Pagato Privacy Policy – Service Providers
Last updated : January 4th, 2023.
Agence Pagato inc. ("we," "us," "our", “Pagato”) 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 Pagato, through our website https://pagato.ca, through our websites optimized for mobile services and through our mobile applications (the Sites). Pagato cares about your privacy and is committed to protecting it by adhering to the Policy. This policy should be read in conjunction with our Service Provider Terms and Conditions of Use¹. By accepting the Policy, you expressly consent to the collection, use and disclosure of your personal information in accordance with this Policy. Businesses should review our Businesses Privacy Policy² and Terms and Conditions of Use³.For the purposes of the Policy, “personal information” refers to information which relates, directly or indirectly, to an identifiable individual. Any personal information collected by Pagato on the Sites is subject to this Policy. All capitalized terms not defined in the Policy are defined in our Service Provider Terms and Conditions of Use⁴.
Pagato Privacy Policy
1. Object of the policy
2. Collection of personal information
3. Use of personal information
4. Disclosure of personal information
5. Ensuring the security of your personal information
6. Cookies and other tracking technologies
7. Links to other sites and voluntary disclosure of personal information
8. Accessing, correcting and deleting your information
9. Changes to this Privacy Policy
10. Contact us
1. Object of the policy
Our main objective when we collect information about you is to offer you a secure, effective and personalized experience, provide you with services and functions that meet your needs and to personalize our service to make your experience more secure and friendlier. The information we collect about you is solely information we deem necessary to achieve this objective. This Policy describes the information that we collect from you as part of our services and what may happen to that information. Signing up as a Pagato Service Provider and providing the necessary personal information is required to access the Sites and benefit from the services provided therein. You can still opt not to provide the requested information by simply not accessing the functions or services offered on our Sites. Please read the Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your option is not to use our Sites. By accessing or using the Sites, you indicate that you understand, accept, and consent to the practices described in the Policy.
2. Collection of personal information
In order to use the features of our Sites, 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.
● When you sign up as a Service Provider, you must provide us with certain information such as your full name, date of birth, email address, home address, telephone number and password, in order to establish your membership file. Only Pagato has access to your membership file and only Pagato can disclose the information contained therein in accordance with this Policy.
● When registering as a Service Provider, you will also be asked to provide various information, such as relevant work experience you may have, your CV and any languages you speak. You may also, at your discretion, provide proof of any specific certifications you may possess (courses, attestations, etc.) In addition, you will be required to confirm your capacity to work in Canada (for example, as a Canadian citizen or permanent resident). Note that no personal information will be collected by Pagato with regards to this statement, and that any inaccurate, false or otherwise misleading statements regarding your capacity to work in Canada shall be treated according to the Service Provider Terms and Conditions of Use⁵.
● To comply with legal requirements, including without limitation anti-money laundering laws, Pagato is required to conduct a “Know your Client (KYC) procedure on all Service Providers. As part of our KYC procedure, you will be required to provide your banking information to be used for payment of all Laborer Services you provide to Businesses, and upload a government-issued ID. This information will be processed directly a third party provider selected by Pagato, and Pagato will not have access to any personal information collected for such KYC purpose. You will not be able to respond to advertisements for Laborer Services until the KYC procedure is complete.⁵ Link to Website Terms and Conditions of Use - SERVICE PROVIDERS2
● If you subscribe to a mailing list, we will collect your name and email address to send you emails about various news and promotions. Even after subscribing to a newsletter or promotional communication from us, you may elect to modify their preferences by following the “Unsubscribe” link provided in an email or communication received.
● When you visit our Sites, we may collect information about your visit through cookies and similar technologies (see our section on Cookies and other tracking technologies for more information).The Sites also contain functions allowing Service Providers to be located. These functions can track your location and are used to allow Service Providers to confirm they are at the right location to perform Laborer Services and have arrived at the agreed-upon time, and to notify Businesses that any hired Service Providers have arrived. Location functions can also be used to show Service Providers advertisements for Laborer Services near them. These functions are deactivated by default, and the necessary steps to activate such functions are detailed on the Sites. We may collect other information about you, including information you communicated to us in discussion forums, chat rooms, during dispute settlements or in correspondence you sent us. This information will be used to improve the services we provide to you. We can also collect references or ratings provided by Businesses accessing the Sites and to whom you have provided Laborer Services, which may review their experience and interactions with you. Such information is available to all Businesses who access the Sites. We shall not be responsible for the contents of these reviews, nor for ensuring their accuracy.
3. Use of personal information
We collect information about you essentially to be able to give you access to our Sites and thereby allow you to benefit from a secure, effective and personalized experience. You agree that we use such information to:
● give you access to our Sites and services, including for you to offer Laborer Services to Businesses;
● personalize and improve our services, content and advertisements;
● contact you to resolve problems affecting your account or our Sites or for other reasons authorized by law;
● contact you to inform you of our services and the services of our affiliates, send you niche marketing products and give you access to our updated services ● prevent, detect and, eventually, investigate fraud and security breaches, activities that may prove to be prohibited or illegal;
● provide you with opportunities to provide Laborer Services similar to those you have previously booked or to and
● enforce our Terms and Conditions of Use⁶ and meet legal, regulatory, insurance and processing requirements, and otherwise with your consent, or as permitted or required by law.⁶ Link to Website Terms and Conditions of Use - SERVICE PROVIDERS3
4. Disclosure of personal information
Pagato will disclose your personal information if it has legal authority to do so, such as in the following contexts:
● We may disclose or otherwise make available to Businesses any information pertaining to your status as a Service Provider, including your CV and any certification or qualification you may have provided to us.
● We may use and disclose personal information in the context of a business transaction, in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of Pagato, or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of Pagato, or our business or assets, may use and disclose your personal information for similar purposes as those described in this Policy.
● We may be asked to disclose your personal information to meet certain legal, regulatory, insurance, and audit requirements, enforce our Terms and Conditions of Use, respond to claims to the effect that some content breaches the law or the rights of a third person, including intellectual property rights or ensure everyone’s safety and security, 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). In particular, without the need for a subpoena, we are entitled to disclose your personal information, including your family name, first name, postal code, email address, telephone number (if available), your browsing history of our Sites, your IP address, and any other information that might seem relevant, in response to a formal request from a regulatory body in connection with a criminal investigation or allegedly illegal activities or any other activity that might expose Pagato to legal liability.
● We may share our data, including personal information about you, with our affiliated companies, potential partners and third-party service providers that perform services on our behalf such as insurance providers, legal counsel, data hosting, tech development, payment processing, and marketing, to the extent it is necessary for them to complete their function. To the extent that these entities may have access to your information, they are contractually bound to keep personal information confidential and use it only for the purposes for which we disclose it to them. Our affiliated companies, potential partners and third-party service providers shall follow privacy practices no less protective of all users than our practices described in the Policy. We may share your personal information with our contracted service providers that participate in our commercial activities.In addition, we can disclose your personal information if we have your consent, or as permitted by applicable privacy laws. If your personal information must be disclosed outside your jurisdiction of residence, we will do so in accordance with applicable laws, and ensure our external partners do the same. In such circumstances, governments, courts, law enforcement, or regulatory agencies of that jurisdiction may be able to obtain access to your personal information through the laws of the foreign jurisdiction. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy legislation. By using the Sites, you consent to such disclosure of your personal information outside your jurisdiction of residence.
5. Ensuring the security of your personal information
Servers located in Quebec retain and process your information. We take reasonable steps to protect the personal information in our custody or control using physical, electronic or administrative security measures that are appropriate having regard to the nature and sensitivity4of the information, including firewalls, information filtering and encryption. We use different security techniques to protect collected data against unauthorized access by Pagato’s internal and external users and we take reasonable measures to limit access to this data to authorized employees and contractors who need to know that information in order to perform, develop or improve our services, and ensure that those authorized employees and contractors are aware of their responsibilities. Please note that the safety and security of your information is also your responsibility. Your password is an essential tool to ensure the protection of your account. We advise you to create your password with a unique string of numbers, letters and unique special characters and not give it to anyone. If you give your password or your personal information to other people, be advised that you will be held liable for everything done using your account identifiers. If you lose control of your password, you could also lose, to a large extent, the control of your personal information and will have to bear the consequences of legally binding actions taken in your name. If the security or use of your password is compromised, for any reason whatsoever, please notify Pagato immediately and create a new password. Despite all our efforts to preserve the confidentiality of your personal information, we cannot guarantee the security of your personal information transmitted via the Sites, and third persons may illegally intercept information housed on our Sites or our systems’ security may otherwise be breached. In such a case, we cannot be held liable for any loss, corruption or unauthorized disclosure of information that would be beyond our reasonable control.
6. Cookies and other tracking technologies
When you browse our Sites or use our services, we automatically collect information that is sent to us via your computer, your mobile device or, more generally, whatever device you use. The information thus collected may, in particular, include your IP address, your geolocation data, as well as anonymous information collected as a result of our cookies and our web trackers such as the date and time of your visit, the pages you visit, the features you use, the referring URL you came from and which one you go to after, clickstream behavior (i.e., the pages you view, the links you click, and other actions you take in connection with our Sites), your browser type and selected language. Cookies are small text files that are stored on your computer’s hard drive and that help us analyze traffic on our Sites’ pages, personalize our services, the content on our Sites and their advertising and gauge the effectiveness of our promotional campaigns. Our service providers may also download cookies on to your computer to post advertising messages and, on our behalf or on behalf of our advertising partners, gauge the effectiveness of our advertising messages and compile anonymous data on their use by visitors to our Sites. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on a computer.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. However, in such a case, you might have problems browsing our Sites or using some of their functions.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.5Finally, when you download or use one of our mobile applications, or you access one of our mobile-optimized sites, we might receive data on your location and on your mobile device, including a unique identifier of your device. We can then use this information to provide you with services, such as advertisement, research results and other personalized content, taking your location into account. You can use the adjustment menus on most mobile devices to activate or deactivate the location services at your convenience.
7. Links to other sites and voluntary disclosure of personal information
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. Keep in mind that the voluntary disclosure of personal information to a third party, whether via the Sites or otherwise, is not covered by this Privacy Policy, so you should always be cautious about giving out your personal information. You provide this information at your own risk. At all times, we advise you to remain cautious and attentive when you are online on the Internet.
8. Accessing, correcting and deleting your information
By law, you have the right to request access to, the correction and/or a copy of the personal information we hold about you. You can post, consult and change most of your personal information by logging on to Pagato. As a general rule, we do not change your personal information manually as it is very difficult to remotely verify your identity. If your personal information changes or is incorrect, we ask that you update it. You are also allowed to withdraw your consent at any time. Unless we have your consent to do so and in accordance with applicable laws, we will only retain your information on our servers until it is no longer necessary to provide our services, to prevent fraud, for troubleshooting, to cooperate in connection with any investigation, to comply with the legal requirements prescribed by law and to fulfill any other purposes for which it was collected. Once your personal information is no longer required, we will delete or anonymize it in accordance with applicable laws. If you have doubts about whether or not we keep a file containing your personal information and you would like confirmation from us, if you want to correct or access information and are unable to do so on your own, or if you want the personal information we hold permanently deleted from our servers, please contact us at legal@pagato.ca. Note that if you request deletion of certain information or withdraw your consent to the collection of your personal 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. 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. 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.
9. Changes to this Privacy Policy
This 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 Policy, we will make reasonable efforts to notify you of this, including by posting the revised Policy on our Sites or notifying you using the email address you have provided to us. Your continued provision of personal information or use of our Sites following any changes to this Policy constitutes your acceptance of any such changes.
10. Contact us
If you have any questions or concerns about the Policy, or if you wish to make a complaint, please contact our person in charge of the protection of personal information at: legal@pagato.ca.7
