Confidentiality and Personal Data Management Policy
This confidentiality charter complies with the personal data protection provisions set out in Quebec and Canadian law, particularly those set out in the Act to modernize legislative provisions as regards the protection of personal information (Bill 25).
1. Purpose
This charter concerns data gathered directly or indirectly by Culture pour tous in the course of its activities.
The purpose of this charter is to provide all users and partners with clear, specific information on the procedures followed to process their personal data.
2.Basic principle
Culture pour tous does not collect any personal information about you unless you decide, at your absolute discretion, to provide it voluntarily.
3.Definitions
Personal information: information that concerns a natural person and allows them to be identified directly or indirectly.
Non-personal information: any other data that does not meet the definition of personal information.
Privacy Officer: A person designated as such in order to comply with Quebec’s privacy legislation.
4.Nature of data collected
The following data may be collected by Culture pour tous:
- 4.1 Information that you explicitly send to us when you submit a form that you filled out on our website and which is kept anonymous. No information that will identify you is stored. If necessary, this is stated on the form as well as the reasons for collecting the information;
- 4.2 Personal information that you explicitly send to us when you submit a form that you filled out on our website or under an agreement entered into with Culture pour tous, including items of information intended to identify you. In this case, the form or the agreement will clearly state the reasons for collecting the personal information as well as the methods for protecting and retaining the personal information;
- 4.3 Information that is automatically gathered by tools used by a third party when consulting our website or in the course of your digital interactions with Culture pour tous (e.g., website management system or emailing system). The policy for managing this information is set out in paragraphs 8 and 9 hereof.
These three types of data are in no way linked.
5.Privacy Officer
The privacy officer at Culture pour tous is Michel Vallée, Chief Executive Officer. If you have any questions about the protection of personal information, you can contact him at vieprivee@culturepourtous.ca.
6.Use of personal information by Culture pour tous
Personal information collected by Culture pour tous is not disclosed to anyone other than to the organization’s employees, representatives or individuals whose work is necessary to achieve the purposes for which the personal information was explicitly collected. The information will only be shared with them to the extent that they need it to perform a task related to the achievement of the stated purpose.
Culture pour tous ensures that all people who have access to this information are bound by confidentiality agreements that commit them to respecting the principles of this charter.
7.Access to your personal information
You can access the personal information you have provided to Culture pour tous and request that it be updated, as well as request that certain information or data that Culture pour tous has collected be modified or deleted, by sending an email to vieprivee@culturepourtous.ca.
In this case, you may be asked to provide an appropriate piece of identification. We will process access to information requests or requests to modify information in accordance with applicable legislation. We will do our utmost to respond to you within a reasonable time, taking into account the nature of your request.
8.Measures for safeguarding personal information
Culture pour tous implements appropriate security measures to safeguard personal information.
Where Culture pour tous deems it necessary or appropriate, it uses encryption and authentication tools and programs or any other method to protect personal information posted on or obtained from the Internet that Culture pour tous keeps or intends to keep on its servers, in its information management systems or in its databases.
9.Information shared and gathered automatically on the Internet
You are free to access this website and to use it without your personal information being gathered or your identity disclosed.
However, when you view a website, basic information is shared automatically between that website and the device you are using to access the website. This information sharing allows the website manager to obtain various pieces of information:
- The Internet domain name you used to access the website and your IP address (IP stands for “Internet Protocol”, a unique number assigned to your computer or any other device when it is connected to the Internet. It enables the error-free sending of documents to their recipients);
- The type of browser and operating system that you use to access the website;
- The date and time when you accessed the website and the pages you visited;
- If you reached the website from another website, the name and address (URL) of that website as well as keywords (if any) that you entered in a search engine that took you to the website;
- Any other information about your clickstream.
This information is necessary to ensure the proper functioning of a website.
10.Additional information collected on the Internet by means of cookie files
When you visit the Culture pour tous website, a message displays asking you to authorize the use of additional cookie files.
If you agree, this feature may send the following information to Culture pour tous:
- Website pages visited
- Amount of time spent on each page
- Information sent or received
- Names of uploaded or downloaded files.
Culture pour tous uses this information to check its website’s performance for system administration purposes and to make the website more user-friendly.
To analyze some of this information, Culture pour tous uses a few tools on its website, such as Google Analytics. These tools also serve as cookies to analyze your activities on the Culture pour tous website. For detailed information on how the gathered information or data is used by Google, Culture pour tous suggests reading Google’s Privacy & Terms. If you would like to deactivate the sending of your activity data to Google Analytics, you can do so by installing the browser add-on provided for that purpose.
11.Unsolicited sending of personal information
Culture pour tous does not wish to receive personal or confidential information through its website or by email outside the framework specifically provided for this purpose, that is to say, through an agreement, a secure form or web page designed for this purpose or upon a specific request from Culture pour tous.
All information or other documents that you may send to Culture pour tous outside of such a specific framework will be deemed non-confidential.
12.Email correspondence with Culture pour tous
You acknowledge and agree that emails you send to Culture pour tous are not necessarily protected before arriving on its servers. The confidentiality of the information thus transmitted cannot be ensured before being actually received on the Culture pour tous servers.
In the event that Culture pour tous specifically asks you to transmit information of a personal or confidential nature, the information, once received, will be managed and stored securely.
13.Limitation of liability
Culture pour tous undertakes to take all reasonable means to ensure an adequate level of confidentiality and security of personal information.
In the event that a cyberattack or incident that presents a high risk to your rights occurs, you will be notified of this violation as soon as possible and Culture pour tous will take the necessary measures to preserve the confidentiality and security of your personal information.
Notwithstanding the foregoing, you declare that you understand and acknowledge that no computer system offers absolute security and that some risk is always present when transmitting personal information via the Internet.
You therefore accept that Culture pour tous cannot be held responsible for any violation of confidentiality, hacking, viruses, loss, theft, misuse or alteration of personal information transmitted or hosted on our systems or those of a third party.
You also declare that you waive any claim in this regard, except in case of gross negligence or willful misconduct on the part of Culture pour tous. Consequently, you agree to release Culture pour tous and its officers, directors, related persons and partners from liability for any damages of any kind whatsoever, whether direct or indirect, incidental, special or consequential in connection with the use of your personal information.
14.Applicable laws
This act, its interpretation, its execution, its application, its validity and its effects are subject to the applicable laws in force in Quebec, Canada, in the judicial district of Montreal.
15.Disclosures required by law
You agree and acknowledge that Culture pour tous is also authorized to use, disclose or communicate your personal information to the extent provided or required by law, including pursuant to court orders.
16.Data governance framework
Culture pour tous has developed a data governance framework that summarizes the general principles that our organization follows for the use of data and artificial intelligence (AI). You can consult the data governance framework on the following page
17.Changes to this Policy
Culture pour tous reserves the right to make changes to this Policy at any time. Any such changes will be posted on our websites and will be effective immediately upon posting.