This policy aims to ensure the protection of personal information and to frame the way in which Les Innovations ADAPTIVA Inc. collects, uses, discloses, retains, and destroys it or otherwise manages it. Moreover, it seeks to inform anyone interested in how Les Innovations ADAPTIVA Inc., in partnership with BOURRASQUE, processes their personal information. It also concerns the processing of personal information collected by Les Innovations ADAPTIVA Inc. through technological means, in collaboration with BOURRASQUE.
This policy applies to Les Innovations ADAPTIVA Inc., which notably includes its executives, employees, consultants, volunteers, as well as any other person who otherwise provides services on behalf of Les Innovations ADAPTIVA Inc.. It also pertains to the Les Innovations ADAPTIVA Inc. website, as well as all websites controlled and maintained by Les Innovations ADAPTIVA Inc..
It covers all types of personal information managed by Les Innovations ADAPTIVA Inc., whether it be information about its current or potential customers, consultants, employees, members, or any other individuals (such as website visitors or others).
For the purposes of this policy, personal information is information about an individual that directly or indirectly identifies them. For instance, this could be the name, address, email address, phone number, gender, or banking details of a person, information about their health, ethnic origin, language, etc.
Sensitive personal information is information for which there is a high degree of reasonable expectation of privacy, e.g., health details, banking information, biometric data, sexual orientation, ethnic origin, political views, religious or philosophical beliefs, etc.
Generally, a person’s business or professional contact details do not constitute personal information, for example, a person’s name, title, address, email address, or work phone number. More specifically, and for clarity, as per the Personal Information Protection Act in the private sector of Quebec, and starting from September 22, 2023, sections 3 (collection, use, disclosure), 4 (retention and destruction), and 6 (data security) do not apply to information about a person relating to the performance of a role in a company, such as their name, title, role, and the address, email, and phone number of their workplace.
The same sections also do not apply to personal information that is public by law, from the effective date of this policy onwards.
In the course of its operations, Les Innovations ADAPTIVA Inc. may collect various types of information for various purposes. The types of information that Les Innovations ADAPTIVA Inc. might collect, their intended use, and the means by which they are collected are detailed in Annex A of this policy.
Les Innovations ADAPTIVA Inc. will also inform the concerned individuals, at the time of collecting personal information, of any other information gathered, the purposes for which they are collected, and the means of collection, in addition to other mandatory information required by law.
Les Innovations ADAPTIVA Inc. adheres to the following general principles regarding the collection, use, and disclosure of personal information:
Consent
Generally, Les Innovations ADAPTIVA Inc. collects personal information directly from the concerned individual with their consent unless a legal exception applies. Consent may be implied in certain situations, for example, when an individual provides their personal information after being informed by this policy about its use and disclosure for the purposes specified herein (refer to Annex A for more details). Therefore, the individual can review this policy and its contents at the time of data collection.
Typically, Les Innovations ADAPTIVA Inc. must also seek the individual’s consent before collecting their personal information from third parties, disclosing it to third parties, or using it for secondary purposes. However, Les Innovations ADAPTIVA Inc. can act without consent in specific cases allowed by law. Key situations where Les Innovations ADAPTIVA Inc. may act without consent are highlighted in the relevant sections of this policy.
Collection
In all cases, Les Innovations ADAPTIVA Inc. only collects information when there’s a valid reason and limits the collection to what’s necessary for the intended purpose.
Please note that Les Innovations ADAPTIVA Inc.’s services and programs are not intended for minors, and generally, Les Innovations ADAPTIVA Inc. does not intentionally collect personal information regarding minors. In such cases, the data can’t be gathered without consent from a parent or guardian.
Collection from third parties: Les Innovations ADAPTIVA Inc. may collect personal information from third parties. Unless a legal exception applies, Les Innovations ADAPTIVA Inc. will seek the individual’s consent before collecting personal information concerning them from a third party. If such information isn’t directly collected from the individual but from another organization, the individual can ask Les Innovations ADAPTIVA Inc. about the source of the collected data. In certain scenarios, Les Innovations ADAPTIVA Inc. may also collect personal information from third parties without the individual’s consent if there’s a significant and legitimate interest, such as a) if collecting the data benefits the individual and can’t be obtained in a timely manner or b) if necessary to ensure the accuracy of the information. Also, Les Innovations ADAPTIVA Inc. may indirectly collect personal information using platforms like: TidioChat, MailChimp, Cyberimpact, Mailersend, Stripe, Paypal, Twilio, Zeffy – each having its own terms and privacy policy that can be consulted for further details.
Collecting through third parties might be necessary for availing certain services or programs, or otherwise doing business with Les Innovations ADAPTIVA Inc.. When required, Les Innovations ADAPTIVA Inc. collects the individual’s consent at the appropriate time.
Retention and Use
Les Innovations ADAPTIVA Inc. ensures that the information it holds is up-to-date and accurate when making decisions related to the concerned individual.
Les Innovations ADAPTIVA Inc. can only use an individual’s personal information for the reasons specified in this policy or any other reasons provided during collection. If Les Innovations ADAPTIVA Inc. wishes to use this information for another purpose, new consent from the concerned individual must be obtained, expressly if it’s sensitive personal information. However, in certain legally permitted scenarios, Les Innovations ADAPTIVA Inc. can use the information for secondary purposes without the individual’s consent, e.g., if clearly benefiting the individual, necessary for fraud prevention or detection, or necessary to evaluate or enhance security measures.
Limited Access: Les Innovations ADAPTIVA Inc. must implement measures restricting access to personal information only to those within its organization who need to know it. Les Innovations ADAPTIVA Inc. will seek the individual’s consent before granting access to anyone else.
Disclosure
Generally, unless an exception is noted in this policy or legally allowed, Les Innovations ADAPTIVA Inc. will obtain the individual’s consent before disclosing their personal information to a third party. Additionally, when consent is required and it involves sensitive personal information, Les Innovations ADAPTIVA Inc. will need explicit consent before disclosure.
However, sometimes disclosing personal information to third parties is necessary. Thus, personal information might be disclosed without the individual’s consent in specific cases, notably but not exclusively, in the following situations:
Les Innovations ADAPTIVA Inc. can disclose personal information, without the individual’s consent, to a public entity (like the government) collecting it in its official capacity or for a program it oversees. Personal information might be shared with service providers who need the information, without the individual’s consent.
For example, these might be event organizers, Les Innovations ADAPTIVA Inc.’s subcontractors, or cloud service providers. In such cases, Les Innovations ADAPTIVA Inc. must have written contracts with these providers detailing measures to ensure data confidentiality, use of data only for contract fulfillment, and no retention of data post-contract expiration. Also, these contracts must stipulate that providers must notify Les Innovations ADAPTIVA Inc.’s data protection officer (mentioned in this policy) of any breach or attempted breach of confidentiality obligations and allow audits for data confidentiality.
If necessary for a business transaction, Les Innovations ADAPTIVA Inc. might also disclose personal information without the individual’s consent to another transaction party, subject to legal conditions.
Disclosure Outside of Quebec: Personal information held by Les Innovations ADAPTIVA Inc. might be disclosed outside of Quebec, for example, when Les Innovations ADAPTIVA Inc. uses cloud service providers with servers located outside Quebec or when working with subcontractors outside the province.
Additional Information on Used Technologies: Use of Cookies: Cookies are data files transmitted to a website visitor’s computer by their web browser when visiting the site and can serve various purposes. Websites controlled by Les Innovations ADAPTIVA Inc. use cookies to:
Use of Google Analytics
Les Innovations ADAPTIVA Inc.’s site uses Google Analytics for continuous improvement. Google Analytics primarily analyzes how a visitor interacts with a Les Innovations ADAPTIVA Inc. website. Google Analytics uses cookies to generate statistical reports on visitor behavior and viewed content. Information from Google Analytics won’t be shared by Les Innovations ADAPTIVA Inc. with third parties. It’s possible to install a browser add-on to disable Google Analytics.
Other Technological Means Used
Les Innovations ADAPTIVA Inc. also collects personal information using technological means, such as embedded web forms on a Les Innovations ADAPTIVA Inc.-controlled website (e.g., contact form, membership registration form, newsletter and seminar signup), online surveys on its platforms and apps, and other form platforms (e.g., Microsoft Forms). If Les Innovations ADAPTIVA Inc. collects personal information by offering a technological product or service with privacy settings, it ensures these settings provide the highest level of default privacy (excluding cookies).
Unless a minimum retention period is required by applicable law or regulation, Les Innovations ADAPTIVA Inc. will retain personal information only for as long as necessary to fulfill the purposes for which they were collected.
Personal information used by Les Innovations ADAPTIVA Inc. to make a decision regarding an individual must be retained for at least one year following that decision or even seven years after the end of the fiscal year in which the decision was made if it has tax implications, such as circumstances involving termination of employment.
Upon reaching the end of the retention period or when the personal information is no longer necessary, Les Innovations ADAPTIVA Inc. will ensure: to destroy them; or to anonymize them (meaning they no longer, in an irreversible manner, allow the identification of the individual and it’s no longer possible to establish a link between the individual and the personal information) for use for significant and legitimate purposes.
The destruction of information by Les Innovations ADAPTIVA Inc. must be done securely to ensure the protection of this information.
This section can be complemented by any policy or procedure adopted by Les Innovations ADAPTIVA Inc. concerning the retention and destruction of personal information, as applicable.
Please contact the personal information protection officer of Les Innovations ADAPTIVA Inc. (indicated in this policy) to learn more.
In general, Les Innovations ADAPTIVA Inc. is responsible for the protection of the personal information it holds.
The personal information protection officer of Les Innovations ADAPTIVA Inc. is the director of operations of the organization. He or she must generally ensure compliance with applicable legislation regarding the protection of personal information.
The officer must approve the policies and practices governing the management of personal information. Specifically, this person is tasked with implementing this policy and ensuring it is known, understood, and applied. In the absence or inability of this officer to act, the president of Les Innovations ADAPTIVA Inc. will assume the functions of the personal information protection officer.
Staff members of Les Innovations ADAPTIVA Inc. with access to personal information or otherwise involved in its management must ensure its protection and comply with this policy.
The roles and responsibilities of Les Innovations ADAPTIVA Inc. employees throughout the life cycle of personal information may be specified in any other Les Innovations ADAPTIVA Inc. policy on this subject, as applicable.
Les Innovations ADAPTIVA Inc. commits 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) must be subject to greater security measures and must be better protected. Specifically, and in accordance with what was previously mentioned about limited access to personal information, Les Innovations ADAPTIVA Inc. must implement necessary measures to impose constraints on the rights of use of its information systems so that only employees who need to have access are authorized to do so.
To assert their rights of access, correction, or consent withdrawal, the concerned individual must submit a written request for this purpose to the personal information protection officer of Les Innovations ADAPTIVA Inc., at the email address indicated in the following section.
Subject to certain legal restrictions, individuals can request access to their personal information held by Les Innovations ADAPTIVA Inc. and request its correction if it is inaccurate, incomplete, or ambiguous. They can also demand the cessation of the dissemination of personal information concerning them or that any hyperlink attached to their name that provides access to this information through technological means be de-indexed when the dissemination of this information violates the law or a court order. They can do the same, or also demand that the hyperlink providing access to this information be re-indexed when certain conditions provided by law are met.
The personal information protection officer of Les Innovations ADAPTIVA Inc. must respond in writing to these requests within 30 days of the receipt of the request. Any refusal must be justified and accompanied by the legal provision justifying the refusal. In such cases, the response must indicate the remedies under the law and the time limit to exercise them. The officer must assist the applicant in understanding the refusal if necessary.
Subject to applicable legal and contractual restrictions, individuals can withdraw their consent to the communication or use of the collected information.
They can also ask Les Innovations ADAPTIVA Inc. what personal information is collected from them, the categories of people within Les Innovations ADAPTIVA Inc. who have access to it, and its retention period.
Any person wishing to file a complaint regarding the application of this policy or, more generally, about the protection of their personal information by Les Innovations ADAPTIVA Inc., must do so in writing by addressing the personal information protection officer of Les Innovations ADAPTIVA Inc., at the email address indicated in the following section.
The individual must provide their name, contact information, including a phone number, as well as the subject and reasons for their complaint, providing sufficient details for it to be evaluated by Les Innovations ADAPTIVA Inc.. If the filed complaint is not specific enough, the personal information protection officer may request any additional information deemed necessary to evaluate the complaint.
Processing
Les Innovations ADAPTIVA Inc. commits to handling every received complaint confidentially.
Within 30 days of receiving the complaint or after receiving all the additional information deemed necessary and required by the personal information protection officer of Les Innovations ADAPTIVA Inc. to process it, the officer must evaluate it and provide a written, reasoned response by email to the complainant. This evaluation will determine if Les Innovations ADAPTIVA Inc.’s handling of personal information complies with this policy, any other policy and practice in place within the organization, and the applicable legislation or regulation. If the complaint cannot be processed within this period, the complainant must be informed of the reasons justifying the extension, the progress status of their complaint processing, and the reasonable time required to provide a definitive response.
Les Innovations ADAPTIVA Inc. must create a separate file for each complaint addressed to it. Each file contains the complaint, the analysis, supporting documentation for its evaluation, and the response sent to the person originating the complaint.
It is also possible to file a complaint with the Quebec Access to Information Commission or any other personal information protection oversight body responsible for enforcing the law concerned by the subject of the complaint.
However, Les Innovations ADAPTIVA Inc. invites any interested party to first contact its personal information protection officer and await the conclusion of the processing by Les Innovations ADAPTIVA Inc..
This policy is approved by the personal information protection officer of Les Innovations ADAPTIVA Inc., whose business contact details are as follows:
Personal Information Protection Officer:
Thomas Thibault
206 rue St Pierre, Matane, (QC) G4W 2B5
info@adaptinnov.com
Technological Personal Information Officer:
BOURRASQUE
A/S RESPONSABLE NUMÉRIQUE
126 RUE DES URSULINES MATANE QUÉBEC G4W 1H1
For any requests, questions, or comments related to this policy, please contact the digital officer by email.
Versions and changes:
Here is a non-exhaustive list regarding the types of information that Les Innovations ADAPTIVA Inc. might collect, their use, or the intended purpose, as well as the means by which the information is collected. This includes, but is not limited to, the following items. Please note that most of the personal information managed by Les Innovations ADAPTIVA Inc. relates to employees, job applicants, and consultants. For other categories of individuals listed in the table below, the provided information is, in most cases, of a professional or business nature (see Section 2. Application and Definitions regarding professional contact details).
A- Relationship with Les Innovations ADAPTIVA Inc., services, program, etc. Client Type of personal information:
B- Relationship with Les Innovations ADAPTIVA Inc., services, program, etc. Job applicants and employees Type of personal information:
C- Relationship with Les Innovations ADAPTIVA Inc., services, program, etc. Members (individuals and organizations) Type of personal information:
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