DATE OF LAST UPDATE : Therrien Couture Joli-Coeur s.e.n.c.l. 2023-09-22
This Policy sets out how TCJ collects, uses, discloses, processes and protects your Personal information. By using our website https://www.groupetcj.ca/ (the "Website") or by transacting with us, you agree that we 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 our Website, nor to share your Personal information with us in connection with the mandates you entrust to us.
Our privacy practices comply with the following laws
- The Personal Information Protection and Electronic Documents Act (PIPEDA - federal legislation)
- Act respecting the protection of personal information in the private sector (Bill 25 - provincial legislation)
All Personal information is collected in a fair and non-intrusive manner and with your consent. Personal information collected is accessible only to those persons necessary to fulfill the purposes for which it is collected. TCJ is committed to respecting the privacy of its customers, employees, applicants, and all visitors to its Website who voluntarily choose to provide us with Personal information. We recognize the importance of protecting and managing the Personal information you provide to us. This Policy will help you understand what information we collect, how it will be used and to whom it may be disclosed.
This Policy explains TCJ's practices regarding information collected from its users via 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 Canadian Standards Association and enshrined in Canadian privacy legislation PIPEDA. TCJ complies with the following 10 privacy principles:
Principle 1 - Responsibility
TCJ is responsible for 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 applicable laws.
Here are his contact details:
Data Protection Officer
1100 René-Lévesque West, Suite 2000
Montréal (Québec) H3B 4N4
Principle 2 - Identifying Purposes
TCJ shall identify the purposes for which Personal information is collected at or before the time the information is collected. Some of the purposes for which Personal information is collected, used and/or disclosed are described in this Policy. In the event that we wish 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 we are collecting your Personal information.
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 fulfill the purposes for which your Personal Information was collected.
In addition, our 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, we 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, current and necessary 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 holds ISO 27011:2013 certification in information security management.
Principle 8 – Openness
TCJ will make available to you information about our policies and practices relating to the management of Personal information.
Principle 9 - Individual Access
Subject to certain exceptions, TCJ will, upon written request to our Data Protection Officer, disclose the existence, use and disclosure of your Personal information and provide you with 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 our Digital Privacy Officer about our compliance with this Policy.
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 us on the terms and conditions set forth herein.
4. NATURE OF THE INFORMATION WE COLLECT
4.1 "Personal information" means any information concerning the personal or material situation of an identified or identifiable individual. 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.
4.2 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 employment information, such as may be found in a resume, background check information or references from previous employers.
4.3 "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.
4.4 "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.
4.5 In the course of our activities, we may collect, process and use various types of Personal information that you give us only if we are permitted to do so 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 our newsletter;
- contact information, such as your first and last name, e-mail address and job title, to register for our events;
- contact information, such as your first and last name, e-mail address, telephone number, university, areas of interest, eligibility to complete the internship, CV and cover letter, to submit an unsolicited application to us; 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 us when you use the "Write to us" section.
5. INTERNET USERS - COOKIES, INTERNET PROTOCOL (IP) ADDRESSES AND BROWSING INFORMATION
5.2 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/her browser to the time at which he/she leaves his/her browser) or cookies may be retained for a longer or even indefinite period.
5.3 Persistent cookies - These 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 https://tools.google.com/dlpage/gaoptout.
5.4 For more information on cookies, including how to view the cookies that have been deposited on your computer, how to manage them, how to prevent cookies from being deposited and how to delete them, we invite you to consult the Manage my cookies section of our Website. This will allow you to adjust your browser settings to your desired level of protection.
5.5 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 Web Site and to maintain contact with an Internet user while he or she is visiting its Web Site. The IP address of your connection may also be used to provide you with information based on where you are browsing the Website from. TCJ does not associate your IP address with your Personal information.
5.6 Navigation information - is used to measure interest in and use of certain parts of our Web Site, as well as the effectiveness of certain promotional programs administered by or on behalf of TCJ. This information cannot identify you; rather, it is statistical data regarding the duration of the visit, the pages consulted, and the order in which the pages were visited. TCJ performs statistical analysis of this browsing information in order to establish profiles of Internet users and determine their behavior and characteristics. TCJ may share this information with third parties; however, none of this information can identify you or determine anything personal about you.
5.9 We also use the services of Google Analytics to collect navigation information on our Website. To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout
6. HOW WE USE YOUR PERSONAL INFORMATION
6.2 TCJ may contact you directly by email, post or telephone for the purposes described herein, for example to offer you some of our 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 our newsletters;
- to verify your identity and review your personal history, as permitted by law;
- operate, maintain, supervise, develop, improve and offer all the functionalities of our Website;
- to manage risk and operations;
- to meet our 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
- for any other purpose permitted or required by law.
6.4 TCJ will not use any Personal Information collected pursuant to this Policy or pursuant to 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. We may, however, share Personal Information with our service providers, some of whom are located outside of Quebec but within Canada, or in Europe, our consultants or our subsidiaries for our 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 customer, the customer consents to such disclosure, or such disclosure is necessary or permitted by law.
7.2 We may share your Personal Information with our 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 our secure databases). When we disclose your Personal Information to service providers, we enter into written contracts with them before disclosing your Personal Information to them, and we only provide them with the Personal Information they need to carry out their mandate. As part of these contracts with our service providers, we undertake to comply with the principles set out in this Policy, and these service providers are required to use Personal Information in accordance with our instructions and only for the purposes for which it was provided. In addition, these service providers provide us with sufficient guarantees that they will implement adequate safeguards that are proportionate to the sensitivity of the personal information being processed or disclosed. When our service providers no longer need your personal information, we ask them to destroy it in an appropriate manner.
7.3 The Personal information you provide to TCJ is considered an asset of the company 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 customers by the third party.
7.4 While we make reasonable efforts to maintain the confidentiality of Personal information, TCJ reserves the right to disclose Personal information to a third party under certain specific circumstances, including: to respond to requests from public and governmental authorities, to comply with law, regulation, search warrant, subpoena, legal process, court order or as otherwise required by law, to enforce our policies or contracts, in debt collection, to protect users of our 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, our server usage reports may be reviewed for security reasons; for example, to detect unauthorized activity on our Website. In this case, the data on the servers, 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 firstname.lastname@example.org and sending it by secure e-mail or by post to the attention of our DPO at the contact details set out in section 13.1 of the Policy:
- You have the right to access the Personal Information we hold 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 we hold 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 us 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
10. SENSITIVE PERSONAL INFORMATION
In the course of our business, it is unlikely, but not impossible, that in certain circumstances we may need to collect Personal Information considered to be of a sensitive nature, when it is strictly necessary for our operations. In such cases, we will ensure that we have 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 agree 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 negligence or intentional misconduct 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. INDIVIDUALS UNDER 14 YEARS OF AGE
We do 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 us 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 us with Personal Information without consent, please contact us using the contact details set out in section 14.2 above to request that we delete that child's Personal Information from our systems.
13. OUR DIGITAL PRIVACY OFFICER
If you have any comments, questions or complaints, please do not hesitate to contact the Digital Privacy Officer.
Data Privacy Officer
1100 René-Lévesque West, Suite 2000
Montreal (Quebec) H3B 4N4
15. CONDITIONS OF USE OF OUR WEBSITE