Privacy Policy

Last updated: February 12, 2023

9427-8132 Québec Inc., a Canadian company doing business as Accolad Reconnaissance, and its affiliates or related entities (“Accolad Reconnaissance ”, “ we ”, “ us ” or “ our ”) are committed to protecting the confidentiality of personal information and the data it processes as data controllers on behalf of its clients and as data controllers in the ordinary course of its business services. This privacy policy (“ Privacy Policy ”) applies to your interaction with Accolad Reconnaissance and explains what personal information we process, how we process it and for what purposes.

Please read this Privacy Policy carefully before using our Services or Websites (defined below). By using or accessing our services or websites, you consent to this Privacy Policy, including the use and disclosure of information about you by Accolad Reconnaissance in the manner described below. For residents of the European Economic Area (EEA), this Privacy Policy is provided in accordance with Article 13 of the European Union (EU) General Data Protection Regulation No. 2016/679 (“GDPR ” ) and in general, in compliance with the principle of transparency set out in the GDPR.

About the activities of Accolad Reconnaissance

Accolad Recognition offers its clients employee recognition and other rewards-based services, such as gift cards, branded merchandise and personalized rewards (the “Services” ) . In this context, if you use or request our Services, your employer or your employer's authorized administrator is generally our customer, and we process your personal information on their behalf. Therefore, we only process your personal information in accordance with the written instructions of your employer and this Privacy Policy. Please note that in the event of a conflict between your employer's instructions and this Privacy Notice, your employer's instructions will generally control. In situations where you visit our websites or transact business directly with Accolad Reconnaissance, we control the personal information we collect, and we will use or process it in accordance with this Privacy Policy.

1. Information We Collect and How We Collect Information

The information we collect depends on the features and products included in the Services that you use and how you interact with us. We collect information about you when you or your employer uses the Services, visit our website ( https://www.accolad.com ) or our web application (collectively, the “ Websites ”), or transact business with Accolad Reconnaissance.

1.1. Information collected when using the Services

We may collect the following “ Personal Information ” about you when you use our Services:

• Identifiers. Your first name, last name, login credentials, date of birth, Internet Protocol (IP) address, company information, and contact information (including phone number, email address, business or home mailing address) ).
• Professional or employment-related information. Information about your relationship with your employer and peers, information relating to your employment status and other work-related details (including your employee identification numbers, employee photos, email address, position, your hire date).
• Commercial information. Financial information, purchase history, quotes, estimates and payment card information, including credit or debit card information, that you provide to pay for the Services.
• Characteristics and descriptions. Messages, comments, photos, videos, social media posts, and other information submitted through the Services (also known as “ User Content ,” more specifically detailed in our Terms of Service).
• Internet or other network activity. Information about the device you use to access the Services, including operating system, web browser type, traffic logs, mobile network information, any referring web pages you visited before you connect to the Services and other information about your use of the Services, including browsing patterns, searches, page views, date and time of use of the Services and duration of use.
• Device data. Information about the language or country configuration of the device you use to access the Services.

We may also collect personal information from your employer (as a customer), entities affiliated or related to your employer, from your employer's authorized administrator or directly or automatically from you when you use the Services . We do this to improve the quality of the Services and to prevent or detect fraud.

1.2. Information collected when using the Websites. We may collect the following personal information about you when you use the Websites: login credentials, internet or other network activity, and device data (as further described above). Generally, we collect this information directly or automatically from you when you use the Websites.

1.3. Information collected when you transact business with Accolad Reconnaissance. We may collect the following personal information about you when you transact business with Accolad Reconnaissance: login credentials, transaction-related information (such as details of the product or service purchased), professional or employment-related information ( such as company name or position) and payment card information (if you provide it to us voluntarily). Typically, we collect this information directly from you.

YOU ARE NOT REQUIRED TO PROVIDE PERSONAL INFORMATION TO ACCOLAD RECOGNITION. However, if you do not provide us with personal information, you may not be able to use certain features of the Services, Websites or transact business with us. We may also collect non-personally identifiable or aggregated information in the form of marketing surveys, survey responses, demographic information, and information about your use of the Services and Websites. Your participation in all surveys we conduct is voluntary.

WE GENERALLY DO NOT COLLECT INFORMATION CONSIDERED SENSITIVE UNDER DATA PROTECTION LAWS, such as a social insurance number (or other government-issued identification number) or information about health. If we receive such information from you or your employer, we will delete it. We ask that you not disclose sensitive information to us or transmit other sensitive information through the Services, Websites and business transactions with Accolad Reconnaissance. If you believe that any of your sensitive information has been transmitted or disclosed to us, please notify Accolad Reconnaissance using the contact details provided at the end of this document.

2. Purposes for which Accolad Reconnaissance may use your information

We collect, use or process your personal information and non-personal information to provide our Services to you, pursue our legitimate interests and perform contractual obligations, including to:

• Operate, maintain and provide functionality of the Websites and Services, including our peer-to-peer recognition and rewards services.
• Carry out our contractual obligations. You or your employer may enter into certain contractual agreements with us regarding the Services. As such, we may use your information to fulfill our obligations and enforce our rights arising from such agreements.
• Contact our users and customers. We may use your information to respond to your questions and comments or to provide you with other support relating to our Services.
• Conduct surveys for our own marketing purposes. We conduct surveys to improve our Services.
• Solicit voluntary feedback from you or your employer on our Services.
• To comply with our legal obligations and prevent illegal activities, fraud or abuse on the Websites.

3. How and with whom we share your information

WE DO NOT RENT OR SELL YOUR PERSONAL INFORMATION TO ANYONE. We may share non-personally identifiable aggregate information, such as survey responses and other statistical information for any purpose. We may share your personal information with other people or entities, such as our subsidiaries or affiliates, our contractors, our service providers and other third parties we use to provide the Services to you, other third parties who have the contractual obligation to protect your personal information and use it only for the purposes for which we disclose it to them.

We may also share personal information if we believe in good faith that doing so is required in connection with a subpoena, court order, law or is otherwise required to exercise or defend legal rights, protect the rights, property or safety of any person, protect the integrity of the Services and Websites, protect Accolad Reconnaissance or its affiliates against fraudulent or illegal activities, or defend Accolad Reconnaissance against third party claims. In these scenarios, we will notify you or your employer (as applicable) unless prohibited from doing so by applicable law, subpoena, or order.

In the event of a merger, reorganization or other sale of all or a portion of Accolad Reconnaissance's assets, your personal information may be considered one of the assets transferred to the new owner. In this context, we may share personal information with the new owner, potential owners and advisors related to the transaction or change of control of Accolad Reconnaissance.

4. Storage of personal information and cross-border data transfers

By using the Services, you consent to the collection, storage, processing and transfer of your personal information to our facilities and private cloud storage solutions in the United States and to third parties with whom we share it, as described in this Privacy Policy. For further clarification, we and, where applicable, our affiliates, are located and established in Canada and, therefore, your personal information may be transferred, stored or processed in Canada or the United States at our facilities or on our private cloud storage solutions. The transfer or disclosure of your personal information in or to these countries, including the United States, is necessary for the implementation of pre-contractual measures taken at your request and the performance of the Services for you or your employer (in as a customer).

Although the data protection, privacy and other data protection laws of these countries, including the United States, may not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the security and confidentiality of your personal information in accordance with applicable legislation (including the implementation of standard contractual clauses approved by the European Commission, as updated from time to time).

5. Your rights and choices regarding your personal information

5.1. In accordance with applicable data protection laws (including GDPR), you may contact us to exercise certain rights regarding your personal information, including the right:

• to erase or delete your personal information;
• to access your personal information;
• to limit the processing of your personal information;
• to correct, update or rectify your personal information;
• to receive a copy of your personal information (data portability);
• to object to the processing of your personal information;
• to withdraw your consent to the processing of your personal information, if we have obtained your consent to collect and process your personal information.

Please note that in most cases we are required to forward your request to your employer or your employer's authorized administrator (as the controller responsible for processing your personal information in the course of your employment), who will process the request and will provide us with instructions on how to proceed. If we process your personal information based on a legitimate interest, you have the right to object to such processing. If you wish to exercise your right to object, simply notify us in writing using the contact details at the end of this document.

5.2. Depending on where you are located in the United States (if applicable), you may also have the right to: (i) request that we disclose the nature of and details of the personal information collected and disclosed about you personal informations; (ii) whether we have sold or otherwise rented your personal information (however, we emphasize that we do not sell personal information); and (iii) to request information about Accolad Reconnaissance's disclosure of your personal information to its service providers and third parties, including for direct marketing purposes. You also have the right to lodge a complaint with a supervisory authority. Depending on your location, some of these rights may not apply or be subject to limitations. For example, we may limit the number of requests you make or charge a fee for any requests regarding your rights to your personal information.

You, your employer, or your employer's authorized administrator may contact us (as described at the end of this document) to exercise the rights set forth in Sections 5.1. and 5.2. above. Your request must provide sufficient information to allow us to reasonably verify that you are the person about whom the request is being made and to allow us to properly understand, evaluate and respond to the request.

If you would like to opt-out of certain features of the Services or opt-out of receiving email communications from us regarding new products, features, or other services, please contact us (as described at the end of this document) and we will provide opt-out instructions or we will direct you to your employer, as appropriate.

6. Data retention period

We retain your personal information for a reasonable period of time to fulfill the purposes for which we collected it (as set out in this Privacy Policy). If we no longer need your personal information for these purposes, we will delete it, unless applicable law or legal considerations require a longer retention period.

7. Security measures

We use technical and organizational measures, such as encryption technologies, to protect your personal information against loss, misuse and unauthorized access, use or modification. We regularly review our security measures and consider new, more effective measures where appropriate. However, we cannot guarantee the complete security of these measures. Please therefore exercise caution when submitting personal information online.

8. Cookies and Other Tracking Technologies

Cookies are small text files that are placed on your computer or device when you visit a website or mobile application. Pixels, web beacons and other tracking technologies work in the same way. The term “ Cookies ” in this Privacy Policy refers to any files that collect information in this way.

Cookies store information about your activity on a website and provide that information to the website owner. We use Essential Cookies to manage and optimize the performance of our technology to ensure that the Websites and Services operate as intended. When you visit the Websites or use the Services, we may place temporary and persistent Cookies to facilitate your use of the Websites or Services by recognizing you or providing content based on your language and profile. The information we collect through Cookies may be linked to personal information we have previously collected. You can disable Cookies on your device at any time by adjusting your preferences or your browser or mobile application settings. If you do so, you may not be able to access certain parts of the Websites or Services.

Some web browsers may allow you to enable a “Do Not Track” option that sends signals to websites you visit that you do not want your online activities to be tracked. This option is different from blocking Cookies, as browsers with the “Do Not Track” option selected may still accept Cookies. We currently do not consider “Do Not Track” signals. If we do so in the future, we will update this Privacy Policy accordingly.

9. Children’s privacy

The Services and our Websites are not intended for persons under 18 years of age. We do not knowingly collect information from individuals who are not of legal age to disclose such information. If you are under 18 years of age, please do not submit your email address or any other personal information to us.

10. Updates to our Privacy Policy

We may update or modify this Privacy Policy from time to time due to changes in the law or as a result of an internal review of our policies and procedures. If we make an update, we will change the last updated date listed at the very beginning of this document and we will notify you if those changes affect your rights or our obligations under this Privacy Policy.

11. How to contact us

If you have any questions, comments or complaints regarding this Privacy Policy or our practices under applicable privacy and data protection laws, you can contact our Data Protection Officer using the contact details below. We will respond to you as soon as possible, but no later than the time required by applicable law.