Employee Privacy Notice
Last reviewed: August 6th, 2025
SCOPE AND OVERVIEW
GVE Global Vision Inc. (“GlobalVision”, “we”, “us”, or “our”) is committed to respecting the privacy and security of Personal Information (as defined below) collected from employees, contractors, consultants, freelancers, and any other individuals working on behalf of or with GlobalVision before, during, and after their employment or contract.
This Employee Privacy Notice ensures compliance with relevant provincial privacy laws in Canada and under the European Union’s General Data Protection Regulation (“GDPR”).
This Employee Privacy Notice governs Personal Information collected during employment and engagement activities, whether the information is collected directly by GlobalVision or through third party sources.
DATA CONTROLLER / DATA PROTECTION OFFICER
In most cases, the controller of your Personal Information is GVE Global Vision Inc., located at 16800 Rte. Transcanadienne, Kirkland, Quebec H9H 4M7.
GlobalVision’s Data Protection Officer (DPO) is the Director of Governance, Risk and Compliance, who can be reached at privacy@globalvision.co.
DEFINITIONS
The following words and phrases, when appearing with a capitalized first letter in this Employee Privacy Notice, shall have the meanings ascribed to them below, unless otherwise implied or expressed herein:
Personal Information: means any information or data that relates to a natural person and allows that person to be identified, that is to say, that reveals, directly or indirectly or by reference, something about that person's identity, characteristics, activities, location or other identifiable information or data (e.g., abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behavior, economic, cultural or social status), regardless of the nature of the medium in which it is stored and regardless of the form in which the information or data is made available (written, graphic, audio, visual, computerized or other) and includes, in any case, Sensitive Personal Information (including special categories of Personal Information).
Process or Processing: means any operation or set of operations performed on Personal Information or sets of Personal Information, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.
Sensitive Personal Information: means Personal Information that, by its nature or the context of its use or disclosure, gives rise to a reasonable expectation of privacy. Examples of Sensitive Personal Information include medical, biometric, genetic or financial information, criminal offences information, or information about a person's sexual life or orientation, religious or philosophical beliefs, union membership or ethnic origin.
PERSONAL INFORMATION WE COLLECT
We obtain Personal Information in different ways, as further outlined below. Some Personal Information is provided by you directly (e.g., through the recruitment process). We may obtain Personal Information about you from third party sources, such as recruiters. We may also collect your Personal Information from publicly available sources (e.g., from social media platforms such as LinkedIn). We may automatically collect technical data about your equipment, browsing actions and patterns by using cookies and other similar technologies.
To carry out our activities and obligations as an employer, we may collect, store, and use Personal Information that includes, without limitation:
Personal contact information such as full name, professional title, address(es), telephone number(s), and personal email address(es).
Date of birth.
Gender.
Racial or ethnic origin.
Marital and dependent status.
Beneficiary and emergency contact information.
Government identification numbers such as social insurance or another national insurance number, driver's license number, or other identification card number.
Performance data.
Employment location.
Education and training.
Employment records (including professional memberships, references, work history, and proof of work eligibility).
Health information (including relevant vaccination status, allergies, or any medical condition).
Medical certificates (e.g. for leave).
Photograph.
Other identifiers, such as internet protocol (IP) address, account username, and account password.
Resume/cover letter.
Background checks (including criminal offence background checks where necessary and legally permitted).
Bank account details and payroll information.
Wage and benefit information.
Compensation history.
Tax-related forms.
Insurance enrollment information.
Technical data (including internet protocol (IP) address, cookie ID, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used, browsing activity when accessing our website, application activity and information in relation to electronic communications).
Other information that you choose to provide but is not specifically listed here, which we will use as described in this Employee Privacy Notice or as otherwise disclosed at the time of collection.
PURPOSES FOR COLLECTION AND USE OF PERSONAL INFORMATION
We use your Personal Information to fulfil the performance of a contract with and to enable us to comply with our legal and regulatory obligations. In some cases, we may use your Personal Information to pursue legitimate interests by us or a third party, provided your interests and fundamental rights do not override those interests.
With limited exceptions, we do not rely on consent as a legal basis for processing Personal Information. Where we rely on consent, we will only do so provided you have given your specific consent to processing. You have the right to withdraw your consent at any time.
Human Resource Management.
Recruitment process (including all related recruitment activities).
Executing the employment/contractor agreement.
Employee administration (including payroll and benefits administration).
Processing employee work-related claims (for example, insurance and worker's compensation claims).
Accounting and auditing.
Conducting performance reviews and determining performance requirements.
Assessing qualifications for a particular job or task.
Gathering evidence for disciplinary action or termination.
Education, training, and development requirements.
Complying with health and safety obligations.
Any other activities aimed at managing human resources or protecting the interests of employees.
Other Activities. To enable GlobalVision to carry out its business activities and operations, such as managing its assets, providing IT or web services, implementing information security measures, conducting internal audits and investigations, complying with the obligations of its business contracts, obtaining legal or business advice, preparing for legal disputes, etc.
Compliance with Laws. To enable GlobalVision to comply with its legal obligations and for any other purpose required by law, including disclosing Personal Information to the appropriate tax authorities in order to comply with applicable tax laws.
Where appropriate, we will communicate other purposes to you, to the extent these are not compatible with the original purpose, prior to or at the time of collecting your Personal Information and, if required by law, seek your consent.
We may process your Personal Information without your knowledge or consent where required by applicable law.
For all inquiries, including if you need further details about the specific lawful basis we rely on for Processing your Personal Information, please contact us at privacy@globalvision.co.
SOURCES OF PERSONAL INFORMATION
We collect and receive Personal Information:
Directly from employees, such as information relating to dependents, family members, and emergency contacts.
From colleagues, for example during any evaluation process.
Automatically and indirectly from employees, such as through logging and analytics tools, cookies, pixel tags, and other similar technologies on our websites and information technology systems and equipment.
From third parties, such as job applicant references and our service providers and business partners involved in our employment and retention processes.
Through monitoring of our website and other tools and services.
HOW WE SHARE PERSONAL INFORMATION
We generally disclose the categories of Personal Information listed above in Section 4 (Personal Information We Collect) to the following categories of entities for business or commercial purposes as described in Section 5 (Purposes for Collection and Use of Personal Information) above. We may share Personal Information with the below categories of individuals who may be located outside of Canada. If you are a resident of Quebec, we may transfer Personal Information to the below categories of individuals who may be located outside of Quebec:
To our service providers, such as IT operating system and platform vendors, human capital SaaS solutions, security vendors, monitoring and data analytics providers, insurance vendors, company banks, payroll processors, other benefits providers, auditors, accountants, outside legal counsel, professional advisors, contractors, suppliers, designated agents, and other professional services companies, and;
To other third parties, such as regulatory authorities or other third parties in response to legal process or other legal reporting requirements; to potential buyers (and their agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our shares or assets (including in the event of a reorganization, dissolution or liquidation); and other similar third parties where disclosure is required for an ordinary business purpose in connection with our provision of services.
Purposes for Sharing. We may also disclose your Personal Information for the following purposes, where permitted or required by applicable law:
To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your Personal Information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Information necessary for the specific purpose and circumstances.
During emergency situations or where necessary to protect the safety of persons.
If a business transfer or change in ownership occurs. If a change happens to our business, the purchaser will be entitled to use your Personal Information in the same way as set out in this Employee Privacy Notice and will assume the rights and obligations regarding your Personal Information as set out in this Employee Privacy Notice.
For additional purposes with your consent, where such consent is required by law.
HOW WE STORE AND SAFEGUARD PERSONAL INFORMATION
Your Personal Information may be held in our offices, stored on our servers, or stored on the servers of our service providers.
Access to your Personal Information is limited to our employees, contractors, consultants, freelancers, service providers, and agents that require such access for the purpose of carrying out their duties.
Security measures. Protecting your Personal Information is very important to us. We have reasonable and appropriate security measures in place to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, and to prevent privacy incidents. The nature of the measures will vary depending on different factors, such as the sensitivity of your Personal Information that has been collected, the purposes for which it is to be used, the risks associated with the Processing of your Personal Information, and the medium on which it is stored.
Our security measures, which are reviewed and updated as necessary, include:
physical measures (such as restricted access to our offices);
organizational measures (such as security clearances); and
technological measures (such as the use of passwords and the encryption of your Personal Information).
We communicate the necessity of maintaining the confidentiality of your Personal Information and ensure that care is used in the return or destruction of your Personal Information to prevent third parties from gaining unauthorized access to the same.
Third Parties. Where Processing is to be carried out on our behalf by a third party, such third party shall provide us with sufficient guarantees that appropriate physical, organizational, and technological measures are in place to meet the requirements of the privacy laws and to ensure the protection of your rights. Our third party service providers must use your Personal Information for specified purposes only. We do not allow our third party service providers to use your Personal Information for their own purposes. They will only process your Personal Information as permitted in the applicable agreements and they are subject to a duty of confidentiality.
RETENTION OF PERSONAL INFORMATION
We retain Personal Information for as long as necessary to carry out the processing activities described in this Employee Privacy Notice, including but not limited to administering the employment relationship, complying with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies, and protecting our, our employees’, and our business partners’ and clients’ rights, property, or safety and the rights, property and safety of others.
We may retain Personal Information for a longer period of time if a longer retention period is required or permitted by applicable law, as well as our records retention requirements and policies. For example, we may retain Personal Information for longer periods of time, such as to carry out our human resources operations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such Personal Information.
In specific circumstances, we may also retain Personal Information for longer periods of time so that we have an accurate record of an employee’s dealings with us in the event of any complaints or challenges.
YOUR PRIVACY RIGHTS AND CHOICES
It is important that your Personal Information remains accurate and current. Please keep us informed if your Personal Information changes during your employment relationship or contract with GlobalVision.
Rights. Depending on where you live and to the extent permitted by law, you may have the right to:
Access and Correction: Access, correct, update, delete, receive a copy of, or restrict the use of your Personal Information. Access to your Personal Information will be free of charge (or at a nominal charge for reproductions).
Withdraw Consent: Withdraw your consent at any time, in the event that we have Processed your Personal Information with your consent. In case of withdrawal, GlobalVision will no longer Process your Personal Information based on such consent, unless legally required or permitted to do so (e.g. if your Personal Information is needed by GlobalVision do assert or defend against legal claims). In case GlobalVision is required or permitted to retain your Personal Information for other legal reasons, your Personal Information will be restricted from further Processing and only retained for the term required by law or to fulfil the other legal reasons. However, any Processing of your Personal Information prior to such withdrawal shall not be affected.
Restrict Processing: Restrict or object to the Processing of your Personal Information, if and to the extent GlobalVision is Processing your Personal Information based on its legitimate interest. When you object to GlobalVision's Processing of your Personal Information, GlobalVision will carefully review your objection and cease further use of the relevant information, subject to GlobalVision’s compelling legitimate grounds for continued use of the Personal Information, which may override your interest in objecting, or if GlobalVision requires the information for the establishment, exercise, or defense of legal claims.
Deletion: Request the deletion of your Personal Information. Please note, however, that GlobalVision will only delete your Personal Information if there is no statutory obligation or prevailing right of GlobalVision to retain it.
Data Portability: Request a copy of your Personal Information in a commonly used, technological format to transfer it to you or a third party. This does not include information created or inferred by GlobalVision from the analysis of your Personal Information that was initially provided. GlobalVision is not required to destroy any Personal Information it holds after processing a portability request unless there is no reasonable expectation for this information to be used for the purposes for which it was provided by you.
Opt out: Opt out of certain disclosures of your Personal Information to third parties.
Complaint: Complain to the relevant data protection authority in the jurisdiction in which you are located about our collection and use of your Personal Information.
De-indexation: Residents of Quebec have the right to request that GlobalVision stops disseminating their Personal Information or deindexes a hyperlink associated with their name that provides access to their information, if such dissemination causes harm or violates the law or a court order. Once we receive and confirm their privacy request, we will evaluate the circumstances and based on this evaluation inform them whether we will de-index, re-index or delete the information.
If you object to the processing of your Personal Information (including restricting processing and withdrawing consent) we will respect this choice. This could mean that we cannot achieve the purposes as described above if we are unable to perform certain actions.
Applicable laws may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you or we may have destroyed, erased, or made anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information in line with your inquiry, we will inform you of the reasons why (subject to any legal or regulatory restrictions).
We may request specific information from you to help us confirm your identity in order for you to exercise any of your rights above.
Requests. If you have any questions about this Employee Privacy Notice, including any request to exercise your rights, please contact us at hr@globalvision.co. GlobalVision will respond to a request within thirty (30) days. All requests will be recorded in GlobalVision’s Register of Access and Rectification Requests.
TRANSFER OF YOUR PERSONAL INFORMATION
GlobalVision is headquartered in Canada and has service providers located in Canada, Europe as well as in other countries, such as the United States.
Your Personal Information may be Processed in Canada, the United States, or other locations outside of your country or region, as necessary for the purposes set out in this Employee Privacy Notice. As such, your Personal Information may become subject to the privacy laws of such other jurisdictions, which may not be as protective as the privacy laws in your home country or region. Where required by privacy laws, appropriate measures have been put in place to protect your Personal Information that we transfer across borders. For example, for residents of Quebec, GlobalVision shall conduct a Privacy Impact Assessment (PIA) prior to disclosing your Personal Information outside of Quebec. This analysis will determine whether the Personal Information will be adequately and appropriately protected in accordance with, among other things, generally accepted privacy principles.
If you are from the European Union (EU) or European Economic Area (EEA), the UK, or Switzerland, we will protect your Personal Information when it is transferred outside your home country or region by Processing it in a territory deemed by the European Commission or relevant supervisory authority to provide an essentially equivalent level of protection for Personal Information, or by using EU standard contractual clauses or other appropriate legal mechanisms to safeguard the transfer of your Personal Information. Where appropriate, GlobalVision has put in place EU SCCs with our third party services providers.
All inquiries regarding the transfer of your Personal Information may be submitted to privacy@globalvision.co.
AUTOMATED DECISION-MAKING
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you in advance.
REPORTING PRIVACY INCIDENTS AND RESPONDING TO COMPLAINTS
Any individual whose Personal Information is affected by an actual or apprehended privacy incident may file a complaint with the Data Protection Officer, which will be handled in accordance with the Information Security Incident Detection and Response Procedure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
CHANGES TO THIS POLICY
We reserve the right to update this Employee Privacy Notice at any time based on changes in privacy laws or our Personal Information management practices. All changes will be posted on our intranet (Confluence) and we will notify you of such changes by email. The date of the last update of the Employee Privacy Notice will be indicated to allow you to know when it was changed. We will also archive prior versions of this Employee Privacy Notice for your future reference or review.
CONTACT US
If you have any questions about this Employee Privacy Notice or how we handle your Personal Information, please contact our Data Protection Officer:
Via email: privacy@globalvision.co
Via postal mail:
GVE Global Vision Inc.
Attn: Compliance Department
16800 Route Trans-Canada
Kirkland, Quebec, H9H 4M7, Canada