Privacy policy

1. About this policy

This Privacy Policy details why and how NexWav processes your personal information in connection with its staffing activities (the "Service").

This policy describes the purposes for which we collect, use, and share your personal information, and the measures we take to protect it. It also explains how we process your personal information on behalf of prospective or existing employers, for example, when we assist them in managing their recruitment process or provide them with talent management services.

Companies with whom you seek placement or who use our services to find talent may also process your personal information for other purposes. In this case, we encourage you to contact these companies directly to exercise your rights or to find out more about how your personal information is processed.

2. What is "personal information"?

For the purposes of this Policy, "Personal Information" means any information about an identifiable individual, including information that can be used alone or in combination with other information to identify, contact or locate a single individual.

In general, Personal Information does not include business contact information, such as your name, title or business contact information.

3. Types of personal data collected

Talents or future talents:

Personal identification information (surname, first name, date of birth)
Social insurance number, driver's license number
Contact information (postal addresses, personal and business e-mail addresses, telephone numbers)
Profiles on social networks (LinkedIn, Facebook)
Information on education (diplomas, studies, certifications)
Professional information (experience, position, nationality/status, emergency contacts, spouses and children)

Customers :

Last name, first name, company name

Website visitors :

IP addresses, browser information, times and duration of use

4. How do we collect your personal information?

Directly to you

NexWav collects necessary personal information primarily directly from you, for example when you submit your application via our website, participate in our selection or recruitment processes, or when you contact us with information requests. We may also collect information automatically generated by your devices during your interactions with our online services, such as IP addresses, location data, and other digital identifiers, to improve our service and personalize your experience.

With a legal basis such as your consent

NexWav's collection and processing of your personal information is generally based on your consent, except where applicable law provides another permissible legal basis, such as the need to comply with our legal obligations, or the need to manage recruitment, selection and placement processes.

Refusing collection and withdrawing your consent

You have the right to refuse the collection of your personal information and to withdraw your consent at any time, subject to applicable legal or contractual limitations and after providing us with reasonable notice. However, it is important to understand that if you choose not to provide certain personal information, this may limit our ability to provide you with our investment services. If you have any questions or requests regarding the processing of your data, please contact NexWav via the e-mail address administration@nexwav.com, as mentioned in the "Contact" section.

5. Why do we collect your information?

For specific and limited purposes

NexWav collects your personal information primarily for :

Providing the Service to facilitate staff placement, confirm successful matches, and help you find career opportunities that match your skills and aspirations;
Responding to your requests or questions, about our services or investment opportunities;
Improving our services by better understanding your needs and preferences, enabling us to offer you more personalized opportunities and services;
Administering surveys in which you agree to participate to improve our services and our understanding of the job market;
Managing interactions with potential or current employers, notably by facilitating the selection and hiring process.

To contact you

If you have consented to receive communications from us, NexWav may send you newsletters, updates about new opportunities, important announcements about services or events, and other information relevant to your career path. These communications are intended to keep you informed and to assist you in your career development.

Secondary use of your information

We may also anonymize and aggregate the personal information you provide to create statistics that help us analyze market trends, improve our services, and develop new offerings. This statistical data does not contain any personally identifiable information and may be shared with research partners or used in the development of our services.

You have the option not to receive these communications, as specified in the "Contact Us" section of this policy, or by following the instructions included in the communications you receive. NexWav is committed to respecting your preferences and providing you with easy ways to manage your consent.

6. Recipients of personal data

NexWav ensures the protection of your personal information and only shares it in strict compliance with the objectives of our staffing services, with your consent or when required by law.

6.1 NexWav employees

Our employees have access to your personal information strictly within the scope of their duties, such as processing your applications, providing customer support, or managing payroll. This access is limited to what is strictly necessary, and our employees are trained and committed to respecting the confidentiality and security of your data.

6.2 Operating partners: Zoho Recruit, Cangaroo RH, Le Contrôleur

We work with specific partners and service providers to facilitate and optimize our operations:

Zoho Recruit : Used to manage applications and monitor the recruitment process, this system helps us to efficiently manage candidates' profiles and match their skills with suitable job offers.
Cangaroo RH : This human resources management system supports the administrative management of talent, including employee records, benefits, and leave.
The Controller: Payroll partner, ensuring timely and accurate processing of our talent's remuneration.

These partners have limited access to the data required to perform their services and are subject to strict contractual commitments to ensure the protection and confidentiality of your data, by our policy and applicable regulations.

6.3 Customers

Candidates' personal information is shared with potential clients as part of the placement process, strictly when they have expressed interest in a specific offer or when their profile matches the criteria of a job opportunity.

6.4 Where required by applicable law

Your information may be disclosed in response to legal requirements, such as legal proceedings, court orders, or other governmental requests, to protect our rights and those of third parties, or to respond to emergencies that threaten public safety.

Security and confidentiality

NexWav takes stringent security measures to protect your personal information from unauthorized access, misuse, or disclosure. We are committed to working only with partners who meet our high standards of privacy and data security.

7. How long do we keep your personal information?

NexWav retains your personal information only for as long as is necessary to fulfill the purposes for which it was collected, including facilitating staff placement, managing our customer and talent relationships, and meeting our administrative and legal obligations. For these purposes, and to respect our legitimate interests as well as applicable legal, fiscal or regulatory requirements, we have established a 5-year retention period for your data.

After this period, your personal information will either be destroyed or made anonymous so that it can no longer be associated with you or used to identify you. This is to ensure that your privacy is respected and that your data is protected over time.

If you would like further information about the length of time we keep your data or our data deletion policy, please do not hesitate to contact us via the address provided in the "Contact" section. We will be happy to answer any questions you may have and to provide you with any information you may require regarding NexWav's handling of your personal information.

8. Safety measures

To protect personal data against unauthorized access, loss or destruction, our company will implement the following security measures:

Staff training on data protection and information security.
Management of access to personal data is limited to employees who need this information to perform their duties.
Use strong passwords and change them regularly.
Set up regular data backups.
Keeping software up to date with the latest security fixes.
Encryption of sensitive data, especially during storage and transmission.

9. Rights of data subjects and how to exercise them

Individuals have the right to access, rectify, delete their personal data, and withdraw their consent at any time. To exercise these rights, they can contact us by e-mail at administration@nexwav.com.

With these detailed sections, your privacy policy will be adapted to reflect your company's practices and comply with Quebec's Bill 25.

10. How do we use cookies?

NexWav uses cookies and similar technologies to improve your experience when using our online services, to understand how our services are used, and to personalize our communication with you. Cookies that are strictly necessary for the provision of our online services will be placed on your devices without requiring your consent. However, for all other types of cookies, your consent will be requested.

You can manage your consent to cookies and adjust your preferences at any time via your browser's cookie settings and your mobile device's advertising settings. Cookies, other than those strictly necessary, will be retained for a maximum period of thirteen (13) months from the time they are deposited on your devices. After this period, we will ask for your consent to use cookies again.

11. Where is your personal information stored and transferred?

Your personal information collected by NexWav may be stored and processed in locations other than your province, territory, state, or country of residence, including in Canada, and more specifically in Quebec. In addition, as part of our operations and to optimize our services, NexWav may use subcontractors or share your data with partners located in other jurisdictions. Some data is hosted on Google Drive, Zoho Recruit, Cangaroo, or Employeur D.

We take stringent measures to ensure that the transfer of your personal data abroad is carried out securely and in compliance with applicable regulations. This includes transferring data to countries recognized by the Commission de l'Accès à l'Information du Québec or by competent authorities as offering an adequate level of protection, or by implementing appropriate safeguards such as standard contractual clauses, binding corporate rules, or other adequate legal mechanisms to ensure the security of your data.

NexWav is committed to protecting your personal information and applying high-security standards, regardless of where this data is processed or stored. If you would like further information on how your data is protected during international transfers, please do not hesitate to contact us at the address given in the "Contact" section of our privacy policy.

12. Contact the DPO

If you have any questions about this privacy policy, wish to make a comment, lodge a complaint, or exercise any of your rights under applicable data protection laws, you are encouraged to contact our Data Protection Officer (DPO) as follows:

NexWav

Address: 520-275 rue du Parvis, Québec (QC), G1K 6G7.
Quebec, Canada
E-mail: administration@nexwav.com.

We will carefully consider each request or complaint and respond within a reasonable time. NexWav will take appropriate corrective action in the event of non-compliance with this Privacy Policy. It is important to note that NexWav shall not be liable for any indirect, incidental, consequential, or punitive damages arising out of the use or implementation of this policy.

In the event that you are not satisfied with our response or the way in which we manage your personal data, you have the right to lodge a complaint with your local data protection authority. In Quebec, this body is the Commission d'accès à l'information du Québec (CAI), which oversees compliance with privacy regulations.

13. Changes to the policy

NexWav regularly reviews this Privacy Policy to ensure that it remains consistent with legal requirements and our practices. Any material changes to this policy will be communicated to you by appropriate means, such as online notifications or emails, to inform you of such changes. Publication of the updated policy on our website also constitutes sufficient notification. By continuing to use our services, our website, or by providing us with your personal data after these changes, you agree to the revised terms of our Privacy Policy.

Date of last revision: March 2024