Privacy Policy

Monark Privacy Policy

 

Overview
This Privacy Policy establishes rules to govern the collection, use and disclosure of personal information collected by Monark in the course of business, in compliance with applicable privacy laws including the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Information Protection Act (Alberta). This Privacy Policy also covers Monark’s efforts and activities regarding the collection, processing and storage of personal information of persons residing in the United States pursuant to applicable privacy laws, including the California Consumer Protection Act of 2018. 

This Privacy Policy applies to all individuals whose personal information Monark collects uses or discloses in the course of doing business. This includes individuals who are clients and all individuals who are contract workers, contractors, consultants to Monark, and/or those that participate in Monark’s application, surveys or assessments. It is our policy to only disclose your personal information as required or authorized by law or as otherwise set out in this policy. We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time.  

What is Personal Information?
For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual, but does not include a person’s name, title, business address or telephone number, as an employee of an organization. Where this Privacy Policy states that a list of items is “including”, the lists so described are meant to be examples and not exhaustive or exclusive. This Privacy Policy applies to all personal information that is collected, used or disclosed by Monark. 

What Personal Information Do We Collect?
Monark collects and uses only the personal information that we need for providing services and operating our business. Generally, Monark collects the personal information from individuals such as the type of information described below for the various purposes set out herein:
- name
- address
- email address (work or home)
- age
- date of birth
- comments
- employment information, including department, tenure, location, and position.

Monark collects uses and discloses personal information for the following purposes:
- To manage Monark’s business and operations.
- To meet legal and regulatory requirements.
- Inform individuals about Monark services that we believe may be of interest to them.
- To understand an individual’s interests in our services and programs.
- Deliver, develop, enhance or improve services.
- Evaluate suitability of candidates.
- Provide information on future opportunities.

- To enforce our legal relationship with you.
- As is necessary in contemplation of a business transaction.

- Using anonymized data only, to conduct academic, educational, or other non-commercial research.

We normally collect information directly from you. We may collect your information from other persons with your consent or as authorized by law.  Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent.

In addition, we also receive and send data from our servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our site, if any. We may use tracking technologies in a variety of ways, including the following: keeping count of return visits to our site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best. Finally, your Internet browser has a feature called “cookies”, which stores small amounts of data on your computer about your visit to our site. Cookies tell us nothing about who you are, however, unless you specifically give us personal information. You do not need to have cookies turned on to visit www.leadwithmonark.com or any other websites operated by us. You may also elect not to allow cookies to be collected by selecting certain options on your browser.

Consent
Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose. You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfill our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information. In the case of certain assessments and surveys, participation is anonymous and we have no ability to track individual responses or otherwise identify you. In these instances, we will not be able to withdraw your data and answers after you have submitted them. 

The purpose for collecting personal information is set out in this policy. Any necessary consents shall be obtained before personal information is collected, used or disclosed. We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button). In cases that do not involve sensitive personal information, we may rely on “opt-out” consent. 

The amount and type of personal information collected by Monark shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected, or anonymously for conducting research. Exceptions may be made with the consent of the individual or if authorized or required by law.

In certain cases, we may transfer your personal information outside of Canada, including to our service providers who may need to access, process or store your personal information in the United States. When your personal information is used or stored in a jurisdiction outside of Canada, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. 

How do I Access my Personal Information?
Upon request received by Monark in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information only in the cases where it is identifiable. In some scenarios, data is collected anonymously and therefore we will not be able to identify/access individual-level data or responses.  

Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such documentation provided shall be used for verification purposes only. 

Monark responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation. A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee. Requested information will be provided in a form that is generally understandable. Monark will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information, Monark will provide a list of organizations to which it is likely to have disclosed information. 

Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from Monark, individuals wishing to view an original record will do so at Monark’s head office and under the supervision of designated Monark personnel.

Limitations on Access
Monark will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation. In the event that Monark refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Monark will respond to your requests for access in accordance with applicable privacy legislation. 

 

Limited Use

Monark’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

How will my Personal Information be Maintained?
Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used. Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by Monark and have it amended as appropriate. Individuals seeking a correction or amendment to their personal information should direct their requests in writing to Monark.

All formal requests to amend personal information must be accompanied by appropriate supporting documentation. Monark will manage any exceptions. The amended information will be transmitted to third parties, as appropriate. If the individual is not satisfied with the results of the request, Monark shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.

How is my Personal Information Stored and Secured?
Personal information will be retained only as long as necessary and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records. Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information. 

Please note that we may use cloud-based services to store information in the following countries: Canada and the United States. Where personal information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts, law enforcement, or regulatory agencies. Monark has taken appropriate technical, organizational, and legal steps to secure this information. 

 

The protection of personal information is of paramount concern to Monark, and Monark is prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws. We will notify all required authorities without delay of a security breach affecting personal information if it creates a real risk of significant harm to individuals.

Challenging Compliance
Inquiries or complaints concerning compliance with this Privacy Policy should be addressed, in writing, to Monark. If you are not satisfied with the response after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.

Questions and Complaints
If you have a question or concern about any collection, use or disclosure of personal information by Monark, or would like to request access to your own personal information, please contact: hello@leadwithmonark.com 

‍Last Updated March 2024

 

Additional Information For Residents of California

The California Consumer Protection Act of 2018 (CCPA) sets out obligations and rights with respect to the personal information of California consumers. Monark is committed to ensuring that it complies with the requirements of the CCPA. As such, this section outlines additional information relevant only to individuals accessing our services in California. Please see the remainder of Monark’s Privacy Policy for more information on our privacy practices.

Your Rights relating to personal information

Subject to some exceptions, the CCPA provides you with the following rights:

1. The right to know: You have the right to request that Monark disclose what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information.

2. The right to opt-out: You have the right to say “no” to the sale of your personal information. Please note that Monark does not sell or trade personal information.

3. The right to delete: You have the right to request the deletion of your personal information held by Monark and by extension Monark’s service providers.

4. The right to non-discrimination: Monark is prohibited from discriminating against you in terms of price or service if you choose to exercise a privacy right under the CCPA.

Categories of personal information Monark collects

Monark has collected the following categories of personal information in the last twelve (12) months: 

 

Category

Examples

Identifiers

Full Name, Email Address

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Name, Employment

Protected classification characteristics under California or federal law

Gender

Internet or other electronic activity information

Record of user interactions, specifically and ONLY in relation to the Monark product.

Geolocation data

Timezone

Professional or employment-related information

Current or past job history or performance evaluations, Department, Job Title / Role, Years of Experience, Industry

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes.

 

Categories of personal information Monark has disclosed for business purposes

Monark does not disclose personal information for business purposes.

 

Categories of personal information Monark has sold

Monark does not sell personal information.