Privacy policy

1. Person in charge of the protection of personal information

Name / title	Mike Lemdasni (RPRP)
Email	dpo@itgrate-nearshore.com
Mailing address	92, chemin de Lachalade, Lorraine (Québec) J6Z 1W6

2. Scope

This policy applies to:

• Site visitors
• people who contact us (prospects, partners, suppliers)
• candidates (application, talent pool, assignment proposal)
• client representatives (B2B contacts)

3. Personal information collected

A. Contact / business relationship

First and last name, company, role, email, message content, history of communications.

B. Application / talent pool

Resume/CV and professional information (experience, skills, certifications, availability, preferences), contact details, links (LinkedIn/GitHub), and any information you voluntarily provide.

C. Technical data

Data strictly necessary for the security and operation of the Site (e.g. server technical logs), to the extent that such data may constitute personal information.

4. Purposes

1. Respond to your requests and manage the B2B relationship (follow-up, meetings, service proposals).
2. Manage applications: assess the profile, arrange interviews, build a talent pool, propose assignments.
3. Internal search and filtering: indexing, internal search and filtering of profiles.
4. Security: protection of the Site, prevention of abuse, diagnostics and continuity.
5. Legal obligations: compliance, dispute management and requests from authorities.
6. Communications: send commercial communications where permitted, with an unsubscribe mechanism.

5. Consent

Where required, we obtain explicit consent. You may withdraw your consent, subject to legal or contractual obligations, by writing to dpo@itgrate-nearshore.com.

6. AI and automated processing

We use a technology to assist with ranking and filtering applications to support our internal searches.

• No decision is made exclusively by AI
• Human review is available upon request: dpo@itgrate-nearshore.com

7. Pseudonymisation of candidates

To limit exposure of identifiers, we apply pseudonymisation / masking of profiles during certain internal processing (indexing, filtering, search), according to our operational and security needs.

8. Sharing resumes with clients

Principle: we do not send your named resume/CV to a client without your explicit consent.

1. Processing and internal search on a pseudonymised basis.
2. If an assignment is relevant, we request explicit consent to present the profile.
3. The resume/CV is shared in accordance with applicable confidentiality commitments (e.g. NDA).

9. Vendors and processing locations

Website hosting	Namecheap — Canada (based on the current configuration)
Internal ATS	Internal system — hosted in Canada
Internal emailing	Internal system — hosted in Canada
CRM	HubSpot (CRM module only) — Canada

10. Cookies and trackers

As of the last updated date:

• no cookies are set by the Site
• no analytics tool is used
• no advertising tracker or pixel is used

11. Consent text — application

By checking this box, I consent to 9438-5564 Québec inc., doing business as ITGrate Nearshore / Rekruit Nearshore, collecting and using the personal information contained in my application (including my resume/CV) in order to process my request, assess my profile, contact me and, where applicable, propose assignments. I also consent to the pseudonymisation of my profile for internal indexing and filtering. My resume/CV will only be shared with a client with my explicit consent. I can withdraw my consent by writing to dpo@itgrate-nearshore.com. I have read the privacy policy.

12. Retention

We retain personal information only for as long as necessary for the purposes described, then we proceed with deletion, destruction, or anonymisation / strengthened pseudonymisation, as applicable.

Prospects / requests	24 months after the last contact, then deletion
Candidates (CV / talent pool)	24 months after the last exchange, or earlier upon withdrawal of consent (unless there is a legal obligation or a dispute)
Proof of consent	3 years after the last processing based on that consent
Contracts / billing	6 years, according to applicable obligations
Security logs	12 months, unless an incident or investigation requires longer retention

13. Security and incidents

We apply proportionate measures (access control, encryption in transit, backups, logging, segregation). In the event of an incident presenting a risk of serious harm, we apply the notification and record-keeping obligations provided by law.

14. Your rights

You may request access, rectification, withdraw consent, and exercise the rights provided by law by writing to dpo@itgrate-nearshore.com.

15. Updates

The version in force is the one displayed on the Site with the last-updated date.