What is personal information?
Personal information is any information about an identifiable individual, such as your name, email address, mailing addresses, gender, date of birth, any answers and data you elect to provide to questionnaires, information collected electronically through the Website, and any other information that identifies who you are. Personal information about you may be collected by the Sponsor directly or provided to the Sponsor by third parties.
What personal information does the Sponsor collect?
The Sponsor limits the collection and use of your information to that which is necessary to fulfil identified purposes or to deliver requested information, products or services to you.
If we intend to use your information in any way we didn’t tell you about previously, we will obtain your consent for the new purpose or use prior to doing so.
The information we ask for will depend on the information or service requested. Different information and services require different types of information. Your information may be collected via an “active information collection point” or through passive means.
Active information collection
You might choose to actively provide the Sponsor certain kinds of personally identifiable information, such as your full name, address, phone number, e-mail address and other personal details, including by submitting or posting same to the Website. All information that you actively provide to the Sponsor is provided at your option.
There are many ways you can give your consent to our use of information that you provide. Your express consent may be given in writing, verbally or through electronic means. Alternatively, where permitted by law, your consent may be implied through an action you’ve taken or when you continue to use a product or service after we’ve notified you of a change. For certain communications and services, we will verify your express consent prior to commencing the requested service or communication.
Passive information collection
The Website may use various technologies to passively collect information from you while you are visiting (that is, you do not actively provide this information to the Sponsor). Such technologies allow the Website to collect a range of non-personally identifiable information, including your Internet Protocol (IP) address (a unique identifier automatically assigned to Your computer when logging onto the Internet), the type of Web browser and operating system you use, the date and time you visit the Website, the specific pages you visit on the Website, and the address of the Web site you visited before coming to the Website.
The Sponsor may use such passively collected information for a variety of purposes, such as to administer the Website, customize the Website to your preferences, and compile aggregated statistics for marketing and research purposes. The Sponsor reserves the unrestricted right to use this passively collected, non-personally identifiable information, including, but not limited to, selling, leasing, permitting access to, or otherwise transferring it to our affiliates, business partners, advertisers and other third parties.
The “passive information collection” technologies that we use may include “cookies”. Cookies are small text files that store information about your interactions with a particular Web site, either temporarily (known as a “temporary” or “session” cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a “permanent” or “persistent cookie”). Cookies can make it easier to use a website by allowing servers to access certain information quickly.
Uses and disclosure of information
Except as described in this Policy or as you may otherwise consent to from time to time, the Sponsor will not use, and will not disclose or provide any of your personal information to any other person except: i) in accordance with the terms of this Policy, ii) to comply with legal requirements such as a law, regulation, warrant, subpoena or court order, or iii) if you are reporting an adverse event, in which case the Sponsor may be required to disclose such information to Canadian and/or international regulatory authorities. We do not sell, trade, or rent your personal information to others for marketing purposes. As described above, generally, the purpose for collecting your personal information will be explained to you, in clear language, at the time of collection.
When you provide information to the Sponsor by completing a registration form, submitting questions or comments or feedback concerning the Sponsor or products and services and other topics, completing surveys and evaluations and other similar situations, we will use this information to learn more about our customers and their preferences, improve our products, services and the Website and for related marketing and research purposes.
The Sponsor reserves the right to transfer any information submitted by you and retained by the Sponsor to its affiliates to the extent necessary to perform requested services and provide requested information. The Sponsor may sell all or part of its business, sell or securitise assets, or merge or amalgamate part or all of our business with other entities. Since customer information and data would normally be a part of such transactions, we may use or disclose such information to other parties included in the transaction, as part of due diligence activities and/or on the completion of the transaction.
The Sponsor does not knowingly collect personal information from children under the age of 18.
Rights to provide information
With respect to all content and information you submit to the Sponsor, including by submitting or posting to the Website, in providing us with such content and information we rely on you to ensure that you have the lawful right to do so without limitation or restriction.
The Sponsor may collect aggregated, anonymous information (such as demographic and profile data, usage and selection data and similar information and data) about you, including in connection with your use of a Website in order to better understand and learn more about our customers and their preferences, improve our products, services and the Websites and for related marketing and research purposes. Any such aggregated information will not contain personally identifiable information about you.
The Sponsor will keep your information only for as long as it is reasonably needed to fulfil the purposes for which it was collected, unless and to the extent a longer retention is permitted or required by law. Your information is destroyed when it is no longer needed or it is converted to an aggregated and anonymous form. The length of time we keep your information varies depending on the reason it was collected and the nature of the personal information. For legal reasons, we may keep information beyond the end of your relationship with us.
Accuracy & access to your information
You have the right to access, verify, rectify and update your personal information which is held by the Sponsor.
The Sponsor takes reasonable steps to ensure your personal information is accurate, complete, and up to date. However, in certain circumstances, we must rely upon you to advise us if your personal information changes. If you notify us that your personal information is inaccurate or incomplete, we will take steps to correct, delete, or add to it, as appropriate. You can contact the Sponsor to request to know what information the Sponsor may have collected and retained about you and how that information is being used. Depending on the nature of the information you are requesting and complexity of your request, we may ask you to put your request in writing.
We protect other people’s privacy when we make information about you available to you. It may not be appropriate for us to release certain information directly to you. There may be records that include information about you and other customers, or that have information confidential to the Sponsor or are the property of the Sponsor. Because we must protect everyone’s confidentiality and legal rights, we cannot make these records available to persons outside of the Sponsor. We will, however, make available to you any factual information about you contained in such records. If we are unable to disclose information to you, we’ll explain why, subject to any legal restrictions.
Safeguards and security
We will use reasonable efforts to protect information that you provide to the Sponsor once it has been received by the Sponsor. The Sponsor employs physical, administrative and technical safeguards, reasonably appropriate to the sensitivity of the information, to safeguard your personal information against loss, theft, misuse, unauthorized access or disclosure and alteration.
Although the Sponsor uses reasonable efforts to safeguard your information, we cannot guarantee it. The Sponsor cannot ensure or guarantee that any information you provide to us is completely secure from individuals who might attempt to deliberately evade security measures, including by intercepting transmissions over the Internet. You provide the Sponsor with your information at your own risk.
Contacting the Sponsor
The Sponsor’s legal department is responsible for this Policy and the Sponsor’s compliance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act.
If you have any questions, comments or complaints about this Policy or our handling of your personal information, or if you wish to withdraw your consent to our use of your personal information (subject to reasonable notice, any legal requirements and similar exceptions) or to request access to or update any information we have on file, you may contact us using the contact information below:
Privacy Officer, Legal Department
2150 St-Elzéar Blvd. West, Laval
Quebec, H7L 4A8
The Sponsor will use reasonable efforts to promptly respond to all questions, inquiries and complaints received, and will typically respond to you within 30 days. Except where required by law, the Sponsor cannot ensure a response to questions or comments regarding topics unrelated to this Policy or the Sponsor’s privacy practices.
Revisions to policy