Effective date: October 25, 2023
- 1. GENERAL PRINCIPLES
- 2. DEFINITIONS AND INTERPRETATION
- 3. COLLECTION AND USE OF PERSONAL INFORMATION
- 4. SHARING OF COLLECTED PERSONAL INFORMATION
- 5. STORAGE OF PERSONAL INFORMATION
- 6. IMPLEMENTED SECURITY MEASURES
- 7. THIRD-PARTY WEBSITES
- 8. ACCESSING, CORRECTING AND DELETING PERSONAL INFORMATION
- 9. CHANGES TO THIS POLICY
- 10. CONTACTING FOLKS
1. GENERAL PRINCIPLES
- Definitions and Interpretation
- Collection and Use of Personal Information
- Sharing of Personal Information Collected
- Storage of Personal Information
- Security Measures Implemented
- Third-Party Websites
- Accessing, Correcting and Deleting Personal Information
- Contacting FOLKS
2. DEFINITIONS AND INTERPRETATION
2.1 In this Policy, the terms set forth below have the following meanings:
- Application means FOLKS’ website accessible to Clients and Users who have an account with FOLKS, available at https://folkshr.app/ or any other URL.
- Client means entities that have entered into a Software-as-a-Service agreement (SaaS agreement) with FOLKS to manage their human resources (HR) using the Services, including their respective officers, directors, employees, agents and other respective representatives with access to the Services, such as authorized administrative personnel.
- Cookies designates the small text files that are placed on the hard disk of devices as applicable when someone uses the Services or accesses the Public Website, which may either be temporary and disappear when such devices are turned off or be permanent and remain even after such devices are turned off.
- Employees means employees of a Client whose employee records are managed through the Services, as well as external consultants who may be hired by a Client and require access to the Services.
- Mobile Application means FOLKS’ mobile application compatible with various electronic devices, such as smartphones and tablets.
- Personal Information means any information about an identifiable individual which may be used to directly or indirectly identify them, including but not limited to contact information, address, e-mail address, photo or video and Internet Protocol address, as well as the information contained in the Employees’ files on the Application and the Mobile Application as may be collected by any Client.
- Public Website means FOLKS’ website available at https://folksrh.com/ or any other URL, accessible to Visitors.
- Services means FOLKS’ electronic services available via the Application and Mobile Application, including: (i) human resources information system (HRIS) solutions to optimize HR management; and (ii) job offer and application management solutions (ATS); as well as implementation assistance services for these services, both accessible, depending on the Client’s decision to obtain these solutions or not, on the Application or the Mobile Application after the conclusion of a SaaS agreement with FOLKS.
- User means the persons designated by a Client who must be able to access and use the Services offered by FOLKS to which the Client has subscribed, including the Client’s employees and external contractors.
- Visitor means any person browsing on the Public Website.
2.2 Unless the context requires otherwise: (i) grammatical variations of any term defined herein have a similar meaning; and (ii) words importing the singular number shall include the plural and words importing the masculine gender shall include the feminine and neutral genders and vice versa.
3. COLLECTION AND USE OF PERSONAL INFORMATION
In the course of providing its Services, FOLKS will collect and/or process information about the Clients. The collection of Employees’ Personal Information by the Clients will also be rendered possible on the Services’ platform(s), as described below. Finally, FOLKS will collect information about any Visitor when such Visitor accesses the Public Website or otherwise contacts FOLKS to enquire or make comments about the Services. In all cases, such Personal Information is only collected and used for the purposes detailed in this Policy and for no other purpose.
3.1 Information collected through the HRIS Service
3.1.1 Request a personalized demo
Should a new Client wish to request a personalized demo of the Services via the Public Website, the designated representative of the Client (the Super User) will be required to disclose their first and last name, profession, organization, organization address and e-mail address. Such information is required to allow FOLKS to authenticate that Super User and to contact them to provide access to a demonstration environment of the Services. The application form also includes a section where the Super User may disclose any additional information that they deem relevant.
3.1.2 Purchase of Services
In order to subscribe to the Services online, the Client must contact FOLKS via the Public Website, in which case the Super User will be required to disclose their first and last name, profession, organization, organization address, phone number and e-mail address. The Super User must also provide the first and last name, telephone number and e-mail address of the person responsible for the Client’s accounts payable, as well as a credit card number or pre-authorized debit form containing bank account details. Such information is required to allow FOLKS to authenticate the Super User, proceed with the registration process and contact the Super User in order to provide them with a password enabling them to create any account which can be used to provide the Services requested by the Client.
Once the SaaS agreement has been concluded and the Services have been purchased, the Client’s accounts must be created. During the initial configuration of the Services for each Client, FOLKS will integrate the Personal Information provided by the Client about its Employees into the Client portal, but any subsequent changes to the Personal Information available via the Services will not be made by FOLKS.
3.1.3 Creation of online accounts
User accounts will need to be created in order for the Client and its Users to use the Services.
Each Super User will have to configure the type of account needed for each User to ensure that such User be provided with the proper rights, levels and types of access to the Services, including, as applicable, the right to upload, edit, approve or delete files and edit records, or to review and consult information and records created or uploaded. As such, the access of each User to the Personal Information will be determined by the Client and its Super User, without FOLKS’ intervention.
Once this information has been configured by the Client, FOLKS will send each User an identification token which will enable the User to select a password to access the Services.
Should any User have difficulty logging in or need to reset their password, they should then contact their Super User who, if necessary, will be able to contact FOLKS and obtain technical support. Unless otherwise specified, Employee passwords will be managed directly by the User and the Super User, without FOLKS’ intervention. In both cases, the disclosure of some information will be required (e.g. full name and login name, if applicable and different) to ascertain the User’s identity and to provide them with a new token as needed.
3.1.4 Features of Services’ electronic records
Various features are available on the Services through the use of the HRIS developed by FOLKS, which will enable Clients to collect, store and access Employees’ Personal Information, all in the manner provided below:
- Employee records: In order to use this feature, Clients will first be required to create an electronic file for each Employee. As such, all Clients will be able to collect and download or upload various Personal Information regarding their Employees, including, but not limited to: the name, surname, birthday, phone numbers, e-mail, address, marital status, start date and job title, social insurance number, salary, emergency contacts and medical conditions. Each Client may configure and determine the Personal Information it collects about Employees via the Services. Any Client can then upload or keep on this file any additional information, including any other Personal Information on such Employee, including for example void cheques for payroll processing purposes, attestations or proof of particular certifications, terms and conditions of the Employee’s employment, absenteeism rate, etc. This information is added at the Client’s discretion, in accordance with the level of integration of its HR management in the HRIS.
Once created, an Employee’s record can be accessed, completed, updated and reconfigured by that Employee, or by a User to whom the Client has granted access to an Employee’s record.
- Client’s dashboard: This feature provides Clients with an overview of the HR situation within their company. Data available to the Client in this way includes: absenteeism, departures statistics, occupational health and safety statistics, training budget, employee demographics, number of disciplinary cases, work climate, etc. FOLKS does not have access to the data available on a Client’s dashboard.
The features and functions to which Users have access may vary depending on their type of account. Furthermore, some Users may, depending on their duties within the Client, have access to some sections of Employees’ records: (i) to edit any basic Employees’ Personal Information; (ii) to update information specific to an Employee’s employment; and otherwise (iii) to use the Services as required and allowed.
3.1.5 Comments, requests for information and referrals
Should any person contact FOLKS to obtain information about the Services or about any other matter, such person will then be required to provide their contact information (including name and e-mail address). This information is required by FOLKS in order to communicate with such person, determine whether the Services are available and respond to his/her enquiries, comments or requests for information. Such person may also provide additional Personal Information, including when making comments, enquiries or suggestions.
Furthermore, should any person recommend that FOLKS communicate with any other Clients’ representatives to provide them with information about the Services, FOLKS will need the contact information of that individual for the above-mentioned purpose; such communication will thereafter be made in compliance with applicable laws.
3.1.6 Invoice and expense account management
FOLKS enables Clients to integrate invoice and expense account management services for their Employees. Should such a module be selected by the Client, Employees may submit invoices and supporting documents that may contain Personal Information, which will be processed by the Client in accordance with its internal practices.
3.1.7 Client support
Should a Client or a Visitor communicate with FOLKS’ customer support, FOLKS will have access to any information communicated or otherwise disclosed, such as the contact information, as well as any question asked, or comment or statement made. In the case of a Client, FOLKS will also have access to the Client’s information accessible via the Services, which may be used to respond to the Client’s communication. FOLKS will thereafter collect the information needed to (i) categorize the communication; (ii) respond to any enquiry, comment or request for information; (iii) send any information requested, and (iv) investigate any breach of the Policy or other applicable terms and conditions. Note that as described in more detail in the Accessing, Correcting and Deleting Personal Information section, any Employee must contact their employer, i.e. the appropriate Client, and not FOLKS, if such Employee has any questions regarding a Client’s use of their Personal Information; if such Employee contacts FOLKS’ customer service, FOLKS will redirect them to the appropriate Client.
3.1.8 Marketing and social media
FOLKS may wish to provide information about its Services. In this regard, FOLKS may use the e-mail address or other contact information any person may provide from time to time to FOLKS to communicate information about new features or services or to send news and information regarding the Services. Such communications will be sent in accordance with applicable laws, and any recipient may withdraw his/her consent at any time as set in the section Accessing, Correcting and Deleting Personal Information. Note that FOLKS does not sell or share Personal Information to third parties for marketing purposes and that no marketing initiative is intended for, concerns or targets Employees.
FOLKS shares information about itself and its Services on social networks. Any person who interacts with FOLKS’ publications on social networks may have their Personal Information collected and processed. Any person should review the privacy settings applicable to such social networks and become familiar with their personal information management practices.
Should FOLKS collect information available on social networks, it shall do so on an aggregate and de-identified basis and for lawful purposes only. Note that FOLKS’ intended use of social media is not to learn, be added by or to follow Employees, but rather to learn more about its current and potential Clients.
3.1.9 Testimonials and promotional materials
Should a Client and/or any other person wish (or agree) to render any testimonial, opinion, photo or any other material available online regarding their appreciation of the Services, FOLKS may post such promotional materials on its Public Website or any other social media, and may include their name or nickname and any other information they agreed to disclose. The Client and/or such other person can thereafter request, at all times, that such materials or other Personal Information be removed from the Public Website and any other social media.
3.1.10 Job applications
FOLKS collects Personal Information that is voluntarily provided to it when any person applies for a job position via FOLKS’ Public Website. Such application is voluntary, and job applicants choose the information they wish to submit to FOLKS; these may include full name, e-mail address, phone number and CV. The Personal Information submitted will be shared only with those people in FOLKS’ organization who need the information: (i) to assess and verify job applicants’ qualifications, knowledge, skills and experience; (ii) to conduct reference and background checks and otherwise to verify the information submitted to FOLKS; (iii) to communicate with job applicants, and (iv) to improve the recruitment process. In addition to the Personal Information obtained from job applications, FOLKS may also conduct its own verification and obtain additional Personal Information.
3.2 Information collected for the ATS Service
3.2.1 Application collection
Through the ATS Service, FOLKS provides candidate management services for Client job postings. The ATS Service collects Personal information voluntarily provided when a person applies for a job through the ATS Service offered to a Client, including full name, e-mail address, phone number and CV. Each Client may configure and determine the Personal Information it collects through the ATS Service. The Personal Information submitted will be accessible to the Client, who may use it to process the application received.
3.3 Information collected using Cookies and similar technologies
When the Client uses the Services or any Visitor navigates the Public Website, certain information, including Personal Information (such as general browser information, Internet Protocol addresses, the interactions with the Services and/or Public Website and any other information described below) may be collected by automated means, such as through the following types of Cookies and other forms of technology:
- Process Cookies: allow the Services and the Public Website to work properly in keeping track of requests, ensuring the integrity of web pages and allowing the Clients and Visitors to browse from one page to the other.
- Security Cookies: are used each time Services are purchased or an account is opened. These Cookies contain an encrypted, unique identifier that is tied to each account and placed in the browser, allowing FOLKS to identify the users of the Client when they are logged in to their account.
- Statistical Cookies: collect data, such as the date and time when the Services, and/or the Public Website, were last used and the frequency of such uses, the pages or content consulted and the manner the Services and/or the Public Website were used, the information provided and the features of their operating systems and connection information (e.g. Internet Protocol address). This information is collected for analytical and statistical purposes, such as to determine how often the Services, and/or the Public Website, or certain specific pages are visited, and what kinds of features and content seem to be most interesting. This information helps FOLKS to improve its Services and/or Public Website, according to the needs and interests identified.
Other forms of technology can also be used for similar purposes. Cookies and other forms of technology can be blocked unless they are required to allow the Services and/or the Public Website to run properly. For instance, while statistical Cookies can be blocked, the situation is different for process and security Cookies, as they are essential for ensuring that the Services function properly. However, even if they cannot be blocked without affecting one’s ability to use the Services, these Cookies are of a temporary nature and accordingly, they will disappear when the browser software is closed or the device is turned off. Anyone experiencing problems with the functionalities of the Services and/or the Public Website should contact FOLKS.
Google Analytics may collect data on any Visitor’s interactions with the Public Website. This information will then be processed and updated each time the Visitor interacts with the Public Website. To do so, Google Analytics will place codes on the Public Website, which will allow Google Analytics to see what information has been consulted, as well as the browser and device used. Information collected in this way may be shared (in whole or in part) with FOLKS so that FOLKS may update, improve or otherwise optimize the Public Website, or develop new services. Please visit the site http://www.google.com/policies/privacy/partners to learn how Google Analytics uses this information.
4. SHARING OF COLLECTED PERSONAL INFORMATION
FOLKS does not sell, trade or rent Personal Information. Furthermore, Personal Information is not shared, used or disclosed to third parties for purposes other than those for which it was collected as described herein, unless required or authorized by law or unless proper consent was obtained, as applicable.
4.1 Personal Information
4.1.1 Sharing made in connection with the provisions of Services
Personal Information (other than Employees’ Personal Information) may be disclosed to FOLKS Partners that facilitate the provision of any Service, such as by providing assistance to FOLKS with respect to the maintenance and development of its Services, including providing software development, data hosting and back-up, billing and subscription management and marketing. Disclosure will be made on a “need-to-know” basis, and after ensuring that proper contractual and other measures are in place to ensure the protection of the shared Personal Information.
4.1.2 Business transaction
Some Personal Information may be rendered accessible to a potential purchaser or other business in connection with any business transaction or corporate reorganization, if such communication is necessary for the purposes of deciding whether to proceed with the sale or other transaction, and provided that such disclosure is made in full compliance with applicable laws and in absence of specific requirement with this Policy.
4.1.3 Law enforcement
Personal Information may be used and disclosed if FOLKS, acting reasonably, believes that such use or disclosure is necessary to comply with any applicable laws, legal process or governmental request, or is otherwise required to protect its rights or to fulfil any other purpose set forth in the applicable law allowing or requiring the disclosure of Personal Information.
4.1.4 Client Partners
At the Client’s request, FOLKS may from time to time interact with external third parties in order to integrate the Services with other services offered by such third parties for the benefit of the Client. In such cases, it may be necessary to communicate Personal Information to such third parties. FOLKS will only make such disclosures at the express request of a Client, and the treatment of Personal Information disclosed in such manner will be subject to the privacy policies and practices of the Client’s third party partner.
5. STORAGE OF PERSONAL INFORMATION
Subject to applicable laws, FOLKS shall retain and store Personal Information for use and disclosure consistent with this Policy, as long as necessary for the purposes detailed herein. FOLKS will store Personal Information of a Client and its Employees until 30 days after the end of the business relationship between FOLKS and the Client. To that end, FOLKS may retain and store Personal Information after the specific purposes for which it was collected have been fulfilled if reasonably necessary: (i) to comply with applicable laws or to prevent any contravention; (ii) to resolve disputes; and (iii) to enforce this Policy. Once no longer required, the information will be erased.
FOLKS is a Quebec company, and operates in Quebec, using servers and infrastructure located in Quebec. However, to enable FOLKS to provide its Services, FOLKS may do business with third-party service providers who may themselves be located outside Quebec. As such, any processing of personal information by such a service provider may take place in another Canadian province and in the United States, for the purposes detailed in this Policy. Please note that privacy laws in these jurisdictions may differ from Canadian and Quebec privacy laws. The reasonable measures, contractual or otherwise, that FOLKS may take to protect your personal information while it is being processed or handled by these service providers are subject to applicable foreign legal requirements, including lawful requirements to disclose personal information to government and law enforcement authorities in certain circumstances. By providing your personal information in connection with the Services offered by FOLKS, you consent to such transfer and hosting.
If you would like more information about FOLKS’ policies and practices regarding the transfer and processing of personal information outside Quebec and/or Canada, please contact FOLKS’ Data Privacy Officer in one of the ways described in the Contacting FOLKS section of this Policy.
6. IMPLEMENTED SECURITY MEASURES
6.1 FOLKS uses measures that may be reasonably required to preserve the security and privacy of Personal Information. In this regard, FOLKS has notably put in place or currently implements the following measures:
6.1.1 Client Website Access: Measures are taken to ensure that each FOLKS Client can only access data relating to themselves and their authorized Users, and cannot access data relating to other Clients.
6.1.2 Securing data in transit: Each time the Services are accessed (via the Application or the Mobile Application), an HTTPS protocol is used to transit information from servers to mobile devices. Also, every time the Public Website is consulted, Secure Sockets Layer (SSL) technology protects Personal Information by using server authentication and data encryption. No Personal Information will be communicated prior to such technology being activated, which can be confirmed by looking (i) at the address bar which will, depending on the browser, have a lock to the left of the website address (URL), and (ii) at the URL or the address bar of the browser, where the first characters of the address in that line should change from “http” to “https”.
6.1.3 Securing data at rest: Personal Information is encrypted by Amazon Web Services when at rest. Employees’ Personal Information is also encrypted by FOLKS when at rest.
6.1.4 Role-based security measures: The Services allow for the creation of various types of roles and permissions each of which have their own access limitations and restrictions. This offers reliable means to ensure that the different Users of a Client only access, review, process, share, edit, etc. the information they are entitled to access, review, process, edit, share, etc.
6.1.5 Limited access: Access to any Personal Information is granted to FOLKS’ employees, representatives and, as applicable, sub-contractors (collectively, the Authorized Persons) on a “need-to-know” basis only, and is given through access credentials which are kept confidential. All authorized Persons are made aware of the security measures to be taken to protect the Personal Information.
6.1.6 Secured datacenters: FOLKS’ platform and servers are located in Canada. Furthermore, cloud providers used by FOLKS employ various measures to protect the Personal Information they host.
6.1.7 Firewall: FOLKS’ platform and servers are hosted by cloud providers which use an Internet Protocol-based firewall to control who can connect to these datacenters.
6.2 Despite the foregoing, the Client and any other person shall be aware of the following:
6.2.1 GENERAL CONSIDERATIONS: EVEN IF FOLKS USES TECHNOLOGIES, WHICH ARE OF MERCHANTABLE QUALITY SUITABLE FOR THE PROVISIONS OF SERVICES, ANY ELECTRONIC PLATFORMS AND SERVERS – AS WITH ANY OTHER FORM OF FILE – ARE NOT INFALLIBLE AND FULLY SHELTERED FROM UNFORESEEABLE OR FORCE MAJEURE EVENTS, CYBERATTACKS OR UNAUTHORIZED USES AND ACCESS, AND ANY CLIENT AND ANY OTHER PERSON SHALL BE AWARE THAT THERE IS A RISK IN TRANSMITTING ANY DATA ELECTRONICALLY. THIS RISK IS INHERENT TO ALL ELECTRONIC DEALINGS, AS WELL AS TO ALL OTHER FORMS OF COMMUNICATION. CONSEQUENTLY, FOLKS CANNOT GUARANTEE THAT INFORMATION WILL NEVER BE INTERCEPTED OR VIEWED OR SUBJECT TO OTHER INCIDENTS. SUCH EVENTS MAY OCCUR, PURSUANT TO WHICH DEVICES OR SYSTEMS CAN BE ACCESSED OR CONTROLLED BY UNAUTHORIZED PERSONS, AND UNDESIRABLE COMMUNICATIONS AND INVITATIONS MAY BE RECEIVED. SHOULD THE CLIENT OR ANY PERSON RECEIVE A COMMUNICATION THAT LOOKS LIKE IT IS FROM FOLKS ASKING FOR PERSONAL INFORMATION, THE CLIENT OR SUCH PERSON SHALL AVOID RESPONDING TO SUCH COMMUNICATION. FOLKS WILL NEVER REQUEST FINANCIAL AND OTHER SENSITIVE INFORMATION THAT WAY. IF THE CLIENT OR ANY PERSON HAVE COMMUNICATED PERSONAL INFORMATION IN RESPONSE TO A SUSPICIOUS E-MAIL, POP-UP OR PHONY WEBSITE CLAIMING TO BE AFFILIATED WITH FOLKS OR IF ANY OF THE FOREGOING EVENTS TAKES PLACE, PLEASE CONTACT FOLKS IMMEDIATELY.
6.2.2 Measures to be implemented: The Clients acknowledge and agree in their name and on behalf of their respective users that said Authorized Users and their respective users are responsible for implementing and strictly adhering to all physical, electronic, technological, organizational, contractual and other security measures, processes and safeguards to ensure that the confidentiality of the files and information they sent or received is preserved. In this regard, the Clients shall notably ensure that their respective Users: (i) choose strong account passwords meeting platform’s minimal criteria; (ii) change their passwords regularly; (iii) maintain the security and confidentiality of their usernames/personal identification numbers; and (iv) carefully consider enabling the two-factor authentication process, by which an e-mail validation code is required in addition to the password to connect to the Services.
7. THIRD-PARTY WEBSITES
8. ACCESSING, CORRECTING AND DELETING PERSONAL INFORMATION
8.1 Requests from the Client
In accordance with applicable laws, any Client may access or correct Personal Information collected as part of the Services directly on the Application or the Mobile Application. With respect to Personal Information collected by FOLKS for billing, business relationship maintenance, advertising or other purposes, any Client may make requests for access or correction. The Super User and any other User may also update or change the basic information available on their user account by editing their account profile. In order to do so, they will need to log-in to their account (via the Application or Mobile Application) and enter the profile section. Some Client user accounts are also attributed the right to delete any information uploaded, received, saved or stored on their accounts.
Furthermore, any Super User is responsible for ensuring that the account of any other user who left the Client’s business or otherwise stopped being employed by the Client is shut down. Each Client is responsible for ensuring that all measures as may be required, including removing access to that account, be implemented by its Super User. FOLKS does not access the Client’s User accounts and Personal Information to which the Client has access without having received a prior express request to that effect from the Client.
Following the termination of a SaaS agreement with any Client, FOLKS will shut down all accounts of the Client and all the information stored on these accounts will then be permanently deleted following a reasonable transition period provided for in the agreement between FOLKS and the Client. In this regard and as required, the Client is responsible for ensuring that proper copies of Employees’ Personal Information (and any other information as applicable) be saved.
In some cases, applicable laws may require FOLKS to deny a Client access to some or all of the Personal Information FOLKS holds about them, or which FOLKS may have destroyed, erased or made anonymous in accordance with its legal record-keeping obligations and best privacy practices. If FOLKS is unable to provide a Client with access to any personal information, FOLKS will inform them of the reasons, subject to any legal or regulatory restrictions. Such restrictions may include, for example, references to information regarding another person that would reveal their personal information or confidential commercial information, or information that is difficult and prohibitively expensive to obtain.
8.2 Employee and candidate requests
Employees of a Client have access to their own record via their user account, and may consult their own Personal Information. In the event that a former Employee of a Client who no longer has access to their account wishes to access their Personal Information, they should contact the Client directly, who will be responsible for processing the access request in accordance with applicable laws. If an Employee contacts FOLKS, FOLKS will redirect the Employee to the Client.
Similarly, in the event that a Client uses the ATS Service to collect applications for a position, any candidate wishing to consult or have deleted their collected Personal Information shall contact the Client. If a candidate contacts FOLKS, FOLKS will redirect the candidate to the Client.
8.3 Withdrawal of consent
FOLKS may communicate with the Client or with any Visitor for promotional and marketing purposes. FOLKS will generally use the same means of communication the Client or such Visitor chose to contact FOLKS or the preferred means specified by the Authorized User or that Visitor. Should any recipient wish to be removed from one or more of FOLKS’ promotional mailing lists, such recipient should click on the ready-to-use “unsubscribe” mechanism provided at the bottom of each e-mail or simply reply to that e-mail with the word “STOP” or “Unsubscribe”.
9. CHANGES TO THIS POLICY
FOLKS reserves the right to change or modify this Policy from time to time. Any material change will be notified prior to the change taking effect via a web banner or by any other means. Thereafter, the Policy as updated will be made available and easily accessible. Furthermore, an updated version of this Policy will be published each time a minor change is made. Anyone may determine whether this Policy has changed by looking at the effective date appearing at the top of said Policy. FOLKS recommends that this Policy be reviewed periodically in order to assess FOLKS’ current practices, as the continued use of the Services and/or Public Website shall constitute acceptance of any amendment thereto. Should the Client or any other person, as applicable, disagree with the amendments made to this Policy or other applicable terms and conditions, the Client or such person shall immediately stop accessing or using the Services and/or Public Website.
10. CONTACTING FOLKS
All questions and comments regarding this Policy or requests made in furtherance of said policy should be directed to FOLKS’ Data Privacy Officer at the following contact information:
Data Privacy Officer
7065 Boul. Henri-Bourassa
Quebec, G1H 3E2, Canada
Requests and demands made will be dealt with as soon as possible.