personal information saving and analysis requires your consent.

Your consent is considered to be valid for a maximum period of thirteen (13) months. At the end of that period, we will ask again for your consent to save cookies and log files on your hard disk.

a) Cookies used by the Website

The cookie files used on the Website are the following:

  • IP address
  • Operating system
  • Pages visited and queries
  • Day and time of connection

The use of such files allows us to achieve the following purposes:

  • Improvement of the service and personalized welcome
  • Order tracking
  • Statistical surveys

b) Objection to the use of cookies and log files by the Website

You have the right to object to the recording of these cookies and log files by configuring your web browser.

Once you have deactivated cookies and log files, you may continue your use of the Website. However, any malfunction resulting from this deactivation shall not be considered of our making.

4. SHARING PERSONAL INFORMATION

We are committed not to sell to third parties or otherwise commercialize the personal information we collect. However, we may share this information with third parties for the following reasons:

  • Order fulfillment
  • Partnership

5. STORAGE PERIOD OF PERSONAL INFORMATION

The controller will keep in its computer systems, in reasonable security conditions, the entirety of the personal information collected for the following duration: 1 year.6. RIGHT OF OBJECTION AND OF WITHDRAWAL

You have the right to object to the processing of your personal information by the Website ("right to object"). You also have the right to request that your personal information not appear, for example, on a mailing list ("right to withdraw").

If you wish to exercise the right to object or the right to withdraw, you must follow the procedure described hereinafter:

Use the customer profile options when logged into the website, or contact us.

7. RIGHT OF ACCESS, OF RECTIFICATION AND OF REMOVAL

You have the right to consult, update, modify or request the removal of information about you by following the procedure described hereinafter:

Use the customer profile section of the website when logged in, or contact us.

If you have a personal account, you may request its removal by following the procedure described hereinafter:

Use the customer profile section of the website when logged in, or contact us.

8. GENERAL PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA UNDER EUROPEAN REGULATION 2016/679

In accordance with the provisions of Article 5 of European Regulation 2016/679, the collection and processing of your personal data comply with the following principles:

  • Lawfulness, fairness and transparency: your personal data may only be collected and processed with your consent. Every time your personal data is collected, you will be informed that your personal data is collected and for which reasons your personal data is collected;
  • Limits purposes: the data is collected and processed for one or more purposes set out in this Privacy Policy;
  • Data minimization: only personal data necessary for the purpose to which it is necessary is collected;
  • Storage limited in time: personal data is stored for a limited time, of which you are notified;
  • Integrity and confidentiality of collected and processed personal data: the Controller is committed to guarantee the integrity and confidentiality of the collected personal data.

In order to be lawful and to comply with Article 6 or European Regulation 2016/679, collection and processing will only occur if one of the following applies:

  • You have given your express consent;
  • Processing is necessary for the performance of a contract;
  • Processing is necessary for compliance with a legal obligation;
  • Processing is necessary in order to protect your vital interests or those of another physical person;
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority;
  • Processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party.

9. DATA PROTECTION OFFICER PURSUANT TO EUROPEAN REGULATION 2016/679

The following person has been appointed as the Data Protection Officer (also referred to as DPO): REPLACEME.

The purpose of the Data Protection Officer is to ensure the successful implementation of the applicable European legislative provisions relating to the collection and processing of personal data.

The Data Protection Officer may be reached as follows:

REPLACEME

10. ADDITIONAL RIGHTS PURSUANT TO EUROPEAN REGULATION 2016/679

In accordance with European regulation relating to the processing of personal data, you also have the rights listed below.

In order for the Controller to grant your request, you must provide your first and last name, your email address, and if relevant, your personal account or membership number.

The Controller must answer your request within a period of thirty (30) days.

a) Right to portability of personal data

You have the right to request the portability of your personal data held by the Website to another site by following the procedure described below:

Use the customer profile section of the website when logged in, or contact us.

b) Right of not being the object of a decision based only on automated processing

In accordance with the provisions of the European Regulation 2016/679, you have the right of not being the subject of decision based solely on automated processing if the decision produces legal affecting concerning you or significantly affects you.

c) Right to submit a complaint to the competent authority

In the event that the Controller does not answer your request, you wish to challenge his or her decision or you believe one of your rights has been infringed upon, you have the right to submit a complaint to the competent authority.

11. SECURITY

Personal information we collect is stored in a secured environment. People working for us are obligated to respect the confidentiality of your personal information.

To ensure the security of your personal information, we use the following methods:

  • SSL (Security Sockets Layer) Protocol
  • SET (Secure Electronic Transaction) Protocol
  • Access management - person authorized
  • Access management - person concerned
  • Network surveillance software
  • Automatic backup
  • Digital certificate
  • Username/password
  • Firewalls
  • Other:  All information used for site usage, reporting and statistical analysis is anonymized.

We are committed to maintaining a high degree of confidentiality by integrating the latest technological innovations that allow us to ensure the confidentiality of your transactions. Nevertheless, no mechanism can ensure complete security, and transmitting personal information on the Internet always contains an element of risk.

12. PERSONAL DATA OF MINORS UNDER EUROPEAN REGULATION 2016/679

In accordance with the provisions of Article 8 of Regulation 2016/679, only minors over 15 years of age may consent to the processing of their personal data.

If you are a minor under the age of 15, the consent of a legal representative is required in order for your personal data to be collected and processed.

We reserve the right to verify by any means that you are over 15 years of age or that you have obtained the consent of a legal representative before using our Website.

13. PRIVACY CERTIFICATION

Our commitments relating to the protection of personal information meet the standards of the following program(s):

  • VeriSign: http://www.verisign.com

14. CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may be viewed at all times at the following address:

https://initiateprotection.com/privacy

We reserve the right to modify our Privacy Policy in order to guarantee its compliance with the applicable law.

You are therefore invited to regularly consult our Privacy Policy to be informed of the latest changes.

15. ACCEPTANCE OF OUR PRIVACY POLICY

By using our Website, you certify that you have read and understood this Privacy Policy and accept its conditions, more specifically conditions relating to the collection and processing of personal information, and the use of cookies.

16. APPLICABLE LAW

We are committed to ensuring compliance with all applicable legislation, including, but not limited to:

  • the Criminal Code (R.S.C., 1985, c. C-46);
  • the United States's anti-spam legislation (CASL);
  • the National Security Act, 2017 (S.C. 2019, c. 13);
  • the Communications Security Establishment Act (S.C. 2019, c. 13, s. 76);
  • the Security of Information Act (R.S.C., 1985, c. O-5);
  • the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) or Provincial counterparts in jurisdictions that have their own privacy laws ; and

General Data Protection Regulation, Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 for the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.