This privacy policy contains information about the processing of personal information carried out by Solutions Kumojin inc. ("Koddian" or "we") and about how you can exercise your rights regarding that personal information.
1.Transmission of personal information
Koddian protects the personal information you entrust to us. If you voluntarily communicate personal or highly confidential information to a member of our staff, by email or through our demo booking page, only the information required to allow staff to respond to your request is used. We handle electronic correspondence with the same confidentiality measures as other written documents. This information is shared with third parties only with your consent or when permitted by law.
The Act respecting the protection of personal information in the private sector grants you, among others, the following rights:
- Respect for the confidentiality of your personal information
- Access to the personal information we hold about you
- Correction of your personal information if it is incomplete, inaccurate, equivocal, or if its collection, disclosure, or retention is not authorized by law
You may submit written comments about this privacy policy by mail or by email to lkokot@kumojin.com, to the person in charge of the protection of personal information:
Mr. Lukasz Kokot
CTO
lkokot@kumojin.com
SOLUTIONS KUMOJIN INC.
200-125 boulevard Charest Est
Québec, QC G1K 3G5To make a request for access to or correction of your personal information, see section 15.
2.When does this policy apply?
This Policy applies in the context of our digital marketing activities, such as the use of cookies, or when you interact with us through our social media, by email, or otherwise (our "digital services"). For example:
- Your browsing and use of our websites
This Policy applies only to the processing of personal information. By "personal information", we mean any information that concerns a natural person and allows that person to be identified, directly or indirectly, including information collected through cookies.
3.When does this policy not apply?
This Policy does not apply to the processing of your personal information carried out by websites, applications, or services provided by independent third parties.
For example, if you click on a link on our website that leads to a third-party site, this Policy does not apply to the processing of your personal information by that third party. Third parties include social networks and services referenced through our digital services.
Please review the privacy policies of these third parties to learn more about how they process your personal information.
4.Data automatically exchanged when accessing the site
When you access the koddian.io site, your computer and the servers of our host, Microsoft Azure, automatically exchange data without any action on your part. This exchange is necessary for those servers to send you a file compatible with the computer equipment you are using. The data exchanged is as follows:
- IP address, the numeric address that identifies and locates your computer
- Browser (Chrome, Safari, etc.) and operating system (Windows, macOS, etc.) you use
- Date and time of your access to the site
- Web pages you visit
- Address of the site that directed you to Koddian's site, if applicable
If you accept analytics cookies in our cookie consent tool, Google Analytics collects similar data directly from your browser (pages viewed, device and browser type, referring site) for statistical purposes, including counting the number of visitors and identifying the most visited pages. To this end, Google Analytics, a website analysis tool, allows Koddian to produce reports on navigation within its site. Google Analytics runs only with that consent. It then assigns your browser a random (pseudonymous) identifier, stored in the _ga and _ga_<ID> cookies, and uses your IP address to infer your approximate location. Koddian only consults aggregated reports. You can also install the Google Analytics browser opt-out add-on (tools.google.com/dlpage/gaoptout) on your computer. This add-on prevents Google Analytics from recording data about your visits.
5.Use of cookies
A "cookie" contains data collected from the websites you visit and is stored as a small text file in your browser. In this Policy, the term cookie includes tracking technologies such as invisible pixels and web beacons. If you would like more information about cookies, you can consult the cookie resources published by the Office of the Privacy Commissioner of Canada (priv.gc.ca).
We use the cookies described below for the reasons indicated.
Our site sets no advertising cookies and loads no advertising pixels.
NecessaryNecessary cookies are required for our site to work and cannot be disabled. The only necessary cookie is the consent cookie (cc_cookie), valid on koddian.io and its subdomains, which keeps your choice, its date, a random consent identifier, the version of our cookie settings and the tool's language for 182 days. If you choose a language with the language switcher, we keep that choice in your browser's local storage (not in a cookie).
AnalyticsWe use Google Analytics 4 to obtain statistics on the performance of our site. It is off by default: it runs and sets its cookies only after you consent, and you can withdraw your consent at any time. The data shows aggregated metrics such as the number of visitors, pages viewed, peak traffic hours, and the approximate location of visitors (city, region or country). To produce them, Google Analytics assigns your browser a random (pseudonymous) identifier, stored in the _ga and _ga_<ID> cookies, and uses your IP address to infer your approximate location. We only consult these aggregated reports, which help us understand how the site is used so we can improve your experience. If you withdraw your consent, Google Analytics is disabled and its cookies are deleted.
6.What personal information do we collect and for what purposes?
We collect your personal information in order to provide you with digital services, which includes marketing our products and services, as well as responding to your requests or interacting with you on social networks.
When we collect this personal information, we act as the controller for individuals located in the European Union, the United Kingdom, and any other relevant region ("Europe"). As such, we determine the legal bases for processing your personal information.
When we process your personal information based on your consent, you may withdraw that consent at any time by contacting us at lkokot@kumojin.com. Some services may not be available without your consent to the processing of your information.
Personal information relating to your communicationsExamples: email addresses, information related to your social networks, content of emails and messages.
We collect and process your personal information when you communicate with us by email, through social media, or otherwise. If you communicate with us via our social media, we may have access to the personal information you make publicly available. We collect the personal information you choose to provide. We may also use your contact details to send you information about our products and services related to your request; you can ask us at any time to stop sending you these communications by replying to one of them or writing to us at lkokot@kumojin.com. If you are located in Europe, we respond to your requests based on our legitimate interests, or based on your express consent in certain cases.
Personal information relating to demo requestsExamples: name, email address, chosen time slot, and meeting details.
When you schedule a Koddian demo, you are directed to a Microsoft Bookings (Microsoft 365) booking page. We collect the personal information you provide there to schedule the meeting, confirm it with you, and communicate with you about it. We may also use your contact details to send you information about our products and services related to your request; you can ask us at any time to stop sending you these communications by replying to one of them or writing to us at lkokot@kumojin.com. If you are located in Europe, we process this information based on our legitimate interests in responding to your request.
AdvertisingOur site uses no targeted advertising cookies. We advertise on third-party platforms, outside this site; that processing is governed by the policies of those platforms (see section 7).
Electronic personal informationExamples: technical logs, IP address, browser type and configuration, operating system, mobile device type, number of visitors, number of pages viewed, visit duration, approximate geographic location, language preferences, and device information.
When you visit our site, our host, Microsoft Azure, and Google Fonts automatically receive certain technical data, such as your IP address and browser type, needed to send you the site's pages and fonts. We use this data to ensure the security and performance of our services. In Europe, this processing is based on our legitimate interest in providing, monitoring, and securing our services. Analytics data (Google Analytics) is collected through cookies only after you consent. In Europe, this processing is based on that consent, which you can withdraw at any time using the "Cookie preferences" button in the footer of our site.
7.What do we do about digital advertising?
This site installs no advertising tags and sets no advertising cookies. Google Analytics runs on it only with your consent, with its advertising features turned off.
Koddian does, however, advertise on third-party platforms, outside this site. That advertising is governed by the privacy policies of those platforms, not by this Policy. These platforms may personalize ads based on your interests.
To learn more about targeted advertising, you can consult the resources published by the Digital Advertising Alliance of Canada (youradchoices.ca).
Here are the platforms on which we advertise.
Google AdsWe run advertising campaigns on Google Ads. These campaigns take place on Google's platforms, not on this site.
LinkedInWe run advertising campaigns on LinkedIn. These campaigns take place on that platform, not on this site.
FacebookWe run advertising campaigns on Facebook. These campaigns take place on that platform, not on this site.
8.How can you manage your cookie preferences?
You can change or withdraw your consent at any time using the "Cookie preferences" button in the footer of our site. It reopens our cookie consent tool, where you can accept or decline analytics cookies. Your choice is kept for 182 days. We will ask you again after that period or when our use of cookies changes.
For the advertising we run on third-party platforms, the Digital Advertising Alliance of Canada (youradchoices.ca), through the AdChoices program, allows you to control your cookies through a tool and an application.
- To manage preferences on your computer, use the WebChoices browser opt-out tool
- To manage preferences on your mobile device, use the AppChoices application
If you choose to decline personalized ads, you may still receive Koddian ads on those platforms, but they will not be personalized.
In addition, browsers and devices have tools that allow you to control cookies; you can block them, ensure you are notified when cookies are used, and control cookies already stored on your device. However, if you block all cookies, you may not be able to access all features of the service.
Cookie control tools vary depending on the browser you use:
- Google Chrome
- Firefox
- Safari
- Microsoft Edge
- Opera
- Brave
For advertising on third-party platforms, you can also manage your preferences by turning off "Allow Apps to Request to Track" on iOS devices or by deleting your advertising ID on Android devices.
Finally, you can opt out of having your web activity made available to Google Analytics by installing the Google Analytics browser opt-out add-on (tools.google.com/dlpage/gaoptout). This add-on prevents Google Analytics JavaScript (gtag.js and analytics.js) from sharing information about your web visits with Google Analytics. For more information about Google's privacy practices, please see Google's page on how it uses data from partner sites (policies.google.com/technologies/partner-sites).
9.To whom do we disclose your personal information?
As part of our digital services, some of your information may be shared with our subcontractors and third-party service providers.
We also disclose your personal information in the following situations:
- When required or authorized by law, including to comply with an order or a subpoena, to respond to an authority with the power to require the information, or because of an emergency that threatens your life, health, or safety.
- In the context of a merger, acquisition, or sale of part or all of our assets.
As part of our digital services, we may share or disclose your personal information to the following categories of third parties.
Business partnersWe use third parties to promote, sell, or distribute our products and services. We disclose your personal information to them only with your consent or when permitted by law, and we receive from them only information they are authorized to share with us.
IT service providersWe use service providers such as data hosting centers to offer our digital services. For example, our site is hosted by Microsoft Azure and we use Microsoft Bookings (Microsoft 365) to schedule demos.
Analytics service providersWe use Google Analytics, only with your consent, to better understand traffic related to our site. Google Analytics assigns your browser a random (pseudonymous) identifier, stored in the _ga and _ga_<ID> cookies, and uses your IP address to infer your approximate location. We only consult aggregated reports on traffic to our website. However, Google Analytics does collect data about your browsing habits through these cookies.
Font providerOur site loads its fonts from Google Fonts. Your browser then sends a request to Google's servers, which receive your IP address. No cookies are set.
Advertising partnersFor our advertising campaigns outside this site, we work with platforms such as Google, LinkedIn, or Facebook. This site installs no advertising tags from these platforms, and Google Analytics runs only with your consent and its advertising features are turned off. These platforms' processing of data is governed by their own policies.
10.Where do we store your personal information?
Your personal information may be processed outside Québec and Canada, including in the United States. Our main providers are Google, for Google Analytics (only with your consent) and Google Fonts, and Microsoft, for hosting our site (Microsoft Azure) and scheduling demos (Microsoft Bookings). Your information may then be accessible to the authorities of those jurisdictions, in accordance with the laws that apply there. Before communicating personal information outside Québec, we conduct a privacy impact assessment, as required by law. Information we entrust to our providers (Google Analytics, Microsoft Azure and Microsoft Bookings) is covered by a written agreement that takes that assessment into account. Google Fonts receives your IP address directly from your browser and processes it under its own privacy rules (policies.google.com/privacy).
If you are located in Europe, the transfer of your information to Canada relies on the European Commission's adequacy decision for Canada. For transfers to the United States, Google and Microsoft are certified under the EU-U.S. Data Privacy Framework and its UK Extension. Otherwise, we use the European Commission's standard contractual clauses.
11.How do we govern and retain your personal information?
Our policies and practices governing personal information are approved by the person in charge of the protection of personal information. Only members of our sales, customer support and technical teams who need your personal information to perform their duties have access to it. The person in charge of the protection of personal information oversees the application of our policies, from collection to destruction.
To file a complaint about how we handle your personal information, write to the person in charge of the protection of personal information at lkokot@kumojin.com, describing the subject of your complaint. We will acknowledge receipt of your complaint, review it and respond in writing. You may also, at any time, file a complaint with the Commission d'accès à l'information du Québec (see section 13).
We retain your personal information for as long as necessary for the purposes for which it was collected, or longer if required by applicable law, after which we destroy or anonymize it in accordance with the law. You can ask us which retention period applies to your information by writing to lkokot@kumojin.com.
A cookie can be persistent or session-based. Session cookies are deleted as soon as you close your browser, while persistent cookies remain active on your device for a period of time. For example, the cookie that remembers your consent choice is kept for 182 days. Google Analytics cookies are set only with your consent and can last up to two years according to Google, but they are deleted if you withdraw your consent.
12.How do we ensure the security of your personal information?
The security of your information matters to us, but remember that no method of transmission over the Web or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We have put in place reasonable security measures for the risks related to your personal information. For more information, please contact us.
13.What are your rights regarding your personal information?
You have certain rights regarding your personal information. Your rights vary depending on the laws that apply to you and the specific circumstances of your request.
EuropeIf you are located in Europe, including the United Kingdom, we are the controller of your personal information. We will respond to your requests regarding the rights provided by law, including:
- The right of access to your personal information
- The right to rectification
- The right to erasure
- The right to restriction of processing
- The right to data portability
- The right to object to processing, including for direct marketing
- The right to withdraw your consent at any time
- The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you
- The right to lodge a complaint with a supervisory authority
The Commission nationale de l'informatique et des libertés (CNIL) (cnil.fr) has published a guide on these rights. These rights are subject to certain conditions and may not apply in every case.
QuébecIf you are located in Québec, the Act respecting the protection of personal information in the private sector grants you, among others, the following rights:
- The right to access the personal information we hold about you and to have it corrected if it is inaccurate, incomplete, or equivocal (sections 27 and 28)
- The right to obtain, unless doing so raises serious practical difficulties, the computerized personal information collected from you, and not created or inferred from personal information about you, in a structured, commonly used technological format, and to ask that it be communicated to any person or body authorized by law to collect it (section 27, third paragraph)
- The right to ask us to cease disseminating your personal information or to de-index any hyperlink attached to your name, when the conditions set out in the law are met (section 28.1)
- The right to withdraw your consent at any time, including for cookies, using the "Cookie preferences" button in the footer of our site
To file a complaint about our practices, you may write to the person in charge of the protection of personal information at lkokot@kumojin.com. You may also, at any time, file a complaint with the Commission d'accès à l'information du Québec.
CanadaIf you are located elsewhere in Canada, your rights may vary by region but generally include the right to access your personal information and to have it corrected in certain cases.
Processing your requestTo exercise your rights, file a complaint, or withdraw your consent, or if you have questions about how we process your personal information, write to the person in charge of the protection of personal information:
Person in charge of the protection of personal information:
Mr. Lukasz Kokot
CTO
lkokot@kumojin.com
SOLUTIONS KUMOJIN INC.
200-125 boulevard Charest Est
Québec, QC G1K 3G5If needed, we will help you prepare your request at no additional cost. For security reasons and to avoid fraudulent requests, we may ask you to provide proof of identity with your request. Once the request is processed, we will securely delete that proof.
In Québec and elsewhere in Canada, we will respond to your request in writing within 30 days of receiving it. If we do not respond within that period, your request is deemed refused. Access to your personal information is free of charge. However, a reasonable fee may be charged for transcribing, reproducing, or transmitting it (for individuals located outside Québec, any fee is minimal); in that case, we will inform you of the approximate amount before processing your request.
In Europe, the first copy of your data is provided free of charge, and we respond to your request within one month of receiving it. That period may be extended by two months, taking into account the complexity and number of requests; in that case, we will inform you of the extension and the reasons for it within the first month.
If your request is refused, we will notify you in writing, giving the reasons for our decision and the provision of law on which the refusal is based, the available remedies, and the time limit for exercising them. At your request, we will help you understand the refusal. We will retain the personal information covered by the request for as long as necessary to allow you to exhaust your remedies.
Recourse in case of refusalIf you are located in Europe, you may file a complaint with the supervisory authority of your country if you are not satisfied with our practices regarding your personal information or our response to your request. For example, if you are in France, you may address your complaint to the Commission nationale de l'informatique et des libertés (CNIL) (cnil.fr).
If you are located in Québec and we refuse your request for access, correction, cessation of dissemination or de-indexing, or do not respond within 30 days, you may submit an application for the examination of a disagreement to the Commission d'accès à l'information du Québec (cai.gouv.qc.ca) within 30 days of the refusal or the expiry of our response deadline (see section 15). You may also, at any time, file a complaint with the Commission about our practices. If you are located elsewhere in Canada, you may file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca).
We will do our best to improve our processes. If you are not satisfied with how we handle your request, you may file a formal complaint with the Office of the Privacy Commissioner of Canada, or with the competent authorities in your country of residence.
14.Can we update this privacy policy?
We may update this Privacy Policy as needed and to reflect our personal information protection obligations. The most recent update date appears at the beginning of the Policy. Every change is announced on our site with a dated notice published at the top of this Policy.
15.How can you submit an access or correction request?
Your recourseFollowing a written request for access, correction, cessation of dissemination or de-indexing, you may submit an application for the examination of a disagreement to the Commission d'accès à l'information du Québec if:
- You received a refusal or a response you consider unsatisfactory from us;
- You did not receive a response.
You must submit this application within 30 days of the refusal or the expiry of our response deadline. To learn more, consult the Commission d'accès à l'information du Québec website.
What is an access request?An access request targets the personal information about you that Koddian holds. An access request is therefore not a request for general information. The right of access to personal information includes several restrictions. Consequently, access to certain personal information may be refused in whole or in part if a restriction provided by law applies, including under the Act respecting the protection of personal information in the private sector.
For any general question, write to us at info@koddian.io. To obtain a copy of your personal information, follow the access request procedure described below instead.
What is a correction request?A correction request aims to correct personal information that is inaccurate, incomplete, or equivocal, or whose collection, disclosure, or retention is not authorized by law.
Submitting an access or correction requestYou may submit any written request for access to or correction of personal information by mail or by email to lkokot@kumojin.com, to the attention of the person in charge of the protection of personal information. Your written request must be specific enough to allow us to identify the personal information you wish to obtain or have corrected; if needed, we will help you clarify it. We ask that you include your contact details (first name, last name, address, telephone number, etc.) so that we can send you a response or contact you if we need additional information to process your request.
We have 30 days from receipt of your request to respond. If we do not respond within that period, your request is deemed refused. We send our response by mail or by another secure means agreed with you, including, at your request, in a structured, commonly used technological format. We do not send personal information by email, as this method of transmission is not sufficiently secure.