Privacy Policy

1. Introduction and Scope

This Privacy Policy (the "Policy") outlines how Intelcom Courrier Canada inc. and its affiliates (hereinafter referred to as "Intelcom | Dragonfly", "we", "our", or "us") processes your Personal Data, as defined in the Definition of “Personal Data” section below. Specifically, the purpose of this Policy is to explain how and for what purposes Intelcom | Dragonfly collects, uses, shares or otherwise processes (together “process”) your Personal Data and how we safeguard the confidentiality of your Personal Data when providing our package delivery services to our clients, when you visit our Website located at https://intelcom.ca/en/ ("Website") or when you communicate with us in person, by phone or by email regarding the delivery of a package from one of our clients, or apply for a professional opportunity with Intelcom | Dragonfly.

Please take the time to familiarize yourself with this Policy, as it describes your privacy choices and how you can contact us. If you have any questions or would like to exercise your rights under applicable privacy laws, you can contact us via the information provided in Section 14 of this Policy. By providing us with Personal Data and/or otherwise interacting with us, you understand that your Personal Data will be processed in accordance with this Policy.

This Policy is not a contract and does not create any contractual rights or obligations.

2. Definition of “Personal Data”

In this Policy, “Personal Data” generally means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, mailing address, email address, telephone number, or any other contact details. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be Personal Data.

3. Personal Data We Collect

The Personal Data we collect about you depends on the nature of your interactions with Intelcom | Dragonfly. Below is a description of the Personal Data we may collect about you.

a. Information we collect directly from you

• Contact and delivery information, including your name, delivery tracking number, and delivery address when you contact us with a question regarding your delivery.

• Other Personal Data, including any information you may provide us when contacting us, including by phone, email, in person or through our Website, or information you may be requested to provide us with from time to time.

b. Information we collect about you from our clients

• Contact information, including your name, phone number, and email address.
• Information about your delivery, including your delivery address, delivery tracking number and the Intelcom | Dragonfly client from whom you are receiving a delivery.

c. Information we collect automatically

• Information about your use of the internet, our networks, our devices, and our premises. We collect information automatically when you visit our Website using technologies such as cookies and pixels. The technical information we collect when you visit our Website includes information about the device you are using, including (as applicable) your Internet, telecom or mobile carrier and service provider, IP address, device ID, the date and time of your visit, the pages of the Website you visit, and the referring URLs you came from. See the Cookies section below for more information on how we use cookies to collect your Personal Data.

Unless we specifically request you to send us such information, we ask that you do not send us, and do not disclose, any “Special Categories of Personal data” (as defined by applicable law, but including for example information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, sex life or sexual orientation, criminal background or trade unions membership) and other sensitive Personal Data, such as social security numbers, on or through the Services or otherwise to us.

4. How and Why We Use Your Personal Data

We may use your Personal Data for general business purposes such as providing or delivering our services, managing our Website, preventing or reducing commercial risk, as well as for purposes relating to our information system or network security.

When we use your Personal Data, we require a legal justification, also known as a “legal basis”. Normally, we will rely on one or more of the following legal bases:

• Performance of a contract. This is relevant where we collect and use your Personal Data where necessary to enter into a contract with you or to perform our obligations under a contract with you.
• Legitimate interest. This is relevant where we use your Personal Data where it is necessary for our legitimate interests and our reasons for using it outweigh any prejudice to your data protection rights.
• Legal obligation. This is relevant where we use your Personal Data where necessary to comply with applicable laws.
• Consent. This is relevant where we need your consent to use your Personal Data. However, we do not usually need your consent if there is another legal basis as above. You can withdraw your consent by contacting us (see the section ‘Contact Us’ below).

We sometimes need to collect and use your Personal Data to enter into a contract with you or to perform our obligations under a contract with you, or because the law requires us to collect the Personal Data. If you do not provide certain Personal Data, we may not be able to achieve some of the purposes outlined in this Policy. We will not, however, collect or retain more Personal Data from you than we are legally allowed.

The table below contains a description of the general business purposes for which we process your Personal Data, as well as the legal bases that we rely upon for such purposes:

5. With Whom We Share Your Personal Data

Processing of your Personal Data generally will be limited to individuals who have a need to know the information for the purposes set out in this Policy. From time to time, Personal Data may also be made available to third parties. We do not share your Personal Data with third parties, except as set forth below or as required or permitted by applicable law. We may share your Personal Data with the following categories of recipients:

• Within our corporate group. Within Intelcom | Dragonfly, our employees may have access, in whole or in part, to your Personal Data on a need-to-know basis, such as to enhance operational efficiency and support workforce management.

• Service providers. We may use service providers to perform specific services on our behalf, including contractors who handle the delivery of your packages from our stations to your delivery address, as well as providers that provide us with data hosting, processing, analytics, and other similar services. As a result, these providers may process or handle your Personal Data on our behalf.

• Government, regulatory, or law enforcement third parties and entities when permitted or required by applicable law. We may disclose when necessary or appropriate to comply with applicable law or regulations, such as to respond to court order or law requiring disclosure of Personal Data.

• Business transactions. We may disclose Personal Data to facilitate or enable any corporate or commercial transaction involving Intelcom | Dragonfly to the extent permitted by applicable law.

6. Cross-border Transfers

Some of the recipients listed in Section 5 above are based outside of your country of residence, including in the United States, Europe, and Australia. Their processing of your Personal Data will therefore involve a transfer of information outside of your country of residence. Organizations based outside of your country of residence may not be subject to privacy laws that provide you with the same rights and protections as in your country of residence. As a result, when your Personal Data is used or stored in a jurisdiction other than where you are residing, 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.

Whenever we transfer your Personal Data to other countries, we ensure that the Personal Data is protected as described in this Policy and in accordance with the applicable law. For any cross-border data transfers, Intelcom | Dragonfly takes necessary (contractual) measures to ensure that your Personal Data receives an adequate level of protection.

If your country of residence is within the European Economic Area (EEA), please note that some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as the European Commission’s Standard Contractual Clauses to protect your Personal Data. The Standard Contractual Clauses are available here.

You have a right to complain to a data protection authority about our collection and use of your Personal Data. More information on your privacy rights can be found in Section 8 of this Policy. For further information about Intelcom | Dragonfly’s international data transfer practices, and to consult said (contractual) measures, please contact us using the contact details in the Contact Us section below.

7. Automated Decision Making and Profiling

We do not conduct any profiling or automated decision making.

8. Your Privacy Rights

Under privacy laws applicable in the region in which you reside, you may have the following rights with respect to your Personal Data, subject to limited exceptions set out in such laws. Moreover, please note that if your request involves Personal Data that Intelcom | Dragonfly processes or handles on behalf of our clients, we may refer you to the relevant client or share your request with them, allowing the client to respond to your request as permitted by applicable laws and Intelcom | Dragonfly’s contractual obligations.

• Right to information: You have the right to ask us about our processing of your Personal Data, including about the processing purposes and the applicable retention period.
  
  
• Right to access. You can ask us if we hold any Personal Data about you, and if so, you can request access to that Personal Data.

• Right to correction. You have the right to ask us to rectify any Personal Data that you demonstrate to be incorrect or outdated and to complete any information that you demonstrate to be incomplete.

• Right to withdraw consent. You may withdraw your consent to our processing of your Personal Data. Withdrawal of consent does not impact the lawfulness of any processing before withdrawal.

• Right to erase. You have the right to ask us to erase Personal Data in certain circumstances.

• Right to restriction. You can require certain Personal Data to be marked as restricted whilst objections and challenges to our processing activities are pending to be resolved, for the time necessary to answer such obligations and challenges.

• Right to object. You have the right to object to our processing of your Personal Data.

• Right to portability. You have a right to transmit your Personal Data to you or to another company.

• Right to complain. You have a right to lodge a complaint with the data protection authority in your country of residence if your are dissatisfied with our processing of your Personal Data.

To exercise any of your privacy rights, please contact us using the information provided in the Contact Us section below.

Please note, however, that certain Personal Data or certain use of your Personal Data may be exempt from these rights pursuant to applicable data protection laws. We may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive in particular because of its repetitive character.

9. Cookies

A cookie is a text file which is stored on your computer or device when you visit a website. They are generally used to make websites work, or work more efficiently, as well as to provide information about your use of the website, and to display content and advertising that is relevant to you.

Other technologies operate in a similar way but use different names: for example, pixels, web beacons, tags, scripts, social media plug-ins, and device fingerprinting techniques. In this Privacy Policy, we use the term “cookie” to refer to all similar technology.

We use four types of cookies on our Website that collect certain information about you by automated means: necessary, functional, analytics and advertisement cookies. Each type of cookie has a different purpose. For more information on the cookies and similar technologies we use, as well as how long each cookie will stay on your device, please refer to the Manage Cookies section at the bottom of our Website.

In general, we use cookies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes IP address, device ID, and other identifiers associated with your device, device type, device characteristics (such as operating system), the pages you visited on the Website, the date and time of your visit, the referring URLs you came from, and other information about your online activities.

With respect to analytics cookies, we use third-party analytics services on our Website, such as those of Google Analytics. To learn more about Google Analytics and how to opt out, visit: https://policies.google.com/te... and https://support.google.com/ana....

When you first enter our Website, you will see a banner that allows you to manage your cookie preference. We will not place any cookies without your prior consent, except for necessary cookies that are crucial for our Website to function. Note, however, that without certain cookies, you may not be able to use all of the features of our Website. You can change your cookie preferences at any time by clicking on the ‘MANAGE COOKIES’ icon at the bottom of our Website. You can then adjust the available sliders to ‘On’ or ‘Off’ and then click on ‘Save’, or ‘Decline All’ for automatic rejection of all non-necessary categories of cookies. You may need to refresh your page for your settings to take effect.

Alternatively, your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Find out how to manage cookies on popular browsers:

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

• Microsoft Internet Explorer

• Opera

• Apple Safari

For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

10. Minors

The Website is designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit Personal Data from children under the age of 13 through the Website. If we become aware that we have collected Personal Data from a child under the age of 13 through the Website, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with Personal Data, contact us as specified in the Contact Us section.

11. Retention

We will retain your Personal Data only for as long as necessary to fulfill the purposes for which the information was collected as outlined in this Policy. However, we may retain your Personal Data for a longer period when required to comply with our legal, contractual, or regulatory obligations regarding information or record retention, such as a 7 year retention period for tax purposes.

Our retention periods are determined by criteria including:

• The length of time we have an ongoing relationship with you and provide the services to you (for example, for as long as you have an account with us or keep using the services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

12. Security Safeguards

We protect and safeguard your Personal Data using physical, electronic and procedural measures appropriate to the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, including safeguards to protect your information against loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Specifically, we implement the following measures to protect your Personal Data, including:

• Internal policies and procedures that define the roles and responsibilities of our employees, representatives, and service providers throughout the life cycle of an item of information and limit their access to that information on a “need-to-know” basis;
• Physical, electronic and procedural safeguards that comply with relevant standards to protect Personal Data;
• If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures;
• A designated privacy officer to monitor Intelcom | Dragonfly’s compliance with applicable privacy laws;
• Procedures for receiving, investigating, and responding to complaints or inquiries about Intelcom | Dragonfly’s information handling practices; and
• Contractual protections to ensure that service providers with whom we share Personal Data maintain adequate protections and security standards.

If you have reason to believe that Personal Data has been compromised or accessed, used or disclosure unlawfully, please contact us using the information provided in the Contact Us section.

13. Updates To This Policy

This Policy is current as of the Effective Date set forth above and may be amended from time to time at our sole discretion. We recommend that you periodically review this Policy as it may be updated or revised from time to time. If we make material changes, we will take reasonable steps to notify you of those changes.

14. Contact Us

If you have any questions regarding our processing of your Personal Data or about this Policy, please contact our Privacy Officer in writing at privacy@dragonflyinternational.com.

Intelcom Courrier Canada Inc.

#200-1380 William Street

Montreal, H3C 1R5, Quebec

Canada

Email: privacy@dragonflyinternational.com

Please see details below of our further country-specific notices.

Dragonfly Shipping NL B.V.

Newtonlaan 115, 3584 BH

Utrecht, Pays-Bas

Email: privacy@dragonflyinternational.com

Dragonfly Shipping PTY Ltd.

7/33 Vulture Street, West End

QLD 4101, Australia

Email: privacy@dragonflyinternational.com

Australia

In Australia, certain additional restrictions apply – please see our Australian Privacy Policy.