PRIVACY POLICY
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1. General information
1.1 Introduction
Protecting your privacy is important to Station Mont-Sainte-Anne Inc, Les Entreprises de Stoneham Inc. et/ou Les Distributions LMC Ltée (hereinafter “the Organization,” “we,” “us,” “our”). For this reason, we have put in place safeguards and practices to manage your personal information in accordance with applicable laws.
This Privacy Policy (the “Policy”), which should be read in conjunction with our Website Terms of Use and Service Agreements with the Organization, https://mont-sainte-anne.com/avertissement/ describes our practices with respect to the collection, use, processing, disclosure and retention of Personal Information of our customers, visitors and users regardless of how they are collected (e.g., on our Website or on site).
By using our Web sites under the domains and subdomains https://mont-sainte-anne.com/ https://ski-stoneham.com/ https://legrandvallon.com/ https://hotelstoneham.com/collectively, the “Website”) or any of our Services, 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, your alternative is to stop visiting, accessing or using our Website or Services, and not to share your Personal Information with us.1.2 Purpose
For the Organization, respecting your privacy and the confidentiality of your data is essential. That’s why we’ve developed this privacy policy to tell you what information we collect, how we process it, and when we need to pass it on to subcontractors or third parties.
By giving your consent, you authorize the Organization to proceed with the collection and processing of your personal information that is required to offer you our services. Please be aware that you remain in control of your personal information at all times, and that the consent you give us to collect or process your personal information may be withdrawn at any time. We will respect your choice in accordance with our legal obligations.
In addition, it is essential to read this Policy in conjunction with our Website Terms of Use and Website Terms of Sale.1.3 The person responsible for the protection of personal information
Questions, comments and complaints regarding the Organization’s Privacy Policy and practices may be addressed to our Privacy Officer at the following coordinates:
1.4 E-mail: protection_renseignements_personnels@rcrquebec.com
Michelle Lucas
(418) 827-4561 #304
Station Mont-Sainte-Anne Inc : 2000 boul. du Beau-Pré, Beaupré Québec, G0A 1E0
Les Entreprises de Stoneham Inc : 600 chemin du Hibou, Stoneham-et-Tewkesbury Québec, G3C 1T3
Les Distributions LMC Ltée : 600 chemin du Hibou, Stoneham-et-Tewkesbury Québec, G3C 1T32. Definitions
The following words and expressions, when appearing with a capitalized first letter in the Policy, have the meanings attributed to them hereinafter unless otherwise implied or explicit in the text:
“Service Provider” means any natural or legal person who processes data on behalf of the Organization. This includes third-party companies or individuals employed by the Organization to facilitate the Services, to provide the Services on behalf of the Organization, to perform services related to the Services or to assist the Organization in analyzing the use of the Services.
“Personal information,” means any information that relates to a natural person and allows that person to be identified, i.e., that directly or indirectly reveals something about the identity, characteristics (e.g., abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour of the person concerned) or activities of that person, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, sound, visual, computerized or other).
“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. It may include, for example, medical, biometric, genetic or financial information, or information about a person’s life or sexual orientation, religious or philosophical beliefs, trade-union membership or ethnic origin.
“Privacy Officer”: the person who is responsible for the application of this Policy and whose contact information is identified in section 1.2 of this Policy.
“Services”: Services refers to the website and all related services offered by the Organization, which include professional services and, where applicable, associated media, printed materials and “online” or electronic documentation.3. Treatment of Personal Information
3.1 Collection of personal Information
Your consent to share your personal information with us
In the course of our activities, we may collect, process and use different types of Personal Information, with your consent or as permitted by law. Wherever possible, we indicate which fields are mandatory and which are optional, and collect only the information necessary to provide you with the Services We may collect the Personal Information listed below:,
In the course of our business, we may collect, process and use various types of Personal Information that you provide to us only as permitted by law, including the information listed below:
Via our Website:
● When you subscribe to our newsletter, contact information such as your first and last name, e-mail address and company name is used to subscribe you. This information is used to contact you and send you our newsletters and other relevant publications. You can unsubscribe at any time by clicking on the “unsubscribe” tab at the bottom of each advertising e-mail/newsletter we send;
● When you visit and use our Website and Services, we may automatically collect data about your technological device and use of the Website and our Services, including
○ connection and other information about your activities on the Website, such as your IP address, the pages you have visited, the time and date of your visits, the type of browser you are using, your device’s operating system and other hardware and software information;
○ geolocation data, such as your IP address, a precise or approximate location determined from your IP address or your mobile device’s GPS (depending on your device’s settings);
For details of how we use tracking technologies to collect information about you when you visit our Website, please refer to section 6.• Personal Information may also be collected by our Internet payment partners, including Moneris, PayPal, Stripe, Lightspeed. To learn more about how they process, store and destroy your Personal Information, we invite you to consult their privacy policies here.
In carrying out the mandates you entrust to us
● contact information, such as your first and last name, e-mail address, telephone number, address and/or company number for the creation of a customer account;
● information about products or services, such as information about services we have provided to you;
● transaction and payment information, such as the payment method used, date and time, payment amount, billing postal code, your address and other related information;
● transaction and payment information, such as the payment method used, date and time, payment amount, billing zip code, your address and other related information;
● information you choose to provide or transmit to us, for example, when you fill out a form, respond to surveys or communicate with one of our employees or representatives;
In each case, such Personal Information is processed in accordance with the legitimate and necessary purposes listed in section 3.2 below. In addition, we ensure that we only collect and process data and Personal Information that is strictly necessary for the purposes for which you provide it to us. In the event of any subsequent use of your Personal Information, we will notify you as required by law unless the law allows us to use them without your consent.
In certain specific situations, we may also need to collect other information about you, such as sensitive Personal Information. In such cases, we will do so with your consent or in accordance with applicable law.3.2 Use of Personal Information
As stated in paragraph 3.1, we use your Personal Information only as permitted by law. In addition to the purposes described in paragraph 3.1, we may use your Personal Information for the legitimate purposes described below:
● provide you with Services, including the processing of any transactions previously necessary to provide these to you;
● allow you to subscribe to our newsletter;
● to verify your identity and review your personal history, as permitted by law;
● operate, maintain, supervise, develop, improve and offer all functionalities of our Website;
● to manage risk and activities;
● to meet our obligations under applicable laws and regulations
● develop new Services and improve our Website and Services;
● for marketing and business development purposes, if you have previously consented to the processing of your personal information for these purposes;
● send you messages, updates and security alerts;
● answer your questions and provide assistance when needed;
● administer a contest, promotion, survey or other feature of the Website or our Services;
● gather opinions and comments on our Services;
● conduct research and analysis related to our business and Services;
● detect and prevent fraud, errors, spam, abuse, security incidents and other damaging activities;
● to establish, exercise or defend a right or legal claim;
● send you communications in accordance with the law;
● enable the function to apply for a job with the Organization;
● for any other purpose permitted or required by law.
Please note that we do not use the information we collect to draw inferences, to profile you or in any other way.
The Personal Information we collect and store remains secure on servers located in Canada. Please be assured that this Personal Information is disclosed only when we have a legal obligation to do so. Furthermore, in order to provide you with the Services, we or our suppliers may need to communicate, store or process Personal Information on servers located outside Quebec. Please note that the privacy laws of these jurisdictions differ from Canadian and Quebec privacy laws. The reasonable measures, contractual or otherwise, that we may take to protect your personal information while it is being processed or handled by these service providers are subject to applicable foreign legal requirements, including lawful requirements to disclose personal information to government and law enforcement authorities in certain circumstances. By submitting your personal information or engaging with the Site or any of its subdomains, you consent to such transfer and hosting.3.3 Disclosure of Personal Information
We may disclose your Personal Information to our employees, contractors, consultants, agents, Service Providers and other trusted third parties who require such information to assist us in operating our Website, conducting and protecting our business or serving you, provided that such Service Providers have previously agreed in writing to keep your Personal Information confidential in accordance with applicable laws and our Information Governance Program. In addition, only those members of our organization’s Personnel who have a need to access and process your Personal Information will have access to it, in accordance with our internal Privacy Policy.
We do not sell, trade or otherwise disclose your personal information to third parties, subject to exceptions provided by law.3.3.1 Service providers and other third parties
We may use Service Providers to perform various services on our behalf, such as IT management and security, marketing, and data analysis, hosting and storage.
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 necessary to perform their mandate. As part of these contracts with our Service Providers, we are committed to ensuring that the principles set out in this Policy are respected, 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 implement adequate safeguards that are proportionate to the sensitivity of the Personal Information processed or communicated. When our Service Providers no longer need your Personal Information, they are obliged to destroy this data in an appropriate manner.3.3.2 Compliance with legislation, responding to legal requests, preventing harm and protecting our rights
We may disclose your Personal Information when we believe such disclosure is authorized, necessary or appropriate, including:
● To respond to requests from public and government authorities, including public and government authorities outside your country of residence;
● To protect our activities ;
● To comply with legal proceedings ;
● To protect our rights, our privacy, our safety, our property, yours or that of third parties;
● To enable us to pursue available remedies or limit the damages we may suffer; and
● In accordance with applicable laws, including laws outside your country of residence;3.3.3 Commercial Transactions
We may share, transfer or disclose, strictly in accordance with this Policy, your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of the Organization or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or other business transaction, including in connection with the negotiation of such transactions).
3.3.4 Collection of personal information from third parties
Wherever possible, the Organization obtains consent directly from the individual concerned for us to collect, use and disclose his or her Personal Information. To the extent that you provide us with Personal Information about other individuals, you must ensure that you have duly notified them that you are providing us with their information, in addition to obtaining their consent to such disclosure.
Unless we are authorized to do so by law, we will seek your express consent before using or disclosing your Personal Information for purposes other than those set out herein.3.4 Storage of personal information
Subject to our legal obligations which may require us to retain your Personal Information for a longer period of time, we retain your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected, unless you consent to your Personal Information being used or processed for another purpose. 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).
Please also be assured that when the purpose for which Personal Information was collected has been fulfilled, we will proceed to destroy such information, in accordance with applicable legislation.
For more information on the periods for which your Personal Information is retained, please contact our Privacy Officer using the contact details set out in section 1.2 of this Policy.3.5 Sensitive personal information
To ensure the safety of our users and infrastructure, surveillance cameras have been installed at various locations on the site. These cameras enable us to ensure the smooth running of our daily operations, and to intervene rapidly when a situation warrants it. This video surveillance system is not used to monitor or record specific individuals, but rather to ensure general surveillance of the site. The recordings from these cameras are accessible by certain employees of the Organization, as well as by Service Providers who require access in the course of their duties, and organizational measures are in place to preserve the integrity and confidentiality of these recordings. In addition, records are kept for a limited period of time, and are irreversibly destroyed when no longer required.
4. Safety Measures
The Organization has implemented physical, technological and organizational security measures to adequately protect the confidentiality and security of your personal information against loss, theft or any unauthorized access, disclosure, reproduction, communication, use or modification. These measures include access control, segregation of duties, internal audits, etc.
Among the various measures implemented
● Our website is equipped with an SSL (Secure Sockets Layer) protocol, firewall and computer backup to ensure a secure connection between your device and our server;
● The Organization’s employees are aware of this Policy and are required to comply with it and to respect the confidentiality of Personal Information concerning our potential and existing customers. In addition, each employee undertakes to follow and comply with a data governance policy applicable to all of the Organization’s personnel;
● As mentioned in section 3.3, we have implemented measures to restrict access to Personal Information to persons who have a valid reason to consult, process, communicate or otherwise use your information;
● As mentioned in section 3.3, the Service Providers who do business with the Organization and with whom we may need to communicate your Personal Information have previously agreed to protect the confidentiality and privacy of such information;
● When the purpose for which your Personal Information was collected has been fulfilled and we no longer need to retain it, the Organization will destroy or anonymize such data, subject to applicable laws.
Despite the measures described above, we cannot guarantee the absolute security of your Personal Information. If you have reason to believe that your Personal Information is no longer secure, please contact our Privacy Officer immediately using the contact details provided in section 1.2 above.5. Links to Third-Party Websites
From time to time, we may include on our Website references or links to websites, products or services provided by third parties (“Third Party Services”). These Third-Party Services, which are not operated or controlled by the Organization, are governed by privacy policies entirely separate from and independent of our own. We therefore assume no responsibility for the content and activities of these sites, and encourage you to consult the privacy policies of these Third-Party Services before providing them with any Personal Information. This Policy applies only to the Web site and the services we offer. This Policy does not extend to Third Party Services.
6. Cookies and Other Tracking Technologies
When you visit our Website, we use cookies and similar tracking technologies to collect information to remember your preferences and settings as you navigate our Website. The information collected includes: your IP address, the date and time of your visit, the pages you visit, the features you use, the reference URL you came from and the one you go to next, your clickstream (i.e., the pages you view, the links you click and other actions you take in relation to the Website), your browser type and the language you select.
We use this information to conduct internal research into our users’ demographics, interests and behaviour in order to better understand, protect and serve our users and our community, and to improve our services. We may use functional cookies and statistical cookies. A “functional cookie” expires immediately when you end your session (i.e., when you close your browser). A “statistical cookie” store information on the hard disk, so that when you end your session and return to our site at a later date, the cookie information is still available. Cookies placed by our server are readable only by us, and cookies cannot access, read or modify other data on your computer.
We also use Google Analytics to better understand who uses our site and how people use it. Google Analytics uses cookies to collect information such as the pages of the site visited, the places where users click, the time spent on each page of the site, the Internet protocol address, the type of operating system used and your location. Please visit http://www.google.com/policies/privacy/partners/to find out how Google Analytics uses this information. Google can track your activity over time and across different websites. This information is used to target ads and content that may be of interest to you, as well as to provide statistical information through features such as Google Analytics and Google Ads.
Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete some of them. You may also be able to manage other tracking technologies in the same way. In some cases, tracking tools used by third-party service providers can be disabled. For example, Google allows you to deactivate cookies used to target ads by accessing the deactivation page on its main site. Google Analytics can also be deactivated, by downloading the browser add-on available for this purpose. You can also refuse the use of cookies by other third-party suppliers by logging on to the Network Advertising Initiative’s consumer deactivation page.7. Your rights
As a data subject, you may exercise the rights set out below by completing the access request form available at [ Insert link here] and sending it by e-mail or regular mail to the attention of our Privacy Officer at the coordinates provided in section 1.2 of the Policy.
● You have the right to be informed of 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, equivocal, out of date or inaccurate;
● You have the right to withdraw or change your consent to the Organization’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 provides access to such information if such dissemination contravenes the law or a court order;
● 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;
To fulfill your request, you may be asked to provide appropriate identification or otherwise identify yourself. Please note that if you request the deletion of your Personal Information or withdraw your consent to its use, we may not be able to provide you with certain services. We will explain the consequences of this decision once we have received your request to assist you in your decision.
We encourage all our customers to keep their personal information with us up to date. Decisions regarding the various services we can offer our customers may vary depending on the accuracy of this data. It is therefore essential to ensure that we have an accurate picture of your situation.8. Limitation of liability
The Organization undertakes to take all reasonable steps to ensure the confidentiality and security of Personal Information in accordance 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 a degree of risk involved in transmitting Personal Information over the public network that is the Internet.
You hereby agree that the Organization 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, and hereby waive any claim you may have against the Organization. Accordingly, you release the Organization and its officers, directors, affiliates, and business partners from all liability for 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.
In the event of a breach of confidentiality or security of your Personal Information, the Organization will take the necessary measures to preserve the confidentiality and security of your Personal Information, in accordance with its legal obligations.9. Changes to this Privacy Policy
We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a change, we will post the revised Privacy Policy and update the update date in the footer of the Privacy Policy. If you do not agree to the new terms of the Privacy Policy, please do not continue to use our Website and Services. If you choose to continue using our Web Site or Services after the new version of our Policy becomes effective, your use of our Web Site and Services will be governed by the new version of the Policy.
10. Contact us
Any questions, comments, requests or concerns regarding this Privacy Policy should be directed to our Privacy Officer at the contact information provided in section 1.4 of this Policy.