Privacy Policy

- in the course of your exchanges with a Mely.ai recruiter and/or steps further to a job application for employment proposed by Mely.ai, whether initiated by you or the Mely.ai recruiter.

And aims in particular to inform:

the user about information related to the website (the “USER”, “you”, “your”, ”yours”)

candidates and potential candidates, “candidates”, “you”, “your”

with respect to the following questions:

What personal information we seek;

How we use your information, and with whom we share your personal information;

Which options are available concerning the collection, use and dissemination of information;

Types of security in place to protect your information from loss, misuse or altering of information under our control:

How to rectify inaccurate information;

For your information, this Privacy Policy solely applies to information collected by Mely.ai, resulting from:

your use of the website.

based upon your exchanges with Mely.ai recruiters, further to their initiative or yours, and whether or not it results in a formal hiring interview or job offer.

This Privacy Policy does not apply to any information collected on- or off-line by any other entity, whether related or not to Mely.ai.

In any event, Mely.ai covenants and agrees to comply with the following three core principles under all circumstances:

We shall solely and exclusively collect data strictly necessary for its intended purpose;

You always retain control over your personal information; and

Your personal information will be dealt with transparently, confidentially and securely.

This privacy policy can be broken down into four sections:

The first section deals with personal information governed by (EU) General Data Protection Regulation 2016/679 of the European Parliament and Council of 27 April 2016, adopted on 25 May 2018 (hereinafter the “GDPR”);

The second section, available in French, deals with personal information governed by the Act respecting the protection of personal information in the private sector (hereinafter the “PPIPS”) of Quebec, Canada ; (known as Bill 25, adopted on September 22, 2021;

The third section, available in English, deals with “personal information” governed by the California Consumer Privacy Act of 2018;

The fourth section, available in English, is designed to protect consumers residing in the Commonwealth of Virginia whose personal data (“personal data”) is governed by the “Virginia Consumer Data Protection Act";

If none of the above legislation applies to you, solely section 2 will apply.

SECTION 1: RULES APPLICABLE TO PERSONS CONCERNED BY PERSONAL INFORMATION GOVERNED BY THE GDPR

Article 1. Definitions

The terms mentioned below, where they appear in this Privacy Policy, shall be defined as follows:

CONTROLLER: means the entity that determines the methods and purpose of personal data processing.

OFFICER IN CHARGE OF PROTECTION OF PERSONAL INFORMATION: means the person in charge of compliance with European General Data Protection Regulation, and with the protection of personal information.

USER: means any adult person who accesses and navigates on the SITE.

CANDIDATE: means any adult person interested by employment with Mely.ai and/or any adult person with whom a recruiter initiates an exchange.

Article 2. Why do we collect your personal information? Purpose of processing.

Personal information that we collect on the Mely.ai.ca site and during exchanges or meetings serves principally to follow up on on-line requests that you have addressed to our attention.

Your personal data is collected by Mely.ai for transparent, legitimate and defined purposes in order to ensure:

Proper maintenance and upgrades of the SITE, its services and its features;

Processing and storage of data referenced by you or a recruiter during job applications;

Management of your registration in events organized by Mely.ai ;

Management of your networking and meetings;

Management of your applications for right of access, rectification and opposition, erasure, limitation, portability, and the right to introduce a claim before qualified authorities in such matters; and

Development and creation of commercial statistics.

Article 3. Identity of the controller

Your personal information is collected and processed by Mely.ai. The Officer in Charge of the Protection of Personal Information is responsible for processing data collected during the course of SITE maintenance and operation and/or further to any job application process.

For any question related to the management or use made of your personal information, please contact us by email at privacy@Mely.ai.ca or by ordinary mail addressed to 1000 St-Jacques, C-0115, Montreal, Quebec, Canada, H3C 1G7

Article 4. Collection and processing of personal data.

Where:

Users navigate and/or wish to access on-line services on the SITE, and Mely.ai receives personal information. This information is processed in accordance with the purposes stated at the time such information is collected.

CANDIDATES meet with Mely.ai recruiters and thereafter follow a trajectory of recruitment inside Mely.ai.

Information collected, used or processed by Mely.ai for the purposes described at Article 3 of this Privacy Policy include:

Identification data (name, first name, email address, telephone number, business name, position, a copy of identity card, if necessary as evidence of the exercise of a right of access, rectification or opposition or to respond to any legal obligation);

CV and information related to your professional experience, current position, academic record, diplomas and certificates;

Connection data (IP addresses, connection logs) and information collected by our Cookies (for information on data tracked by Cookies, please consult our Cookies Management Policy);

Navigation preferences (languages, countries, etc.);

Trajectory and history of navigation on our SITE;

IP address ; and

Information related to your device, your operating system or your navigator.

Mely.ai may collect personal information:

During your visit to the SITE;

At the time of your request seeking contact with Mely.ai.

Communication in person or on-line with a Mely.ai employee authorized to receive personal information, or by email.

Notwithstanding the form of data collection, Mely.ai agrees to inform you of the purposes intended for processing, the mandatory or elective nature of the responses to provide, future impacts and consequences in the event of a failure to respond by recipients of the data, the existence and means of exercise of such rights of access, rectification and opposition to data processing.

Article 5. Consent

Personal information may be collected via professional platforms or directly from you during your navigation on the SITE, during contacts with recruiters or when you complete a contact form.

Where required under current legislation, Mely.ai agrees to seek your consent and/or to allow you to oppose the use of such information for certain purposes.

Article 6. Recipients of Data

Access to your personal information is limited to:

Authorized personnel in various Mely.ai departments (authorized personnel in the recruitment and assignment departments, agents, communications, administration and IT departments),

Mely.ai subcontractors acting on behalf of Mely.ai, including the SITE host.

Your personal information will neither be disclosed nor exchanged with any person other than the aforementioned.

Article 7. Duration of storage of personal information

Mely.ai agrees that personal information collected shall be stored in a form allowing for your identification, and for a duration not to exceed the time necessary to achieve the stated purposes for which such data has been collected or processed.

However, the processing of such data is possible in order to evidence a right or a contract. Such data may also be stored for the purpose of compliance with a legal obligation or kept in files in accordance with relevant laws and regulations.

Personal identifying information of the USER is stored by Mely.ai for a duration of three (3) years commencing on the date of most recent contact with the USER.

CANDIDATE data is stored by Mely.ai for an initial period of 23 months, commencing on the date of initial contact with Mely.ai, and may be subject to an additional 24-month period, subject to consent of the CANDIDATE.

For the management of the applications to exercise the right to personal information, your personal information is stored for 1 year.

For cookies, in order to ensure maintenance and upgrades of the SITE and its features, raw visits data associated with a username is stored for a thirteen (13) month period. Beyond this lifespan, the foregoing data is deleted or anonymised. (For further details, consult our cookies management policy ).

Article 8. Your rights

Under current legislation, you are entitled to:

Access personal information in our data banks;

Require rectification of inaccurate or incomplete personal information in our possession;

Demand updating or completion of personal information in our possession;

Revoke your consent at any time; and

Demand deletion of any hyperlink that allows your identification on our site.

These rights may be exercised upon simple request via email at privacy@Mely.ai.ca, or by ordinary mail addressed to the Director of the Protection of Personal Information, 1000 St-Jacques, C-0115, Montreal, Quebec, Canada, H3C 1G7, adding your personal information and indicating your contact information (name, first name, address, and a copy of a signed identity card) and a valid purpose where required by law.

Article 9. Contact information for the Officer in Charge of the Protection of Personal Information

For any application for information concerning the policy of protection of personal information on the SITE, the exercise of your rights or to respond to your questions, you can write to the Mely.ai Officer in Charge of the Protection of Personal Information.

You can attach your request to an email forwarded to privacy@Mely.ai.ca, or by ordinary mail to the Officer in Charge of the Protection of Personal Information.

Article 10. Security

We agree to apply any and all technical and organisational solutions necessary in order to ensure security and confidentiality of your personal information.

In this regard, Mely.ai shall preserve data security and integrate guard rails to prevent damage, or access by unauthorized third parties (physical protection of premises, authentication process of our clients with access personnel and securing via confidential usernames and passwords, logbooks of connections, quantification of certain data…).

Article 11. Cookies

Our website may, from time to time, use cookies and other similar tracking devices in order to better recognize you when you return to the website. A cookie is a small text file stored on the computer of an Internet user via a web server. Cookies are used to help us to identify you when you return to the site and to adapt the information that you receive when you navigate on the website. For more information on our Cookies policy, click here.

Article 12. Privacy of children

Our website is not intended for the attention of minors.

Article 13. Links

This website may contain links to sites not affiliated with Mely.ai. Mely.ai assumes no liability for confidentiality practices of any other entities or their websites.

Article 14. Notice of changes

Mely.ai hereby reserves the right to amend this Privacy Policy at any time. Solely the current Privacy Policy as displayed on the SITE shall be deemed official and enforceable. By using the website and/or providing us with your personal information, you consent and agree to the terms and conditions of the Privacy Policy and any amendment incorporated therein by your ongoing, continuous use.

SECTION 2 - ACT RESPECTING THE PROTECTION OF PERSONAL INFORMATION IN THE PRIVATE SECTOR

This section, available in French, deals with personal information governed by the Act respecting the protection of personal information in the private sector (hereinafter the “PPIPS”) of Quebec, Canada ; (known as Bill 25, adopted on September 22, 2021;

To access this section, please refer to Section 2 of the French version of this Policy named Politique de confidentialité.

SECTION 3 - INFORMATION FOR CALIFORNIA CONSUMERS

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Mely.ai.ca and Mely.aiconsulting.com and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).

Notice at collection

Categories of personal information collected, used, sold, or shared

In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers.

We do not collect sensitive personal information.

We will not collect additional categories of personal information without notifying you.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of the website and features thereof (“business purposes”) and and for all questions related to potential recruitment . In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

How we collect information: what are the sources of the personal information we collect?

We collect directly the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Website and from conversations between You and our employees.

For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, as personal information about you is automatically observed and collected.

How we use the information we collect:

We do not disclose your personal information to third parties. For our purposes, the word “third party” means “a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration,” as defined by the CCPA.

This means that, for example, a sale can happen whenever a Website runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.

Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.

We do not sell or share your personal information with any third parties.

Your privacy rights under the California Consumer Privacy Act and how to exercise them

The right to access personal information: the right to know and to portability

You have the right to request that we disclose to you:

the categories of personal information that we collect about you;

the sources from which the personal information is collected;

the purposes for which we use your information;

to whom we disclose such information;

the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;

the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights, etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

The right to opt out of sale or share personal information and to limit the use of your sensitive personal information

You have the right to opt out of the sale or share your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. All requests to exercise your rights must be addressed in writing to the Chief Privacy Officer

C/O: Chief Privacy Officer

MELY.AI Inc.

1000 St-Jacques, C-0115, Montreal, Quebec, Canada, H3C 1G7

E-mail address: privacy@Mely.ai.ca

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;

describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain to you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

SECTION 4 - INFORMATION FOR VIRGINIA CONSUMERS

This part of the document integrates with and supplements the information contained in the rest of the Mely.ai privacy policy and is provided by the controller running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

Categories of personal data processed

In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How we use the data we collect: sharing of your personal data with third parties.

We do not share nor disclose your personal data with third parties.

For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.

Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.

We do not sell your personal data to anyone.

Processing of your personal data for targeted advertising

We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.

Correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of personal data.

Request the deletion of your personal data. You have the right to request that we delete any of your personal data.

Obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.

Opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via

. All requests to exercise your rights must be addressed in writing to the Chief Privacy Officer

C/O: Chief Privacy Officer

MELY.AI SOLUTIONS Inc.

1000 St-Jacques, C-0115, Montreal, Quebec, Canada, H3C 1G7

E-mail address: privacy@Mely.ai.ca

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a minor under your parental authority.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

This policy was last updated: September 21, 2023