123Commence

Privacy Policy


  1. Objective

This policy applies to all processing of personal data carried out by Commence and has the objective of informing the user regarding the way in which Commence carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and regarding the rights of the user in relation to their personal data.

  1. Contact – How can I contact?

In case of having any questions about the Privacy Policy, the user can contact Commence through the following means:

The user may establish direct and effective communication with Commence by written communication sent to any of the indicated addresses or also by sending an email to the address: dpo@commence.page or dpo@123c.ca
In addition, information of the officer in charge of processing your personal data is listed below:

  1. Processing identification – How do we collect personal data?

In compliance with current regulations on the protection of personal data, especially:

Commence collects personal data in its possession when the user:

  1. Personal Data Collected - What personal data do we collect?

Commence collects information when visiting their web page, and mainly by completing its registration forms.

The following data is collected: full name, email, phone number, gender, date of birth, address and credit information.

As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.

The user declares and guarantees that all the data provided by him are true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof.

Likewise, the user acknowledges that the data required by Commence are necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data are not provided.

Any false or inaccurate statement that occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user.

  1. Purpose - What do we use personal data for?

The personal data requested to the user will be used for the following purposes:

The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics, managing incidents or conducting market studies. However, in the event that personal data is processed for a purpose other than that initially specified when collecting said data, a compatibility analysis will be carried out by Commence in accordance with applicable regulations. The processing will only be authorized if the original purpose is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or legal justification for the processing of their data.
We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from Commence, reliably notifying Commence, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, it may send an email to the address indicated in Section 2, a postal mail addressed to the address indicated in Section 2 hereof, or directly follow the unsubscribe instructions detailed at the end of each email of Commence.

  1. How do we use your information?

We will use the information we collect about you for the following purposes:

If we want to use your information for any other purpose, we will ask for your consent and use your information only when we receive your consent and then only for the purpose(s) for which consent will be granted, unless we are required by law to do otherwise.

We will retain your personal information with us for 24 months after user accounts remain idle or for as long as necessary to fulfil the purposes for which it was collected, as detailed in this Privacy Policy.

  1. Consent

By providing personal data to Commence, the user declares to accept its processing fully and without reservation by Commence. The user gives his/her free, express and informed consent to Commence's use of the data collected for the purposes indicated in Section 5, as well as its incorporation into a Commence database.

The Commence carries out the processing of legitimised user data: (i) the contracting of Commence services by the user, in accordance with the terms and conditions that are made available to the user at the end of the completion of the service request form (prior to possible contracting) and which the user (after reading them), and if the user agrees, can accept by ticking the box that has been included for this purpose; and (ii) the free, informed and unambiguous consent of the user, made after reviewing this privacy policy, where Commence informs you of the processing it will carry out with your data, and if you agree, by ticking the box that has been included for this purpose in the service request form. Data processing that is not covered by any of the above legal bases will be carried out if Commence considers it necessary to protect a legitimate interest and only if it does not infringe the fundamental rights and freedoms of the user.

  1. Validity - How long do we keep it?

The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes described in Section 5 above. In particular, personal data will be kept for as long as the business relationship is in force (and to the extent that you have not previously requested their deletion) and for as long as obligations, indemnities and/or liabilities may arise under the business relationship or for the services provided.
Commence informs you that it will retain information essential to identify the origin of the data stored for the duration of the client's relationship with Commence and/or revocation of the user's consent in accordance with the information in Section 5 of this Privacy Policy and/or as long as required by applicable law.

  1. Confidentiality / Assignment / International Transfer - Do we disclose data to third parties?

Commence will keep collected personal data private and confidential, and will not use it for purposes other than those set out in Section 5 hereof. Commence requires its employees and third parties providing services that access the contents of the databases to sign confidentiality and personal data processing agreements (or include such obligations in the service agreements it signs with such providers, as indicated in the following paragraph).

The user's personal data collected by Commence will not be transferred, sold, exchanged, transmitted and/or communicated to third parties outside Commence without the user's consent, except for legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers enabling Commence to keep the Site operational, fulfil the objectives set out in Section 5 of this document and/or provide services to the user, who have undertaken the obligation to maintain the confidentiality of the data provided and undertake to comply with applicable regulations on the protection of personal data, at the time of contracting. Contracts with service providers stipulate the purpose, scope, content, duration, nature and purpose of data processing, the type of personal data, the categories of data subjects and the obligations and responsibilities of Commence and contracted third parties.

In particular: Commence may share the personal information provided with parent companies, affiliates, subsidiaries, related companies and/or intermediaries related to Commence.

Commence may share certain user-provided personal information internally within Commence, with certain departments, such as administration, marketing, or IT.

Social Networks. Commence also uses social networks, such as Facebook or Instagram, and has integrated functions of these networks into its services. The user may only use these social networks to the extent that they are registered in them and have accessed the corresponding social network with their user. These social networks have their own privacy policies and their own terms and conditions, over which Commence has no interference or control.

Finally, you should be aware that Commence may (and that Commence reserves the right to) disclose your information in the following cases:

  1. Security - How do we ensure data security?

Commence declares its intention to adopt the necessary technical and organisational measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of RGPD, and ,PIPEDA-CASL in order to prevent its tampering, loss, consultation or unauthorised processing. In particular, all the credit data provided is transmitted via SSL (Secure Socket Layer) and encrypted in the database of the payment platform of the provider of these payment services. It is stated that credit data (credit card number, among others) are not stored in the Commence servers or in Google Drive. In order to guarantee the confidentiality of the processing, the payment service provider is contractually obliged to respect the confidentiality of the information.

Commence does not guarantee absolute privacy when using the Site, since the possibility that unauthorised third parties may have knowledge of it cannot be excluded. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information. In the event that a security incident is detected and entails a significant risk to the data owner, such event will be reported without delay to the competent control authority, together with the corrective and remedial measures implemented and/or to be implemented.

Commence is not responsible for the loss or deletion of data by users. Similarly, Commence accepts no responsibility for possible damage caused by computer viruses.

Finally, the user must also take measures to protect their information. Commence insists that you take every precaution to protect your personal information while on the Internet. At the very least, it is advisable to change your password periodically, using a combination of letters and numbers, and to make sure you are using a secure browser.

  1. Data owner rights and procedures to respond to their exercise - What rights do I have as a data owner?

The data owner user may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality and deletion of his/her personal data, in accordance with the provisions of articles 15 and following of the RGPD, the provisions of the PIPEDA-CASL, as applicable.
The exercise of these rights may be carried out by the user him/herself by means of an e-mail addressed to dpo@commence.page, or by any of the methods provided for in the applicable regulations referred to above. Commence may request the data necessary to validate the identification of the data owner.

The deletion of some data shall not be carried out where it may cause damage to the legitimate rights or interests of third parties, or where there is a legal obligation to retain the data.

If you are located in the UK or EEA, and subject to national or local law exemptions, you have certain data protection rights in certain circumstances. Please contact us if you would like to exercise any of these rights.

  1. Training - Do we train?

The staff of Commence whose functions are related to the processing of personal data are trained in order to ensure better protection of personal data and the rights of data subjects.

  1. Links to third parties - Does our Site contain links to other websites?

The Site may contain links to third party websites, with or without advertising content, whose privacy policies are foreign to Commence. The linked sites are not related to Commence and, their existence in no way presupposes that there is any kind of suggestion, invitation or recommendation to visit the target sites or any kind of link or association between Commence and such sites. Commence is not responsible for the content, use and activities of these linked sites, or for any actual or potential, material or moral, direct or indirect damages suffered by users and derived from the information contained in such sites or the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the above, any feedback on these linked sites will be useful to Commence in order to improve the services and/or ensure the integrity of the Site. Commence undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content.

  1. Children's Privacy

At Commence, we recognize the importance of protecting the privacy of children. Our commitment to safeguarding the personal information of minors is unwavering. We may collect and process personal information from children under the age of 13, but only in compliance with all applicable laws and regulations, including obtaining parental or guardian consent as required.

If you are a parent or guardian and you believe that we have collected personal information from your child without appropriate consent, please contact us immediately, and we will take prompt action to address the situation.

For residents of California: We do not sell the personal information of California consumers who are 16 years old or younger unless we have obtained prior parental authorization. If your child is under the age of 13, we insist on receiving parental or guardian consent for the collection and processing of their personal information. If your child falls within the age range of 13 to 16 years, they can opt-in to allow the sale of their personal information. Our websites and services designed for children will incorporate age verification and ensure the necessary consents are obtained.

For EU residents: We do not collect or process personal information of individuals in the EU under the age of 16 without explicit consent from a parent or guardian. Our websites and services directed towards children will include age verification and require the appropriate consents.

  1. Cookies - Do we use cookies?

When you visit the Site, Commence may store certain information on your computer in the form of a "cookie" or similar file. The Site uses cookies to (i) track advertising, (ii) collect traffic data from the Site, and (iii) improve the user experience when using the Site.

The user should be aware that, in order to browse the Site, it is not necessary for him or her to allow the installation of cookies sent by the Site. This may only be required in relation to certain services. You may delete cookies from your computer hard drive, prevent access to your computer through your browser or by choosing the corresponding option when asked about the possibility of using cookies for these purposes and in accordance with Commence Cookie Policy.

Cookies are files of information that a website or the provider of certain services on the site transfers to the hard drive of the user's computer via the browser. Cookies by themselves cannot personally identify the user (although they may contain the user's IP address) but they allow them to recognise the user's browser, and to capture and store certain data (the user's operating system, the domain name of the website from which the Site was linked, among others). Commence reserves the right to hire the services of third parties to analyse and understand the users of the Site, who may not use the information collected for purposes other than improving Commence's services.

  1. Approval

Your use of the Site constitutes your acknowledgement and approval of Commence's Privacy Policy and Commence's Terms and Conditions, if any. Likewise, the user accepts Commence's Privacy Policy and Commence's Terms and Conditions by completing the request for services.

  1. Modifications - Is this the most current version?

This is the current version of the Commence Privacy Policy, updated on December 17, 2023.

Commence may at any time and without prior notice, modify this Privacy Policy. Such modifications will be operative from their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed about the terms included here by entering periodically.