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Privacy Policy

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1. Context

This policy aims to ensure the protection of personal information and to frame the manner in which Destination Chic-Chocs collects, uses, communicates, retains, and destroys or otherwise manages it. Furthermore, it aims to inform any interested person regarding how Destination Chic-Chocs, in partnership with BOURRASQUE, handles their personal information. It also covers the processing of personal information collected by Destination Chic-Chocs via technological means, in collaboration with BOURRASQUE.

2. Application and Definitions

This policy applies to Destination Chic-Chocs, including notably its officers, employees, consultants, volunteers, as well as any person who otherwise provides services on behalf of Destination Chic-Chocs. It also applies to the Destination Chic-Chocs website, as well as all websites controlled and maintained by Destination Chic-Chocs.

It covers all types of personal information managed by Destination Chic-Chocs, whether it be information regarding its clients (potential or current), consultants, employees, members, or any other persons (such as visitors to its websites or otherwise).

For the purposes of this policy, personal information is information that concerns a natural person and allows, directly or indirectly, for their identification. For example, this could be a person’s name, address, email address, phone number, gender, banking information, health information, ethnic origin, language, etc.

Sensitive personal information is information for which there is a high level of reasonable expectation of privacy, e.g., health information, banking information, biometric information, sexual orientation, ethnic origin, political opinions, religious or philosophical beliefs, etc.

Generally, a person’s professional or business contact information does not constitute personal information, for example, a person’s name, title, address, email address, or telephone number at work. More specifically and for the sake of precision, within the meaning of the Act respecting the protection of personal information in the private sector of Quebec, and as of September 22, 2023, sections 3 (collection, use, communication), 4 (retention and destruction), and 6 (data security) do not apply to information concerning a person relative to the exercise of a function within an enterprise, such as their name, title, and duties, as well as the address, email address, and telephone number of their workplace.

These same paragraphs also do not apply to personal information that is public by law, effective upon the entry into force of this policy.

3. Collection, Use, and Communication

In the course of its activities, Destination Chic-Chocs may collect different types of information for different purposes. The types of information that Destination Chic-Chocs may collect, their use (or the intended objective), as well as the means by which the information is collected, are indicated in Annex A of this policy.

Destination Chic-Chocs will also inform the persons concerned, at the time of the collection of personal information, of any other information collected, the purposes for which it is collected, and the means of collection, in addition to other information to be provided as required by law.

Destination Chic-Chocs applies the following general principles regarding the collection, use, and communication of personal information:

Consent:

Generally, Destination Chic-Chocs collects personal information directly from the person concerned and with their consent, unless an exception is provided by law. Consent may be obtained implicitly in certain situations, for example, when the person decides to provide their personal information after having been informed by this policy of the use and communication for the purposes indicated herein (see Annex A for more details). Thus, this policy and the information it contains may be consulted by the person concerned at the time of the collection of personal information.

Normally, Destination Chic-Chocs must also obtain the consent of the person concerned before collecting their personal information from third parties, before communicating it to third parties, or for any secondary use thereof. However, Destination Chic-Chocs may act without consent in certain cases provided by law and under the conditions provided therein. The main situations where Destination Chic-Chocs may act without consent are indicated in the relevant sections of this policy.

Collection:

In all cases, Destination Chic-Chocs only collects information if it has a valid reason to do so. Furthermore, the collection will be limited only to the necessary information needed to fulfill the intended objective.

Please note that Destination Chic-Chocs services and programs do not target minors, and more generally, Destination Chic-Chocs does not intentionally obtain personal information regarding minors (in such cases, information cannot be collected from them without the consent of a parent or guardian).

Collection from Third Parties: Destination Chic-Chocs may collect personal information from third parties. Unless an exception is provided by law, Destination Chic-Chocs will ask for the consent of the person concerned before collecting personal information concerning them from a third party. In the event that such information is not collected directly from the person, but from another organization, the person concerned may request the source of the collected information from Destination Chic-Chocs.

In certain situations, Destination Chic-Chocs may also collect personal information from third parties without the consent of the person concerned, if it has a serious and legitimate interest in doing so and: a) if the collection is in the interest of the person and it is not possible to collect it from them in a timely manner, or b) if this collection is necessary to ensure the information is accurate.

Also, Destination Chic-Chocs may collect personal information indirectly, notably by using:

This collection via third parties may prove necessary to use certain services or programs, or to otherwise do business with Destination Chic-Chocs. When required, Destination Chic-Chocs obtains the person’s consent at the appropriate time.

Holding and Use:

Destination Chic-Chocs ensures that the information it holds is up to date and accurate at the time of its use to make a decision relative to the person concerned.

Destination Chic-Chocs may only use a person’s personal information for the reasons indicated herein or for any other reasons provided at the time of collection. As soon as Destination Chic-Chocs wants to use this information for another reason or another purpose, new consent must be obtained from the person concerned, which must be obtained explicitly if it concerns sensitive personal information. However, in certain cases provided by law, Destination Chic-Chocs may use the information for secondary purposes without the person’s consent, e.g.:

  • When this use is clearly for the benefit of that person;
  • When necessary to prevent or detect fraud;
  • When necessary to evaluate or improve protection and security measures.

Limited Access: Destination Chic-Chocs must implement measures to limit access to personal information only to employees and persons within its organization who are qualified to know it and for whom this information is necessary in the exercise of their duties. Destination Chic-Chocs will ask for the person’s consent before granting access to any other person.

Communication:

Generally, and unless an exception is indicated in this policy or otherwise provided by law, Destination Chic-Chocs will obtain the consent of the person concerned before communicating their personal information to a third party. Furthermore, when consent is necessary and when it concerns sensitive personal information, Destination Chic-Chocs must obtain the explicit consent of the person before communicating the information.

However, communicating personal information to third parties is sometimes necessary. Thus, personal information may be communicated to third parties without the consent of the person concerned in certain cases, including, but not limited to, the following cases:

Destination Chic-Chocs may communicate personal information, without the consent of the person concerned, to a public body (such as the government) which, through one of its representatives, collects it in the exercise of its powers or the implementation of a program it manages.

Personal information may be transmitted to its service providers to whom it is necessary to communicate the information, without the person’s consent. For example, these service providers may be event organizers, subcontractors of Destination Chic-Chocs designated for the execution of mandates in programs administered by Destination Chic-Chocs, and cloud service providers. In these cases, Destination Chic-Chocs must have written contracts with these providers indicating the measures they must take to ensure the confidentiality of the personal information communicated, that the use of this information is made only within the framework of the execution of the contract, and that they may not retain this information after its expiry. Furthermore, these contracts must provide that the providers must notify Destination Chic-Chocs’ Privacy Officer (indicated in this policy) of any violation or attempted violation of confidentiality obligations regarding the communicated personal information and must allow this officer to conduct any verification regarding this confidentiality.

If necessary for the conclusion of a commercial transaction, Destination Chic-Chocs could also communicate personal information, without the consent of the person concerned, to the other party to the transaction and subject to the conditions provided by law.

Communication Outside Quebec: It is possible that personal information held by Destination Chic-Chocs may be communicated outside of Quebec, for example, when Destination Chic-Chocs uses cloud service providers whose server(s) are located outside Quebec or when Destination Chic-Chocs does business with subcontractors located outside the province.

Additional Information on Technologies Used:

Use of Cookies Cookies are data files transmitted to the computer of a website visitor by their web browser when they consult that site and can have several uses.

Websites controlled by Destination Chic-Chocs use cookies notably:

To memorize visitor settings and preferences, for example, for the choice of language and to allow tracking of the current session.

For statistical purposes to understand visitor behavior, content viewed, and to allow improvement of the website.

Websites controlled by Destination Chic-Chocs use the following types of cookies:

Session Cookies: These are temporary cookies that are kept in memory for the duration of the website visit only.

Persistent Cookies: These are kept on the computer until they expire, and they will be retrieved during the next visit to the site.

Some cookies may be disabled by default, and visitors may choose to activate these functions or not when consulting Destination Chic-Chocs websites.

It is also possible to activate and deactivate the use of cookies by changing preferences in the settings of the browser used.

Use of Google Analytics

The Destination Chic-Chocs site uses Google Analytics to allow for its continuous improvement. Google Analytics notably allows for the analysis of how a visitor interacts with a Destination Chic-Chocs website. Google Analytics uses cookies to generate statistical reports on the behavior of visitors to these websites and the content viewed.

Information coming from Google Analytics will never be shared by Destination Chic-Chocs with third parties.

It is possible to install a browser add-on to disable Google Analytics.

Other Technological Means Used

Destination Chic-Chocs also collects personal information through technological means such as web forms integrated into a website controlled by Destination Chic-Chocs (for example, its contact form, its membership application form, its form to subscribe to the newsletter and seminars), questionnaires accessible online on its platforms and applications, as well as other platforms or form tools (e.g., Microsoft Forms).

If Destination Chic-Chocs collects personal information by offering a technological product or service that has privacy settings, Destination Chic-Chocs must ensure that these settings offer the highest level of confidentiality by default (cookies are not covered).

4. Retention and Destruction of Personal Information

Unless a minimum retention period is required by applicable law or regulation, Destination Chic-Chocs will only retain personal information for the duration necessary to fulfill the purposes for which it was collected.

Personal information used by Destination Chic-Chocs to make a decision relative to a person must be retained for a period of at least one year following the decision in question or even seven years after the end of the fiscal year in which the decision was made if it has tax implications, for example, the circumstances of a termination of employment.

At the end of the retention period or when the personal information is no longer necessary, Destination Chic-Chocs will ensure:

to destroy it; or

to anonymize it (meaning it no longer allows, irreversibly, for the identification of the person and it is no longer possible to establish a link between the person and the personal information) to use it for serious and legitimate purposes.

The destruction of information by Destination Chic-Chocs must be done securely to ensure the protection of this information.

This section may be supplemented by any policy or procedure adopted by Destination Chic-Chocs regarding the retention and destruction of personal information, if applicable.

Please contact Destination Chic-Chocs’ Privacy Officer (indicated in this policy) to learn more.

5. Responsibilities of Destination Chic-Chocs

Generally, Destination Chic-Chocs is responsible for the protection of the personal information it holds.

The Privacy Officer (Responsable de la protection des renseignements personnels) of Destination Chic-Chocs is the organization’s Director of Operations. They must, generally, ensure compliance with applicable legislation regarding the protection of personal information. The Officer must approve policies and practices governing the governance of personal information. More specifically, this person is responsible for implementing this policy and ensuring it is known, understood, and applied. In the event of the absence or inability to act of this Officer, the President of Destination Chic-Chocs will assume the duties of the Privacy Officer.

Destination Chic-Chocs staff members having access to personal information or being otherwise involved in the management thereof must ensure its protection and respect this policy.

The roles and responsibilities of Destination Chic-Chocs employees throughout the lifecycle of personal information may be specified by any other Destination Chic-Chocs policy in this regard, if applicable.

6. Data Security

Destination Chic-Chocs is committed to implementing reasonable security measures to ensure the protection of the personal information it manages. The security measures in place correspond, among other things, to the purpose, quantity, distribution, medium, and sensitivity of the information. Thus, this means that information that can be qualified as sensitive (see the definition provided in section 2. Application and Definitions) will have to be subject to greater security measures and will have to be better protected. Notably, and in accordance with what was mentioned previously regarding limited access to personal information, Destination Chic-Chocs must put in place necessary measures to impose constraints on the rights of use of its information systems so that only employees who need access are authorized to access it.

7. Rights of Access, Rectification, and Withdrawal of Consent

To assert their rights of access, rectification, or withdrawal of consent, the person concerned must submit a written request to this effect to Destination Chic-Chocs’ Privacy Officer at the email address indicated in the following section.

Subject to certain legal restrictions, persons concerned may request access to their personal information held by Destination Chic-Chocs and request its correction in the event it is inaccurate, incomplete, or equivocal. They may also demand the cessation of the dissemination of personal information concerning them or the de-indexing of any hyperlink attached to their name allowing access to this information by a technological mean, when the dissemination of this information contravenes the law or a court order. They may do the same, or demand that the hyperlink allowing access to this information be re-indexed, when certain conditions provided by law are met.

Destination Chic-Chocs’ Privacy Officer must respond in writing to these requests within 30 days of the date of receipt of the request. Any refusal must be motivated and accompanied by the legal provision justifying the refusal. In these cases, the response must indicate the remedies under the law and the time limit to exercise them. The Officer must help the applicant understand the refusal if needed.

Subject to applicable legal and contractual restrictions, persons concerned may withdraw their consent to the communication or use of the collected information.

They may also ask Destination Chic-Chocs what personal information is collected from them, the categories of persons at Destination Chic-Chocs who have access to it, and its retention period.

8. Complaint Processing Process

Receipt

Any person wishing to formulate a complaint regarding the application of this policy or, more generally, regarding the protection of their personal information by Destination Chic-Chocs, must do so in writing by addressing Destination Chic-Chocs’ Privacy Officer at the email address indicated in the following section.

The individual must indicate their name, contact details to reach them, including a phone number, as well as the subject and grounds of their complaint, giving sufficient details so that it can be evaluated by Destination Chic-Chocs. If the formulated complaint is not sufficiently precise, the Privacy Officer may request any additional information they judge necessary to be able to evaluate the complaint.

Processing

Destination Chic-Chocs commits to treating any complaint received confidentially.

Within 30 days following the receipt of the complaint or following the receipt of all additional information judged necessary and required by Destination Chic-Chocs’ Privacy Officer to be able to process it, the latter must evaluate it and formulate a reasoned written response by email to the complainant. This evaluation will aim to determine if the processing of personal information by Destination Chic-Chocs is compliant with this policy, with any other policy and practice in place within the organization, and with applicable legislation or regulation.

In the event the complaint cannot be processed within this timeframe, the complainant must be informed of the reasons justifying the extension of the deadline, the progress status of the processing of their complaint, and the reasonable time necessary to be able to provide a final response.

Destination Chic-Chocs must establish a separate file for each complaint addressed to it. Each file contains the complaint, the analysis and documentation supporting its evaluation, as well as the response sent to the person who originated the complaint.

It is also possible to file a complaint with the Commission d’accès à l’information du Québec or any other supervisory body regarding the protection of personal information responsible for the application of the law concerned by the subject of the complaint.

However, Destination Chic-Chocs invites any interested person to first address its Privacy Officer and wait for the conclusion of the processing process by Destination Chic-Chocs.

9. Approval

This policy is approved by Destination Chic-Chocs’ Privacy Officer, whose business contact information is as follows:

Privacy Officer:

Denis Duteau
170 Rte du Parc, Sainte-Anne-des-Monts, QC G4V 2C2

administration@destinationchicchocs.com

Technological Privacy Officer

BOURRASQUE

C/O DIGITAL OFFICER
126 RUE DES URSULINES MATANE QUEBEC G4W 1H1

info@bourrasque.ca

For any request, question, or comment regarding this policy, please contact the Digital Officer by email.

10. Modifications

Versions and changes:

  • 1.0 – In effect since 2023-09-21:
    • Online launch
  • 1.1 – In effect since 2024-09-06:
    • Update of the consent window;
    • Adjustment of the list of third parties in section 3.

Annex A

Here is a non-exhaustive list of the types of information that Destination Chic-Chocs might collect, their use, or the intended objective, as well as the means by which the information is collected. Thus, this includes, without limitation, the following elements.

Please note that most personal information managed by Destination Chic-Chocs is personal information of employees, job applicants, and consultants. Regarding other categories of persons indicated in the table below, the information provided is, in the majority of cases, professional or business information (see section 2. Application and Definitions regarding business contact information).

A –

Relationship with Destination Chic-Chocs, services, program, etc.

  • Client

Type of personal information:

  • Name
  • Phone number
  • Email
  • Postal address
  • Language
  • Banking information (when necessary)

Purpose of collection / uses:

Establishing and managing customer relationships and obtaining a means of communication, providing a service, collecting information within the framework of a program, support program, protection of personal information. Note that it is sometimes necessary to communicate the provided information to the targeted program to respond to a request for information.

Means of collecting information:

By means of web forms integrated into a website controlled by Destination Chic-Chocs.

B-

Relationship with Destination Chic-Chocs, services, program, etc.

  • Applicants and Employees

Type of personal information:

  • Name
  • Phone number
  • Email
  • Postal address
  • Social Insurance Number (SIN)
  • Date of birth
  • CV (employment experience) and reference letters
  • Language

Purpose of collection / uses:

  • Managing communications with the applicant or employee.
  • Ensuring the functioning of the payroll system.

Means of collecting information:

By means of web forms integrated into a website controlled by Destination Chic-Chocs, online questionnaires.

C-

Relationship with Destination Chic-Chocs, services, program, etc.

  • Members (Individuals and Organizations)

Type of personal information:

  • Name
  • Phone number
  • Email
  • Banking details
  • Language

Purpose of collection / uses:

Registration as a member, future communications, billing, registration for activities organized by Destination Chic-Chocs and portals (member zone).

Means of collecting information:

By means of web forms integrated into a website controlled by Destination Chic-Chocs.