Privacy Policy

1. Definitions:

“Cookies” are small files stored on your device (computer or mobile device).

“User” means any living individual of whom Innovatia collects Personal Data.

“Personal Data” means data about a living individual who can be identified from this data (or from this and other information either in our possession or likely to come into our possession).

“Usage Data” is data collected automatically either by the use of Innovatia Accelerator Inc.’s website or from the website’s infrastructure itself, for example, the duration of a page visit, IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

2. Information Collection

Innovatia Accelerator Inc. collects several different types of information for various purposes in the operation of its business and associated website. Personal Data collected by Innovatia Accelerator Inc. includes, but is not limited to:

1. Employee records;
2. Email and Internet usage guidelines;
3. Customer information;
4. Internal systems and access- permission, responsibilities, access to files, etc…;
5. Individual asset information - phones, laptops and other Innovatia devices; and,
6. Cookies and Usage Data.

3. Use of Data

Innovatia Accelerator Inc. uses the collected Personal Data for various purposes including:

1. To fulfil contractual commitments to customers, suppliers, employees and contractors;
2. To provide and maintain Innovatia Accelerator Inc.’s products and services;
3. To maintain Innovatia Accelerator Inc.’s website;
4. To provide customer support;
5. To gather analysis or valuable information so that Innovatia can improve products and services;
6. To monitor the usage of Innovatia’s internal information systems; and,
7. To detect, prevent and address technical issues.

4. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If Innovatia Accelerator Inc. collects Personal Data of a User governed by the European Economic Area (EEA), Innovatia Accelerator Inc.’s legal basis for collecting and using the personal information described in this Policy depends on the Personal Data Innovatia collects and the specific context in which Innovatia Accelerator Inc. collects the Personal Data. Innovatia may process Personal Data when:

1. Innovatia Accelerator Inc. needs Personal Data to perform its contractual obligations;
2. A User has given Innovatia permission to process Personal Data;
3. The processing is in Innovatia’s legitimate interests and it is not overridden by the rights of the User; or,
4. Required at law.

5. Retention of Data

Innovatia Accelerator Inc. will retain Personal Data only for as long as is necessary for the purposes set out in this Policy. Innovatia Accelerator Inc. will retain and use Personal Data to the extent necessary to comply with Innovatia Accelerator Inc.’s legal obligations (for example, if Innovatia Accelerator Inc. is required to retain Personal Data to comply with applicable laws), resolve disputes and enforce Innovatia Accelerator Inc.’s legal agreements and policies.

Innovatia Accelerator Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Innovatia Accelerator Inc. website, or Innovatia Accelerator Inc. is legally obligated to retain this data for longer periods.

6. Transfer of Data

Personal information, including Personal Data, may be transferred to — and maintained on — computers located outside of the state, province, country or other governmental jurisdiction where the data protection laws may differ from those of the User’s jurisdiction.

If you are located outside Canada and choose to provide information to us, please note that Innovatia Accelerator Inc. may transfer the data, including Personal Data, to Canada for processing.

Innovatia Accelerator Inc. will take all the steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Policy and no transfer of Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of the Personal Data.

7. Disclosure of Data

Under certain circumstances, Innovatia Accelerator Inc. may be required to disclose Personal Data if required to do so by law. Innovatia Accelerator Inc. may disclose Personal Data in the good faith belief that such action is necessary to:

1. Comply with a legal obligation;
2. Protect and defend the rights or property of Innovatia Accelerator Inc.;
3. Prevent or investigate possible wrongdoing;
4. Protect the personal safety of users of Innovatia’s information systems, website or the public; and,
5. Protect against legal liability.

8. Security of Data

The security of Personal Data is important to Innovatia Accelerator Inc. and Innovatia will strive to use commercially acceptable means to protect Personal Data.

9. Privacy and Data Protection Rights Generally

All Users are entitled to the data protection rights found under applicable legislation including, but not limited to, the following:

European Union General Data Protection Regulation (GDPR) Legal Data protection and privacy of personal information; right-to-be-forgotten, mandatory data breach notifications, mandatory data protection officers and fines. Applies to data processors of personal information of persons in the EU. Private sector privacy laws European Union General Data Protection Regulation (GDPR) Legal department Applies to EU data

Personal Information Protection and Electronic Documents Act, S.C. 2000,c.5 Legal Regulates the process of obtaining consent, collecting personal information, using personal information and disclosing personal information Private sector privacy laws https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/02_05_d_15/

Legal department Canada

Right to Information and Protection of Privacy Act, c. R-10.6 Legal To the extent that Innovatia must interact with public bodies, the information exchanged is subject to provincial privacy laws Public sector privacy law NB: http://www.info-priv-nb.ca/right-to-information.asp Legal department NB

Access to Information and Protection of Privacy Act, 2015, c.A-1.2 Legal To the extent that Innovatia must interact with public bodies, the information exchanged is subject to provincial privacy laws Public sector privacy law NL:http://www.oipc.nl.ca/legislation Legal department NL

Freedom of Information and Protection of Privacy Act, 1993, c. 5 Legal To the extent that Innovatia must interact with public bodies, the information exchanged is subject to provincial privacy laws Public sector privacy law NS: https://nslegislature.ca/sites/default/files/legc/statutes/freedom%20of%20information%20and%20protection%20of%20privacy.pdf Legal department NS

Personal Information Protection Act, c.P-6.5 Legal AB version of PIPEDA Private sector privacy law AB: http://www.qp.alberta.ca/documents/Acts/P06P5.pdf

Legal department AB

Freedom of l Information and Protection of Privacy Act, c. F-25 Legal To the extent that Innovatia must interact with public bodies, the information exchanged is subject to provincial privacy laws Public sector privacy law AB: http://www.qp.alberta.ca/documents/Acts/F25.pdf Legal department AB

Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31 Legal To the extent that Innovatia must interact with public bodies, the information exchanged is subject to provincial privacy laws Public sector privacy law ON: https://www.ontario.ca/laws/statute/90f31

Legal department ON

Occupational Health and Safety Act (S.N.B. 1983, c. O-0.2) Legal Privacy of personal information related to worksite health and safety Private section health and safety law NB: http://www.info-priv-nb.ca/right-to-information.asp Legal department NB

10. Data Protection Rights under the General Data Protection Regulation (GDPR)

In circumstances where GDPR is applicable, Users have the following data protection rights:

1. The right to access, update or delete the User’s Personal Data in Innovatia Accelerator Inc.’s control if permitted at law;
2. The right to have Personal Data rectified if that information is inaccurate or incomplete;
3. The right to object to Innovatia Accelerator Inc. processing of Personal Data;
4. The right to request that Innovatia restrict the processing of the User’s Personal Data;
5. The right to be provided with a copy of the Personal Data of a User in Innovatia Accelerator Inc.’s control;
6. The right to withdraw consent at any time where Innovatia Accelerator Inc. relied on consent to process Personal Data; and,
7. Please note that Innovatia may ask for identity verification before responding to such requests.

11. Service Providers

Innovatia Accelerator Inc. may employ third party companies and individuals in its operations. These third parties have access to Personal Data only to perform tasks on Innovatia’s behalf and are bound by confidentiality.