Privacy Policy

Alyee Investments (“Alyee”), a corporation organized under the laws of Quebec with a place of business at 300-150, de la Côte-Vertu Blvd., Saint-Laurent, QC, H4N 1C6, CANADA, provides a cloud-based contact center software-as-a-service (“Alyee Investments Services”) directly to customers (“Customer(s)”, “You”) or through authorized partners.

At Alyee Investments Technology, Inc., we take the protection of personal information provided to us by our customers and website visitors very seriously. Alyee Investments regularly reviews and updates its privacy policy, procedures, and guidelines to strengthen its commitment to relevant Privacy and Data Protection legislation and regulations, and better protect customers personal information when processing personal data as a controller. Data subjects whose personal information is processed by a customer of Alyee Investments as a data controller, must consult that customer’s privacy policies.

Alyee Investments must act as both a data processor and a data controller. Alyee Investments stores and process personal information on behalf of its customers and determines the purpose and means of the data processing (e.g. for billing purposes).

Nothing in this Policy has the effect of creating obligations for Alyee Investments beyond those imposed by applicable laws and regulations pertaining to protection of personal data.

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1. Alyee Investments as data controller

Alyee Investments limits collection of information about Customers only to what is relevant, proportional, adequate, and necessary for identified operating the Alyee Investments Services. Alyee Investments considers the requirements of the jurisdiction that govern the information collection and proceeds according to applicable privacy & data protection legislation.

1.1 Data that Alyee Investments collects directly from Customers

Alyee Investments collects personal information that You voluntarily provide when You

register on the Alyee Investments website for the Alyee Investments Services,
request information about Alyee, Alyee Investments services and Alyee Investments products,
request a demo of the Alyee Investments Services,
interact with Alyee Investments social media campaigns via social networks,
register in Alyee Investments events,
apply for job offers,
download Alyee Investments software and documents, or use resources available in Alyee Investments website or
contact Alyee Investments using the official contact channels available (phone, chat, email).

The information that Alyee Investments collects is

identification data (first name, last name),
contact data (business email address, business phone number), and
professional details (functional role, company name, country).

When applying for a job offer, Alyee Investments collects the information provided in the resume, cover letter and LinkedIn profile. Alyee Investments also collects the information that you choose to share when contacting us through our official contact mechanisms.

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1.2 Data that Alyee Investments obtains from third-party sources

Alyee Investments may use business contact information collected by third parties, including your employer, reseller partners, trusted strategic alliances, and acquired professional contacts databases. Appropriate privacy and security assessments are performed to ensure compliance with applicable laws and regulations and to ensure the collection of the data is lawful and uses fair means, including the existence of notice and collection of consent for sharing with third parties (Alyee Investments), when required by the applicable laws.

The information used is

identification data (first name, last name),
contact data (business email address, business phone number),
professional details (functional role, company name), and
LinkedIn Profile.

1.3 Data that Alyee Investments obtains from public sources

Alyee Investments may also collect data from publicly accessible sources such as LinkedIn. The personal information collected is primarily identification and contact data, and job and skills details to support recruitment processes.

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1.4 Purposes of processing personal information

Some of the purposes for processing personal information are:

Be able to get in touch with you to respond to your requests (information, demo, or services);
Talent recruitment;
To support the sales effort, including to getting feedback from the engagement process in a B2B perspective;
To send marketing information on our products and services marketing (including telemarketing) in a B2B perspective;
Customer relationship and contractual management which could include payment information;
To provide support and information to customers;
Management of business relationships with prospective customers, vendors, suppliers, resellers, or partners;
Events registrations (including webinars, conferences, roundtables, and others);
Access to our offices and online resources for onsite or remote work;
Provide access to Alyee Investments training materials;
Navigation and usage of Alyee Investments website;
Cookies usage (specific policy shared on the site);
To ensure compliance with applicable laws and regulations, and to assert Alyee Investments' rights or to defend Alyee Investments against any legal claim.

Alyee Investments collects the minimum amount of data needed for the purposes listed above. The legal basis of each processing is to perform contractual obligations, the advancement of a legitimate plan or interest, or with explicit consent.

Personal data processing for the purpose of marketing or product awareness, may rely on a legitimate interest of Alyee Investments or your consent. Alyee Investments requires your consent according to the applicable laws but may rely on legitimate interest when the applicable law allows and when you already have shown Alyee Investments interest in the Alyee Investments products or Alyee Investments Services. In communications related to marketing and/or product & brand awareness purposes, Alyee Investments also provides a choice to opt-out of further marketing and product awareness communications.

Alyee Investments may conduct automated screenings against applicable sanctioned-party lists with regard to Alyee Investments' processing of personal data for the purpose of export control and sanctions laws’ compliance. In case of a possible match, Alyee Investments may ask for clarifications.

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1.5 Personal information limited use, disclosure, and retention

Alyee Investments does neither use nor process personal information for other purposes, and does not sell or allow its sub-processors to sell personal information. Personal information will not be processed for purposes other than those for which it was collected, except with your consent or as required by law.

Except as otherwise set out herein, Alyee Investments will not disclose, trade, rent, sell, or otherwise transfer to a third person your personal information unless you consent thereto, or such disclosure or use is provided for by law.

Alyee Investments and its service providers may be compelled to disclose personal information in response to a search warrant or any other legally-valid inquiry or order, or to an investigative body in the case of a breach of an agreement or breach of law, or as otherwise required by applicable law.

Personal information may also be disclosed without your consent for research purposes if the documents containing the data are not structured so as to allow retrieval by reference to your name or identifying code or symbol and the personal information cannot be retrieved by means of such a reference.

Any person holding Personal Data on behalf of Alyee Investments may refer to the latter every request for access or rectification received from an individual to whom Personal Data relates.

Personal information will be retained only as long as necessary for the fulfilment of those purposes in a form which permits your identification for no longer than is necessary for the purposes for which the personal information is processed.

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1.6 Rights of data subjects

A data subject has the following rights:

Access data: Right to request and receive confirmation of whether their personal data is held, and, where that is the case, request and receive a copy of the data.
Have data transferred: Right to receive the data they have provided in a structured, commonly-used and machine readable format.
Have data rectified: Right to have their personal data amended where it is inaccurate or added to where it is incomplete.
Restrict processing: Right to restrict the processing of the personal information to the extent permitted by law and in accordance with Alyee Investments contractual and legal commitments.
Have data erased: Right to the erasure of personal information concerning the data subject.
Objections: Right to object to the processing of the data for particular reasons.
Withdraw consent: Right to remove consent for specific processing.
Complaints: Right to send complaints to the competent authority.

In addition, data subjects have the right to opt-in to receive marketing communication from Alyee Investments, and opt-out of email marketing messages by clicking on the unsubscribe link in the email, and when using the Alyee Investments website, data subjects can accept or decline cookies.

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1.7 Exercise the rights

Data subjects can exercise their rights by submitting a request to: privacy@alyeeinvestments.com

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1.8 Personal information transfer

Alyee Investments holds the right to share, transfer, or disclose personal information in specific situations to particular categories of recipients:

Alyee Investments' trusted SaaS third parties providers, acting as processors and according to Alyee Investments instructions;
Alyee Investments reseller partners, trusted strategic alliances that may support Alyee Investments sales effort and according to privacy laws and regulations;
Alyee Investments affiliates and according to Alyee Investments' security and privacy policies and applicable laws and regulation of each region;
Government entities where the transfer of information is legally required under local laws or required to comply with legal requests;
Potential buyers in connection to a merger & acquisition or any form of transfer or sale.

Alyee Investments does not sell and does not allow its sub-processors to sell personal information. A list of Alyee Investments' processors can be requested by email to: privacy@alyeeinvestments.com.

2 ALYEE INVESTMENTS AS DATA PROCESSOR/SUB-PROCESSOR

Alyee Investments as a provider of a cloud-based contact center as a service solution becomes a date processor, and occasionally a data sub-processor. At all times, the data collected by Alyee Investments' customers when using Alyee Investments products is under the customer’s responsibility.

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2.1 Collected Data

The information being collected can include

Contacts: These are usually the end customers, or prospects, of Alyee Investments' customers. The customer is responsible for determining the types of contacts for which service is provided using the Alyee Investments Services. Contacts can include the name, phone number and email.
Agents: These are employees of the customer that uses Alyee Investments Services to handle incoming and outgoing communications using different channels. Information on agents can include the name, email address, phone number, and date of birth.
Interactions metadata: Metadata such as a contact phone number, agent ID and phone number, date and time, duration, and context of the interaction.
Interactions recordings: Audio recordings of all audio/video calls, transcripts of all text-based interactions, files attached and exchanged during a communication, and, when configured, screen captures of the agent screen are collected.
Content data: Audio recordings of all audio/video calls, transcripts of all text-based interactions (chat, email, SMS, WhatsApp, Facebook Messenger, Twitter, Telegram, and other possible social media communication channels), files attached and exchanged during a communication, screen captures of the agent screen when configured, and call transcriptions when such functionality is used for a customer, are collected.

Alyee Investments restricts the collection of the information to the minimum amount required to provide its services and it will be processed according to the purposes for which it was collected.

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2.2 Purposes of collecting personal information

Alyee Investments collects some personal information to provide the service of Contact Center as a Service and to support and troubleshoot issues reported by customers.

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2.3 Personal information limited use, disclosure, and retention

Alyee Investments customers acting as data controllers define the retention period for the information collected. On the other hand, when the contract between Alyee Investments and a customer is terminated, the personal information is removed according to the Master Subscription Agreement, or earlier if requested by the customer. However, Alyee Investments may keep anonymized information (that will not identify directly or indirectly any agent, contact, or customer) for longer periods for analysis of how service is used and for the improvement of it.

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2.4 Rights of data subjects

A data subject has the following rights:

Access data: Right to request and receive confirmation of whether their personal data is held, and, where that is the case, request and receive a copy of the data.
Have data transferred: Right to receive the data they have provided in a structured, commonly-used and machine readable format.
Have data rectified: Right to have their personal data amended where it is inaccurate or added to where it is incomplete.
Restrict processing: Right to restrict the processing of the personal information to the extent permitted by law and in accordance with Alyee Investments contractual and legal commitments.
Have data erased: Right to the erasure of personal information concerning the data subject.
Objections: Right to object to the processing of the data for particular reasons.
Withdraw consent: Right to remove consent for specific processing.
Complaints: Right to send complaints to the competent authority.

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2.5 Exercise the rights

When Alyee Investments processes information on behalf of a customer, all data subject rights must be addressed directly to the customer.

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2.6 Personal information transfer

As a service provider/processor, Alyee Investments only uses data to provide the service agreed and according to customer instructions and Alyee Investments does not sell the information its customers collect while using Alyee Investments Service.

Alyee Investments holds the right to share, transfer, or disclose personal information in specific situations to particular categories of recipients:

Alyee Investments' trusted SaaS third parties’ providers, acting as processors and according to Alyee Investments instructions;
Alyee Investments reseller partners, trusted strategic alliances that may support Alyee Investments sales effort and according to privacy laws and regulations;
Alyee Investments affiliates and according to Alyee Investments' security and privacy policies and applicable laws and regulation of each region;
Government entities where the transfer of information is legally required under local laws or required to comply with legal requests;
Potential buyers in connection to a merger & acquisition or any form of transfer or sale.

Alyee Investments does not sell and does not allow its sub-processors to sell personal information. A list of Alyee Investments' sub-processors can be requested by email to: privacy@alyeeinvestments.com.

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3 SAFEGUARDS

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3.1 Security measures

Alyee Investments will take the security measures necessary to ensure the protection of the personal data processed and that are reasonable given the sensitivity of the personal data, the purposes for which it is to be used, the quantity and distribution of the personal data and the medium on which it is stored. The security safeguards of Alyee Investments will protect personal data against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the personal data that has been collected, the amount, distribution and format of the personal data and the method of storage.

The methods of protection will include

physical measures (such as restricted access to offices);
organizational measures (such as security clearances); and
technological measures (such as the use of passwords).

Alyee Investments provides access to personal data only to employees and authorized intermediaries who require this personal data for the purposes described in this policy. Alyee Investments will make its employees aware of the importance of maintaining the confidentiality of personal data, and care will be used in the disposal or destruction of personal data, to prevent unauthorized parties from gaining access to the personal data.

Alyee Investments will implement appropriate technical and organizational measures to ensure and to be able to demonstrate that processing is performed in accordance with applicable laws and regulations, considering the nature, scope, context, and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons. Those measures will be reviewed and updated where necessary.

Considering the state of the art, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Alyee Investments will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

the encryption of the databases used by Alyee Investments service;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

All personal data collected by Alyee Investments is stored on private servers which are not accessible to the public. For increased security, authorized users must protect access to their online accounts by selecting a password of their choosing.

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3.2 Intermediaries

Where processing is to be carried out on behalf of Alyee Investments, Alyee Investments will use only intermediaries providing sufficient guarantees regarding the implementation of appropriate technical and organizational measures in such manner that processing will meet the requirements of the applicable laws and regulations and ensure the protection of customer’s rights. The intermediary will not engage another intermediary without prior specific or general written authorization of Alyee Investments. Processing by an intermediary will be governed by a contract that is binding on the intermediary with regard to Alyee Investments and that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of individuals and the obligations and rights of Alyee Investments. All Alyee Investments' suppliers sign and consent to a non-disclosure agreement regarding all the personal data. Our Alyee Investments' suppliers agree not to disclose any Alyee Investments or Alyee Investments' clients’ protected information, including personal data to any third party, whether directly or indirectly. Where an intermediary engages another intermediary for carrying out specific processing activities on behalf of Alyee Investments, the same data protection obligations as set out in the contract between Alyee Investments and the intermediary will be imposed on that other intermediary by way of a contract. The intermediary and any person acting under the authority of Alyee Investments or of the intermediary, who has access to personal data, will not process those data except on instructions from Alyee Investments, unless legally required to do so by a statutorily-empowered public authority. Alyee Investments may transfer your personal data to intermediaries such as providers of payment processing services. Processing of your personal data may take place in the United States or in Canada by our affiliates and other third-party service providers.

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3.3 Notification of personal data Breach

No data transmission over the Internet may be guaranteed to be entirely secure. As a result, Alyee Investments does not represent, warrant or guarantee that personal data will be protected against all loss, misuse or alteration and accepts no liability for personal data submitted by you, nor for the use or misuse of such personal data by you or by third parties.

Alyee Investments will document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken without undue delay and, where feasible, not later than seventy-two (72) hours after having become aware of it, notify the personal data breach to the statutorily-empowered public authority appropriate in accordance with applicable laws and regulations, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Such notification will at least:

describe the nature of the personal data breach including where possible, the categories and approximate number of individuals concerned, and the categories and approximate number of personal data records concerned;
communicate the name and contact details of the data protection officer or other contact point where more information can be obtained;
describe the likely consequences of the personal data breach; and
describe the measures taken or proposed to be taken by Alyee Investments to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Alyee Investments will communicate the personal data breach to customers without undue delay when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons. Such communication will describe in clear and plain language the nature of the personal data breach, and contain at least the information and measures referred to in points (b), (c) and (d) above.

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4 HOW TO CONTACT ALYEE INVESTMENTS

For questions or complaints regarding this privacy policy, you can contact us:

by email at: privacy@alyeeinvestments.com

or by mail at our address:

Alyee Investments
300 – 150 boul. de la Cote Vertu
Montreal, QC, H4N 1C6
CANADA

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5 LANGUAGE

The parties confirm that it is their wish that this policy be written in the English language only. Les parties confirment leur volonté que la présente politique soit rédigée en anglais seulement.

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