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Privacy Policy and Confidentiality Policy

Welcome to the privacy policy of MYLÈNE PAQUETTE & COMPAGNIE INC.

Welcome to the privacy policy of MYLÈNE PAQUETTE & COMPAGNIE INC, a company duly registered with the Quebec Business Registry under number 1166808080.

We are committed to protecting your personal information and want to inform you of how we collect, use, disclose, store, and, if applicable, destroy it.

This policy also aims to inform you about the management of personal information collected by MYLÈNE PAQUETTE & COMPAGNIE INC through technological means.

The address of our website is: https://mylenepaquette.com/en

This privacy policy applies to MYLÈNE PAQUETTE & COMPAGNIE INC, including its officers, employees, consultants, volunteers, as well as anyone providing services on behalf of MYLÈNE PAQUETTE & COMPAGNIE INC It also covers MYLÈNE PAQUETTE & COMPAGNIE INC’s website.

This policy applies to all types of personal information managed by MYLÈNE PAQUETTE & COMPAGNIE INC, including information about our clients, potential or current, our consultants, our employees, our members, our service or product providers, and any other individuals, including visitors to our website.

Under the Quebec Private Sector Personal Information Protection Act, personal information is defined as any information about an individual that can directly or indirectly identify them. This may include the individual’s name, address, email address, phone number, gender, banking information, health information, ethnic origin, language, etc.

Sensitive personal information is a special category of personal information for which there is a high degree of reasonable privacy expectation. This may include health information, banking information, biometric data, sexual orientation, ethnic origin, political opinions, religious or philosophical beliefs, etc.

In general, professional, or business contact information, such as name, title, work address, work email, or work phone number, is not considered personal information.

Furthermore, in accordance with Bill 25, effective September 22, 2023, sections 3 (collection, use, disclosure), 4 (retention and disposal), and 6 (data security) do not apply to an individual’s information related to the performance of their professional duties, such as their name, title, role, as well as the address, email address, and phone number of their workplace.

These sections also do not apply to personal information that has become public under the law, as of the effective date of this policy.

During its activities, MYLÈNE PAQUETTE & COMPAGNIE INC may collect various types of information for various purposes. The types of information that MYLÈNE PAQUETTE & COMPAGNIE INC may collect, their use (or intended purpose), and how the information is gathered are outlined in the Appendix at the bottom of this policy and in its cookie usage policy available at the link: https://www.mylenepaquette.com/en/cookies

MYLÈNE PAQUETTE & COMPAGNIE INC will also inform individuals, at the time of collecting personal information, about any other information collected, the purposes for which it is collected, and the means of collection, in addition to other information to be provided as required by law.

MYLÈNE PAQUETTE & COMPAGNIE INC adheres to the following general principles regarding the collection, use, and disclosure of personal information:

Consent:

In general, MYLÈNE PAQUETTE & COMPAGNIE INC collects personal information directly from the individual and with their consent unless an exception is provided by law. Consent can be obtained implicitly in certain situations, for example, when the individual decides to provide their personal information after being informed by this policy about the intended use and disclosure purposes (see the Appendix for more details). Therefore, this policy and the information it contains can be accessed by the individual at the time of collecting personal information.

Normally, MYLÈNE PAQUETTE & COMPAGNIE INC must also obtain the consent of the individual before collecting their personal information from third parties, before disclosing it to third parties, or for any secondary use of that information. However, MYLÈNE PAQUETTE & COMPAGNIE INC may act without consent in certain cases provided by law and as set out by it. The main situations where MYLÈNE PAQUETTE & COMPAGNIE INC may act without consent are outlined in the relevant sections of this policy.

Collection:

In all cases, MYLÈNE PAQUETTE & COMPAGNIE INC only collects information if it has a valid reason to do so. Additionally, the collection will be limited to the necessary information required to fulfill the intended purpose. Please note that MYLÈNE PAQUETTE & COMPAGNIE INC’s services and programs are not intended for minors, and, in general, MYLÈNE PAQUETTE & COMPAGNIE INC does not intentionally obtain personal information about minors (in such cases, information cannot be collected from them without the consent of a parent or guardian).

Collection from Third Parties:

MYLÈNE PAQUETTE & COMPAGNIE INC may collect personal information from third parties. Unless an exception provided by law applies, MYLÈNE PAQUETTE & COMPAGNIE INC will seek the consent of the individuals before collecting their personal information from a third party. In cases where such information is not collected directly from the individual but from another organization, the individual may request the source of the information collected from MYLÈNE PAQUETTE & COMPAGNIE INC.

In some situations, MYLÈNE PAQUETTE & COMPAGNIE INC may also collect personal information from third parties without the consent of the individual if it has a legitimate and significant interest to do so and (a) if the collection is in the interest of the individual, and it is not possible to collect it from them in a timely manner, or (b) if the collection is necessary to ensure the accuracy of the information.

Retention and Use:

MYLÈNE PAQUETTE & COMPAGNIE INC ensures that the information it holds is up-to-date and accurate at the time of its use for decisions about the individuals concerned.

MYLÈNE PAQUETTE & COMPAGNIE INC may only use an individual’s personal information for the purposes set out in this policy or for any other purposes provided at the time of collection. When MYLÈNE PAQUETTE & COMPAGNIE INC wishes to use this information for another purpose or reason, new consent must be obtained from the individual, and explicit consent must be obtained if it is sensitive personal information. However, in certain cases provided by law, MYLÈNE PAQUETTE & COMPAGNIE INC may use the information for secondary purposes without the individual’s consent, for example:

  • When this use is clearly in the individual’s benefit.
  • When it is necessary to prevent or detect fraud.
  • When it is necessary to assess or enhance protection and security measures.

Limited Access: MYLÈNE PAQUETTE & COMPAGNIE INC must implement measures to restrict access to personal information only to employees and individuals within its organization who have the authority to access it and for whom the information is necessary in the performance of their duties. MYLÈNE PAQUETTE & COMPAGNIE INC will seek the consent of the individual before granting access to anyone else.

Disclosure:

Generally, and unless an exception is indicated in this policy or otherwise provided by law, MYLÈNE PAQUETTE & COMPAGNIE INC will obtain the consent of the individual before disclosing their personal information to a third party. Moreover, when consent is required, and when it is sensitive personal information, MYLÈNE PAQUETTE & COMPAGNIE INC must obtain the explicit consent of the individual before disclosing the information.

However, disclosure of personal information to third parties is sometimes necessary. Thus, personal information may be disclosed to third parties without the individual’s consent in certain cases, including, but not limited to, the following:

  • MYLÈNE PAQUETTE & COMPAGNIE INC may disclose personal information, without the consent of the individual, to a public agency (such as the government) that collects it in the exercise of its powers or the implementation of a program under its management.
  • Personal information may be transmitted to service providers who need to receive the information without the individual’s consent. For example, these service providers may be event organizers, subcontractors designated by MYLÈNE PAQUETTE & COMPAGNIE INC to carry out mandates in programs administered by MYLÈNE PAQUETTE & COMPAGNIE INC, and cloud service providers. In these cases, MYLÈNE PAQUETTE & COMPAGNIE INC must have written contracts with these providers indicating the measures they must take to ensure the confidentiality of the personal information disclosed, that the use of this information is only for the execution of the contract, and that they cannot retain this information after its expiration. In addition, these contracts must stipulate that the providers must notify MYLÈNE PAQUETTE & COMPAGNIE INC ‘s responsible for personal information protection (indicated in this policy) of any breach or attempted breach of confidentiality obligations regarding the disclosed personal information and must allow this responsible to conduct any related verification.
  • If it is necessary for the conclusion of a commercial transaction, MYLÈNE PAQUETTE & COMPAGNIE INC may also disclose personal information, without the consent of the individual, to the other party to the transaction and subject to the conditions provided by law.

Disclosure Outside Quebec:

Personal information held by MYLÈNE PAQUETTE & COMPAGNIE INC may be disclosed outside Quebec, for example, when MYLÈNE PAQUETTE & COMPAGNIE INC uses cloud service providers whose servers are located outside Quebec or when MYLÈNE PAQUETTE & COMPAGNIE INC deals with subcontractors located outside the province.

Additional Information on Technologies Used:

Use of Cookies:

Cookies are data files transmitted to a visitor’s computer by their web browser when they visit a website and can serve various purposes. They are commonly referred to as cookies. MYLÈNE PAQUETTE & COMPAGNIE INC’s website uses cookies, and all information about these files is described in the cookie usage policy available at this address:

Other Technological Means Used:

MYLÈNE PAQUETTE & COMPAGNIE INC also collects personal information through technological means such as web forms integrated into its website (e.g., its contact form, newsletter registration form, etc.), online questionnaires on its platforms and applications, and other form platforms or tools. If MYLÈNE PAQUETTE & COMPAGNIE INC collects personal information by offering a technological product or service with privacy settings, MYLÈNE PAQUETTE & COMPAGNIE INC must ensure that these settings provide the highest level of privacy by default (cookies are not covered).

Unless a minimum retention period is required by applicable law or regulations, MYLÈNE PAQUETTE & COMPAGNIE INC will retain personal information only for the period necessary to fulfill the purposes for which it was collected.

Personal information used by MYLÈNE PAQUETTE & COMPAGNIE INC to decide regarding an individual must be retained for a period of at least one year following the decision in question, or even for seven years after the end of the fiscal year in which the decision was made if it has tax implications, such as employment terminations.

At the end of the retention period or when personal information is no longer needed, MYLÈNE PAQUETTE & COMPAGNIE INC will ensure:

  • Either to destroy it, or
  • Anonymize it (i.e., it no longer allows, in an irreversible manner, the identification of the individual, and it is no longer possible to establish a link between the individual and the personal information) for legitimate and significant purposes.

The destruction of information by MYLÈNE PAQUETTE & COMPAGNIE INC must be carried out securely to ensure the protection of this information.

This section may be supplemented by any policy or procedure adopted by MYLÈNE PAQUETTE & COMPAGNIE INC regarding the retention and destruction of personal information, if applicable. Please contact MYLÈNE PAQUETTE & COMPAGNIE INC’s responsible for personal information protection (as indicated in this policy) for further information.

In general, MYLÈNE PAQUETTE & COMPAGNIE INC is responsible for the protection of the personal information it holds.

The person responsible for the protection of personal information at MYLÈNE PAQUETTE & COMPAGNIE INC is the Director of Operations of the organization. He or she must, in general, ensure compliance with the applicable legislation concerning the protection of personal information. The responsible person must approve policies and practices governing the governance of personal information. Specifically, this individual is responsible for implementing this policy and ensuring that it is known, understood, and applied. In the absence or inability to act of this responsible person, the President of MYLÈNE PAQUETTE & COMPAGNIE INC will assume the functions of the person responsible for the protection of personal information.

Members of the MYLÈNE PAQUETTE & COMPAGNIE INC staff who have access to personal information or are otherwise involved in its management must ensure its protection and adhere to this policy.

The roles and responsibilities of MYLÈNE PAQUETTE & COMPAGNIE INC employees throughout the lifecycle of personal information may be specified by any other MYLÈNE PAQUETTE & COMPAGNIE INC policy in this regard, if applicable.

MYLÈNE PAQUETTE & COMPAGNIE INC is committed 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. This means that information that can be classified as sensitive (see the definition provided in section 2) will require more significant security measures and better protection. In particular, and in accordance with what has been mentioned previously regarding limited access to personal information, MYLÈNE PAQUETTE & COMPAGNIE INC must implement necessary measures to impose restrictions on the rights of use of its information systems so that only employees who need access are authorized to do so.

To exercise their rights of access, rectification, or withdrawal of consent, the data subject must submit a written request to the responsible party for the protection of personal information at MYLÈNE PAQUETTE & COMPAGNIE INC. This can be done by completing the dedicated form provided in this policy, which is available in the Annex.

Subject to certain legal restrictions, data subjects may request access to their personal information held by MYLÈNE PAQUETTE & COMPAGNIE INC and request corrections if the information is inaccurate, incomplete, or ambiguous. They may also demand the cessation of the dissemination of personal information that concerns them or that any hyperlink associated with their name that allows access to this information through technological means be delisted when the dissemination of this information violates the law or a court order. Similar requests can be made, or they may demand that the hyperlink allowing access to this information be relisted when certain conditions stipulated by the law are met.

The responsible party for the protection of personal information at MYLÈNE PAQUETTE & COMPAGNIE INC must respond in writing to these requests within 30 days of receiving the request. Any refusal must be justified and accompanied by the legal provision justifying the refusal. In such cases, the response must indicate the legal remedies available and the time frame for exercising them. The responsible party must assist the requester in understanding the refusal if necessary.

Subject to applicable legal and contractual restrictions, data subjects can withdraw their consent to the communication or use of the information collected.

They can also request that MYLÈNE PAQUETTE & COMPAGNIE INC disclose what personal information has been collected from them, the categories of individuals within MYLÈNE PAQUETTE & COMPAGNIE INC who have access to it, and the duration of its retention.

Complaint receipt:

Anyone wishing to file a complaint regarding the application of this policy or, more generally, the protection of their personal information by MYLÈNE PAQUETTE & COMPAGNIE INC must submit their complaint in writing to the Data Protection Officer of MYLÈNE PAQUETTE & COMPAGNIE INC. To do so, they may use the provided form, available in this policy as an Annex.

The individual should provide their name, contact information for follow-up, including a phone number, and clearly state the subject of their complaint along with the reasons for it. The complaint should contain sufficient details to allow for its evaluation by MYLÈNE PAQUETTE & COMPAGNIE INC. If the complaint is not sufficiently precise, the Data Protection Officer may request any additional information deemed necessary for evaluating the complaint.

Complaint processing:

MYLÈNE PAQUETTE & COMPAGNIE INC is committed to handling all complaints in a confidential manner.

Within 30 days of receiving the complaint or, if necessary, within 30 days of receiving all additional information required by the Data Protection Officer of MYLÈNE PAQUETTE & COMPAGNIE INC to process the complaint, the Data Protection Officer must assess the complaint and send a written, reasoned response to the complainant, typically by email. This assessment aims to determine whether legal’s handling of personal information complies with this policy, other policies, and practices within the organization, as well as applicable legislation or regulations.

If the processing of the complaint cannot be completed within this timeframe, the complainant should be informed of the reasons for the extension, the status of the complaint processing, and a reasonable timeframe needed to provide a definitive response.

MYLÈNE PAQUETTE & COMPAGNIE INC must create a separate file for each complaint received. Each file should contain the complaint, the analysis, and supporting documentation, as well as the response sent to the complainant.

It is possible to file a complaint with the Access to Information Commission of Quebec or any other regulatory body responsible for the enforcement of the law relevant to the subject of the complaint.

However, MYLÈNE PAQUETTE & COMPAGNIE INC encourages all concerned individuals to first contact their Data Protection Officer and wait for the completion of the processing by MYLÈNE PAQUETTE & COMPAGNIE INC before seeking the intervention of a regulatory body.

This policy is approved by the Data Protection Officer of MYLÈNE PAQUETTE & COMPAGNIE INC, whose business contact information is as follows:

Data Protection Officer:

     Mylène Paquette
     MYLÈNE PAQUETTE & COMPAGNIE INC
     A-8909 Henri-Julien
     Montréal, Québec, H2M 1M8
     Email: info@mylenepaquette.com
     Phone: (514) 660-3085

For any requests, questions, or comments regarding this policy, please contact the Data Protection Officer via email.

This policy is published on the MYLÈNE PAQUETTE & COMPAGNIE INC website, as well as on all websites controlled and maintained by MYLÈNE PAQUETTE & COMPAGNIE INC, to which this policy applies, in relation to the personal information collected there. This policy is also disseminated through any means suitable for reaching the individuals concerned.

MYLÈNE PAQUETTE & COMPAGNIE INC must do the same for any amendments to this policy, which must also be the subject of a notice to inform the individuals concerned.

*Note: Please be aware that the use of the masculine gender is for the purpose of simplifying this policy and making it easier to read.