Privacy Policy

Last updated: May 25, 2022

Fleexer Management Inc. ( Fleexer) takes steps intended to meet privacy principles and requirements with respect to personal information under applicable privacy legislation. This Privacy Policy (the Policy) applies to services offered by Fleexer through its website (the Site), software platforms (such as “SWARM”), web extensions, mobile applications, and other online offerings (together with any and all future online and offline offerings operated by or on behalf of Fleexer (the Platforms). Fleexer cares about your privacy and is committed to protecting it by adhering to the Policy.

This Policy describes the information that we collect from you as part of the normal operation of our services and what may happen to that information. Our subsidiaries and affiliated companies operate under similar privacy practices as described in this Policy and, subject to the requirements of applicable law, we strive to provide a consistent set of privacy practices throughout our global user community.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

By accepting the Policy, you expressly consent to our collection, use and disclosure of your personal information in accordance with this Policy.

Scope

Fleexer is specialized in digital support in predictive meshing (more commonly known as twinning). We work with different industries in the leading sectors to develop their innovation. With our know-how, our clients become very competitive in a competitive and constantly changing environment.

In addition to our 7 years of expertise in the field of collaborative platforms, we have developed a cutting edge expertise in artificial intelligence matching that can be integrated on any platform. Matching is not only about cross-referencing data, but more importantly, it is about bringing out the potential of the customer’s data.

Fleexer offers a software platform known as “SWARM” which is aimed at mapping, connecting and providing business intelligence and predictive analytics to corporations seeking to connect with others sharing similar interests and projects. Fleexer does this by collecting and presenting this data about the corporate landscape on its platform in an interactive and accessible way.

For the sole purpose to operate our software platforms and offer you our innovative services, we gather, analyze and publish information on corporations and users, classify and compile the data with data from other sources and enrich this data using machine learning techniques to make profiles as complete as possible and make all data accessible to users for their legitimate purposes related to the above.

Collection and use of personal information

You can access our platforms without providing any personal information. However, in order to use certain features of our Platforms, we may request that you provide certain personal information. We only collect personal information that is necessary to provide you with our different services. Where possible, we indicate which fields are required and which fields are optional.

If you subscribe to our SWARM Platform and join a Hub (as defined in our Terms of Use), we may collect your name, pronouns, age, gender, ethnicity, business email address, phone number, job title, self-reported interests and other information about you or your company or employer, as well as all user-submitted information and traceable patterns, interactions, searches, connexions and other usage of the features of the Platform. Some of this information constitutes personal information within the meaning of privacy laws in Canada and other does not. This Policy applies to all personal information within the meaning of applicable law, whereas the Terms of Use of the SWARM Platform applies to all other related business data.
If you use the contact feature on our Site or one of its subdomains, we may collect your name, business email address, phone number, job title, and other information about your company. We use this information to respond to your request or comment. If you send us emails or letters, we may collect such information in a file specific to you.
If you wish to create an account and/or subscribe to a service on one of our Platforms, we may collect your name, business email address, phone number, and other information about your company. Information from your account will be used to facilitate the service(s) you request. Amongst other things, we use your information to troubleshoot problems; customize your experience; detect and protect us against error, fraud, and other criminal activity. We may compare and review your personal information for errors, omissions and for accuracy. In certain cases, we may verify this information to ensure only professionals from a specific field have access to our services.
For most of our Platforms aimed at mapping and presenting a corporate landscape, we may collect information on corporations and financial opportunities including information on data subjects such as directors, managers, angel investors, team members, and other persons. The information we collect, show, and share on our Platforms may hold the following personal data: name, known investments, online presence and sources, photos and likeness, gender, ethnicity, education, professional contact information (not all of which constitutes Personal Information under applicable law in Canada).

We may also use the personal information we collect to: communicate with you, including through tailored marketing messages and transactional emails, about our products, services and related services; conduct, process and complete transactions with customers; meet legal, regulatory, insurance, security and processing requirements; and otherwise with your consent, or as permitted or required by law.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Collection and use of customers’ information

While most of our services are aimed at collecting and presenting business-specific and professional information, certain services may require our customers to provide us with their personal information. When we collect and use personal information on the instructions of our customers, we are acting as a service provider/data processor to that client, processing personal information on their behalf, and we refer to this data as “Customer Data”. We may also use Customer Data on an aggregated and non-identifiable basis to improve and enhance our product and service offerings.

We use all of the personal information mentioned in the above overview for the sole purpose of gathering, analyzing, and publishing information on companies and investors and to provide transparency on financing, ownership, and activities of those involved.

More specifically we use the collected data to:

Provide you with services and products that you request from us,
Inform you about platform and service updates, content, offers, and advertisements that may be of interest to you,
Contact you as required to perform our services,
Send you an invoice for our products or services,
Provide customer service and follow-up to sales or support requests,
Improve your customer experience on our Platform(s),
Develop customized and personalized content, offers, products and services,
Store your preferences for future interactions with us or our Platform(s),
Create research and marketing reports,
Prevent illegal activities, suspected fraud and potential threats to our Platform(s),
Analyse the characteristics of our customers and their use of our Platform(s) to understand customer and market needs and improve our product as well as business development; and
Any other sharing of collected and enriched data on your business with your consent.

We rely on our customers to comply with all applicable privacy laws when collecting, using, or disclosing personal information through the services, including by obtaining appropriate consent prior to collecting, using, and disclosing personal information through the services.

If you have any questions regarding the personal information we process on behalf of a customer, please contact the customer directly and/or review their applicable privacy policy.

Disclosure
of personal information

Fleexer will only disclose your personal information with your consent or if it has legal authority to do so, such as in the following contexts:

Service Providers: Fleexer may transfer personal information to third-party service providers (including affiliates acting in this capacity) that perform services on our behalf, such as data hosting and processing, marketing and information technology, and to complete transactions.

Business Transactions: We may use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of Fleexer, or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of Fleexer, or our business or assets, may use and disclose your personal information for similar purposes as those described in this Policy.

Legal: Fleexer may disclose personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent, or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to us or our service providers). Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, province, telephone number, email address, and order history without a subpoena. However, in an effort to balance your right to privacy and the ability to keep the community free from bad actors, we will not disclose additional information to law enforcement or other government officials without a subpoena, court order, or substantially similar legal procedure, except when the additional disclosure of information is necessary to prevent imminent physical harm or financial loss.

International storing and transfer of personal information

In order for us to carry out the services offered by our Platforms, the information may be processed by us (or our third-party service providers) outside of your jurisdiction of residence, including on Amazon Web Services Cloud Platform servers in Canada. Our primary encrypted data storage is located in Canada.

All data transferred in and out of the Fleexer are encrypted securely end-to-end. We ensure that our service providers comply with applicable privacy and data protection laws, and implement contractual clauses that ensure the protection of privacy rights, as applicable.

By submitting your personal information or engaging with the Platform, the Site or one of its subdomains, you consent to such transfer and storage.

Cookies and other tracking technologies

When you visit our Site or one of its subdomains or use and interact with our Platform(s), we use cookies and similar technologies to collect information about your visit to our Site or your usage of our Platform(s) to remember your preferences and settings when you navigate through our services. We also use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve you and our community, and to improve our services.

With respect to our Site, the information collected include: your IP address, the date and time of your visit, the pages you visit, the features you use, and the referring URL you came from and which one you go to after, clickstream behaviour (i.e. the pages you view, the links you click, and other actions you take in connection with our website) and product information, your browser type and selected language.

When you visit our Site or one of its subdomains or otherwise interact with our Platform(s), we may use both session and persistent cookies. A “session cookie” expires immediately when you end your session (i.e. close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to our site at a later date, the cookie information is still available. This cookie placed by us may contain information (such as a unique user ID) that is used to track your usage of our site, and may be used to send you ads or offers when you browse our site or other websites. We employ cookies to enable our systems to recognize your browser and tell us how and when pages in our site are visited and by how many people, and also in order for our server to recognize a return visitor as a unique user. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on a computer.

We also use Google Analytics to better understand who is using our Site, and how people are using it. Google Analytics uses cookies to collect information such as Site pages visited, places where users click, time spent on each Site page, Internet Protocol address, type of operating system used, and location. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information. Google may track your activity over time and across websites. Once again, such information is used to target advertisements and content that may be of interest to you, and also to provide statistical insight through features such as  Google Analytics and Google Ads.

Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preference. In some instances, tracking tools used by third-party service providers may be disabled. For example, Google allows you to deactivate cookies designed to target ads by accessing the Opt-Out Page  of its main website. Google Analytics may also be deactivated, once you download the browser add-on available for that purpose. You may also decline the use of cookies by other third-party vendors by logging on to the  Network Advertising Initiative consumer deactivation page.

Links to other sites

We may offer links to other websites controlled by other entities. We are not responsible for, nor do we accept any liability for how such other entities collect, use, and disclose personal information. You should consult the privacy policies of these other websites before providing any personal information.

Security

We take reasonable steps to protect the personal information in our custody or control using physical, electronic or procedural security measures, including firewalls and encryption, that are appropriate having regard to the nature and sensitivity of the information.

We employ many different security techniques to protect such data from unauthorized access by users inside and outside the company. Your information is stored and processed on computers located in Canada. More specifically, our website and Platform uses SSL encryption. We have also put in place access profiles for our employees (and any third-parties) giving them limited access to our systems and (personal) data actually needed to perform their work.

Please note that the safety and security of your information is also your responsibility. If you have chosen a password to access certain parts of the Platform(s), you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.

However, please note that no security measures can offer absolute security.

Access, correction and contacting us

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes. By law, you have the right to request access to and/or correction of the personal information we hold about you.

If you wish to review, verify, correct, or withdraw your consent to the use of your personal information, you may also send us an email to privacy@swarmplus.io to request access, correction, or deletion of any personal information you have provided to us. We may not accept a request to change information if we believe that the change would violate a law or legal requirement or result in incorrect information.

Before providing you with access to your information, we may ask you for specific information to help us confirm your identity and right of access, and to provide you with the personal information we hold about you, or to make the requested changes. In some cases, applicable law requires us to refuse to provide you with access to some or all of the personal information we hold about you, or that we may have destroyed, erased or made anonymous in accordance with our legal record-keeping obligations and privacy best practices.

Please note that if you request deletion of certain information, we may not be able to provide you with certain services. We will explain the consequences of deletion at that time to assist you in your decision.

If we are unable to provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Such restrictions may include, for example, information about another individual that would reveal their personal information or confidential business information, or would be prohibitively costly to provide.

Privacy policy changes

This privacy policy is effective as of the last updated date above and may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this privacy policy, we will make reasonable efforts to notify you of this, including by posting the revised privacy policy on our Site. Your continued provision of personal information or use of the Platforms or our Site following any changes to this privacy policy constitutes your acceptance of any such changes.

Contact us

If you have any questions or concerns about the Policy, or if you wish to make a complaint, please contact our Privacy Officer Alexandre Laberge at privacy@swarmplus.io.