PRIVACY POLICY
(Last updated: November 2012)

At The VIGILIS Group (hereafter referred to as VIGILIS), we understand the importance of protecting personal information of users and viewers. We have designed our policy to meet the requirements of the Personal Information Protection and Electronic Documents Act ("PIPEDA") and abide by the following Ten Privacy Principles.

If you have questions or complaints regarding our privacy policy or practices, you should first contact us by e-mail or mail as follows:

John Desormeau - The Vigilis Group
100-1800 Berlier Street
Laval, QC H7L 4S4 Canada
info@vigilis.ca

Accountability

VIGILIS has appointed a privacy officer who is responsible for ensuring compliance with the Privacy Policy. Other individuals within the business may be delegated to act on behalf of the privacy officer or to take responsibility for the day-to-day collection and/or processing of personal information.

Identifying Purposes of Collection

When you use this website www.vigilis.ca (the "Site") or any of the services available on this Site (the "Services"), you will be required to provide certain personal information to open and complete your account. This may include traditional and Internet contact information (such as address, phone and fax numbers, email address), information about the computer system (such as web browser type, IP address and operating system), navigation information (such as the number of web pages visited) and non-financial identification information (such as username and password), if applicable.

Compiling the above information is required to identify you or helps VIGILIS to better understand site usage patterns and which types of content are of greatest interest to the users or viewers of the Site. In addition, it allows The VIGILIS to notify users and viewers of updates to the Site and to contact them for their account or for VIGILIS' Services.

Further reference to "purposes" means the purposes identified hereinafter in this section.

Consent

Using the Site is always voluntary. When you use the Site, the fact of you doing so provides VIGILIS with your implied consent to collect, use or disclose your information to fulfill your request to use the Services. Moreover, when you use the Site, you may be added to our email list that will be used to contact you occasionally with offers that we feel will be of interest to you. All promotional emails sent to you by VIGILIS contain simple instructions telling you how to "unsubscribe".

Limiting Collection

VIGILIS will limit the collection of personal information to that which is necessary to fulfill the purposes for which it was collected and will collect personal information by fair and lawful means.

VIGILIS is responsible for personal information in its possession or control and will use contractual or other means to provide a comparable level of protection whenever a third-party agent is used to complete some or all the stages of processing necessary to provide you the Services. Third party agents may contact users or viewers directly on VIGILIS's behalf to conduct research or surveys. Research and survey data is reported back to VIGILIS as aggregated data with no reference to individual users or viewers. These third parties may not use any personally identifiable information for their own marketing purposes.

Users and viewers who do not wish to be contacted for research or survey purposes should advise VIGILIS in writing.

Limiting Use, Disclosure and Retention

VIGILIS will not use or disclose personal information for purposes other than those for which it was collected, other purposes that you consent to or as required or permitted by applicable law.

Without limiting the generality of the foregoing, VIGILIS may disclose personal information to a third party engaged to perform the Services on its behalf, in part or in whole; a public authority or its agent if, in its reasonable judgment, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; a third party, where you consent to such disclosure or when disclosure is required or permitted by applicable law.

VIGILIS’s employees (or VIGILIS's affiliates' employees) with a business need-to-know, or whose duties reasonably so require, are granted access to personal information.

Personal information will be retained for as long as necessary for the fulfillment of those purposes or as required or otherwise permitted by applicable law.

VIGILIS will maintain reasonable and systematic controls and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the purposes or required by applicable law to be retained.

Accuracy

Personal information that is collected, used, or disclosed will be as accurate, complete and up to date as is necessary for the purposes for which it is to be used. You supply the information and if it should change, you shall make the necessary changes in your account.

Safeguards

Personal information will be protected by security safeguards appropriate to the sensitivity of the information to avoid misuse or release of personal information.

VIGILIS uses the Secure Socket Layer protocol (SSL). This allows personal information such as credit card number, to be encrypted as it travels from your computer to VIGILIS's system. Once received, the information is unencrypted and processed in the same way as a credit card transaction via telephone.

Openness

VIGILIS's privacy policies and practices are as outlined within this Privacy Policy. VIGILIS will make readily available to individuals’ specific information about its policies and procedures relating to the management of personal information. Should you have any questions or comments you may contact VIGILIS as indicated above.

Individual Access

Subject to certain exceptions provided in the PIPEDA, upon written request to the privacy officer, VIGILIS will inform you of the existence, use and disclosure of your personal information and give you access to your personal information held in files. You may verify the accuracy and completeness of your information and have it amended as appropriate. Also, you may access your profile information held in your account directly and modify your profile information as you see fit or as required.

In certain situations, VIGILIS may not be able to provide access to all the personal information that it holds, as for example this would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual.

In order to safeguard personal information, you may be required to provide sufficient identification information to permit VIGILIS to authorize access to your personal information or account for the existence, use and disclosure of your personal information. Any such information will be used only for this purpose.

Upon written request, VIGILIS will correct or complete any personal information found to be inaccurate or incomplete. Where appropriate, VIGILIS will transmit to third parties having access to such personal information any amended information or the existence of any unresolved differences.

You may obtain information or seek access to your files by contacting the privacy officer.

Challenging Compliance

If you have any inquiries or concerns regarding VIGILIS 's Privacy Policy, practices or compliance with the Privacy Policy, you may contact the privacy officer as indicated above.

VIGILIS may seek external advice where appropriate before providing any final response to you.

If a complaint is found to be justified, VIGILIS will take appropriate measures to resolve the complaint.

Cookies

A cookie is a small non-executable file that is stored on your hard drive for the purpose of identifying your computer. While it is possible to use the Site by having your browser's Internet security set such that it will not accept cookies your online experience may be greatly reduced.

VIGILIS uses both session cookies and permanent cookies at the Site. Session cookies are active only during the period you are logged on to the website and are removed when you leave. They help us track the sections of the website that you use to allow us to make improvements in keeping with observed user preferences. Permanent cookies remain on your hard drive until you remove them through your browser's Internet security settings. Permanent cookies are used to store user preferences such as preferred language and thus eliminate you having to make the same entries on each visit. Our cookies are not tied to personally identifiable information.

This Privacy Policy covers the use of cookies by VIGILIS only and does not cover the use of cookies by any third party. Some of our business partners may use cookies on the Site but we have no access to or control over these cookies.

Flash LSOs

We use local shared objects ("Flash cookies") to store your preferences or display content based upon what you view on the Site. Third Parties, with whom we partner to provide certain features on the Site or to display advertising based upon your Web browsing activity, may also use Flash cookies to collect and store information.

Cookie management tools provided by your browser will not remove Flash cookies.

Conversion Beacons

VIGILIS uses Conversion Beacons (small, simple snippet of HTML code) inserted in the source of the designated website pages. This technology works by leveraging industry standard browser-based cookie technology and simple standard html coding. Email recipients who receive a Conversion Beacon enabled email message will receive a small unique cookie that is stored in their browser session. This unique cookie is later used to connect the email recipient with the subsequent recipient activity on the client website. The purpose of tracking the activity is to better understand the email flow of our subscribers and to measure the effectiveness of ads. For this reason, our Conversion Beacons are tied to personally identifiable information (email address).

Changes to the Privacy Policy

VIGILIS reserves the right to modify this Privacy Policy at any time, without prior notice, by posting the amended Privacy Policy on the Site, so please review it frequently.