Privacy policy
DATE OF LAST UPDATE : Therrien Couture Joli-Coeur s.e.n.c.l. 2025-02-12
Therrien Couture Joli-Cœur L.L.P. (hereinafter referred to as “TCJ”) believes that the protection of Personal Information is of paramount importance. It is for this reason that it has established this privacy policy (hereinafter referred to as the “Policy”), the purpose of which is to protect your integrity and your right to decide whether or not to disclose your Personal Information.
This Policy sets out how TCJ collects, uses, discloses, processes and protects your Personal Information. By using TCJ’s website https://www.groupetcj.ca/ (the “Website”) or by transacting with TCJ, you agree that TCJ may collect, use, process, disclose and retain your Personal Information in accordance with the terms described herein. If you do not agree to abide by and be bound by this Policy, you are not authorized to visit, access or use the Website, nor to share your Personal Information with it in connection with the mandates you entrust to TCJ.
TCJ’s privacy practices comply with the following laws:
- the Personal Information Protection and Electronic Documents Act (the “PIPEDA”—federal legislation);
- the Act respecting the protection of personal information in the private sector (the “Bill 25”—provincial legislation).
All Personal Information is collected in a fair and non-intrusive manner and with your consent. All Personal Information collected is accessible only to those persons who require it to fulfill the purposes for which it is collected. TCJ is committed to respecting the privacy of its clients, employees, applicants, and all users of its Website who voluntarily choose to provide their Personal Information. TCJ recognizes the importance of protecting and managing the Personal Information you provide. This Policy will help you understand the type of information it collects, how it will be used and to whom it may be disclosed.
This Policy explains TCJ’s practices regarding the information it collects from users of its Website.
1. TCJ’S COMMITMENT TO THE TEN PRIVACY PRINCIPLES
In Canada, the “Fair Information Principles” regarding Personal information are contained in a series of 10 principles developed by the CSA Group and incorporated in Canada’s privacy legislation. TCJ complies with the following 10 privacy principles:
Principle 1 - Accountability
TCJ is responsible for the Personal Information under its control and has designated a Data Protection Officer who is accountable and responsible for TCJ’s compliance with this Policy and the applicable laws.
Contact details:
Data Protection Officer
801, Grande Allée Ouest, Suite 300
Québec (Quebec) G1S 1C1
privacy@groupetcj.ca
Principle 2 - Identifying Purposes
TCJ shall identify the purposes for which the Personal Information is collected before or at the time the information is collected. Some of the purposes for which the Personal Information is collected, used and/or disclosed are described in this Policy. In the event that TCJ wishes to collect, use and/or disclose Personal Information for purposes other than those described in this Policy, TCJ will obtain your consent.
Principle 3 - Consent
TCJ is committed to obtaining your informed consent for the collection, use or disclosure of your Personal information, except as required by law.
Principle 4 - Limiting Collection
TCJ will limit the collection of Personal Information, both the type and the amount of information, to that which is necessary to fulfill the purposes identified by TCJ. TCJ will collect your Personal Information by fair and lawful means and not by misleading or deceiving you about the purposes for which it is collected.
Principle 5 - Limiting Use, Disclosure and Retention
TCJ will not use or disclose your Personal Information for purposes other than those identified and for which it was collected, except with your prior consent or as permitted or required by law. TCJ will retain your Personal Information only as long as necessary to serve the purposes for which your Personal Information was collected.
In addition, retention periods may be modified from time to time in response to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and breaches, or to prosecute criminals).
You can also rest assured that once the purpose for which the information was collected has been fulfilled, TCJ will destroy or anonymize it in accordance with the law.
Principle 6 - Accuracy
TCJ will attempt to ensure that your Personal Information is accurate, complete and up-to-date as possible for the purposes for which it was collected.
Principle 7 - Safeguards
TCJ will protect your Personal Information using security safeguards appropriate to the sensitivity of the information. TCJ has achieved ISO 27001:2013 certification in information security management.
Principle 8 - Openness
TCJ will make available to you information about its policies and practices relating to the management of Personal Information.
Principle 9 - Individual Access
Subject to certain exceptions, TCJ will, upon written request to the Data Protection Officer, disclose the existence, use and disclosure of your Personal Information and give you access to that information. An individual shall be able to challenge the accuracy and completeness of the information held by us and have it amended as appropriate.
Principle 10 - Challenging Compliance
You have the right to file a complaint to the Data Protection Officer about compliance with this Policy.
2. CONSENT
2.1 This Policy applies to all information collected by and on behalf of TCJ, whether collected in writing, verbally or electronically or through any website operated by or on behalf of TCJ. By browsing the Website, or transacting with TCJ, you consent to the collection and use of your Personal Information in accordance with the purposes described herein.
2.2 By submitting Personal information to TCJ and/or by browsing and using the Website, you consent to TCJ’s collection, use and disclosure of such Personal Information in accordance with this Policy and subject to the terms and conditions permitted or required by law.
3. CONSENT TO THE SHARING AND DISCLOSURE OF PERSONAL INFORMATION
In addition to consenting to the terms and conditions of this Policy, including any applicable supplemental policies, you consent to TCJ sharing your Personal Information that you have provided to TCJ on the terms and conditions set forth herein.
4. NATURE OF THE INFORMATION COLLECTED BY TCJ
4.1 “Personal Information” means any information concerning the personal or material situation of an identified or identifiable person. An identifiable person is one who can be identified, directly or indirectly, by reference to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
Personal information includes, but is not limited to, a person’s first and last name, home address, home telephone number, cellular telephone number, e-mail address and any employment information, such as may be found in a resume, background check information or references from previous employers.
4.2 “Non-personal Information” means any information in the public domain. Information of a professional nature is considered non-personal information and therefore not subject to special protection and may be regularly shared with persons both inside and outside TCJ. Business information includes, but is not limited to, company name, address, e-mail address, business telephone number and is not considered personal information in some jurisdictions.
4.3 “Sensitive Personal Information” means Personal Information which, by its nature or the context in which it is used or disclosed, gives rise to a high reasonable expectation of privacy.
4.4 In the course of its activities, TCJ may collect, process and use various types of Personal information, only if permitted by law, including the information listed below:
- contact information, such as your first and last name, e-mail address and telephone number, to subscribe to its newsletter;
- contact information, such as your first and last name, e-mail address and job title, to register for its events;
- contact information, such as your first and last name, e-mail address, telephone number, university, areas of interest, eligibility to an internship, resume and cover letter, to submit an unsolicited application; and
- contact information, such as your first and last name, e-mail address, telephone number, the subject of your request and any other information you voluntarily submit to TCJ when you use the “Write us” section of the Website.
5. INTERNET USERS—COOKIES, INTERNET PROTOCOL (IP) ADDRESSES AND BROWSING INFORMATION
5.1 Cookies — In addition to Personal Information, TCJ uses information-gathering tools such as cookies on certain pages of its Website in order to analyze navigation on its Website. Cookies are small pieces of information that are sent by a website to an Internet user’s hard drive when he or she visits a webpage. Cookies allow the site to save important information that will make your visit to the site more useful. TCJ uses cookies to improve your subsequent visits. If you do not wish to receive cookies, or if you wish to set your browser to notify you each time a cookie is being sent, or if you wish to disable all cookies, use the “Cookie settings” section and/or your browser options to do so. Your browser’s “Help” option can guide you through changing your cookie preferences. Please note that if you disable cookies, you may not be able to access of some of the Website’s features.
Cookies may cease to exist at the end of a browsing session (a browsing session is defined as the time at which the Internet user opens his or her browser to the time at which he or she leaves his or her browser) or cookies may be retained for a longer or even indefinite period.
5.2 Persistent cookies—Persistent cookies are stored on the user’s hard drive and survive the end of sessions, making it possible to save a user’s preferences or actions between different pages of the same website (or in some cases between different websites). Persistent cookies may be used for a variety of purposes, such as saving a user’s choices and preferences while visiting the Website.
5.3 For more information on cookies, including how to view, manage and delete the cookies saved on your computer and how to prevent their storage, TCJ invites you to consult the “Cookie settings” section of its Website. This will allow you to adjust your browser settings to your desired level of protection.
5.4 Internet Protocol (IP) Address—An Internet Protocol (IP) address is assigned to your computer’s Internet connection by your Internet service provider. TCJ may use this address to diagnose problems with its Web servers, to administer its Website and to maintain contact with an Internet user while he or she is visiting its Website. The IP address of your connection may also be used to provide you with information based on the location from which you are browsing the Website. TCJ does not associate your IP address with your Personal Information.
5.5 Browsing information is used to measure interest in and use of certain parts of TCJ’s Website, as well as the effectiveness of certain promotional programs administered by or on behalf of TCJ. This information consists of statistical data regarding the duration of the visit, the pages consulted and the order in which they were viewed, and cannot identify you. TCJ performs statistical analysis of this browsing information in order to establish profiles of Internet users and determine their behaviour and characteristics. While TCJ may share this information with third parties, none of this information can identify you or any Personal Information about you.
5.6 TCJ also uses the services of Google Analytics to collect browsing information on its Website. To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
6. USE OF YOUR PERSONAL INFORMATION
6.1 TCJ uses your Personal Information to facilitate the processing of your requests. TCJ has developed a customized Privacy Policy to inform you about the use of your Personal Information.
6.2 TCJ may contact you directly by e-mail, mail or telephone for the purposes described herein, including to offer you some of its new or existing services.
6.3 TCJ may use your Personal Information for the legitimate purposes described below:
- provide you with services and carry out mandates;
- allow you to subscribe to its newsletters;
- verify your identity and review your personal history, as permitted by law;
- operate, maintain, supervise, develop, improve and offer all the functionalities of its Website;
- manage risks and operations;
- meet its obligations under applicable laws and regulations;
- detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities;
- send you communications in accordance with the law;
- allow the function to apply for a job with TCJ; and
- serve any other purpose permitted or required by law.
6.4 TCJ will not use any Personal Information collected in accordance with this Policy or with any other law or regulation for any other purpose whatsoever unless it has obtained your prior consent, except in certain exceptional circumstances where TCJ reasonably and in good faith believes that it is required to do so by law.
7. SHARING OF PERSONAL INFORMATION
7.1 TCJ does not sell, transfer or assign any Personal Information to third parties. TCJ may, however, share Personal Information with its service providers, some of whom are located outside of Quebec but within Canada, or in Europe, its consultants or its subsidiaries for its internal business purposes. Except as described in this Policy, TCJ will not disclose any Personal Information to third parties unless requested to do so by the client, the client consents to such disclosure, or such disclosure is necessary or permitted by law.
7.2 TCJ may share your Personal Information with its agents, affiliates or service providers who act for or on behalf of TCJ in the course of TCJ’s business, or with anyone who processes the data in accordance with the purposes for which it was obtained (such as the maintenance of its secure databases). TCJ enters into written contracts with service providers before disclosing any of your Personal Information to them and only provides them with the Personal Information they need to carry out their mandate. As part of these contracts, TCJ undertakes to comply with the principles set out in this Policy, and these service providers are required to use Personal Information in accordance with TCJ’s instructions and only for the purposes for which it was provided. In addition, these service providers provide TCJ with sufficient guarantees that they will implement adequate safeguards that are proportionate to the sensitivity of the Personal Information being processed or disclosed. When its service providers no longer need your Personal Information, TCJ asks them to destroy it in an appropriate manner.
7.3 The Personal Information you provide to TCJ is considered an asset and may be disclosed or transferred to a third party in the event of a sale (proposed or completed), lease, merger, or other type of acquisition, sale, financing of all or a portion of TCJ or any business assets or shares of TCJ or any of its divisions, provided, however, that such disclosure or transfer shall not affect the products or services rendered to clients by the third party.
7.4 While TCJ makes reasonable efforts to maintain the confidentiality of Personal Information, TCJ reserves the right to disclose Personal Information to a third party under specific circumstances, including to respond to requests from public and governmental authorities; to comply with any law, regulation, search warrant, subpoena, legal process, court order or as otherwise required by law; to enforce its policies or contracts, in debt collection; to protect users of its sites from fraudulent or abusive use; in emergency situations where security is compromised, as determined by TCJ; or otherwise when necessary to establish, exercise or defend against any legal action. In addition, from time to time, TCJ’s server usage reports may be reviewed for security reasons, including to detect unauthorized activity on its Website. In this case, the server data, including IP addresses, would be shared with the authorities so that they can identify users in connection with the investigation of unauthorized activity.
8. YOUR RIGHTS
8.1 As a data subject, you may exercise the rights set out below by completing the form available at privacy@groupetcj.ca and sending it by secure e-mail or by mail to the attention of the DPO at the contact details set out in section 13 of this Policy:
- You have the right to access the Personal Information TCJ holds about you and to request a paper copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;
- You have the right to have the Personal Information TCJ holds about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
- You have the right to withdraw or change your consent to TCJ’s collection, use, disclosure or retention of your Personal Information at any time, subject to applicable legal and contractual restrictions;
- You have the right to ask TCJ to stop disseminating your Personal Information and to de-index any link attached to your name that gives access to this information if such dissemination contravenes the law or a court order; and
- You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions set out in the applicable law.
In order to process your request, you may be asked to provide appropriate identification or to identify yourself in some other way.
9. LINKS TO EXTERNAL WEBSITES BELONGING TO THIRD PARTIES
9.1 Please note that TCJ’s Website may contain links to other websites that are not affiliated with TCJ. TCJ has no control over these websites or their privacy practices, which may differ from those of its Website. This Policy cannot and does not apply to any external website. TCJ does not endorse or make any representations about third-party websites. Any Personal Information that you choose to provide to third parties is not covered by this Policy. TCJ encourages you to review the privacy policy of any company or website before submitting any Personal Information. Third parties may choose to share the Personal Information they hold with TCJ; such sharing is subject to that third party’s privacy policy.
10. SENSITIVE PERSONAL INFORMATION
In the course of its business, it is unlikely, but not impossible, that in certain circumstances TCJ may need to collect Personal Information considered to be of a sensitive nature, when it is strictly necessary for its operations. In such cases, TCJ will ensure that it has your express consent to do so, in accordance with the law.
11. LIMITATION OF LIABILITY
TCJ undertakes to take all reasonable measures to ensure a level of confidentiality and security of Personal Information that complies with technological standards appropriate to its sector of activity.
Notwithstanding the foregoing, you declare that you understand and acknowledge that no computer system offers absolute security and that there is always some degree of risk involved in transmitting Personal Information over the public network that is the Internet.
You acknowledge that TCJ shall not be liable for any breach of confidentiality, hacking, virus, loss, theft, misuse or alteration of Personal Information transmitted or hosted on its systems or those of a third party. You also waive any claim in this regard, except in the case of gross or intentional fault on the part of TCJ. Accordingly, you agree to hold TCJ and its officers, directors, affiliates and business partners harmless from any damages of any kind, whether direct or indirect, incidental, special or consequential, arising out of or in connection with the use of your Personal Information.
12. PERSONS UNDER 14 YEARS OF AGE
TCJ does not knowingly collect or use Personal Information from persons under the age of 14. If you are under 14 years of age, you must not provide TCJ with your Personal Information without the consent of your parent or guardian. If you are a parent or guardian and become aware that your child has provided TCJ with Personal Information without consent, please contact TCJ using the contact details set out in section 13 below to request that TCJ deletes that child’s Personal Information from its systems.
13. DATA PROTECTION OFFICER
If you have any comments, questions or complaints, please do not hesitate to contact the Data Protection Officer:
Data Protection Officer
801, Grande Allée Ouest, Suite 300
Québec (Quebec) G1S 1C1
privacy@groupetcj.ca
14. CHANGES TO THE PRIVACY POLICY
This Policy is effective as of September 22, 2023. TCJ reserves the right to update this Policy at any time. When TCJ makes changes to this Policy, it will also change the “Last Update” date at the top of the first page of the Policy. TCJ encourages you to periodically review this Policy to be informed of how TCJ is protecting your information and to be notified of any changes to the Policy. Your use of the Website after the posting of an amended Policy constitutes your consent to be bound by such changes. This Policy is incorporated into all terms and conditions governing the various websites and all programs and services used or operated for or on behalf of TCJ. Any changes to this Policy are effective immediately upon posting by TCJ.
15. CONDITIONS OF USE OF TCJ’S WEBSITE
The terms and conditions governing your use of the Website can be found at https://www.groupetcj.ca/en/terms-and-conditions.html (the “Terms”) and contain important provisions that disclaim and exclude TCJ’s liability for your use of its Website. The Terms also contain provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute regarding your use of this Website. All of these provisions apply to any disagreements or disputes that may arise in connection with this Policy and the collection, use and disclosure of your Personal Information. These Terms have the same effect as if they had been reproduced in full in this Policy.