PERSONAL INFORMATION PROTECTION
NOTICE ON PERSONAL INFORMATION PROTECTION
Note: The masculine gender is used only to lighten the text.
Table of contents
3. DEFINITIONS4. PERSONAL INFORMATION COLLECTED BY COFOMO
5. PURPOSES OF COLLECTING PERSONAL INFORMATION
6. UNDER WHAT CONDITIONS MAY WE COLLECT, USE AND DISCLOSE YOUR PI?
7. WHEN AND HOW CAN YOU WITHDRAW YOUR CONSENT?
8. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
9. TO WHOM IS YOUR PERSONAL INFORMATION DISCLOSED?
10. CONSERVATION OF PERSONAL INFORMATION COLLECTED
12. MEASURES FOR THE PROTECTION OF PERSONAL INFORMATION
13. YOUR RIGHTS AND HOW TO EXERCISE THEM
1. FOREWORD
Cofomo Inc. (“Cofomo”, “we”, “us” or “our”) is committed to protecting the personal information (“PI”) that it collects and processes as part of its business operations and the maintenance of its business relationships.
2. OBJECTIVE OF THE NOTICE
This Notice on Personal Information Protection (the “Notice”) describes the personal information protection (“PIP”) practices applied by Cofomo, in accordance with applicable laws, to protect the PI that we collect when you visit our website (the “website” or the “service”) at https://staging.cofomoconseil.com. By accessing the website, you consent to the collection, use, disclosure and processing of PI by Cofomo, in accordance with this notice. The Notice also describes the rights of the persons concerned with respect to their PI, including the right to access, correct or amend their PI, and the right to withdraw their consent to the collection and use of PI.
3. DEFINITIONS
“Person concerned” or “you” refers to any identified or identifiable person about whom Cofomo collects personal information through the website or during your interactions with the service.
“Personal information” refers to any information about an individual that directly or indirectly identifies that individual.
Please see the Notice on Cookies for defined terms relating to technical and usage information in connection with cookies that may be collected.
4. PERSONAL INFORMATION COLLECTED BY COFOMO
Cofomo is responsible for processing the PI it collects and ensures that it only collects PI that is necessary for its purposes and activities, including identity information, such as your names, addresses, email addresses and telephone numbers, and information relating to the use of its website.
5. PURPOSES OF COLLECTING PERSONAL INFORMATION
Cofomo uses and discloses your PI only for the purposes to which you have consented or as permitted by law. The purposes for which your PI will be used will be specified to you explicitly at the time of collection.
In general, and without limitation, Cofomo collects personal information for the following purposes:
- providing access to the website;
- providing information about its company, products and services;
- evaluating an application for a position posted on our career page for which you have submitted your PI;
- responding to communications sent through the “Contact” page;
- communicating promotional or informational material requested by the person concerned (through our newsletters) and which the person concerned can unsubscribe from by clicking on the unsubscribe link or by following the unsubscribe instructions in each email of our newsletters.
If Cofomo were to use, disclose or otherwise process the personal information of a person concerned for purposes other than those identified in this Notice, Cofomo will obtain the consent of the person concerned before using, disclosing or otherwise processing such information, except in the circumstances referred to in section 9 of the Notice.
Cofomo will not use personal information for purposes other than those for which it was collected, except with the consent of the person concerned, unless:
a) there are legal, medical or security reasons why consent cannot be obtained; or
b) Cofomo is permitted or required to do so under applicable laws.
6. UNDER WHAT CONDITIONS MAY WE COLLECT, USE AND DISCLOSE YOUR PI?
Cofomo collects, uses and discloses your personal information only with your consent in accordance with applicable requirements.
If Cofomo needs to use or disclose your personal information for purposes other than those to which you have consented, Cofomo will obtain your consent again, except in cases where other uses are permitted without consent, or where exceptions are provided by law.
Please note that when we collect personal information in a way that does not necessarily allow you to be aware of it, for example using cookies or other tracking technology, your consent is implied until you withdraw it (opt out) in accordance with your Notice on Cookies.
7. WHEN AND HOW CAN YOU WITHDRAW YOUR CONSENT?
It is possible to withdraw your consent to the use and disclosure of your personal information for purposes that are not essential to the management and administration of the products and services you have acquired.
If you choose to withdraw your consent for purposes that are essential to the management and administration of your products and services, this will generally result in the termination of your contractual relationship with us.
Any request to withdraw consent should be made to the chief privacy officer, whose contact details are set out below.
8. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
a) Directly from you
Most of the PI we collect is what you provide to us directly, such as when you:
- fill in the subscription form available on the website;
- communicate through the ‘Contact’ page of the website;
- wish to receive expert advice on a quarterly basis.
b) From third parties
For the purposes of the service, Cofomo will only collect PI about you from third parties with your consent or as permitted by law.
c) Automated interactions or technologies
Cofomo may also collect information when you browse the website, including technical and usage information, the use of which is defined in the Notice on Cookies.
d) Third party links
The service may contain links to third party websites, plug-ins and applications. Clicking on these links or allowing these connections may result in third parties collecting or exchanging PI about you. We do not control these third party components and are not responsible for their privacy policies or notices. When you leave the service to use these elements, we encourage you to read the privacy policies or notices that govern them.
9. TO WHOM IS YOUR PERSONAL INFORMATION DISCLOSED?
The PI is available to Cofomo employees on a need-to-know basis, i.e., on the condition that the PI is necessary for the performance of their duties, and based on the need to access the PI to achieve the purposes set out in this Notice. The principle of least privilege is followed in granting access to PI, based on the role and responsibilities of Cofomo employees.
The PI collected may be disclosed to:
a) affiliates of ours in connection with our provision of services to you as set out in this Notice;
b) third party suppliers used by us to provide services to you, who act as subcontractors;
c) courts, regulators, government officials or prosecutors or any other investigative or law enforcement party.
Your PI may also be disclosed to third parties if we believe, in good faith, that such action is appropriate or necessary to prevent a breach of our terms of service or any other agreement to which you are a party. This disclosure is considered solely to protect against a claim; to protect our rights, property, or safety or those of a partner, person, or the public; and to maintain and ensure the security and integrity of the service or our infrastructure from misuse or illegal use.
In addition, we will require the third party receiving your PI to agree to protect the confidentiality of your PI in accordance with this Notice and to comply with the privacy laws to which they are subject. They will also be required to agree to process your PI only in accordance with this Notice, unless you provide prior notice, and where required by law, by obtaining your consent.
10. CONSERVATION OF PERSONAL INFORMATION COLLECTED
Cofomo uses systems and technology service providers to ensure that your personal information is stored in a manner that maintains its confidentiality.
The PI collected is generally stored in the province of Quebec. However, it is possible that the disclosure of collected PI to certain service providers may result in the transfer of such PI outside of Quebec, in which case Cofomo will consult the applicable PIP laws and practices in the relevant jurisdiction and ensure that it provides adequate protection for your PI.
Cofomo will only retain PI for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet legal, accounting and disclosure requirements, and to enforce or defend its rights.
In determining the appropriate length of time to retain your PI, we consider the amount, nature and sensitivity of the PI, the level of risk and severity of unauthorized use or disclosure, and whether we can accomplish the purposes by other means, as well as applicable legal, regulatory, tax, accounting and other obligations.
11. CHIEF PRIVACY OFFICER
Cofomo has appointed a Chief Privacy Officer (the “CPO”) who is responsible for ensuring that Cofomo complies with applicable privacy laws.
If you have any questions about your PI and about the collection, use, disclosure or storage of PI, please contact Cofomo’s Chief Privacy Officer, whose contact information is indicated below.
Chief Privacy Officer – Alain Plante
1000 De La Gauchetière Street West
Suite 1500
Montreal, Quebec
H3B 4W5
Tel.: +1-514-866-0039
Email: vieprivee@cofomo.com
12. MEASURES FOR THE PROTECTION OF PERSONAL INFORMATION
Cofomo is committed to protecting the confidentiality, integrity, availability and privacy of your PI, using safeguards that are customary in the industry and reasonable for the sensitivity of the PI, including physical, electronic and organizational security measures.
Cofomo restricts access to its offices (physical security), provides training on PIP concepts, restricts access to PI to its staff on a need-to-know basis, uses strong passwords, and implements well-defined internal policies and practices that include ensuring that Cofomo staff can only process your PI in accordance with these policies.
In all cases of transfer of your PI outside of Quebec, we ensure that your PI will be handled securely in accordance with this Notice and that no transfer of your PI will be made to any organization or country unless appropriate or tailored safeguards are in place, including the security of your PI, such as standard contractual clauses or a privacy impact assessment. These standard contractual clauses or other appropriate or tailored safeguards for this transfer outside of Quebec can be obtained upon request from Cofomo’s CPO, whose contact information is indicated in paragraph 11.
All Cofomo employees are bound by a commitment to confidentiality, which includes keeping your PI confidential.
Unfortunately, the transmission of information over the Internet is not completely secure. While Cofomo makes every effort to protect your PI, we cannot guarantee the security of PI transmissions through the service or the job application form or spontaneous application. Any transmission of the PI of a person concerned through the website is made at their own risk. Once we receive PI from a person concerned, we apply our security measures to try to prevent unauthorized access, use and disclosure.
13. YOUR RIGHTS AND HOW TO EXERCISE THEM
As a person concerned whose PI has been collected by Cofomo, you may, at any time, exercise any of the above rights by contacting the CPO, whose contact details are indicated in paragraph 11.
Cofomo respects your legal rights with respect to your PI and has procedures in place to handle the following requests:
a) Access: You have the right to consult your PI that we retain or to request a copy of it. However, we may not provide you with PI about yourself where disclosure would reveal PI about another individual or would violate applicable laws.
Access to your PI is free of charge. In certain circumstances, such as where the request is excessive or unfounded, Cofomo may charge you an administration fee for transcribing, reproducing or transmitting your PI. Before processing a request, Cofomo will inform the person concerned if a fee is to be charged.
b) Accuracy: We aim to ensure that your PI is accurate, up-to-date and complete. We encourage you to contact the CPO, whose contact details are indicated in paragraph 11, to advise us if any of your PI is not accurate or if any changes have been made to it so that we can ensure that it is kept up to date.
c) Withdrawal of consent: In certain circumstances, you also have the right to object to the processing of your PI and to ask us to block, erase and limit access to it, for purposes that are not essential to the management and administration of our products and services. A withdrawal of consent for a purpose essential to the provision of Cofomo’s services will terminate your contract.
d) Portability (requirement effective September 2024): You have the right to request that some of your PI be provided to you, or another processing officer, in a structured, commonly used and readable format via a technological solution.
e) Complaints: If you believe that your privacy rights may have been infringed, you have the right to lodge a complaint with the applicable supervisory authority or have recourse to the courts.
Cofomo will respond to all requests within 30 days of receiving such a request. Where Cofomo is unable to meet this deadline, or where additional time is required to comply with a request, we will inform the person concerned in writing.
14. UPDATING AND REVISION
a) Applicable version
The Notice takes effect on the date mentioned at the very beginning of the Notice and replaces all previous versions. The version history of this Notice may be obtained from the CPO upon request. The collection, use, disclosure and other processing by Cofomo of the PI of a person concerned will be governed by the version of the Notice in effect at that time.
b) Changes to the Notice
Privacy laws are constantly evolving and, as a result, this Notice may be amended from time to time by Cofomo, at its sole discretion. Changes to this Notice will be posted on the website’s home page for a period of time to notify you of such changes. Where such changes are material or require your consent, we will notify you by any means to obtain such consent, prior to any potential use of PI.
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CNESST Licence :AR-2202537, AP-2202662, AP-2000230, AR-2000231