Privacy policy
1. Introduction and Scope
The Fédération des Chambres de Commerce du Québec (“FCCQ”) and the Chambre de commerce du Montréal métropolitain (“CCMM”) (hereinafter referred to as “we” or “us”) are committed to protecting the privacy and security of information in accordance with Canadian and Quebec laws regarding the protection of Personal Information (as hereinafter defined).
Accordingly, we are adopting this privacy policy (the “Policy”) which addresses the protection of Personal Information collected from users of the website https://visees.ca/ (the “Website”), jointly operated by the FCCQ and the CCMM, as well as from individuals who communicate with us using the email address available in the box “Why subscribe to the Visées program newsletter?” (“you”). It demonstrates the importance we give to transparency in the way we collect, use and communicate your Personal Information.
For clarity, this Policy does not apply to Personal Information collected on Visées program participants once they have been admitted.
2. What do we collect, how and why
Personal Information means any information pertaining to a natural person which, directly or indirectly, allows that person to be identified.
In general, we collect only the Personal Information necessary to establish, manage and maintain our business relationship with you.
In order to contact you, compile a list of contacts interested in the program and keep you informed of its progress, we collect the following information via the “Why subscribe to the Visées program newsletter” box:
- Last name, First name;
- Email address;
- City
- Phone number;
To facilitate the navigation on the Website we may collect information by using cookies. Kindly refer to section 8 for more details.
We only use your Personal Information for the purposes stated above except where we are permitted by law, in very limited circumstances, to do so without your consent.
3. Your Consent
BY VISITING, USING THE WEBSITE OR OTHERWISE COMMUNICATING WITH US, YOU AGREE TO BE BOUND BY THIS POLICY AND CONSENT TO THE COLLECTION, USE, RETENTION, DISCLOSURE AND DESTRUCTION OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE TERMS DESCRIBED HEREIN. IF OTHER TERMS APPLY, WE WILL DESCRIBE THEM AT THE TIME OF COLLECTION.
If you do not want your Personal Information to be collected, used or disclosed in this manner, then please either refrain from providing it to us or exercise your right to withdraw your consent.
YOU UNDERSTAND THAT CERTAIN FEATURES OF OUR WEBSITE MAY NO LONGER BE ACCESSIBLE OR MAY BE RESTRICTED FOLLOWING YOUR REFUSAL TO PROVIDE THE REQUIRED INFORMATION OR THE WITHDRAWAL OF YOUR CONSENT.
4. Security and Governance
Information security is a priority for us. As such, we have adopted policies and practices to manage our governance with regards to the protection Personal Information that include:
- A framework applicable to the use, communication, retention and destruction of such information;
- The roles and responsibilities of our employees throughout its life cycle;
- A process for handling complaints concerning its protection.
Each employee who uses Personal Information is bound by confidentiality obligations and has received appropriate training. In addition, each employee may only access Personal Information that is necessary for the performance of his or her duties. In the event of a breach, our governance policies and practices provide for sanctions.
5. Disclosure of Your Personal Information
We may disclose Personal Information to third parties with your consent or, without your consent, in specific circumstances permitted by law. The following table summarizes these circumstances and the steps we take to protect such information.
Recipient
Description and purpose
Steps
Service providers, agents, subcontractors (“Subcontractors”)
We may enter into contracts with Subcontractors to provide a service to our clients, such as a Website feature.
The contract requires Subcontractors to:
- Use Personal Information only for providing the service.
- Refrain from disclosing or communicating Personal Information without our authorization.
- Implement rigorous security measures.
- Allow us to audit these measures.
- Notify us immediately of a confidentiality incident.
- Destroy Personal Information at the end of the contract.
These authorities are required by their governing laws to establish measures to respect and preserve the confidentiality of your Personal Information.
We inform our partners of any requests from legitimate authorities to access Personal Information about their employees. We decline to provide access where the request is not legally binding.
Another party in a Business Transaction
We may enter into a contract with a third party to conclude a Business Transaction. Such transaction is defined as the disposition or lease of all or part of our business or its assets, a change in our legal structure by merger or otherwise, the obtaining of a loan or other form of financing or a security interest taken to secure any of our obligations (“Business Transaction”).
The contract requires the other party to:
- Use Personal Information only for the purposes of entering into the Business Transaction.
- Implement rigorous security measures.
- Refrain from disclosing or communicating Personal Information without our authorization.
- Notify us immediately of a confidentiality incident.
- Destroy Personal Information if the Business Transaction is not entered into or the Personal Information is no longer necessary for entering into the Business Transaction.
Our legal counsel
In order to defend or enforce our rights, we may, in certain circumstances, disclose your Personal Information.
Both the law and the retainer agreements we sign require our lawyers to protect the confidentiality of all our communications with them.
6.Retention
We retain Personal Information about you only as long as necessary to fulfill the purpose for which it was collected or to comply with legal retention requirements.
We reserve the right to establish Personal Information destruction policies from time to time. If you request the destruction of your Personal Information, we will use reasonable efforts to comply with your request unless we are allowed or required by the law to keep it.
7.Your Rights
You have the following rights:
- The right to change or withdraw your consent to the collection, use and disclosure of your Personal Information. Withdrawal of your consent will not have retroactive effect and may affect your ability to access our services, offers and content.
- The right to have access to your Personal Information.
- The right to have your Personal Information corrected if it is inaccurate or misleading and to have it completed if it is incomplete.
- The right to obtain your Personal Information in a commonly used digital form (i.e. right to data portability).
- The right to be informed of a confidentiality incident involving your Personal Information that may cause you serious injury.
You may exercise these rights, at any time by sending written notice to the Privacy Officer whose contact information can be found at the end of this document.
We will respond to any request within 30 days of receipt, except where the law permits an extension of that period. If we refuse to provide or correct the information, we will provide you with the reasons for the refusal, the applicable sections of the law and information about your remedies, all subject to the limitations of the law.
If we refuse to rectify your Personal Information, we will allow you to place comments in your file in respect of the Personal Information for which rectification has been refused. We will also retain the Personal Information that has been the subject of an access request for as long as necessary to allow you to exhaust any recourse provided by law.
8. Cookies
- Definition
A cookie is a small text sent by a server to your browser, which it will send back the next time it connects to servers sharing the same domain name.
When you visit the Website for the first time, a pop-up window will allow you to accept or reject certain categories of cookies.
If you wish, you can set your browser to notify you when you receive cookies or to refuse them. You do not need to accept the non-essential cookies to visit our Website. However, if you refuse them, you could be unable to use some of its features.
- Types of cookies
Essential cookies: These essential cookies are crucial to the website’s basic functions, and the Website will not function as intended without them.
Functional cookies: These cookies are used to perform certain functions, such as sharing Website content on social media platforms, collecting comments and other third-party functionalities.
Performance-related cookies: These cookies are used to understand and analyze key performance indicators of the Website, thereby providing visitors with a better user experience.
Analytical cookies: These cookies are anonymous and are used to collect statistics on the use of the Website.
Advertising cookies: These cookies may be added by the Website or by other ad-serving sites. They are used to provide visitors with personalized advertisements based on previously visited pages and to analyze the effectiveness of the advertising campaign.
9. Privacy Officer
If you have any questions or requests regarding the Policy, you can send an e-mail to our Privacy Officer using the following address: annik.larin@fccq.ca
10. Privacy Officer
We reserve the right to change the content of this Policy at any time. Any changes will be posted on our Website and brought to your attention when you log in. We recommend that you print a copy of this Policy for your records and review this section of our Website periodically.