PRIVACY POLICY OF ÉLANCE INC.

1. INTRODUCTION

With the advent of new communication tools, it is necessary to pay particular attention to the protection of privacy. This is why Élance Inc. (hereinafter referred to as "Élance Inc.") takes the privacy of your personal information seriously and is committed to respecting the confidentiality of the information we collect.

Élance Inc. is committed to complying with the applicable laws governing the protection of personal information obtained in the course of operating a business, including:

• Québec's Bill 25;
• The GDPR (General Data Protection Regulation) for users located in the European Economic Area (EEA).

These laws ensure the rights of Persons Using the Platform, including the right to access, correct, delete, and transfer their data, as well as the right to limit or oppose the processing of their data under certain conditions. Thus, Élance Inc. undertakes to adhere to the fundamental principles of these laws, notably:

• processing data lawfully, fairly, and transparently;
• collecting data for specific and legitimate purposes;
• limiting the collection of data to what is strictly necessary;
• ensuring its accuracy and regular updates;
• retaining data only for the necessary duration;
• guaranteeing its security through appropriate technical and organizational measures.

Accordingly, this privacy and personal information protection policy (hereinafter referred to as the "Policy") describes the information that we may collect from Persons Using the Platform, understood as the final user or the organization you represent or work for (hereinafter the "User" or the "Persons Using the Platform") in the context of our activities, the purposes for which we collect it, how we use it, and the circumstances under which we may share it with third parties. Furthermore, this Policy outlines the rights available to the User regarding the collection, use, and sharing of their personal information. Élance Inc. commits to not collecting, using, or sharing the personal information of the User in ways that are not consistent with this Policy and the laws applicable in Canada and Québec.

2. SCOPE OF THE POLICY

This policy applies to:

• Individual Users of our services (platform, website);
• Client organizations using our services for their employees or representatives;
• All personal data collected directly or indirectly by Élance Inc. in the course of its activities.

When the User uses our online services by visiting Élance Inc.'s website (hereinafter the "Website") or its platform (hereinafter the "Platform"), subscribing to our newsletters, requesting services, or completing an online form, they agree to the terms and conditions of this Policy.

Élance Inc. will inform Persons Using the Platform of any substantial modifications to this policy via email or notification on the Platform. These changes will take effect 30 days after such notification. If you continue to use our services after this period, it implies that you accept the new terms. For any objection, you may cease using our services and request the deletion of your data by contacting us at

The personal information we collect is that which is necessary to provide a service to the User, to process a transaction they have requested, or to anonymize the data for use in statistical studies. By providing us with this information, the User consents to their personal information being collected and used as defined in this Policy.

3. COLLECTION OF PERSONAL INFORMATION

Élance Inc. may obtain personal information from the User, as well as information without names, first names, or specific details allowing the identification of the User (hereinafter "Anonymized Information"), when they browse the Website, the Platform, submit a form, or engage in conversations with a representative affiliated with Élance Inc.

This information may be obtained, among other instances, when the User provides personal information, such as by creating an account on the Platform and choosing a password, logging in as a registered User of the Platform, launching a product search on the Website, requesting a service, providing information in their account, communicating with us by phone, email, or otherwise, participating in one of our events, or filling out a form to participate in a contest, inventory request, promotion, or survey.

3.1 ÉLANCE INC. PLATFORM

To register on our Platform, the User must agree to provide the following information:

• Email address
• IP address
• Type of device used by the User to connect
• Connection times
• Progression on the platform
• Pages visited on the website

If the User is asked to respond to a survey from Élance Inc., the following personal information may be collected with explicit consent, and will be anonymized upon receipt to protect their identity as much as possible:

• Age
• Gender identity
• Sexual orientation
• Racial identity/Origins
• Skin color
• Linguistic affiliation
• Immigration status and personal and family immigration background
• Visible or invisible disabilities (visible or invisible disability)
• Membership in underrepresented groups (ethnic/gender/sexual/language/religious/neurodivergent minorities or others)
• Indigenous affiliation
• Family situation
• Number of children
• Religious or philosophical affiliation

3.2 ONLINE SERVICE REQUEST

When a User on the Website completes a contact form to receive a quote or more information about our services, they agree that the information shared will be governed by the terms of this policy. Since any request for information requires a needs assessment, it is not possible to list all the information that may be shared by the User, for which we have a legal responsibility to protect. This also applies to online forms that, for example, assess the maturity level of a company: Élance collects explicit consent to use the shared data in order to share information related to this maturity stage and request contact for further information. Élance Inc. may also keep a record of the products the User is interested in and obtain information about them from divisions or current or future companies that are part of Élance Inc.

If the User is not subscribed to our newsletter, they will not receive any emails from Élance Inc., except in specific cases (e.g., follow-up or expiration of their subscription, follow-up on their free trial, participation in a contest, etc.)

3.3 OTHER DATA COLLECTION AND COOKIES

On our Website, we request permission to collect certain information during exchanges between the User's computer and our server. Cookies are files created by a website and automatically stored on the electronic devices of the User to collect information about their browsing activities. These cookies vary in type; some expire when the User closes their browser and no longer have any effect, while others may be retained. At any time, the User can disable cookies; however, in such a case, Élance Inc. does not guarantee the optimal functioning of its Website.

During visits to the Website, a consent banner allows the User to choose which cookies they wish to enable. Preferences can be modified at any time through the browser settings.

Cookies primarily store the following information:

• Domain name;
• IP address;
• Browser history; and
• Language preference of the User

Most information automatically transmitted does not allow Élance Inc. to identify the User and is collected due to technological requirements inherent to Internet browsing. This information is mainly used to improve service, personalize the experience of the User, and better track a request or order.

3.4 USE OF PERSONAL INFORMATION OBTAINED

The information obtained from the User through the use of the Website, the completion of forms, or conversations with them may be used for the following purposes:

• Understanding how the User interacts with the Platform;
• Improving the Platform;
• Staying in contact with the User and providing personalized services;
• Processing the requests and orders of the User and responding to their questions;
• Complying with laws and regulatory requirements;
• Sending promotions tailored to the needs of the User;
• Conducting research and development to develop new products and services;
• Conducting market studies and performance research to assess customer service, measure performance, enhance the user experience, and improve products;
• Communicating with the User via email and sending them advertising material or additional information about products, services, surveys, contests, promotions, and special offers.

Regarding the Platform, no cookies are used. Information obtained is directly tied to the actions taken by the User and is primarily used to understand their progress in the various services offered.

The surveys available on the Platform collect personal information to create a demographic profile of the client organization's workforce and diagnose its DEI performance. Generally, these services are offered to provide client organizations with recommendations on actions they could take to improve their DEI performance. The Platform's survey functionality ensures that, once a survey is completed and submitted, it is no longer linked to the profile of the User, thus automatically anonymizing their data. The data is then used only in an anonymized and aggregated form to ensure the confidentiality of their personal information.

The Platform is designed for use by adults only, as defined in the province of Quebec. Élance Inc. does not knowingly collect personal information from individuals under the age of eighteen (18).

3.5 RETENTION AND MANAGEMENT OF PERSONAL INFORMATION

Élance Inc. retains your personal information only for the duration necessary to fulfill the purposes for which it was collected, in compliance with Law 25 and the GDPR. The retention period is determined based on the nature of the information collected: for instance, contractual data is retained for seven (7) years after the end of the contract to meet legal requirements, while data related to the use of the Platform is retained for two (2) years after the account is closed.

Once the retention periods have expired, Élance Inc. securely destroys personal information. This destruction is carried out using recognized technical methods, including the complete deletion of data from servers, local devices, and cloud tools. In certain cases, data may be irreversibly anonymized for use in statistical or benchmarking purposes, ensuring that no direct or indirect identification of individuals is possible.

Élance Inc. implements rigorous measures to safeguard the security and confidentiality of your personal information. These measures are designed to protect it against loss, theft, unauthorized access, disclosure, reproduction, unlawful use, or modification. The applied measures include:

• Encryption of sensitive data during storage and transmission;
• Firewalls and secure connection protocols (e.g., HTTPS);
• Protected and restricted access to servers and computers, using password-secured networks;
• Mandatory confidentiality agreements for employees, agents, and representatives;
• Regular audits and access controls to ensure secure data management;
• Deletion of unnecessary data and anonymization when feasible.

Élance Inc. is committed to maintaining a high level of security by integrating the latest technological advancements and applying strict controls throughout the lifecycle of personal information.

If a password is used to protect your account or personal information, it is your responsibility to ensure its confidentiality and not to share it. Élance Inc. also recommends that Users adopt safe practices, such as using complex passwords and updating them periodically.

For further information on protecting your personal information and your related rights, you may contact the Office of the Privacy Commissioner of Canada or the Commission d'accès à l'information of Quebec:

• Office of the Privacy Commissioner of Canada:z

  www.privcom.gc.ca

• Commission d'accès à l'information of Quebec:

  www.cai.gouv.qc.ca

3.6 ANONYMIZATION OF PERSONAL INFORMATION

Personal information collected by Élance Inc. through surveys operates differently from other types of data and is irreversibly anonymized upon submission. This process ensures that the submitted data can no longer, at any time, directly or indirectly identify the User. The anonymization of personal information is carried out in compliance with the requirements of Law 25 and the General Data Protection Regulation (GDPR), transforming it into Anonymized Information.

During the survey completion process:

• A temporary connection is established between the profile of the User and their responses to save the data during the completion phase. This connection is secured using advanced encryption protocols.
• Once the survey is submitted, the connection between the responses and the profile is automatically and permanently deleted.
• The responses then become Anonymized Information and can no longer be associated with an email address, name, or any other identifying information.

Élance Inc. also commits to conducting regular evaluations to ensure that the data remains compliant with anonymization standards, even as technological advancements evolve.

3.7 Table of Users' collected data in Elance's various processes

4. ADVERTISING INFORMATION

If you prefer not to receive advertising information from Élance Inc. or if you do not want us to use your personal information to enhance your experience as a User, please let us know by contacting us at the address provided in the "Right to index, modify, delete and export personal information" section.

Be sure to include your full name and the email address you used when registering or making a purchase with us. Please note that there may be a processing delay of up to 30 days during which you may continue to receive communications from Élance Inc.

5. THIRD-PARTY SERVICES AND LIMITATION OF LIABILITY

Élance Inc. may use third-party services (e.g. hosting on Microsoft Azure, payment processing) to provide its services. These third parties are rigorously selected and must comply with high standards of confidentiality and security that comply with the requirements of Law 25 and the RGPD. However, Élance Inc. cannot guarantee that these third-party services will be free of errors, failures or interruptions. In the event of a problem involving a third-party service, Élance Inc. undertakes to work with Users to resolve the problem and minimize the impact.

We encourage Users to consult the terms of use and privacy policies of third-party services to better understand how their data is used.

Limitation of liability

Élance Inc. cannot be held liable for damages caused directly by a third party in circumstances beyond its reasonable control. However, Élance Inc. undertakes to act diligently to ensure the security and compliance of the data entrusted to it.

Élance Inc. prohibits and is not responsible for the resale or use by third parties of “opt-ins” obtained through the Platform by event organizers. If you agree to share your contact information with partner organizations, we will share it with them. We do not sell or rent our lists.

6. INTERNATIONAL COMMUNICATIONS

Data collected by Élance Inc. may be transferred to or hosted on servers located outside Canada, notably in the United States, as part of hosting services provided by compliant partners (e.g. Microsoft Azure). Élance Inc. ensures that all international transfers comply with applicable legal requirements, including :

• Standard contractual clauses adopted by the European Commission;
• Adequacy agreements for jurisdictions recognized as offering an adequate level of protection;
• Technical and organizational measures guaranteeing the confidentiality and security of transferred data.

Although Élance Inc. cannot guarantee absolute data security in all circumstances, we are committed to selecting compliant partners and regularly assessing their compliance. If you have any questions or concerns regarding these transfers, please contact us at:

7. SHARING OF PERSONAL INFORMATION

Élance Inc. commercializes the personal information collected from the User who gives express consent in this regard. The situations in which personal information may be shared are as follows: with the company's partners, promotional offers and the application of the law or legal requests, as well as for research and development purposes to improve the delivery of services and for statistical purposes.

The User understands that Élance Inc. may at any time share his/her personal information in the event of a partial or total transfer of the business to a third party. In such a case, the information transferred as an asset of Élance Inc. will be subject to the same guarantees as those in this Policy.

If the User does not wish his or her personal information to be communicated to third parties or partners, he or she may object at any time, as mentioned in the following section.

Élance Inc. may, in the following cases, exceptionally communicate the User's personal information without his or her consent:

• In the event of a legal obligation, in particular when a court order requires Élance Inc. to disclose the Personal Information of the Individual User.
• When it is impossible to obtain the consent of the Individual User and privacy laws allow Élance Inc. to disclose this personal information. This is particularly the case when the protection of the public interest so requires.

In all of the above cases, Anonymous Information may be shared and marketed without the consent of the Users.

8. RIGHT TO INDEX, MODIFY, DELETE AND EXPORT PERSONAL INFORMATION

Élance Inc. is committed to providing a clear and structured framework for Users to exercise their rights with respect to their personal information. This section describes the applicable processes for submitting requests for access, modification, de-indexation, deletion, opposition, withdrawal or export of data, as well as the management of complaints related to these rights

8.1 Submitting applications

Individual Users may submit requests regarding their non-anonymized personal information, including access, correction, de-indexation, deletion, objection, removal or export. To do so, they should send the following form to legal@elancedei.com. Confirmation of receipt will be sent within a reasonable time.

Each request is evaluated individually and will be processed within a maximum of thirty (30) days of receipt. In the event of unforeseen delays, the User will be informed of the status of his/her request.

8.2 Verification of identity

Before responding to a request, Élance Inc. verifies the identity of the requester to ensure the security of personal information. This verification may include the provision of additional information, such as details of past interactions, identification or other means of confirming identity.

If identity cannot be verified, Élance Inc. reserves the right to refuse the request for security reasons. A written explanation will be provided in such cases.

8.3 Processing of applications

Eligible requests are processed in accordance with legal obligations and with respect for confidentiality. Élance Inc. may refuse a request in certain cases, in particular :

• If the information is required to provide ongoing services;
• Due to legal or regulatory requirements;
• In the event of a legal dispute.

A detailed explanation of the reasons for refusal, together with available remedies, will be provided to the User.

8.4 Anonymized and non-anonymized data

Anonymized data (e.g. data collected via surveys) cannot be modified, deleted or exported, as it is no longer associated with a specific User. On the other hand, non-anonymized data, such as name, e-mail address or browsing data, are subject to this procedure.

8.5 Exporting data

Users may request a copy of their personal information in a structured, machine-readable format. Given the sensitivity of this operation, additional verification measures may be applied to ensure the security of transmitted data.

8.6 Follow-up and documentation

All stages of request processing are documented, including :

• Receipt and acknowledgement;
• Actions taken;
• Results of decisions (acceptance or refusal).

Information relating to requests is kept for a maximum period of two (2) years after resolution, in accordance with legal requirements.

8.7 Complaint management

Élance Inc. allows Users to submit complaints related to the management of their personal information via the same channel: legal@elancedei.com. Complaints are treated with diligence and confidentiality, and an initial response is sent within five (5) business days of receipt.

The resolution process includes a preliminary assessment, a thorough investigation and the proposal of corrective or compensatory measures, if necessary. If the Relying Party is not satisfied with the resolution, it may appeal to the Commission d'accès à l'information du Québec (CAI).

8.8 Confidentiality and Data Protection

Personnel involved in processing requests and complaints are required to adhere to strict confidentiality and data protection standards. They receive regular training to ensure compliance with applicable laws and best practices for managing personal information.

9. ANTI-SPAM LEGISLATION

Élance Inc. complies with the Canadian Anti-Spam Law (CASL). We always obtain your consent before sending you promotional electronic communications.

If you no longer wish to receive our communications, click on the unsubscribe link included in each e-mail or contact us at info@elancedei.com.

10. ENGLISH AND FRENCH LANGUAGE

In the event of any problem of definition or interpretation between the French and English versions of these Terms of Use, the French version shall prevail.

11. APPLICABLE LAW AND COMPETENT COURTS

The Web Site and the Platform and their content are managed by Élance Inc. from its offices located in the province of Quebec, Canada. The Platform and its content, these Terms of Use and your use thereof are all governed by the laws of Quebec and Canada applicable therein, without giving effect to any principles of conflict of laws.

In the event of a dispute, we encourage you to seek mediation before taking any legal action. If no agreement is reached, the courts of Montreal will have jurisdiction. For users located outside Quebec, Quebec law applies insofar as it is compatible with local data protection rules.

Notwithstanding any attribution of jurisdiction and applicable law, where the User is a consumer within the meaning of the Quebec Consumer Protection Act, then any dispute relating to this Policy shall be governed by the laws of the Province of Quebec, and shall necessarily be brought before a court of competent jurisdiction pursuant to the rules of the Code of Civil Procedure.

12. INTERPRETATION

This Policy is governed by the laws of Quebec and Canada applicable therein, including the Privacy Act of Canada. These laws apply without giving effect to any principles of conflict of laws.

Wherever the context requires, words importing the singular number include the plural and vice versa; words importing the masculine gender include the feminine and vice versa.

13. DIVISIBILITY

Each provision of this Policy forms a distinct whole, so that any decision by a court to the effect that one of the provisions of this Policy is null or unenforceable in no way affects the validity or enforceability of the other provisions of this Policy.

14. CONTACT

You may exercise your rights under this Policy or direct any other questions or complaints regarding the privacy practices of Élance Inc. by contacting us at :

Name: Thierry Nazon

E-mail:

If you do not receive a response within 30 days, you may contact the Commission d'accès à l'information du Québec at

15. MODIFICATION OF THIS POLICY

This policy is revised annually or in the event of relevant legislative changes. Updates will be e-mailed to the user 30 days before they come into effect via e-mail or notification on the Platform.

Last updated on November 30, 2024.