Privacy Policy 

Last updated: February 20, 2020 

This Privacy Policy describes Our policies and procedures on the collection, use and  disclosure of Your information when You use the Service and tells You about Your privacy  rights and how the law protects You. 

We use Your Personal data to provide and improve the Service. By using the Service, You  agree to the collection and use of information in accordance with this Privacy Policy. 

Interpretation and Definitions 

Interpretation 

The words of which the initial letter is capitalized have meanings defined under the following conditions. 

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. 

Definitions 

For the purposes of this Privacy Policy: 

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. 

Under GDPR (General Data Protection Regulation), You can be referred to as the  Data Subject or as the User as you are the individual using the Service. Company (referred to as either “the Company”, “We”, “Us” or “Our” in this  Agreement) refers to Ndex Systems Inc, 500 Saint Jacques, suite 400. 

For the purpose of the GDPR, the Company is the Data Controller. 

  • Application means the software program provided by the Company accessed by You on  any electronic device, named F-Engine 
  • Affiliate means an entity that controls, is controlled by or is under common control  with a party, where “control” means ownership of 50% or more of the shares, equity  interest or other securities entitled to vote for election of directors or other managing  authority. 
  • Account means a unique account created for You to access our Service or parts of our  Service. 
  • Website refers to Artiffex Universal Data Conversation, accessible from  https://www.artiffex.com 
  • Service refers to the Application or the Website or both. 
  • Country refers to: Quebec, Canada

Service Provider means any natural or legal person who processes the data on  behalf of the Company. It refers to third-party companies or individuals employed  by the Company to facilitate the Service, to provide the Service on behalf of the  Company, to perform services related to the Service or to assist the Company in  analyzing how the Service is used. 

For the purpose of the GDPR, Service Providers are considered Data Processors. 

Personal Data is any information that relates to an identified or identifiable  individual. 

For the purposes for GDPR, Personal Data means any information relating to You  such as a name, an identification number, location data, online identifier or to one or  more factors specific to the physical, physiological, genetic, mental, economic,  cultural or social identity. 

For the purposes of the CCPA, Personal Data means any information that identifies,  relates to, describes or is capable of being associated with, or could reasonably be  linked, directly or indirectly, with You. 

  • Cookies are small files that are placed on Your computer, mobile device or any other  device by a website, containing the details of Your browsing history on that website  among its many uses. 
  • Device means any device that can access the Service such as a computer, a cell phone or  a digital tablet. 
  • Usage Data refers to data collected automatically, either generated by the use of the  Service or from the Service infrastructure itself (for example, the duration of a page  visit). 
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation),  refers to the Company as the legal person which alone or jointly with others determines  the purposes and means of the processing of Personal Data. 
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities,  in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to  develop and implement a mechanism for allowing internet users to control the tracking  of their online activities across websites. 
  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the  Company as the legal entity that collects Consumers’ personal information and  determines the purposes and means of the processing of Consumers’ personal  information, or on behalf of which such information is collected and that alone, or  jointly with others, determines the purposes and means of the processing of consumers’  personal information, that does business in the State of California. 
  • Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a  natural person who is a California resident. A resident, as defined in the law, includes  (1) every individual who is in the USA for other than a temporary or transitory purpose,  and (2) every individual who is domiciled in the USA who is outside the USA for a  temporary or transitory purpose.
  • Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling,  renting, releasing, disclosing, disseminating, making available, transferring, or  otherwise communicating orally, in writing, or by electronic or other means, a  Consumer’s Personal information to another business or a third party for monetary or  other valuable consideration. 

Collecting and Using Your Personal Data 

Types of Data Collected 

Personal Data 

While using Our Service, We may ask You to provide Us with certain personally identifiable  information that can be used to contact or identify You. Personally identifiable information  may include, but is not limited to: 

  • Email address 
  • First name and last name 
  • Phone number 
  • Address, State, Province, ZIP/Postal code, City 
  • Usage Data 

Usage Data 

Usage Data is collected automatically when using the Service. 

Whether You access the Service via web browser or a mobile device, Usage Data may  include information such as the pages of our Service that You visit, the time and date of Your  visit, the time spent on those pages. We may also collect information that Your browser  sends whenever You visit our Service. 

Information Collected while Using the Application 

While using Our Application, in order to provide future enhanced and further value added  features, we may monitor and collect user navigation and actions without your prior  permission: 

We use this information to provide features of Our Service, to improve and customize Our  Service. The information may be uploaded to the Company’s servers and/or a Service  Provider’s server or it be simply stored on Your device. 

Tracking Technologies and Cookies 

We audit trails and tracking technologies to track the activity on Our Service and store  certain information to improve Our Service level and product offering. 

Use of Your Personal Data 

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service. • To manage Your Account: to manage Your registration as a user of the Service. The  Personal Data You provide can give You access to different functionalities of the Service  that are available to You as a registered user. 
  • For the performance of a contract: the development, compliance and undertaking of  the purchase contract for the products, items or services You have purchased or of any  other contract with Us through the Service. 
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent  forms of electronic communication, such as a mobile application’s push notifications  regarding updates or informative communications related to the functionalities,  products or contracted services, including the security updates, when necessary or  reasonable for their implementation. 
  • To manage Your requests: To attend and manage Your requests to Us. We may share your personal information in the following situations: 

For Business transfers: We may share or transfer Your personal information in connection  with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition  of all or a portion of our business to another company. 

Retention of Your Personal Data 

The Company will retain Your Personal Data only for as long as is necessary for the  purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the  extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal  agreements and policies. 

The Company will also retain Usage Data for internal analysis purposes. Usage Data is  generally retained for a shorter period of time, except when this data is used to strengthen  the security or to improve the functionality of Our Service, or We are legally obligated to  retain this data for longer time periods. 

Transfer of Your Personal Data 

Your information, including Personal Data, is processed at the Company’s operating offices  and in any other places where the parties involved in the processing are located. It means  that this information may be transferred to — and maintained on — computers located  outside of Your state, province, country or other governmental jurisdiction where the data  protection laws may differ than those from Your jurisdiction. 

Your consent to this Privacy Policy followed by Your submission of such information  represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated  securely and in accordance with this Privacy Policy and no transfer of Your Personal Data  will take place to an organization or a country unless there are adequate controls in place  

including the security of Your data and other personal information. If this was the case, we  will provide notice before Your Personal Data is transferred and becomes subject to a  different Privacy Policy. 

Disclosure of Your Personal Data 

Business Transactions 

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be  transferred. We will provide notice before Your Personal Data is transferred and becomes  subject to a different Privacy Policy. 

Law enforcement 

Under certain circumstances, the Company may be required to disclose Your Personal Data  if required to do so by law or in response to valid requests by public authorities (e.g. a court  or a government agency). 

Other legal requirements 

The Company may disclose Your Personal Data in the good faith belief that such action is  necessary to: 

  • Comply with a legal obligation 
  • Protect and defend the rights or property of the Company 
  • Prevent or investigate possible wrongdoing in connection with the Service • Protect the personal safety of Users of the Service or the public 
  • Protect against legal liability 

Security of Your Personal Data 

The security of Your Personal Data is important to Us, but remember that no method of  transmission over the Internet, or method of electronic storage is 100% secure. While We  strive to use commercially acceptable means to protect Your Personal Data, We cannot  guarantee its absolute security. 

Detailed Information on the Processing  of Your Personal Data 

Service Providers have access to Your Personal Data only to perform their tasks on Our  behalf and are obligated not to disclose or use it for any other purpose.

Payments 

We may use third-party services for payment processing (e.g. payment processors). 

We will not store or collect Your payment card details. That information is provided directly  to Our third-party payment processors whose use of Your personal information is governed  by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS  as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa,  Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure  handling of payment information. 

When You use Our Service to pay a product and/or service via bank transfer, We may ask  You to provide information to facilitate this transaction and to verify Your identity. 

Usage, Performance and Miscellaneous 

We may use third-party Service Providers to provide better improvement of our Service. 

Invisible reCAPTCHA 

We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by  Google. 

The reCAPTCHA service may collect information from You and from Your Device for  security purposes. 

The information gathered by reCAPTCHA is held in accordance with the Privacy  Policy of Google: https://www.google.com/intl/en/policies/privacy/ 

GDPR Privacy 

Legal Basis for Processing Personal Data under GDPR 

We may process Personal Data under the following conditions: 

  • Consent: You have given Your consent for processing Personal Data for one or more  specific purposes. 
  • Performance of a contract: Provision of Personal Data is necessary for the  performance of an agreement with You and/or for any pre-contractual obligations  thereof. 
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal  obligation to which the Company is subject. 
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital  interests or of another natural person. 
  • Public interests: Processing Personal Data is related to a task that is carried out in the  public interest or in the exercise of official authority vested in the Company. • Legitimate interests: Processing Personal Data is necessary for the purposes of the  legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the  processing, and in particular whether the provision of Personal Data is a statutory or  contractual requirement, or a requirement necessary to enter into a contract. 

Your Rights under the GDPR 

The Company undertakes to respect the confidentiality of Your Personal Data and to  guarantee You can exercise Your rights. 

You have the right under this Privacy Policy, and by law if You are within the EU, to: 

  • Request access to Your Personal Data. The right to access, update or delete the  information We have on You. Whenever made possible, you can access, update or  request deletion of Your Personal Data directly within Your account settings section. If  you are unable to perform these actions yourself, please contact Us to assist You. This  also enables You to receive a copy of the Personal Data We hold about You. 
  • Request correction of the Personal Data that We hold about You. You have the right  to to have any incomplete or inaccurate information We hold about You corrected. • Object to processing of Your Personal Data. This right exists where We are relying on  a legitimate interest as the legal basis for Our processing and there is something about  Your particular situation, which makes You want to object to our processing of Your  Personal Data on this ground. You also have the right to object where We are processing  Your Personal Data for direct marketing purposes. 
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or  remove Personal Data when there is no good reason for Us to continue processing it. • Request the transfer of Your Personal Data. We will provide to You, or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine readable format. Please note that this right only applies to automated information  which You initially provided consent for Us to use or where We used the information to  perform a contract with You. 
  • Withdraw Your consent. You have the right to withdraw Your consent on using your  Personal Data. If You withdraw Your consent, We may not be able to provide You with  access to certain specific functionalities of the Service. 

Exercising of Your GDPR Data Protection Rights 

You may exercise Your rights of access, rectification, cancellation and opposition by  contacting Us. Please note that we may ask You to verify Your identity before responding to  such requests. If You make a request, We will try our best to respond to You as soon as  possible. 

You have the right to complain to a Data Protection Authority about Our collection and use  of Your Personal Data. For more information, if You are in the European Economic Area  (EEA), please contact Your local data protection authority in the EEA.

CCPA Privacy 

Your Rights under the CCPA 

Under this Privacy Policy, and by law if You are a resident of California, You have the  following rights: 

  • The right to notice. You must be properly notified which categories of Personal Data  are being collected and the purposes for which the Personal Data is being used. • The right to access / the right to request. The CCPA permits You to request and  obtain from the Company information regarding the disclosure of Your Personal Data  that has been collected in the past 12 months by the Company or its subsidiaries to a  third-party for the third party’s direct marketing purposes. 
  • The right to say no to the sale of Personal Data. You also have the right to ask the  Company not to sell Your Personal Data to third parties. You can submit such a request  by visiting our “Do Not Sell My Personal Information” section or web page. 

The right to know about Your Personal Data. You have the right to request and  obtain from the Company information regarding the disclosure of the following: 

  • The categories of Personal Data collected 
  • The sources from which the Personal Data was collected 
  • The business or commercial purpose for collecting or selling the Personal Data • Categories of third parties with whom We share Personal Data 
  • The specific pieces of Personal Data we collected about You 
  • The right to delete Personal Data. You also have the right to request the deletion of  Your Personal Data that have been collected in the past 12 months. 

The right not to be discriminated against. You have the right not to be  discriminated against for exercising any of Your Consumer’s rights, including by: 

  • Denying goods or services to You 
  • Charging different prices or rates for goods or services, including the use of  discounts or other benefits or imposing penalties 
  • Providing a different level or quality of goods or services to You 
  • Suggesting that You will receive a different price or rate for goods or services or a  different level or quality of goods or services. 

Exercising Your CCPA Data Protection Rights 

In order to exercise any of Your rights under the CCPA, and if you are a California resident, You  can email or call us or visit our “Do Not Sell My Personal Information” section or web page.

The Company will disclose and deliver the required information free of charge within 45 days of  receiving Your verifiable request. The time period to provide the required information may be  extended once by an additional 45 days when reasonable necessary and with prior notice. 

Do Not Sell My Personal Information 

We do not sell personal information.  

Website 

You can opt out of receiving ads that are personalized as served by our Service Providers by  following our instructions presented on the Service: 

  • From Our “Cookie Consent” notice banner 
  • Or from Our “CCPA Opt-out” notice banner 
  • Or from Our “Do Not Sell My Personal Information” notice banner 
  • Or from Our “Do Not Sell My Personal Information” link 

The opt out will place a cookie on Your computer that is unique to the browser You use to  opt out. If you change browsers or delete the cookies saved by your browser, you will need  to opt out again. 

Mobile Devices 

Your mobile device may give you the ability to opt out of the use of information about the  apps you use in order to serve you ads that are targeted to your interests:

“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices • “Limit Ad Tracking” on iOS devices 

You can also stop the collection of location information from Your mobile device by  changing the preferences on your mobile device. 

“Do Not Track” Policy as Required by  California Online Privacy Protection Act  (CalOPPA) 

Our Service does not respond to Do Not Track signals. 

However, some third party websites do keep track of Your browsing activities. If You are  visiting such websites, You can set Your preferences in Your web browser to inform  websites that You do not want to be tracked. You can enable or disable DNT by visiting the  preferences or settings page of Your web browser.

Children’s Privacy 

Our Service does not address anyone under the age of 13. We do not knowingly collect  personally identifiable information from anyone under the age of 13. If You are a parent or  guardian and You are aware that Your child has provided Us with Personal Data, please  contact Us. If We become aware that We have collected Personal Data from anyone under  the age of 13 without verification of parental consent, We take steps to remove that  information from Our servers. 

We also may limit how We collect, use, and store some of the information of Users between  13 and 18 years old. In some cases, this means We will be unable to provide certain  functionality of the Service to these users. 

If We need to rely on consent as a legal basis for processing Your information and Your  country requires consent from a parent, We may require Your parent’s consent before We  collect and use that information. 

Links to Other Websites 

Our Service may contain links to other websites that are not operated by Us. If You click on a  third party link, You will be directed to that third party’s site. We strongly advise You to  review the Privacy Policy of every site You visit. 

We have no control over and assume no responsibility for the content, privacy policies or  practices of any third party sites or services. 

Changes to this Privacy Policy 

We may update our Privacy Policy from time to time. We will notify You of any changes by  posting the new Privacy Policy on this page. 

We will let You know via email and/or a prominent notice on Our Service, prior to the change  becoming effective and update the “Last updated” date at the top of this Privacy Policy. 

You are advised to review this Privacy Policy periodically for any changes. Changes to this  Privacy Policy are effective when they are posted on this page. 

Contact Us 

If you have any questions about this Privacy Policy, You can contact us: