Amicus Technologies Inc. and our affiliates and subsidiaries ("Amicus", the "Company" or "We") respect your privacy and are committed to protecting it by complying with this policy. This policy describes:
• How we collect, use, disclose, and protect the personal information of our Platform users ("you").
• The types of information we may collect from you or that you may provide when you visit or use the functionality of website www.amicuspath.com, all related websites, subdomains, related tools, mobile applications, web applications, decentralized applications, technologies, databases, software, systems, APIs and all other technologies owned or operated by Amicus (collectively, the "Platform").
• Our practices for collecting, using, maintaining, protecting and disclosing that information.
We take steps to ensure that the personal information that we collect about youis adequate, relevant and used for limited purposes.
This policy applies to information we collect, use, or disclose about you:
• On the Platform.
• In email, text, and any other electronic messages between you and Amicus.
• Through any mobile and desktop applications or files you may have downloaded from the Platform, which provide dedicated non-browser-based interaction between you and the Platform.
• When you interact with any connections, applications or services on or through third-party websites and services if third parties include links to this policy.
The Platform may include links or functional connections to third-partywebsites, plug-ins, services, social networks or applications. Clicking on suchlinks or using or enabling such connections may allow the third party tocollect or share information or data about you. If you follow a link to athird-party website or engage in the use of a third-party plugin, applicationor service, please note that these third parties may have their own privacypolicies, and we do not accept any responsibility or liability for suchpolicies. We do not control these the actions of any such third parties, and weencourage you to read the privacy policy of every website, service andapplication that you may visit, access or use.Please read this policycarefully to understand our policies and practices for collecting, processing,and storing your information. If you do not agree with this policy and thepractices outlined herein, you may choose to not use the Platform. By accessingor using the Platform in any manner or capacity, you indicate yourunderstanding and acceptance of this policy in its entirety.We collect, use, and discloseyour personal information with your consent and as permitted by applicableprivacy laws. Depending on the information we collect and the purposes forwhich the personal information will be used, your consent may be express or implied.When you voluntarily provide personal information to us, we will imply yourconsent to use and disclose that information in accordance with this policy. Ifyou wish to withdraw your consent to our collection, use, or disclosure of yourpersonal information, please see the “Withdrawing Your Consent” section below. This policy may change from timeto time (see Changes to Our Privacy Policy). Your continued use of the Platformafter we make changes indicates that you accept and consent to those changes,so please check the policy periodically for updates.
We may collect and use several types of information from and about you, including:
• Personal information, that we can reasonably use to directly or indirectly identify you, including your contact information (such as your name, mailing address, email address, telephone number or other information), your account information (such as your username, password or other information), your payment information (such as your credit card information or other information), and your identity verification information (such as your official identification documents or other information) and any other information or identifiers.
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as, demographic information, or statistical or aggregated information. Statistical or aggregated information does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Platform feature.
• Technical information, including your login information, browser type and version, time zone setting, browser types and versions, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use and usage details.
• Non-personal details about your Platform interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from the Platform(including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from a webpage, or any phone number used to call our customer service number.
• Other information, and any other personal information that you or other parties give to us or submit to us on a voluntary basis.
We use different methods to collect your information, including through:
• Direct interactions with you when you provide it to us, for example, by filling informs, entering information on the Platform or corresponding with us by phone, email or otherwise.
• User Generated Content. We may collect content or other personal information(such as testimonials, blog posts, messages and any associated pictures photos or videos) that you may provide or create when you interact with the Platform.
• Automated technologies or interactions, through your use of the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
• Third parties or publicly available sources, including from payment processing providers, risk assessment providers, identity verification providers, regulators and other service providers, technology connections and business partners.
The information we collect directly from you on or through the Platform may include:
• Information that you provide by filling in forms or entering information on the Platform. This includes information provided at the time of creating an account on the Platform, enrolling in a membership, posting material or content on the Platform, or requesting other services. We may also ask you for information when you contact support or report a problem with the Platform.
• Records and copies of your correspondence (including emails), if you contact us.
• Details of activities or transactions you carry out through the Platform, including for example you may be required to provide your banking information (such as your bank account) to enroll in our incentive program so that we may remunerate you on your submissions and incentive programs by municipalities.
You may also voluntarily provide information to be published or displayed (hereinafter, "posted") on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, "User Contributions"). Your User Contributions are posted and transmitted to others at your own risk. Although we may limit access to certain pages and functions, you may be able to set certain privacy settings by logging into your account or by contacting us. Please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Platform or any other parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions or use your User Contributions in some capacity and accordingly we are not responsible for the use by any other party of any of the User Contributions that you disclose, transmit, display or enter in the Platform.
As you access, use and interact with the Platform, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
• Details of your visits to the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking).The information we collect automatically is statistical information and may include personal information and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Platform and to deliver a better and more personalized service, including by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Platform according to your individual interests.
• Recognize you when you return to the Platform.
The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you refuse to accept browser cookies you may be unable to access or use certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or use the Platform.
• Flash Cookies. Certain features of the Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Platform. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Certain components of the Platform including our emails or other electronic communications may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that may provide the Company with certain website or Platform statistics. For example, counting the number of users who have visited certain webpages, accessed certain components of the Platform or opened certain emails.
We use information that we collect about you or that you provide to us, including any personal information, for the following purposes:
• To present the Platform and its contents to you.
• To contact and correspond with you directly and to manage our relationship.
• To facilitate and manage your account and to process any activities or transactions on the Platform.
• To provide you with information or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you may have provided it to us.
• To provide you with notices about your account or updating your account.
• To carry out our obligations and enforce our rights relating to the User Terms of User and any contracts with you, including for payment and collection or manage risk and to comply with legal requirements.
• To notify you about changes to the Platform or any services we offer or provide though it.
• To improve the Platform or services, marketing or customer relationships and experiences.
• To allow you to participate in interactive features, social media, or similar features on the Platform.
• To measure or understand the effectiveness of the information we provide to you and others, and to deliver relevant information to you.
• To send you commercial electronic messages, which could include messages about your activities or transactions on the Platform, upcoming events or offers available from Amicus or any of our membership entities, news or upgrades to the Platform or other information that may be relevant or of interest to you.
• To detect and prevent fraud and protect the security of the Platform.
• To meet our legal obligations and for regulatory purposes.
We may also use your personal information to provide you with information or services you request or for other purposes that we may identify.
If you do not want us to use your information in this way, please contact us at privacy@amicuspath.com. For more information, see Choices About How We Use and Disclose Your Information.
Except as described in this Policy or in other situations where we have provided you with notice, have obtained your consent, or are obligated or permitted by law, we will not share your personal information with third parties.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect, or you provide, as described in this privacy policy:
• To our subsidiaries affiliates to continue operation of the Platform in the event of any potential future reorganization of the business.
• To successor entities or acquiring entities in the event of a potential sale or transfer of any part or all of the business as we may decide to sell or transfer all or part of our business to a related company or to a third party company, to merge with another entity, or to engage in another form of corporate or financing transaction (including transfers made as part of insolvency or bankruptcy proceedings or as part of a corporate reorganization). We may share your personal information in connection with the evaluation of and/or entry into such transactions.
• To our membership entities to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
• To contractors, service providers, and other third parties we use to support our business (such as search engine providers, analytics providers and artificial intelligence models that assist us with Platform improvement and optimization). In such cases, we take steps to help ensure that such parties only use personal information for authorized purposes and that such parties implement reasonable privacy and security safeguards appropriate to the personal information they handle on our behalf. Where you provide information directly to third party providers who operate on our behalf, you may be subject to the collection practices and terms of use and privacy policies of those third parties. You are responsible for reviewing and agreeing to those privacy policies and terms and conditions. In certain circumstances your information may be tokenized or otherwise encrypted or anonymized so that certain parties, including at times Amicus, do not have direct access to such information even if such information is initially entered into online properties, applications or technologies operated by such parties.
• To fulfill the purpose for which you provide it. For example, if you give us an email address with the instructions to "email a friend", we will transmit the contents of that email and your email address to the recipients.
• To any of our membership entities who are contractually obligated to treat personal information in accordance with their own privacy terms and conditions and who may use such information to contact you directly. We take reasonable steps to ensure that our membership entities are only using personal information for authorized purposes and that they implement reasonable privacy and security safeguards.
• For any other purpose disclosed by us when you provide the information, including sharing such information with our membership entities as set out in our User Terms of Service, your agreement with such User Terms of Service is required to use the Platform as set out in such User Terms or Service.
We may disclose certain information on the Platform and share such information with our membership entities and third party service providers, including personal information, relating to any information you provide or enter on the Platform and any activities you attempt, initiate or perform on the Platform. We may also disclose your personal information:
• Where authorized or required by law. For example, we may disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our User Terms of Service and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Amicus, our membership entities, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We do not sell unaggregated personal information to third parties for their marketing purposes. In accordance with the California Consumer Protection Act, under certain circumstances, California users have the right to request Amicus to disclose or to delete specific components of personal information that Amicus may have collected. If you are a California user, you may submit a request by email for this information or for deletion of this information by contacting: privacy@amicuspath.com. If required to do so, we will respond to your request in the manner and time provided for in accordance with the California Consumer Protection Act.
Some of our third-party service providers are partially or fully located outside of Canada. As a result, your personal information may be processed, stored, and transferred outside of Canada. This includes the EU the United States. These jurisdictions may have different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. By submitting your personal information or engaging with the Platform, you consent to this transfer, storage, or processing.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Platform may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
• We do not control actions or activities conducted by third parties including those relating to the collection or use of your information. However, third parties may provide you with ways to choose not to have your information collected or used in certain ways. Withdrawing your consent from a third party may not mean you will no longer receive any online advertisements. It may mean that the party from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
• Promotional Offers from the Company. If you have expressly or implicitly consented to receiving commercial electronic messages from us, as set out in the User Terms of Use, you may receive commercial electronic communications from us. If you no longer wish to receive these types of communications from us, you can opt-out by sending us an email stating your request to privacy@amicuspath.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. If you opt-out, we may still use your e-mail address to communicate with you regarding important matters.
• Data Security. The security of your personal information is very important to us. We use physical, electronic and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
• The safety and security of your information also depends on you. You are responsible for choosing a strong and unique password for all relevant accounts and for keeping your password confidential. We ask you not to share your password with anyone.
• Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained within the Platform.
• Multi-Factor Authentication. The Platform may require the use of your mobile or cell phone number for purposes of multi-factor authentication (“MFA”). To facilitate MFA, we may require that you provide a working mobile or cell phone number. Registering an account to use the Platform, and acceptance of the terms of use, expressly gives your consent that we may deliver SMS text messages to the mobile or cell phone number provided, for the purposes of performing MFA. SMS text messages may be sent as frequently as the frequency of your attempts to access your account. Message and data rates may apply.
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.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. Please contact our privacy officer in writing at the contact information noted below, with sufficient detail to enable us to identify the personal information being sought or corrected.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions may include:
• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process, if applicable.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.
We may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information. We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.
If you are concerned about our response or would like to correct the information provided, you may contact us at privacy@amicuspath.com.
Where you have provided your consent to the collection, use, and transfer or disclosure of your personal information, you have the legal right to withdraw your consent. In some cases, withdrawal of your consent may not be possible due to legal obligations or requirements. To withdraw your consent, if applicable, contact us at privacy@amicuspath.com. Please note that if you withdraw your consent, you may not be able to use certain functions within the Platform or you may not be able to access or use the Platform in its entirety.
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we may notify you through a notice on the Platform or through other means.
We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting the Platform and this privacy policy to check for any changes.
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:
Privacy Officer
privacy@amicuspath.com
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above.
If you are not satisfied with our response to a complaint, you may have options to exercise, including to raise the complaint with the relevant Privacy Commissioner:
The Office of the Information and Privacy Commissioner for British Columbia
www.oipc.bc.ca
The Office of the Information and Privacy Commissioner of Alberta
www.oipc.ab.ca
Commission d’accès à l’information du Québec
https://www.cai.gouv.qc.ca/english/
Office of the Privacy Commissioner of Canada
www.priv.gc.ca
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2024-12
