Last Update: September 21, 2023
This privacy statement explains what personal information we gather about you, what we use that information for, and who we give that information to. It also sets out your rights in relation to your personal information and who you can contact for more information or queries.
Who this privacy statement applies to and what it covers
This privacy statement applies to 10644951 Canada Inc. dba Koula, a Canadian company having its registered address at 808-1055 Rue Lucien-L’Allier, Montréal, Québec H3G 3C4 Canada, and our affiliates and related entities (“Koula”, “we”, “us” or “our”).
We are committed to protecting your privacy and handling your personal information in an open and transparent manner.
This privacy statement sets out how we will access, collect, use, store, transfer, retain and protect (collectively referred to as “process”) personal information about you when:
- providing services to you or our customers
- you use “our Website” or
- performing any other activities that form part of the operation of our business.
When we refer to “our Website” or “this Website” or “Site” in this policy, we mean the specific webpages of Koula.com.
This privacy statement also contains information about when we share your personal information with other third parties (for example, our service providers).
This privacy statement should be read in conjunction with any additional privacy statements or notices available or provided to you by us at or before the time you provide us with your personal information. For example, you may be required to agree to a recruitment privacy statement before submitting an application to Koula career.
About other areas of Koula.com
Please note that other websites that may be linked to this Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of these other websites before disclosing any personal information.
What information we collect
We strive to limit the amount of personal information we collect to that necessary and appropriate for the above purposes.
In the course of providing services to you, or our customers and performing due diligence checks in connection with our services (or discussing possible services we might provide), we will collect or obtain personal information about you. We may also collect personal information from you when you use this Website or through digital interactions with you.
We may collect or obtain such personal information because you give it to us (for example in a form on our Website), because other people give that personal information to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.
We may also collect or obtain personal information from you because we observe or infer that personal information about you from the way you interact with us or others. For example, to improve your experience:
- with Koula’s services, we may consider the strength and frequency of, and feedback through our interactions; or
The personal information that we collect or obtain varies depending on the purpose for processing that personal information and may include, but is not limited to: your name; age; date of birth; email address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); employment and education details (for example, the organization you work for, your job title and your education details); your postings on any blogs, forums, wikis and any other social media applications and services that we provide; your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.
The personal information we collect may also include so called ‘sensitive’ or ‘special categories’ of personal information, such as details about your: gender; dietary requirements (for example, where Koula would like to provide you with lunch during a meeting); family circumstances (for example, your marital status and dependants); financial and tax-related information (for example your income and tax residency); health (for example, so that we can make reasonable accommodations for you in our buildings, products and services) and sexual orientation (for example if you provide us with details of your spouse or partner).
The types of personal information and sensitive personal information that we collect may vary depending on the legal requirements imposed on us, the nature of the services that we provide to you or our customer, or how you use our Website.
Where we are provided with personal information about you, we take steps to ensure that the entity providing such information (“Transferor”) has complied with the privacy laws and regulations relevant to your data. This may include, for example, that the Transferor has provided you with notice of the collection (and other matters) and has obtained any necessary consent for us to process that personal information as described in this privacy statement.
We understand the importance of protecting children's privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally process information about children.
How we use personal information about you
Use of personal information to provide services to our customers
We will use your personal information to provide you or our customer with services. As part of this, we may use your personal information in the course of correspondence relating to the services. Such correspondence may be with you, our customer and any third parties they appoint to work with us to provide the services, our service providers or competent authorities. We may also use your personal information to conduct due diligence checks relating to the services.
Because we provide a wide range of services to our customers, the way we use personal information in relation to our services also varies. For example, we might use personal information:
- about a customer’s employees and customers while implementing new customer relationship management systems
Use of personal information for other activities that form part of the operation of our business
We may also use your personal information for the purposes of, or in connection with:
- applicable legal or regulatory requirements
- requests and communications from competent authorities
- customer account opening and other administrative purposes
- financial accounting, invoicing and risk analysis purposes
- customer relationship purposes, which may involve: (i) sending you thought leadership or details of our products and services that we think might be of interest to you; (ii) contacting you to receive feedback on services; (iii) contacting you for other market or research purposes; or (iv) managing our own customer relationship management processes;
- business development purposes (for example, testimonials from a customer’s employees may be used as part of our business development materials with that employee’s permission)
- recruitment purposes for prospective Koula employees, partners and contractors, as well as to manage the employment, partnership and contractor relationship
- services we receive from our professional advisors, such as lawyers, accountants and consultants
- data analytics to better understand your interactions with us
- protecting our rights and those of our customers and our service providers
Use of personal information collected via our Website
In addition to the purposes connected to the operation of our business above, we may also use your personal information collected via our Website:
- to manage and improve our Website
- to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information about our products and services that may be of interest to you
- to manage and respond to any request you submit through our Website.
The legal grounds we use for processing personal information
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal information.
As a result, we use your personal information for the purposes outlined above because: (a) of our legitimate interests in the effective delivery of our services to you or our customer; (b) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests; (c) of the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; (d) the information is required in order to provide our services to you or our customer; (e) because you have consented to such use of your personal information; (f) because you have voluntarily provided us with your personal information for a specific purpose (i.e., to receive thought leadership from us); or (g) you have made that data public.
To the extent that we process any sensitive personal information relating to you for any of the purposes outlined in the “How we use your personal information” section above, we will do so because: (a) you have given us your explicit consent to process that personal information; (b) we are required by law to process that personal information in order to ensure we meet any legal obligations imposed on us; (c) the processing is necessary to carry out our obligations under employment, social security, social protection or other similar law; or (d) the processing is necessary for the establishment, exercise or defence of legal claims.
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or email firstname.lastname@example.org.
Who we disclose your personal information to
In connection with one or more of the purposes outlined in the “How we use your personal information” section above, we may disclose your personal information to: (a) third parties that provide services to us; (b) competent authorities (including courts and authorities regulating us); (c) your employer and/or their advisers; (d) your advisers; (e) credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud, and other third parties that reasonably require access to personal information relating to you for one or more of the purposes outlined in the “How we use your personal information” section above.
Our Website may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We are not responsible for the personal information processing activities of the Social Media Applications, and subsequently any use, misuse, or misappropriation of any personal information or other information that you contribute to any Social Media Application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.
Please note that we and some of the recipients of your personal information referenced in this privacy statement may process your data in any province within Canada or in countries outside of Canada altogether. In some cases, data processing activities may take place where local laws may not provide the same level of data protection that exist in your local geography. We will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations.
Further details of the transfers described above, and the adequate safeguards used by Koula in respect of such transfers are also available from us by contacting email@example.com.
We may also need to disclose your personal information if required to do so by law, a regulator or during legal proceedings. Your personal information may also be shared as the result of any mergers with, acquisitions or divestitures of any part of our business with another organization.
We may share non-personal, de-identified or aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date.
These measures include, but are not limited to:
- education and training to relevant staff to ensure they are aware of our privacy obligations when processing personal information
- administrative and technical controls to restrict access to personal information on a ‘need to know’ basis
- technological security measures, including firewalls, multifactor authentication, encryption and antivirus software
- physical security measures, such as staff security codes to access our premises
- an appointed Privacy Team to oversee privacy matters for Koula
Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by email) is never completely secure. We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.
How long we keep your personal information for
We will hold your personal information on our systems for the longest of the following periods: (a) as long as is necessary for the relevant activity or services; (b) any retention period that is required by law or professional standards; (c) the end of the period in which litigation or investigations might arise in respect of the services or (d) as directed by Koula’s own internal retention policies or practices, the length of which may vary depending on the nature of the information that is held. Further, any copies of personal information stored in our electronic backups will be destroyed in accordance with that backup’s ordinary lifecycle.
You have various rights in relation to your personal information. The rights afforded to you may vary depending on your geographic location and the applicable laws governing how we process your personal information. To the extent prescribed by applicable law, you may have a right to:
- obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you
- request certain information about how we process your personal information
- ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
- ask that we delete certain personal information that we hold about you, or restrict the way in which we use such personal information
- ask that we de-index or cease disseminating certain personal information that may be included in our websites
- withdraw consent to our processing of your personal information (to the extent such processing is based on consent)
To exercise any of your rights, or if you have any other questions about how we process your personal information, please email firstname.lastname@example.org or write to us at the address below:
Attn: Privacy Team
808-1055 Lucien L’Allier
Montreal, QC H3G 3C4
You may also use the Privacy Team contact details if you wish to make a complaint to us relating to your privacy.
Where we are provided with personal information about you by our customer or our third parties, we encourage you to contact that customer or third party directly (i.e., your employer or service provider) if you have questions about how they manage your personal information.
Right to complain
If you are unhappy with the way we have processed your personal information or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
Privacy laws are rapidly evolving and, as a result, we may change this privacy statement from time to time in our full discretion without any prior notice or liability to you or any other person. Our processing of your personal information will be governed by the version of this privacy statement in effect at that time. The new modified or amended privacy statement will apply from the revision date at the top of this page. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.