Objective

The purpose of this policy is to establish the general principles that govern We.PLM members’ management and protection of personal information, which may be collected, used, and disclosed during the normal course of their professional duties at We.PLM.

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Scope

While exercising its right to collect, use, and disclose personal information for legitimate business purposes, We.PLM’s protection of personal information extends to all personal information under its custody or control.

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Definition of Personal Information

For the purpose of this Privacy Policy, “personal information” refers to any information, factual or subjective, recorded in any form about an individual that allows the individual to be identified. Personal information includes, but is not limited to:

• Name
• Birth date
• Gender
• Religion
• Income
• Home telephone number
• Personal mobile telephone number
• Home address
• Personal email address
• Personal fax number
• Social insurance number (SIN) or social security number (SSN)
• Financial or health information
• Opinions about an individual

However, personal information does not include an individual’s “business contact information,” which comprises an individual’s name, position or title, business telephone number, business address, business email, business fax number, and other similar business-related information.

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Governing Principles of Personal Information Protection

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1. Accountability

We.PLM is responsible for the personal information under its custody or control. Where We.PLM transfers personal information to a third party, We.PLM shall contractually require that a comparable level of protection is provided to the personal information transferred.

We.PLM has designated a Privacy Officer to oversee all ongoing activities related to the development, implementation, maintenance, and adherence to We.PLM’s policies and procedures covering privacy, as well as to ensure compliance with applicable laws and regulations.

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2. Identifying Purposes

When We.PLM collects personal information, individuals will be informed of the identified purpose for which the personal information is being collected, at or before the time of collection.

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3. Consent

Except where permitted or required by law, We.PLM will only collect, use, and disclose personal information with the knowledge and consent of the individual.

• We.PLM will use the form of consent—express or implied—that reflects the nature of the information being collected, taking into account its sensitivity and the reasonable expectations of the individual.
• Consent will also be obtained when a new use for the personal information is identified.
• An individual may withdraw their consent at any time with respect to the continuing use or disclosure of their personal information, subject to legal or contractual restrictions and reasonable notice. We.PLM will inform the individual of the implications of such a withdrawal.

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4. Limitation of Collection, Use, Disclosure, and Retention

We.PLM will only collect personal information necessary to fulfill the purposes identified to the individual.

• We.PLM will only use and disclose personal information for the purpose for which it was collected, in accordance with applicable laws and regulations.
• Personal information will only be retained as long as necessary to fulfill the identified purpose and for legal purposes.
• Personal information retained by We.PLM shall be securely disposed of or destroyed in accordance with We.PLM’s Records Management and Retention Policy and/or client specifications, in compliance with applicable laws and regulations.

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5. Accuracy

We.PLM shall take appropriate measures to ensure that the personal information collected is accurate, complete, and up to date, as necessary to fulfill the purpose for which it is being used.

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6. Individual Access

Upon written request, an individual will be informed of the existence, use, or disclosure of their personal information and will have the right to access it, subject to certain legal restrictions.

• Any refusal or restriction to an individual’s request for access to their personal information will be provided in writing, including the reasons for such refusal.
• An individual may also request corrections to their personal information. Such requests must be accompanied by appropriate supporting documentation.

When personal information is collected for or entrusted by a third party, We.PLM’s obligation to maintain accuracy and provide access or correction will be governed by a formal agreement with that third party.

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7. Safeguards

Personal information shall be protected in accordance with We.PLM’s Information Security Policy and, where applicable, client policies and procedures, in compliance with applicable laws and regulations.

• Personal information is protected from unauthorized use, disclosure, access, copying, and modification.
• Safeguards may include locked filing cabinets, restricted physical access, password protection, encryption, firewalls, and other technological measures.
• The selection of safeguards will be determined based on the nature of the personal information being protected.

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8. Sanctions

Violations of this policy may result in disciplinary action commensurate with the seriousness of the infringement.

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9. Compliance

We.PLM members are expected to comply with all aspects of this Privacy Policy and to support others in doing so.

All requests, questions, complaints, or violations related to this policy should be directed in writing to: privacy@theweplm.com

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We.PLM
15 JARDINS BOIELDIEU
92800 PUTEAUX
France

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