1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. By logging into the Concordia Student Union Clubs Portal you consent to our use of cookies.

1.4 In this policy, "we", "us" and "our" refer to 13928501 Canada Inc (“Ruby Development”). For more information about us, see Section 8. The website covered by this policy is the following: https://portal.csu.qc.ca/

1.5 In this policy, your "Organization" refers to the Concordia Student Union (“CSU“).

2. How we use your personal data

2.1 In this Section 2 we have set out:

general information on how we collect information on this website;
the type of personal data that we may process;
in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
the purposes for which we may process personal data; and
the legal bases of the processing.

2.2 The personal information we collect can be divided into two main categories: information you give to your Organization, the Concordia Student Union, and information we collect automatically. As Ruby Development does not store or manage personal information you provide, please defer to your student union for their policy on handling your data.

2.2.1 Information You Give to Your Organization:

We request to collect information from you when you are engaged in any activities while registering for or signed in to the Concordia Student Union Club’s Portal.
Personal data, or personal information, means any information about an individual from which that person can be identified.
You can choose whether or not to disclose your personal data while engaging in these activities. However, if you do not provide the information we have deemed mandatory, you will not be able to take full advantage of the website and its functions or content.
When you submit data on our website, you will be consenting to the Concordia Student Union and Ruby Development processing the categories of personal data that you have provided. We may collect, use, store, transfer and receive different kinds of personal information about you when you access and use the Site or Services, which we have grouped together as follows (collectively "Data") in accordance with your Organization's policies:
Identity Data includes first name, last name, legal first name, middle initial, maiden name, username or similar name, Organization identifiers (student ID, card number, faculty, club name, etc.).
Contact Data may include your first name, last name, email address, and phone number. The contact data may be processed for the purposes of communicating with you, operating our website, providing our services, processing requests, record-keeping, and marketing and sales purposes. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business.
Transaction Data includes details about transactions which occur on our Site and through the Services, including payments to and from an End User and products and services an End User has purchased from the Groups. We do not store or come in contact with any credit card information.
Technical Data includes internet protocol (IP) address, login data, browser type and version, location, browser versions, and operating system. Include logs of all requests made by the user to the site
Profile Data includes username and password, memberships in a group which is part of an Organization (a "Group"), school program, degree, interests, preferences, feedback, surveys/forms/poll responses, platform join date, photos, and group officer status.
User Contributions includes any messages, photos, news, files or other content submitted through the Services by individual End Users.
Usage Data includes information about how End Users use the Site and/or the Services – includes web analytics relating to usage of the Site and the platform in general and logs of all requests made by users to the Site.
Financial Data includes bank statements.
The Concordia Student Union may also collect, use and share Aggregated Data such as statistical and demographic data for any purpose. Aggregated Data may be derived from your personal information, but it does not directly or indirectly reveal your identity.

2.2.2 Information We Collect Automatically:

Usage Data
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

You can read more about cookies, and our use of them in our Cookie Policy (see below).

More Information
Ruby Development does not purchase marketing lists from third-parties.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
Anchors To Other Websites
The Site may contain links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.

3. Providing your personal data to others

3.1 This section describes how we may share and disclose your information. Please note that Organizations determine their own policies and practices for the sharing and disclosure of information.

3.2 Organization’s Instructions

Where we collect or receive personal information from Authorized Users and Independent Users through their use of the Site and the Services, we will only share and disclose information in accordance with the Organization’s instructions, including any applicable terms in the Organization Agreement and in compliance with applicable law.

3.3 Directory Services

As Ruby Dev is not responsible for your personal information we are not liable for any disclosure of personal information that the Organization may perform in conjunction with the Site.

Please Note: Some of the information you provide on the Site, including Profile Data, User Contributions and Group affiliations might be widely available to the public. You should also be aware that even pages that you mark as "private" in your settings will be accessible to Organization Administrators and Group Officers regardless of your privacy settings. If you do not want these individuals to see your information, please contact us at info@rubydev.ca and we will advise you regarding how your personal information can be removed from the Site.

3.4 Aggregated Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

3.5 Organization Access

Organization Administrators, Group Officers, and other Organization representatives and personnel may be able to access, modify or restrict access to your personal information. This may include, for example, your Organization using features of the Services to export activity logs or modifying access to other Service features. Organization Administrators may also have access to your personal information where you create an account to access certain Services as an Independent User. If you have any questions about your Organization’s account settings, please contact us at info@rubydev.ca. Where appropriate, we will forward your message to your Organization.

3.6 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.7 We use several third-party services to process the data we collect. We may process the following data categories: Contact Data, Usage Data, Notification Data, Inquiry Data, Correspondence Data, using our suppliers or subcontractors, namely Google and LogRocket insofar as reasonably necessary for the purposes specified in section 2 for each respective category. We have entered into a Data Processing Agreement with each of our processors to ensure that they comply with the General Data Protection Regulation, and protect your Personal Data in accordance with the highest standards.

3.8 We use a third-party service to process some of the data we collect. We may process the following data category: Usage Data, using our supplier/subcontractor: Google Analytics, insofar as reasonably necessary for the purposes specified in section 2 for. The Personal Data will only be processed for the aforementioned purpose. We have entered into a Data Processing Agreement with Google Analytics to ensure that they comply with the General Data Protection Regulation, and protect your Personal Data in accordance with the highest standards.

3.9 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside Canada.

4.2 Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted in the Personal Information Protection and Electronic Documents Act (PIPEDA).

4.3 The hosting facilities for our website are situated in Canada and comply with all PIPEDA regulations.

4.4 Ruby Development uses the following subcontractor to assist some data processing: Google Analytics.These subcontractors are situated in the United States.

4.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3

Your personal data that you provide is retained by Your Organization and will be retained in accordance with their policy. Ruby Development is not responsible for the retention and maintenance for the data you provide or liable for any related issues.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendment

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email or through a notification on this website.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent

7.3 The Right of Access. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 The Right to Rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 The Right to Erasure. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 The Right to Restriction of Processing. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. Please refer to your Organization for any and all personal information that they process.

7.7 The Right to Object to Processing. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8 The Right to Object to Processing for Marketing Purposes. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes).

7.9 The Right to Complain to a Supervisory Authority. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.10 The Right to Withdraw Consent. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.11 The Right to Data Portability. To the extent that the legal basis for our processing of your personal data is:

consent; or
that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.12 How to Exercise Your Rights. You may exercise any of your rights in relation to your personal data by contacting your organization, OR for any items relevant to us by emailing us at info@rubydev.ca

8. Our details

8.1 This website is owned and operated by the Concordia Student Union.

8.2 This website was developed and is maintained by Ruby Development.

8.3 We are registered in Canada as 13928501 Canada Inc., A Federally Incorporated Corporation.

8.4 You can contact us:

by telephone, on 613 799 5017;
by email, using info@rubydev.ca

9. Chief privacy officer

9.1 Our chief privacy officer’s contact details are:

Email: privacy@rubydev.ca

Cookie Policy

This Cookie Policy explains how Ruby Development (“we” or “us”) uses cookies and similar technologies to collect information whenever you visit and use our community engagement platform at https://portal.csu.qc.ca/ or our mobile sites (the “Services”).

By using the Services, you agree to our use of cookies and other similar technologies as described in this Cookie Policy.

Capitalized terms used in this Cookie Policy but not defined have the meaning set forth in our Privacy Policy, which also includes additional details about how we collect and use your information.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

HOW WE USE COOKIES

When you use and access the Services we may place a number of cookies files in your web browser. We use both session and persistent cookies on the Services and we use the following types of cookies to run the Services:

Essential cookies

These cookies are essential in helping you move around the Services and use their features, such as accessing secure areas of our community engagement platform and mobile apps. Some examples of the essential cookies we use include:

Identifying you as being signed in to the Services and keeping you logged in throughout your session so that you don’t need to sign in each and every time you visit.
Authenticating users to prevent unauthorized access to the Services or fraudulent use of user accounts.

Preference cookies

These cookies allow websites and applications to remember choices you make and provide enhanced and personalized features, so that we can improve your experience of the Services and make sure that your settings are remembered correctly. Some examples of the preference cookies we use include:

Remembering your preferences and settings, such as your language preference.
Remembering that you have accessed the Services before so that any messages intended for first-time users are not displayed to you.

Analytics cookies

We may use web analytics services to help us understand how people use our Services so that we can make improvements and keep them up-to-date and easy to use. For example, we can see which features of the Services are most popular, identify when errors occur, and test different versions of a page or feature to see which one works best. Web analytics services use cookies to recognize your browser or device and, for example, identify whether you have accessed the Services before and what you have previously looked at or clicked on. This allows the web analytics services to track information, such as how many individual users we have and how often they access the Services. The information collected also helps us to analyze patterns of user activity and improve the user experience within the Services.

Cookies used by our service providers

Our service provider uses cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics and LogRocket to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.

Google's privacy policy is available at: https://www.google.com/policies/privacy/

LogRockets's privacy policy is available at: https://logrocket.com/privacy/

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

UPDATE TO THIS COOKIES POLICY

We may update this Cookie Policy from time to time so please check this page occasionally to ensure that you are comfortable with any changes. If we make any material change to this Cookie Policy, we will provide additional notice to you, such as sending you an email, or displaying a prominent notice in a banner when you next access the Services. By continuing to use the Services after any changes come into effect, you agree to the revised Cookie Policy.