Privacy policy

Effective as of February 20, 2025

Our commitment

Respect for privacy and confidentiality is an important concern for UMAM (“we,” “us”). That’s why we are committed to continuously reviewing and updating our practices, implementing effective safeguards to protect the personal information we hold about you. We also pledge never to sell or rent this information to anyone.

Policy summary

This Privacy Policy (the “Policy”) explains how we collect, share, use, and retain your personal information when you use our website, www.umam.ca, when you contact us by phone, respond to our surveys, participate in our contests, or purchase our products. It also describes the types of personal information we collect about you, the purposes for which we collect it, how we use it, how we protect it, and under what circumstances we may share it with third parties.

In addition, this Policy outlines the choices available to you regarding how we use your personal information, and the various ways you can contact us to access, verify, or update your details, adjust your privacy preferences, or ask questions about our privacy practices.

Applicable laws and regulations

This Policy and the personal information processed by UMAM are subject to applicable Canadian, provincial, and federal privacy laws, as well as the European Union’s General Data Protection Regulation (GDPR), where applicable.

Consent

By accessing our website, you consent to the collection, use, and disclosure of your personal information in accordance with this Policy. In some cases, your consent may be considered “implied”, meaning that your permission is assumed based on your actions, or lack thereof, at the time your personal information is collected, used, or shared.

If you do not agree with this Policy, please refrain from using our website.

Who does this Policy apply to?

This Policy applies to anyone who communicates or interacts with us, by any means, whether you are a customer or simply a visitor to our website. Our employees, consultants, and job applicants responding to our postings are subject to a separate privacy policy.

This Policy does not apply to third-party websites over which we have no control. If you follow a link to a third-party site, that site’s own privacy policy will apply. We are not responsible for the privacy policies, procedures, or practices of such third parties. We encourage you to review their policies before submitting any personal information to those sites.

What is personal information?

Personal information refers to any information about you that identifies you, either directly or indirectly. 

Information that has been anonymized and can no longer be linked to you, directly or indirectly, is not considered personal information. Anonymized information cannot, in an irreversible manner, identify you directly or indirectly.

How do we collect your personal information?

We collect only the personal information necessary to fulfill the purposes described in this Policy. We obtain your personal information primarily from you, in the following ways:

  • when you voluntarily provide it to us directly;
  • when personal information about you is automatically collected through your use of our website;
  • when third parties provide us with personal information about you. These third parties may include service providers or partners who, for example, share your contact information with us to open an account or manage a registration related to our Product, with your prior consent.

Personal information you provide voluntarily

When you visit our website, participate in a contest, sweepstake, promotion, event, or survey, make a request related to our Product, or otherwise communicate or interact with us, we may ask you to voluntarily provide certain personal information, such as your name, email address, mailing address, or phone number, so that we can communicate with you more easily and respond to your request.

Personal information collected automatically

  • Cookies

A cookie is a small text file containing a unique identification number that recognizes the browser of a visitor’s mobile device or computer (but does not necessarily identify the visitor) each time they access our website.

When you visit our website, we use cookies to automatically collect certain user information, such as the Internet Protocol (IP) address identifying your mobile device or computer, the IP address of your Internet service provider, the name and version of your web browser, the date and time you access our website, the Internet address from which you arrived directly at our website, the operating system used, the sections of our website visited, pages viewed, and images displayed, and the documents accessed or downloaded from our website.

With your consent (if you enable these technologies or where permitted by law), we also use cookies to help manage our website and analyze how it is used. Cookies allow us to better understand your interests and provide a more personalized online experience tailored to your needs. You may reset your browser to be notified when cookies are used and/or to accept or refuse cookies. However, refusing cookies may limit your ability to use certain features of our Website.

Why do we collect and use your personal information?

We use the personal information collected about you for the following purposes:

  • to respond to or follow up on your requests, questions, or comments submitted online, by mail, or by phone;
  • to personalize and improve your experience on our website or with our digital tools;
  • to personalize and deliver online (or other media) advertising content; Rest assured that no sensitive information is used for advertising or marketing purposes and, where possible, your information will be de-identified before such use;
  • to conduct analyses and statistics about our audience, our customers, and how our website is used, in order to better understand their interests and preferences;
  • to develop or design new Products that may be of interest to our customers;
  • to manage, review, and improve our Product, including customer service and internal operational processes;
  • to perform aggregated, anonymous user data analyses;
  • to detect security or privacy incidents and protect against malicious, deceptive, fraudulent, or illegal activities;
  • for any other purpose described in this Policy or communicated to you at the time your personal information is collected;
  • or for any other purposes permitted or required by applicable laws.

If you prefer that your personal information not be used within UMAM for advertising or marketing purposes, or for any other purpose that is not necessary to provide our Product or maintain our business operations, you may withdraw your consent at any time (subject to legal or contractual restrictions).

Data analytics

We may use de-identified user information that does not allow for direct identification to create general reports that help us study trends and changes related to the demographic characteristics of our website users. This de-identified information is used for administrative purposes, to better understand our users’ overall interests, and to improve our website.

Who may we share your personal information with?

  • Disclosure to UMAM-affiliated entities

We may share your personal information with UMAM-affiliated entities to comply with applicable laws, regulations, and requirements, and to verify that your information is consistent, accurate, and up to date.

  • Disclosure to our service providers or partners

We may also share your information with third-party vendors, consultants, and other product or service providers we engage to perform tasks or deliver products and services on our behalf. These third parties include payment processors, website analytics providers, business intelligence service providers, messaging service providers, and our advertising partners.

  • Disclosure to public or government authorities

We may disclose your personal information to public or governmental bodies that are legally authorized to obtain such information, or where we have reasonable grounds to believe that the information may be useful in an investigation involving unlawful activity. We may also disclose information to comply with a subpoena, warrant, or order issued by a court, individual, or competent authority requiring the production of records or information; to comply with court rules regarding the production of records; or to protect our rights and property.

  • Business transactions

If necessary for the assessment or completion of a business transaction — such as the sale or lease of all or part of a business or its assets, or a change in its legal structure through merger or otherwise — we may share personal information with the other party to the transaction, in accordance with applicable legal requirements.

How do we protect your personal information?

We have established governance rules at UMAM to ensure the protection of personal information throughout its entire life cycle. Depending on the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, we implement a combination of measures to protect your personal information, including:

  • Appointment of a Privacy Officer, responsible for ensuring UMAM’s compliance with applicable privacy laws;
  • Internal policies, directives, procedures, and guidelines that define employee roles and responsibilities throughout the information life cycle, ensuring that only employees who need to access your information in the course of their work are authorized to do so;
  • Employee training and awareness activities on privacy protection and information security;
  • When information is collected or stored electronically : technical safeguards such as encryption, firewalls, antivirus software, and other similar security measures;
  • Procedures for receiving, investigating, and responding to complaints or requests related to our information-handling practices, including any privacy incidents involving personal information;
  • A framework for the retention and destruction of personal information;
  • Contractual and other measures to ensure that service providers with whom we share personal information maintain appropriate security safeguards. For example, we generally require our service providers to limit their use and retention of personal information to what is necessary to provide their services and to notify us of any breach or attempted breach of confidentiality obligations. We also take steps to monitor and verify their compliance through various means, such as on-site inspections (where possible), audits and interviews, or proof of certification.

Disclaimer

No security measure is absolute or fully guaranteed. If you have reason to believe that your interaction with us is no longer secure (for example, if you notice suspicious activity on your account), please contact us immediately using the contact details provided in the “How to Contact Us” section below.

Accessing your personal information

You may request access to the personal information we hold about you. In some cases, we may not be able to provide the information requested; for example, if doing so would disclose information about another individual.

Deleting your personal information

You may request that we delete your personal information. Our response will depend on the circumstances. If we have fulfilled the purposes for which the personal information was collected, we will delete it. However, we may retain it in order to meet our legal, regulatory, and contractual obligations and to protect our rights in the event of a claim.

If we have not yet achieved the purposes for which the personal information was collected, we will delete any data that is outdated, inaccurate, incomplete, or no longer necessary.

You may submit a written request to exercise any of your rights regarding your personal information by contacting us at the address provided in the “How to Contact Us” section below.

You will receive our written response within 30 days. If we refuse your request in whole or in part, we will provide you with the following information:

  • the reasons for the refusal;
  • references to the laws and regulations justifying the refusal;
  • your right to challenge the refusal before your provincial or territorial privacy authority; and
  • the deadlines applicable for contesting the refusal.

Filing a complaint

You may file a complaint if you believe we have mishandled your personal information. We encourage you to contact us first if you wish to make a complaint. We will take the time to review your concern and work with you to resolve the issue.

You may also file a complaint with the privacy regulatory authority in your province or territory.

Changes to this policy and notice of updates

We regularly update our practices to strengthen them and to reflect changes in privacy laws, regulations, and standards. We will notify you on our website of any significant updates to this Policy. When such changes are substantial, you will receive a notice in accordance with applicable laws.

How to contact us

You may contact our Privacy Officer in writing using the information below to:

  • Request access to, correction of, or deletion of your personal information;
  • File a complaint related to the handling of your personal information;
  • Request assistance, send feedback, or ask any question related to the protection of your personal information.

Please be sure to include all necessary information to allow us to follow up on your request.

Email: info@umam.ca