Last update : April 1,  2026

1. Definitions 

In this Privacy Policy of Diffusion Solutions Intégrées inc., the company operating the website and the ProgressionLIVE Platform (referred to as “Progression”): 

• Application or Platform refers to the ProgressionLIVE platform and its associated application for operations management, created and commercialized by Progression. 
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• Personal Information refers to information that allows a person to be identified, directly or indirectly. This excludes Business Contact Information, except where personal information protection laws consider such information as Personal Information. Information that has been anonymized within the meaning of the law does not constitute Personal Information. 
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• Business Contact Information means information relating to the exercise of a function within a business, such as a person’s name, title and function, as well as the mailing address, email address and telephone number of their workplace. By “exercise of a function,” it is meant that this information must have been collected, used or disclosed for the purpose of communicating with the person in the context of their employment, business or profession. 
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• Client means a client of Progression that is a business or other organization and is not a Consumer. The End User is an employee of Progression’s Client. 
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• Consumer means the individual whose data is uploaded to the Platform by the End User. 
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• Client Personal Information means Personal Information entrusted to Progression by the Client and may include the Personal Information of the Client’s End Users uploaded to the Platform and of Consumers. Such information may include, without limitation: first name and last name, mailing address, email address, telephone number, payment information, completed transactions. 
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• End User means the employee of Progression’s Client who uses the Platform in the course of their work. 

2. Scope and Application 

This Policy applies to Progression’s Clients and End Users. It also applies to Client Personal Information that has been entrusted to Progression for the purpose of providing services under contract, including Client Personal Information held by Progression’s service providers. 

If you are a Consumer under this Policy, please read the following section carefully: “Our Commitments to the Consumer.”  We also recommend that you review the privacy policy of the Client with whom you do business directly. 

Progression’s employees, subcontractors and agents must comply with the Privacy Policy if they have access to Personal Information or Client Personal Information in the course of their duties. If you are a job applicant at Progression, please consult the following section: “Our Commitments to Job Applicants at Progression.” 

3. Personal Information Protection Program 

In order to protect Personal Information, including Client Personal Information, we have implemented policies, practices and procedures relating to the management of the Personal Information we hold or have custody of. 

The collection of Client Personal Information through our Platform complies with the requirements of this program. 

4. Privacy Officer 

The management of the Personal Information Protection Program at Progression is carried out by our general management, which also acts as the Privacy Officer. Their responsibilities include managing and internally overseeing Progression’s Personal Information Protection Program. 

In accordance with applicable laws, the Privacy Officer approves and implements Personal Information protection policies and procedures, ensures their proper functioning and the effectiveness of the program. 

The Privacy Officer is also responsible for providing the necessary guidance in the event of any questions, complaints or requests relating to the protection of Personal Information. For more information, please refer to the “Contact Us” section. 

5. Consent 

We do not have a direct business relationship with Consumers. For this reason, we require our Clients to ensure that all required consents have been obtained from Consumers before entering any data into the Platform. In particular, the Consumer should have consented to having their Personal Information managed by Progression in accordance with this Privacy Policy. 

We also require our Clients to provide legally required notices to End Users and Consumers, and to ensure that the use, collection or disclosure of Personal Information between Progression and the Client is authorized. 

6. Collection and Use 

Progression obtains custody of Client Personal Information when the Client imports End User and Consumer data into the Platform. In parallel, data importation may also result in the collection of Personal Information by Progression for specific purposes listed below. 

When developing and improving our product, we ensure that Personal Information collection fields are limited to what is strictly necessary for the functioning of the Platform and to what is requested by the Client under our contracts, to enable the Client to achieve their objectives. 

Similarly, we require our Clients to limit the sharing of Personal Information to only the information necessary to achieve their objectives. 

7. Personal Information Collected 

Depending on the nature of your activity on our website or Platform, we may collect your Personal Information, including: 

• Information related to the creation of your account and use of the Application or Platform: your contact details such as your first and last name, your professional email address, your telephone number, your profile photo, and other information; 

• Information related to your work experience: your resume, years of experience, qualifications and certifications, and any other information required for employment at Progression; 

• Information related to the use of the Application, website and Platform: for example, date and time of visits, geolocation data (with your consent), duration of time spent on the Site, pages clicked and connection IP address; 

• Information relating to the use of your mobile devices: for example, the type of mobile device, unique identifier, IP address, and mobile identifiers such as Apple IDFAs or Google Android AAID identifiers, as applicable; 

• Information related to human resources or employment status: for example, employee number; 

• Information related to employee work shifts: for example, date, time and place of work, your check-in and check-out times at the workplace (the Application may act as a time clock or task progress tool for your employers). 

For more information on our geolocation collection practices, please consult our Terms of Use. 

8. Purposes for the Collection of Personal Information 

The following are the purposes for which Progression collects and uses Personal Information and Client Personal Information to provide its Services: 

• To establish and maintain a business relationship with our Clients; 

• To consolidate Client or End User Personal Information dispersed across multiple accounts on the Platform through data sources and integrations selected by the Client or End User; 

• To develop, improve, promote or provide products and services to our Clients, including for the diagnosis of technical issues or the improvement of features; 

• To investigate and resolve incidents; 

• To support our Clients in responding to requests by End Users or Consumers to exercise their rights, or in the resolution of disputes; 

• To provide products and services on behalf of Clients (in accordance with contracts between Progression and the Client); 

• For any other purpose permitted by law, including to respond to requests from law enforcement or government authorities. 

The following are the purposes for which Progression collects and uses Personal Information for its own purposes: 

• To maintain and improve the operation and security of the website and Platform; 

• To meet contractual, legal and regulatory requirements; 

• For research and statistics production purposes; 

• For the management and administration of the Client’s user account; 

• To contact you if you use our online forms; 

• To contact you if you apply for employment at Progression; 

• To prevent and detect suspicious, fraudulent or terms-of-use-violating activities; 

• To investigate and resolve incidents; 

• For any other purpose permitted by law, including to respond to requests from law enforcement or government authorities. 

Should an End User or Client refuse to provide the information necessary for the opening and administration of their user or client account, or withdraw their consent to the use or disclosure of their Personal Information or Client Personal Information, Progression may be unable to provide the End User or Client with the subscribed products and services, and may be required to terminate its business relationship with the Client or End User. 

9. Communication and Transfer of Personal Information 

Progression only communicates or transfers Client Personal Information when required or permitted by the contract with the Client or otherwise required or permitted by applicable laws. 

Progression may sometimes need to share Personal Information with its subcontractors or agents to help make all features of our Platform and website available (maintenance, analysis, legal requirements, fraud detection, marketing and development). These parties will only have access to the Personal Information necessary to perform these tasks on our behalf and are required not to disclose or use it for any other purpose. 

Please note that these subcontractors or agents may be located in Canada or in other jurisdictions or countries. We have contractual agreements with them to ensure the security of the data we entrust to them, and we conduct privacy impact assessments before disclosing any Personal Information outside the province of Quebec. Although the Personal Information we transmit is protected by appropriate security measures, it could be made available to foreign government bodies, pursuant to applicable laws. 

10. Retention 

Progression has established retention periods for Personal Information in its custody. Progression will not retain Personal Information longer than it is necessary or relevant for the identified purposes, unless contracts with the Client or legal or regulatory requirements provide otherwise. Once these periods have expired, Progression will return or destroy the Personal Information in accordance with the contract with the Client or its internal Personal Information management policies. By way of guidance, applicable retention periods include, without limitation: (i) Personal Information of active Clients and End Users: retained for the duration of the contract and deleted within sixty-nine (69) days following its termination or expiration, subject to legal retention obligations; (ii) logging and security data: retained for a maximum period of twelve (12) months; (iii) Personal Information of unsuccessful applicants: retained for a maximum period of one (1) year following the end of the recruitment process, unless otherwise consented to. These periods may be extended where required by legal, regulatory or contractual requirements. 

11. Security Measures 

Progression makes the security of the Personal Information it collects, uses and has custody of a priority. Accordingly, Progression ensures that appropriate security measures are implemented, proportionate to the sensitivity of the data, to protect Client Personal Information against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. 

To the extent possible and applicable within the scope of our services, Progression implements, maintains and monitors technical and administrative measures to help protect the security, integrity, availability and confidentiality of the Personal Information we collect or have custody of. No security measure is infallible. To the extent permitted by law, Progression does not guarantee the absolute security of Personal Information against any unauthorized access, disclosure or use. 

12. Accuracy 

Progression relies on the Client and End User to ensure the ongoing accuracy of the Personal Information that Progression collects, uses and retains for the purposes set out above. Progression is not responsible for inaccuracies, omissions or errors in Personal Information resulting from data provided by the Client or End User. 

13. Incident Management 

Progression’s Personal Information Protection Program includes incident detection and response practices and procedures, designed to facilitate the timely reporting to the Client of incidents involving Client Personal Information. 

Since Client Information belongs to the Client, the Client is generally responsible for managing and monitoring security incidents with Consumers. In accordance with contracts with the Client, Progression will provide reasonable assistance to support the Client in investigating the incident and meeting its obligations, for example with respect to notifications to affected individuals (including End Users and Consumers) and reporting the incident to relevant privacy commissioners or other relevant parties. Where Progression acts as the data controller with respect to its own Personal Information and a privacy incident presenting a serious risk of harm occurs, Progression undertakes to notify the Commission d’accès à l’information du Québec (CAI) as well as the affected individuals, in accordance with the requirements of the Act respecting the protection of personal information in the private sector and its regulations, within the prescribed timeframes. 

14. Access to Information and Other Similar Rights 

Since Progression does not have a direct business relationship with the Consumer, Progression will generally refer access to information requests, correction of Personal Information requests or other such requests from End Users or Consumers to the Client. In accordance with applicable personal information protection laws, any person whose Personal Information is held by Progression in its capacity as data controller has the following rights: (i) right of access: to obtain confirmation that Personal Information concerning them is held and to receive a copy thereof; (ii) right of rectification: to have inaccurate, incomplete or ambiguous Personal Information corrected; (iii) right to erasure: to obtain the deletion of Personal Information whose retention is no longer justified by the purposes for which it was collected, subject to legal retention obligations; (iv) right to portability: to receive in a structured, commonly used technological format the Personal Information collected by automated means, or to have it transmitted to a designated third party, where technically possible; and (v) right to withdraw consent: to withdraw your consent to the processing of your Personal Information. Progression undertakes to respond to any request to exercise these rights within thirty (30) days of receipt. To exercise these rights, please contact our Privacy Officer at the contact details provided in the “Contact Us” section. 

15. Our Commitments to the Consumer 

This section describes Progression’s Personal Information management practices when the Consumer (“you,” “your”) does business with one of our Clients who uses the Platform and uploads your data to it. This section also applies to visits to our website. 

Please note that the visit and use of our website and Platform are also governed by our Terms of Use. 

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• Transparency. Transparency about our Personal Information management practices is an integral part of our Personal Information Protection Program. This Privacy Policy aims to inform you as fully as possible about the practices for managing your Personal Information, which is entrusted to us by our Clients, when your data is imported into the Progression Platform. All Personal Information contained in the Platform may be collected, used and retained by Progression to fulfill its contractual obligations and the purposes listed above.  Our Privacy Officer is specifically designated to help answer any privacy-related questions. 
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• Accountability. We assume the responsibilities incumbent upon us under applicable laws. Our accountability is limited to the services we provide to our Clients. Our Clients remain legally accountable for the management of your Personal Information. We strongly recommend that you also review their privacy policy. To the extent permitted by law, Progression is not liable to Consumers for the acts or omissions of the Client in the management of their Personal Information, including with respect to the collection of consents, the issuance of required notices and the management of rights exercise requests. 
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• Limitation. When developing and updating our products, we always keep in mind our objective of minimizing the collection and use of your Personal Information to the strict minimum necessary for the operation and management of our Platform. Similarly, if it is possible for us to use de-identified or anonymized information to achieve the purposes listed above, we will favor these methods. We retain your Personal Information only for as long as your account on the Platform is open and active. When your account is deleted by our Client, Progression will destroy your Personal Information, subject to retention periods imposed by its contracts, internal policies and applicable law. 
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• Security. We are aware of our role as custodian of your Personal Information and for this reason we strive to implement the best reasonable security measures for maintaining the security, integrity, availability and confidentiality of our Platform. 
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• Access to Personal Information. Our Clients may at any time access your profile and view your Personal Information. They may also modify or correct this Personal Information, upon your request. In the event that it is impossible for our Clients to modify certain Personal Information themselves or to view it through the account, please contact our Privacy Officer. 

If you choose to receive our newsletter, news, contests and other promotions or information relating to our services, you may also withdraw your consent to receive them by following the instructions indicated in the email or by contacting our Privacy Officer. 

16. Our Commitments to Job Applicants at Progression 

Progression values and respects the privacy of job applicants. The relevant sections of this Policy also apply to job applicants at Progression, particularly with respect to your rights and the contact details of our Privacy Officer. 

16.1 Categories of Personal Information Collected from Applicants 

Progression may collect personal information directly from job applicants, or receive Personal Information from third parties, for example, in the context of a background check, employment verification or reference, subject to the applicant’s consent, if required by law. We limit our collection to what is strictly necessary for the purposes described below. Examples of the types of information collected include: 

• Name, title, mailing address, telephone number and personal email address; 

• Information appearing on the resume and cover letter (e.g., information on education, training and previous experience); 

• Information collected during telephone interviews (virtual or in-person); 

• Details regarding the type of employment sought, desired salary, employment preferences and other information related to compensation and benefits; 

• Reference information and information received during background checks, as applicable, including information provided by third parties. 

16.2 Use of Job Applicant Personal Information 

The Personal Information of applicants is collected for the following purposes: 

• To identify and evaluate job applicants (e.g., by assessing skills, qualifications and objectives); 

• To verify information and conduct employment, background and reference checks (as applicable and subject to the applicant’s consent, if required by applicable law); 

• To communicate with the individual regarding the recruitment process and their application; 

• To maintain records related to the hiring process; 

• To comply with Progression’s legal and regulatory requirements; 

• To analyze and improve recruitment processes. 

Consent to the processing of personal information for any of the purposes described above may be withdrawn in certain circumstances, by contacting our Privacy Officer. 

16.3 Retention Period for Applicant Personal Information 

Except as permitted or required by applicable laws or regulations, Progression retains Personal Information for the period necessary for the purposes described above. 

If employment is offered to the applicant and the applicant accepts the offer, the Personal Information collected during the recruitment process will become part of their employment file. We may use this information in the context of employment. We securely retain and destroy the personal information of unsuccessful applicants in accordance with our policies and applicable laws and regulations. 

17. Cookies and Similar Technologies 

A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. Other tracking technologies, such as web beacons and tracking pixels, may be used for similar purposes. For reference, web beacons and pixels are tiny images that we may place on our web pages, Platform or emails. They may be used, for example, to anonymously track the number of times a particular page has been visited by a user. Web beacons are invisible and any part of our Platform may contain web beacons. Unlike cookies, web beacons are not placed on your computer. In this Policy, all such tracking technologies are collectively referred to as “Cookie(s).” Any Personal Information collected using Cookies by or on behalf of Progression is treated with the same level of confidentiality as any other Personal Information held by Progression. 

Our Application, website and Platform use both first-party and third-party Cookies for a number of reasons. 

We primarily use first-party and third-party Cookies to measure traffic on our web pages, to understand the performance of our Application, website and Platform, to understand how you interact with our Application, and to offer you an improved user experience. 

17.1 Essential and Security Cookies 

These Cookies are necessary for the operation of the website and cannot be disabled in our systems without impacting the functioning of the website, Application or Platform. Essential and security Cookies must be present for the Application, website or Platform to provide basic functions, which may include logging into our Application or Platform, maintaining your session and preventing security threats. However, if you wish, you may block or delete them by changing your browser settings and forcing the blocking of all Cookies. 

17.2 Non-Essential Cookies 

Non-essential Cookies provide certain non-essential features on our Site for functional, analytical or advertising purposes. Progression will request your consent before using any non-essential Cookie. 

17.3 Marketing and Advertising Cookies 

These Cookies help us track the effectiveness of our advertising campaigns and personalize our advertisements so that they are relevant to you. 

17.4 Analytics and Experience Optimization Cookies 

These Cookies store information such as the number of visitors to our site or the page they visited. They help us understand and analyze the performance of our website, Application and Platform and our potential improvements. These Cookies also allow us to facilitate non-essential features, such as your time zone when you log in. 

17.5 Disabling Cookies 

It is possible to prevent the personalization features of our sites by disabling cookies in your browser or in our cookie banner. You can do this by changing the settings of your browser or mobile device. However, if you decide to refuse cookies, certain pages or sections of our sites may not display correctly or certain features may not be available. 

17.6 Links to Websites 

It is important to understand that this Policy does not apply to other third-party websites that may be accessible from links present on our sites. We are in no way responsible for such third-party sites, their content or access. Consequently, any Personal Information you transmit through these sites is subject to their privacy policy. It is your responsibility to review them in order to ensure the protection of your Personal Information. 

18. Contact Us 

Our Privacy Officer is available to answer any questions, requests or complaints regarding Progression’s Personal Information management practices. 

Contact details are as follows: 

• Vincent Vanier 
• Privacy Officer 
• Diffusion Solutions Intégrées inc. (Progression) 
• 290-4450 Boulevard des Forges 
• Trois-Rivières (Quebec) 
• G8Y 1W5 
• privacy@progressionlive.com 

If you are a Consumer, Progression may direct your request to its Client, if that is more appropriate. 

For a complaint regarding this Privacy Policy, our Privacy Officer will conduct an investigation and communicate with the complainant the procedure to follow. If the complaint is justified, the particular situation will be corrected and the complainant will be informed. 

Progression wishes to inform you that we are committed to responding promptly and accurately to all your questions and concerns regarding the confidentiality and security of Personal Information, as well as with respect to our Personal Information protection policies and practices.