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Privacy Policy

Controller of the processing of your personal data (hereafter: “the City”):

Name and legal form: The Corporation of the City of Guelph

Registered office address: Guelph City Hall

1 Carden Street, Guelph, ON

Contact e-mail address: privacy@guelph.ca

Processor on behalf of the City, and Controller for the processing activities mentioned under 3.3

(hereafter: “Go Vocal”):

Name and legal form: Go Vocal Inc.

Registered office address: 2093 Philadelphia Pike #1527, Claymont, DE 19703

Contact e-mail address: support@govocal.com

Hereafter jointly referred to as “the Platform”.

The Platform respects your privacy and strives to always treat your personal data with the necessary care and confidentiality. The Platform commits itself to comply with the General Data Protection Regulation (“GDPR”) and any other applicable regulations.

Please find all relevant details below. Via the mentioned contact details, you can always reach the Platform for further questions or comments regarding the processing of your Personal Data.

1. SCOPE OF APPLICATION

This ‘Privacy Policy’ applies to the processing of your Personal Data through the Platform.

2. WHAT ARE PERSONAL DATA?

In this Privacy Policy, Personal Data refers to information that makes it possible to identify you. An identifiable person is someone who can be identified, either directly or indirectly, in particular by referring to an identification number or to one or more factors that are linked to physical, physiological, mental, economic, cultural or social identity. A typical example of Personal Data is your name and email address.

3. WHAT PERSONAL DATA DO WE COLLECT?

The Platform collects your Personal Data from the following three sources:

3.1. Personal Data that you provide during the registration process on the Platform, some of which are optional.

The Personal Data that the Platform collects from you during registration are:

  • Name
  • Email address
  • Year of birth (optional)
  • Gender (optional)
  • Postal code (optional)

This list can be extended on request of the City.

If you choose to sign in via a third party authentication provider such as Google Accounts, Facebook, they will provide us with the aforementioned Personal Data. The same applies if you choose to verify your identity with a third party identity provider as COW, FranceConnect or CSAM.

3.2. Personal Data that you provide when taking participative action on the Platform. Every action you take on the Platform (voting, posting an idea, writing a comment, answering a poll,…) constitutes Personal Data and is registered and stored. Such Personal Data is also linked to your registration data (3.1), implying that the City can link your platform profile to this participation data.

3.3. Personal Data that Go Vocal collects when you visit the Platform. Go Vocal (and third party processors acting on our behalf) collect information about the usage of the Platform for assessing the proper functioning and security of the platform. To this end, Go Vocal collects technical information that can identify you, such as your IP address and browser details.

We also gather usage data to improve our services.

The processing activities mentioned above are based on the legitimate interests of Go Vocal.

4. HOW DO WE USE PERSONAL DATA?

The Platform uses your Personal Data for the following purposes:

• First and foremost, to communicate your input to the City with relevant context, and to draw aggregated reports of all the data collected on this Platform to assist their decision-making.

• To create and maintain your user profile on the Platform.

• To manage the identification and authentication of users.

• To provide information about your community and/or alert you when activities on the Platform may interest you. You can opt-out of user emails from your user profile at any time.

• To improve the Platform and to monitor its functionalities.

The Personal Data is only stored and processed for the period required for the purpose of the processing. After that, the Personal Data will be deleted or anonymized.

5. WITH WHOM AND WHERE DO WE SHARE YOUR PERSONAL DATA?

Go Vocal shares your Personal Data with the City on behalf of which Go Vocal processes such Personal Data.

Where necessary the Platform engages external service providers who process Personal Data on its behalf, i.e. (sub-)processors. The Platform will only share your Personal Data with these external service providers to the extent necessary for the relevant purpose. The Personal Data may not be used for any other purposes by these third parties. In addition, these service providers are contractually bound to ensure the confidentiality of your Personal Data by means of a so-called “data processing agreement” concluded with these parties.

The Platform will never sell or rent your Personal Data to other service providers, nor will it share your Personal Data with any service provider that is not compliant with the GDPR.

Should the Platform, for limited and specific processing activities, rely on service providers that operate from outside the EEA, data transfers will only occur to countries from which the European Commission has confirmed that they guarantee an adequate level of protection for your Personal Data, or where other measures have been taken to ensure the lawful processing of your Personal Data in these third countries.

6. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

6.1. Right of access

You have the right to view your Personal Data at any time as well as the right to be informed of the use that the Platform makes of your Personal Data. You may also request a copy of the Personal Data that is being processed.

6.2. Right to rectification,

You have the right to obtain the rectification of inaccurate Personal Data that concerns you.

6.3. Right to erasure

You have the right to ask the Platform to delete your Personal Data. It is however possible that it is still necessary to process your Personal Data. When the Platform deletes your Personal Data, it may nonetheless retain a limited amount of Personal Data to ensure it can fulfill its obligations under the GDPR.

You acknowledge that a request for the erasure of Personal Data means that certain services may no longer be delivered.

If you choose to remove your account from the Platform, the Personal Data that was collected about you will be removed from our servers. Some Personal Data about you may remain in the logging data the Platform keeps for security and legal reasons for up to 30 days.

6.4. Right to object

You have the right to object to the processing of your Personal Data for serious and legitimate reasons. In addition, you always have the right to object to the use of your Personal Data for direct marketing purposes; in such cases, you do not have to state reasons.

6.5. Right to restriction of the processing

You can exercise your right to restrict the processing, if you believe that we process your Personal Data unlawfully. You can also request us to restrict the processing if you believe we process inaccurate Personal Data about you, for the period needed to verify the accuracy of your Personal Data. The same applies when you exercise your right to objection to the processing of your Personal Data. In this case you can restrict the processing for the time needed to verify our legitimate grounds to process your data.

6.6. Right to data portability

You have the right to obtain the Personal Data you have provided to the Platform in a structured, typical and machine-readable form and/or have such transferred to different controllers.

6.7. Right to withdraw consent

Insofar the processing is based on your prior consent, you have the right to withdraw your approval.

6.8. Automated decision-making and profiling

The processing of your Personal Data does not include profiling and shall also not be subjected by Go Vocal to automated decision-making.

6.9. Right to lodge a complaint

You also have the right to lodge a complaint with a competent supervisory authority in the field of data protection. Hereunder we refer to the contact details of the Belgian Data Protection Authority. However, you can also lodge a complaint with the national supervisory authority of the EEA state where you have your habitual residence or place of work, or where the potential infringement occurred. For further information and the contact details of the supervisory authority of each EEA state, we refer to this web page of the European Data Protection Board.

Belgian Data Protection Authority

Drukpersstraat 35

1000 Brussels

Belgium

+32 (0)2 274 48 00

contact@apd-gba.be

Website DPA - file a complaint

Finally, you also have the option to file a legal claim against the City or against Go Vocal with the competent court in the EEA state where you have your habitual residence.

7. HOW TO EXERCISE YOUR RIGHTS?

You can exercise your rights by contacting either:

• the City, by e-mail at privacy@guelph.ca, or by post to The City of Guelph, 1 Carden Street, Guelph, Ontario N1H 3A1, provided you enclose a copy of the front of your identity card; or

• Go Vocal, by e-mail to support@govocal.com, or by post to Pachecolaan 34, 1000 Brussels, Belgium or by using the “Contact us” form on the Platform, provided you enclose a copy of the front of your identity card.

When you submit a request to exercise your rights, we will verify your identity if we have reasonable doubts in this regard. We do so to prevent your Personal Data from falling into the wrong hands. If we have doubts about your identity, we will request you to provide us with documents that enable you to identify yourself without a reasonable doubt, such as a copy of your identity card. In this case we urge you to cross out the non-relevant information for the verification of your identity, such as your national citizen number and photo.

Exercising your rights is in principle free of charge. However, if your request appears to be manifestly unfounded or excessive (in particular because of its repetitive character), we may charge you a reasonable fee to charge our own administrative costs. In such cases, we may also simply opt to reject your request. In this event, you will be notified of the reasons for such decision.

8. ADDITIONAL INFORMATION ON DATA COLLECTION AND PROCESSING

8.1. Legal procedures

Go Vocal and the City for whom we process your Personal Data may use the Personal Data for legal purposes, for the court or legal proceedings preceding phases in the event of unlawful use of this Application or the related services. You are aware that Go Vocal and the City it works with may be obliged to disclose the Personal Data at the request of competent government institutions for the processing of the Personal Data. The legal basis for this processing is the acceptance of the terms and conditions (contractual basis) and the necessity to fulfil a legal obligation.

8.2. Security Measures

The Platform has developed appropriate technological and organizational measures to prevent the destruction, loss, falsification, modification, prohibited access or the erroneous disclosure to third parties of Personal Data as well as any other prohibited processing of this Personal Data . Under no circumstances can the Platform be held liable for any direct or indirect loss resulting from the incorrect or unlawful use of your Personal Data by a third party. You must at all times comply with the security instructions, including by preventing all prohibited access to your login details and password. You are solely responsible for the use made of the Platform on your computer, IP-address and your identification details, as well as for the confidentiality of such.

8.3. Changes to this privacy policy

The Platform reserves the right to change this privacy policy at any time by notifying the users on this page. We encourage you to check this page for possible changes. The date of the last change is indicated at the bottom of the page. If you object to any change in the policy, you must cease to use the Platform.

Unless otherwise indicated, the valid Privacy Policy applicable at that time applies to all Personal Data that the Platform processes.