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 1. Legal


GLOBAL PRIVACY POLICY

This document will help you understand how Genetec collects, manages and uses
personal data as part of our provision of our products and services to
customers.

JANUARY 6, 2020

|

At Genetec, we are committed to protecting our customers’ personal data. This
document will help you understand how we collect, manage and use their and their
users’ personal data as part of our provision of our products and services to
you.

In essence, we (Genetec Inc., together with our affiliates, licensors, partners
and contractors, including their respective successors and assigns, referred to
as “Genetec”, “we”, “us” or “our”) need to collect certain personal data about
our customer (either you as an individual, or the legal entity that you
represent, or for the benefit of which you are agreeing to these terms and have
the full power and authority to bind contractually, as applicable; referred to
as “Customer”, “you”, “your” or “yours”) in order to be able to provide such
Customer and/or its employees or other authorized users acting on its behalf
(each a “user”) with our products. We promise to work hard to preserve the
integrity and the security of Customer’s information (including that of its
users) under our control. We will only use Customer’s data in a manner
consistent with this privacy policy, and will not share it with anyone for any
other purpose.

In this document, the expression “personal data” means any information relating
to an identified or an identifiable natural person. Such information may
include, for example, the person’s name, address, contact information (such as
telephone numbers or email addresses), age, and gender. We further use the term
“product” to refer to any product, service, solution or other offering made
available by Genetec. .

WE STRONGLY ENCOURAGE YOU TO CAREFULLY READ THIS DOCUMENT. YOUR (INCLUDING YOUR
USERS’) USE OF OUR PRODUCTS WILL MEAN THAT YOU ARE AWARE OF THE COLLECTION,
STORAGE, USE AND DISCLOSURE OF PERSONAL DATA IN THE MANNER DESCRIBED IN THIS
DOCUMENT.

 1.  Why we need to collect personal data
     
     We need to collect certain personal data to better understand Customer’s
     needs and preferences, and to provide our products to Customer and its
     users. Additionally, we may rely on such personal data to contact Customer
     regarding Customer’s Genetec™ account, upcoming changes, improvements,
     software updates and upgrades, as well as to improve the effectiveness of
     our offerings, to conduct research, analysis and other business activities,
     as further explained in this privacy policy. In any event, the personal
     data will not be used, made available or otherwise disclosed for purposes
     other than those specified herein, unless we obtain Customer’s prior
     approval or are required to do so by law.

 2.  What kind of personal data may be concerned
     
     General
     
     We make available a variety of products, any combination of which may be
     procured by Customer. Consequently, the scope and nature of information
     collected by us varies based on the products used by Customer. In any case,
     we access and collect personal data only to the extent necessary to ensure
     that Customer can access and use the products that it has procured. We may
     further collect information to identify and associate Customer with its
     Genetec account. This includes Customer’s name, contact information,
     including mailing address, email addresses of certain users entitled to
     access and use the products for or on behalf of Customer, as well as other
     unique identifiers attributed to Customer (including its users) by us or by
     other service provider, as the case may be.
     
     Additionally, we may collect and store personal data that Customer
     (including its users) chooses to provide to us, at its sole discretion,
     without us requiring it to do so. This may occur, for example, where you
     disclose certain personal data to us when you contact us, or when you
     choose to store certain personal data in our products as part of your use
     of such offerings.
     
     Please refer to relevant product privacy sheets for more information on the
     personal data that is collected and processed by us in relation to such
     product.
     
     Personal data collected in relation to our products
     
     Generally, our products may be grouped in four categories: on-premise
     software, cloud services, hybrid products and mobile applications. Below,
     you will find an overview of the type of information that may be collected
     and processed by us in relation to your use of our products. However, we
     encourage you to refer to the relevant product privacy sheet to better
     understand what information may be collected and processed by us in
     relation to your use of such product.
     
     The first category combines our software products that are installed on
     infrastructure provided by or on behalf of Customer. In these cases, all
     personal data remains stored in the Customer’s systems, and will not be
     shared with Genetec. Customer may, however, for its convenience, choose to
     enable the automated modules – known as the Genetec Update Service (GUS)
     and the System Availability Monitor (SAM) – which would respectively allow
     Customer, among other things, to receive automated software and firmware
     updates, security notifications, and other relevant nonmarketing content,
     and monitor the status of their physical security infrastructure. These
     modules, when enabled, will monitor and send to our systems information
     pertaining to the configuration, status and health of software and hardware
     associated with your installation of our on-premise products.
     
     The second category groups cloud products that are hosted on systems made
     available by us. The extent of personal data that may be collected and
     processed by us as part of our cloud products will vary based on the type
     of cloud product being used.
     
     Our hybrid products category represents products that are generally
     installed on infrastructure provided by or on behalf of Customer (with all
     of the personal data being hosted on-premise, as outlined above), but
     additionally require an internet connection to ensure that Customer holds a
     valid subscription to use such hybrid product.
     
     We may also make available certain mobile applications to Customer in
     relation to its use of our products. Generally, our mobile applications are
     an extension of Customer’s other Genetec products. Our mobile applications
     only collect and send to our systems a limited set of information, which
     includes hardware and operating system information, web browser version,
     certain anonymous usage data, as well as the mobile device’s geographic
     location. All other information remains stored on the mobile device or in
     the relevant Genetec product.
     
     Personal data collected in relation to Customer accounts
     
     When you create a customer account with us in association with any Genetec
     product, we will require you to submit to us certain personal data to
     identify you (including your users) as the holder of such customer account,
     but also to protect information associated with your customer account from
     unauthorized disclosure. Such personal data may include, but is not limited
     to, Customer full name, user full name, address, contact information, you
     Genetec account username and password. It is your responsibility to provide
     all necessary information to, and obtain all relevant approvals and
     consents from all your users in relation to their access and use of our
     products.
     
     Personal data collected in relation to support services
     
     When Customer contacts us, whether by phone, chat, email, through our
     websites or otherwise, we may keep a record of such communications to help
     solve issues that Customer might be dealing with, but also for training,
     quality assurance and statistical purposes, as well as to improve our
     products. Please note that we may aggregate personal data to generate
     various performance, analytical and statistical data, as well as to develop
     new products. When we do so, we ensure that such information becomes
     anonymized and may no longer be associated with an identifiable individual.
     
     Personal data collected via our websites
     
     When you visit our websites, we may collect certain information
     automatically from your device. In some countries, including countries in
     the European Economic Area, this information may be considered personal
     data under applicable data protection laws. Specifically, the information
     we collect automatically may include information like your IP address,
     device type, unique device identification numbers, browser-type,
     preferences, broad geographic location (e.g. country or city-level
     location) and other technical information. We may also collect information
     about how your device has interacted with our Website, including the pages
     accessed and links clicked. Collecting this information enables us to
     better understand the visitors who come to our website, where they come
     from, and what content on our website is of interest to them. We use this
     information for our internal analytics purposes and to improve the quality
     and relevance of our website to our visitors.
     
     Some of this information may be collected using cookies and similar
     tracking technology (collectively, “Cookies”). We use cookies to collect
     and use personal data about you. For further information about the types of
     Cookies we use, why, and how you can control Cookies, please see our Cookie
     Notice, at www.genetec.com/legal/cookies.

 3.  Who may have access to personal data
     
     At Genetec, we recognise and respect the importance of protecting our
     customer’s personal data. Keeping personal data in strict confidence is a
     core part of our commitment to service excellence. We do not sell or rent
     any personal data to any third party. However, in order to provide Customer
     with our products, we may share Customer’s personal data with our
     affiliated companies, parent entities and subsidiaries, for internal
     business purposes, as well as with our partners acting on our behalf in
     relation to the provision of such products.
     
     As many other service providers, we use third party partners’ help in some
     aspects of our business operations, which, in some cases, involves
     processing or handling of Customer’s personal data. However, before we do
     so, we take appropriate measures to safeguard personal data, and to ensure
     that it is used only in a manner consistent with this privacy policy.
     
     These measures also include protecting personal data within our
     organisation. Such information may only be accessible by those employees,
     agents, representatives and contractors of Genetec who need to know such
     information as part of their duties. We further ensure that our employees,
     agents, representatives and contractors perform their duties in a way
     compatible with the terms and conditions described in this document.
     
     We may be required to disclose information that we have on Customer and its
     users (including its and their personal data) to governing and law
     enforcement authorities, including where required by law, a court order, or
     by other legal obligations that we may have in any jurisdiction.

 4.  How we protect personal data
     
     We work diligently to maintain administrative, technical and physical
     controls consistent with industry best practices to protect Customer’s
     personal data against unauthorized access or use. We leverage
     industry-leading technologies, including server authentication and data
     encryption, to protect personal data during transit over the internet and
     at rest.

 5.  Where personal data may be processed
     
     While our global headquarters are based in Montreal, Canada, Genetec,
     together with our partners and affiliated companies, operate in various
     locations worldwide. As a result, we may store or otherwise process
     personal data in many places around the world, including outside the state,
     province or country where Customer is located, in which case personal data
     may become subject to foreign laws, and, therefore, may be available to the
     governing authorities under local laws and regulations. We will use various
     legal and contractual means to ensure that data transfers are done in
     compliance with applicable laws and industry best practices.
     
     In certain cases, we may enable Customer to choose the location of data
     centers where we will store Customer’s personal data. Please note that the
     availability of choice of data center locations varies based on the
     product, as well as on Customer’s geographical location.
     
     If Customer is a resident of the European Union (EU) or the European
     Economic Area (EEA), we make sure that his/her personal data is transferred
     to third countries outside the EU/EEA that are deemed "adequate" by the
     European Commission (a list of adequate countries is available here).
     Alternatively, where your personal data is not sent to a country that
     provides adequate protection, we will put in place appropriate safeguards
     to ensure that your personal data remains protected while it is being
     processed outside the EU/EEA in accordance with applicable privacy laws.
     These appropriate safeguards may include signing the European Commission’s
     Standard Contractual Clauses with the group entity, third party service
     provider or partner outside the EU/EEA with whom we share your personal
     data. For further information about transfers of personal data, please
     refer to the “How to contact us” section below.

 6.  Keeping personal data accurate and up-to-date
     
     We rely considerably on your personal data to ensure that we provide
     Customer with the best possible experience. It is, therefore, important
     that your personal data available to us remains up to date. As such, if you
     notice that the information that we have on Customer in our files is no
     longer accurate or is incomplete, we strongly encourage you to contact us
     with the most current information. Not doing so may, in some cases, affect
     our capacity to deliver to our products. Note that before updating
     Customer’s personal data, we may ask you to verify your identity before we
     can act on the request.

 7.  Retention of personal data
     
     Customer’s personal data will be stored in accordance with our retention
     policies and processes. We will keep Customer’s information only for as
     long as it is necessary for us to fulfill our obligations. Thereafter, we
     will put necessary efforts to permanently dispose of your personal data,
     unless we are required to keep it for legitimate business or legal
     purposes.

 8.  Legal basis for processing personal data
     
     The legal basis for collecting and using the personal data described above
     will depend on the personal data concerned and the specific context in
     which we collect it. However, we will normally collect personal data from
     you only where we have your consent to do so, where we need the personal
     data to perform a contract with you or to comply with applicable laws, or
     where the processing is in our legitimate interests and not overridden by
     your data protection interests or fundamental rights and freedoms.
     
     If we ask you to provide personal data to comply with a legal requirement
     or to perform a contact with you, we will make this clear at the relevant
     time and advise you whether the provision of your personal data is
     mandatory or not (as well as of the possible consequences if you do not
     provide your personal data).
     
     Similarly, if we collect and use your personal data in reliance on our
     legitimate interests (or those of any third party), we will make clear to
     you at the relevant time what those legitimate interests are.
     
     In other situations, Customer (including its users) must always give us
     clear consent for the collection, use and processing of personal data in
     order for us to do so. This can be done in several ways, for example, by
     phone, chat, email, by click of a button, or other similar means.
     
     Occasionally, a Customer may give us access to, or provide us with,
     additional personal data which may be necessary to enable us to provide our
     products to Customer. This may, for example, happen when Customer chooses
     to enable a relevant feature in a product. In such case, we will treat such
     personal data in accordance with the terms of this privacy policy and the
     applicable laws.
     
     When Customer procures or uses our products, Customer acknowledges and
     agrees that Customer has the necessary authority and all relevant consents
     (including those that may be required from its uses) to transfer such
     personal data to us, and allow us to treat such personal data in accordance
     with this privacy policy.

 9.  Minors
     
     The products that we provide are not intended for individuals below the age
     of 18. If you are under 18, please do not provide your personal information
     to us.

 10. Openness and accountability
     
     Within Genetec, our privacy team is responsible for our security and
     privacy-related matters, including the application of this privacy policy.
     He and his team oversee training of our staff to ensure security compliance
     and to raise privacy awareness. Security, transparency and integrity are
     among the key values at Genetec. We will gladly answer any questions or
     concerns that you may have with respect to your privacy or the security of
     your personal data, or if they wish to request a correction of your
     personal data in our custody or control. Please do not hesitate to reach us
     by visiting the “contact us” section of our website.

 11. Your data protection rights
     
     You have the right to request access to, and obtain a copy of, your
     personal data. You may also request that any personal data that is
     inaccurate or incomplete be rectified or completed. Note however that, in
     some cases, we may not be able to provide you access to your personal data.
     This may occur when providing such access would be likely to impact the
     privacy or the security of a third party, or for other valid reasons in
     accordance with applicable laws. In these events, we will advise you in
     writing of the grounds of our decision.
     
     Under certain legal conditions (for example, where the personal data is no
     longer needed to achieve the purposes for which the information was
     initially collected) you may request that your personal data be erased. In
     addition, you may object to the processing of your personal data, ask us to
     restrict processing of your personal data or request portability of your
     personal data under certain legal conditions.
     
     In situations, other than those outlined above in this section, where the
     processing of your personal data is based on your consent, you have the
     right to withdraw your consent at any time. Please note, however, that
     withdrawing your consent will not affect the lawfulness of any processing
     we conducted prior to your withdrawal, nor will it affect processing of
     your personal data conducted in reliance on other lawful processing grounds
     (such in relation to your account or use of your products under a
     contract).
     
     You also have the right to opt-out of electronic marketing communications
     that we may send you at any time and free of charge. You may exercise this
     right by clicking on the “unsubscribe”, “opt-out” or other similar links in
     the marketing e-mails that we may send you. To opt-out of other forms of
     marketing (such as postal marketing or telemarketing), please contact us
     using the contact details provided under the “How to contact us” heading
     below. However, we may still contact you using your contact information for
     example to share important technical or functional information relating to
     your account or use of our products.
     
     If we are unable to resolve an issue to your satisfaction, you may choose
     to request assistance from, or submit a complaint to, the privacy
     authorities, such as the Privacy Commissioner of Canada, who may be
     contacted at 1-800-282-1376, or by visiting www.priv.gc.ca.
     
     You may exercise any of the rights described above at any time by
     contacting us as described under the “How to contact us” section below. We
     will respond to your request in accordance with applicable data protection
     laws.

 12. How to contact us
     
     If you have any questions, concerns or complaints about this privacy
     policy, or the way we process your personal data, or if you want to
     exercise your rights as described above, please contact our Data Protection
     Officer and our privacy team by email at privacy@genetec.com, or by postal
     mail at the following address: 2280 AlfredNobel Blvd., Suite 400,
     Montreal, QC, H4S 2A4, Canada. .

 13. Updates to this privacy policy
     
     Continuous improvement of our products is key to our goal to providing our
     customers with the most innovative and relevant solutions. We, therefore,
     continuously implement new technologies and improving our processes,
     software and services, which may require us to update this privacy policy
     from time to time, without prior notice. However, if we make any major
     changes to our privacy practices, we will publish a relevant notice on our
     corporate website, at www.genetec.com.
     
     The revised version of this document terms will take effect as soon as it
     is made available on our website with regards to all new customers. If any
     revision to this policy outlines any material changes to the way that we
     use or otherwise process any personal data, we will provide a more
     prominent notice.
     
     Where applicable, we will also provide Customer with instructions on how to
     opt in to or opt out from our new products, or communications. Note that
     some aspects of our products may not be available to Customer if Customer
     chooses to opt out from certain communications.
     
     This privacy policy has been last updated on December 4, 2019. Please note
     that this version takes into account the provisions of Regulation 2016/679
     of the European Parliament and of the Council on 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 (General Data
     Protection Regulation).
     
     The latest version of this privacy policy is available
     at www.genetec.com/legal/privacy. We invite you to subscribe to the legal
     notifications in our Email Subscription Center to, among other things, be
     notified of any major changes to this document.
     
     Please find below the list of our Product Privacy Sheets that will help you
     understand in further detail the data collection and processing
     implications as part of your use of specific products:
     
     • Product Privacy Sheet – AutoVu
     Cloudrunner™: www.genetec.com/legal/pps-cloudrunner
     • Product Privacy Sheet – Genetec™ Security
     Center: www.genetec.com/legal/pps-gsc
     • Product Privacy Sheet – Stratocast™: www.genetec.com/legal/pps-stratocast
     • Product Privacy Sheet – Genetec
     Clearance™: www.genetec.com/legal/pps-clearance
     • Product Privacy Sheet – Curb Sense™: www.genetec.com/legal/pps-curbsense
     • Product Privacy Sheet – Genetec Retail
     Sense™: www.genetec.com/legal/pps-rs
     • Product Privacy Sheet – Genetec
     ClearID™: www.genetec.com/legal/pps-clearid




SHEETS

AutoVu Cloudrunner™

Curb Sense™

Genetec Clearance™

Genetec ClearID™

Genetec Retail Sense™

Genetec™ Security Center

Stratocast™





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