GemDevStudio — Privacy Policy

1. Introduction

GemDev/Studio ("we", "our", "us") operates the website gemdevstudio.ca (the "Site"). This Privacy Policy explains how we collect, use, store, protect, and, where applicable, disclose your personal information when you visit our Site or use our services.

We are committed to protecting your privacy in accordance with:

• The Personal Information Protection and Electronic Documents Act (PIPEDA)
• Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25)
• Any other applicable privacy legislation

By using the Site, you acknowledge that you have read, understood, and agreed to the practices described in this Policy.

2. Person Responsible for the Protection of Personal Information

In accordance with Law 25, GemDev/Studio has designated a person responsible for the protection of personal information, tasked with ensuring compliance with this Policy and applicable legislation.

Responsible person: The founder of GemDev/Studio
Email: [email protected]

Any questions, access requests, complaints, or exercise of rights may be directed to the responsible person at the email address above.

3. Information We Collect

3.1 Information You Provide Directly

• Contact form: Name, email address, and phone number.
• Discovery questionnaire: Project details, business information, and any other information you choose to submit.
• Communications: Any information you voluntarily provide via email or other means of communication.

3.2 Automatically Collected Information

• Browsing data: Browser type and version, pages visited, time spent on the Site, referring website or source.
• Device information: Device type, operating system.
• IP address: Anonymized where possible.
• Meta Pixel data: Pages visited, actions taken on the Site (e.g., form submissions), browser and device information, IP address. This data is collected only with your explicit consent (see section 4).

3.3 Information We Do Not Collect

• We do not collect precise geolocation data.
• We do not collect biometric data.
• We do not collect credit card or payment information through the Site.

4. Consent and Tracking Technologies

In accordance with Law 25 and PIPEDA, we collect and process your personal information only with your consent.

4.1 Explicit Consent — Cookies and Meta Pixel

On your first visit to the Site, a consent banner is displayed. This banner allows you to accept or decline non-essential tracking technologies, including:

• Meta Pixel (provided by Meta Platforms, Inc.): Used to measure the effectiveness of our advertising, understand how visitors use the Site, and improve our services. The Meta Pixel constitutes a profiling technology under Law 25.

Essential cookies, required for the basic operation of the Site, do not require consent and cannot be disabled.

You can modify your consent preferences at any time via the "Privacy Settings" link in the Site footer.

4.2 Explicit Consent — Forms

Your consent is obtained when you submit the contact form or the discovery questionnaire. By submitting these forms, you consent to our use of the information provided for the purposes described in section 5.

4.3 Withdrawal of Consent

You may withdraw your consent at any time:

• For cookies and Meta Pixel: Via the "Privacy Settings" link in the footer.
• For your personal data: By contacting us at [email protected].

Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

5. How We Use Your Information

We use your personal information for the following purposes:

• Respond to inquiries submitted through the contact form.
• Prepare quotes and proposals based on your discovery questionnaire responses.
• Send follow-up communications related to your inquiry (with your consent).
• Improve our Site and user experience.
• Measure the effectiveness of our advertising campaigns (with your consent, via Meta Pixel).
• Comply with our legal obligations.

We never sell, rent, or share your personal information for marketing purposes with third parties not identified in this Policy.

6. Third-Party Services and Subcontractors

The Site relies on third-party services (subcontractors) to operate. These services may process some of your data for the purposes described in section 5.

Each subcontractor operates under its own privacy policy. An up-to-date list of our subcontractors is available upon request at [email protected].

7. Profiling and Targeted Advertising

The Meta Pixel constitutes a profiling technology under Law 25. When you consent to the activation of the Meta Pixel, the collected data may be used by Meta to:

• Provide us with measurement reports on the effectiveness of our advertisements.
• Create custom audiences for targeted advertising on Facebook and Instagram.
• Perform profiling for advertising purposes.

You may at any time:

• Withdraw your consent via the "Privacy Settings" link in the Site footer.
• Disable interest-based advertising from Meta via your Facebook Ad Preferences.
• Opt out of third-party tracking via the Digital Advertising Alliance.

8. International Data Transfers

Your personal information may be transferred to and processed outside Quebec and Canada, particularly in the United States, by the subcontractors identified in section 6.

In accordance with Law 25, before transferring any personal information outside Quebec, GemDev/Studio conducts a Privacy Impact Assessment (PIA) to ensure that the information will receive adequate protection.

We ensure that our subcontractors provide appropriate contractual guarantees regarding the protection of personal information.

9. Data Storage and Security

We implement the following technical and organizational measures to protect your personal information:

• The Site is hosted on Cloudflare Pages with HTTPS/TLS encryption.
• Data submitted through forms is transmitted in an encrypted manner.
• Access to personal data is restricted to authorized GemDev/Studio personnel.
• We use industry-standard security practices.

While we implement reasonable security measures, no method of electronic transmission or storage is completely secure. We cannot guarantee the absolute security of your data.

10. Data Retention

• Contact form and communications: Retained for a maximum of two (2) years following your last communication, then deleted.
• Discovery questionnaire: Retained for a maximum of two (2) years following submission, or until the end of the project if applicable, then deleted.
• Browsing and analytics data: Retained in accordance with the retention policies of Cloudflare and Meta Platforms.
• IP addresses: Anonymized where possible and not retained beyond immediate technical needs.

11. Your Rights

Under PIPEDA and Law 25, you have the following rights regarding your personal information:

• Right of access: You may request to view the personal information we hold about you.
• Right of rectification: You may request the correction of any inaccurate or incomplete personal information.
• Right of deletion: You may request the deletion of your personal information.
• Right to withdraw consent: You may withdraw your consent to the processing of your data at any time.
• Right to portability: You may request the transfer of your data in a structured and commonly used format.
• Right to file a complaint: If you believe your rights have not been respected, you may file a complaint with the relevant authorities (see section 15).

To exercise any of these rights, contact us at [email protected]. We will respond to your request within thirty (30) days of receipt, in accordance with the time limits prescribed by law.

12. Privacy Incidents

In accordance with Law 25, in the event of a privacy incident involving your personal information (unauthorized access, unauthorized use, unauthorized disclosure, or loss), GemDev/Studio commits to:

• Taking reasonable measures to reduce the risk of harm and prevent similar incidents from recurring.
• Assessing the risk of serious harm to the individuals concerned.
• Notifying the Commission d'accès à l'information du Québec (CAI) if the incident presents a risk of serious harm.
• Notifying the individuals concerned if the incident presents a risk of serious harm, indicating the nature of the information affected, the measures taken, and the remedies available.
• Maintaining a register of privacy incidents in accordance with the law.

13. Third-Party Links

The Site may contain links to third-party websites or platforms (e.g., Instagram, LinkedIn). We are not responsible for the privacy practices of these external sites. We encourage you to review their respective privacy policies before providing them with your personal information.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, the Site, or applicable legislation. In the event of changes:

• Changes will be posted on this page with a revised "Last updated" date.
• For substantial changes affecting your rights or the nature of the data collected, a notice will be prominently displayed on the Site and renewed consent may be requested.

Continued use of the Site after changes are posted constitutes acceptance of the updated Policy.

15. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy, your personal data, or the exercise of your rights, please contact us:

GemDev/Studio
Person Responsible for the Protection of Personal Information
Email: [email protected]
Website: gemdevstudio.ca
Quebec, Canada

To file a complaint with the relevant authority:

• Commission d'accès à l'information du Québec (CAI): www.cai.gouv.qc.ca
• Office of the Privacy Commissioner of Canada: www.priv.gc.ca