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PRIVACY POLICY OF LES SOEURS DE LA CONGRÉGATION DE NOTRE-DAME DE MONTRÉAL

Last update: September 29, 2023

With the development of new technologies, we value the privacy of our users. Which is why we, a non-profit entity legally incorporated under the name “LES SOEURS DE LA CONGRÉGATION DE NOTRE-DAME“, whose registered office is located at 2330 Sherbrooke West (H3H 1G8), in the city of Montreal, in the province of Quebec, in Canada (hereinafter referred to as the “Congregation” or “we”), take your privacy seriously (hereinafter “you” or “User”) and your personal information. 

This privacy policy (hereinafter the “Policy“) describes: 

  1. The information we may collect and from whom
  2. How we use and share your information and with whom
  3. Situations where we do or do not need your consent
  4. Your rights regarding your information and how to exercise them
  5. Our security measures regarding your information
  6. Additional matters
  7. How can we make changes to this Policy 
  8. Our contact information if you have a question, comment or request

The Congregation undertakes not to collect, use or communicate your personal information other than in accordance with this Policy and the laws applicable in Canada and Quebec.

Please read this Policy carefully to understand our practices regarding your personal information. If you disagree with our policies and practices, you must stop using our Platform. By accessing or using this Platform, you indicate that you understand, accept and consent to the practices described in this Policy. The Policy may change from time to time. If you continue to use this Platform after we have made changes to the Policy, you are indicating that you accept and consent to these changes. Where possible, we will notify you in advance of any significant changes made to the Policy.

Scope of the Policy

This Policy applies to information that we collect, disclose, store and otherwise process about you:

  • On our website https://www1.cnd-m.org, our client portal and social media pages, accounts, websites, networks or any applications they contain, designed and operated by the Congregation (hereinafter the “Platform”).
  • In emails, texts, forms and other electronic messages between you and this Platform.
  • Through video calls, phone calls or chats with employees of the Congregation.
  • Through mobile and desktop applications that you download from this Platform, which provide dedicated non-browser-based interaction between you and this Platform.
  • When you interact with our forms, advertisements and applications on third-party websites and services, if those forms, applications or advertisements include links to this Policy.

The Platform may include links to third-party websites, plug-ins, services, social networks or applications. Clicking those links or enabling these connections may allow the third party to collect or share information about you. If you follow a link to a third-party website or activate a third-party plug-in, please note that these third parties have their own privacy policies and that we are not responsible for the privacy practices and policies of third parties. We do not control these third parties and encourage you to carefully read the privacy policy of each third party you visit.

Please be aware that you can obtain more information about our practices and withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice, by contacting our Privacy Officer at contactcnd@cnd-m.org. However, without your consent, the Congregation may no longer be able to provide you with the Platform or the services requested. 

Finally, if you provide the Congregation or third parties with personal information about another person, you agree to hold the necessary authorization to do so and/or to have obtained all necessary consents from these third parties to allow us to process them in accordance with the Policy.

LEGAL INFORMATION

PUBLISHER

LES SOEURS DE LA CONGRÉGATION DE NOTRE-DAME

2330 Sherbrooke Street West, Montreal H3H 1G8

Quebec, Canada

HOSTING SERVICE PROVIDER

OVH Hosting Inc.

800-1801 Ave. McGill College, Montreal (H3A2N4)

Quebec, Canada

1 – COLLECTION OF PERSONAL INFORMATION 

Personal information is information associated specifically with a natural person and which can be used to identify him or her, either directly or indirectly, that is, by combining it with other information held by the Congregation or its third-party service providers.

The Congregation may obtain personal information when you save your personal information on the Platform or, if applicable, by otherwise transmitting your personal information, by requesting a service or by communicating with us by telephone, email or other means.

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed of any changes to your personal information. The law gives you the right to request access to and correct the personal information we hold about you.

We collect the following information from you: 

  • Surnames and first names;
  • Email address;
  • Login information;
  • Your preferred language.

Persons from whom this personal information is collected:

The User’s personal information may be collected:

  • Directly from you through forms and communications, namely:
    • Newsletter subscription form;
    • Contact form;
    • Email communications;
    • Telephone; and
  • Through cookies
    • Preferred settings;
    • Browsing statistics.

The Congregation’s legal basis for processing User’s personal information may be one or more of the following:

  • The consent of the User; 
  • When it is necessary for the Congregation to fulfill its legal obligations;
  • When it is necessary for the execution of a contract between the User and the Congregation or before concluding it at the request of the User;
  • When it is necessary to safeguard the vital interests of the User or those of a third party; or
  • When it is based on a legitimate interest such as:
    • To ensure the security of the Platform, its network and data; 
    • To prevent fraud; or 
    • For internal administrative management purposes.

For more information on the protection of your personal information and your related rights, you may contact the Office of the Privacy Commissioner of Canada or the Commission d’accès à l’information du Québec.

  • Office of the Privacy Commissioner of Canada (www.privcom.gc.ca) 
  • Commission d’accès à l’information du Québec (www.cai.gouv.qc.ca)

2 – USES AND SHARING OF YOUR PERSONAL INFORMATION

Purposes for which personal information is used 

We collect personal information from the User for the following reasons:

  • To provide uninterrupted service;
  • To understand how to use the Platform;
  • To analyze and improve User experience;
  • To communicate with the User;
  • To maintain backups of our databases and retain records;
  • To establish, exercise or defend legal claims, whether in legal proceedings or in administrative or extrajudicial proceedings for the protection and assertion of our legal rights, your legal rights and legal rights of others;
  • To comply with applicable laws and regulations.

Sharing of personal information

The Congregation pays special attention to sharing only the personal information necessary for its legal obligations and your service. In certain situations, personal information may be shared with company partners, third-party applications, websites or integration on or using our Platform and for law enforcement or legal requests. The User’s personal information may be shared by the Congregation to be able to book a videoconference appointment, on Zoom for instance, or on a shared calendar, if applicable.

The categories of persons to whom User information may be transferred are as follows:

  • Payment providers, to process User payments;
  • Verification service providers, to ensure the identity of Users;
  • IT service providers, to ensure the operation and security of the Platform;
  • Analytics service providers, to improve the Platform;
  • Service providers enabling compliance with applicable laws and regulations;
  • Partners, government organizations and regulatory authorities, judicial bodies, associates, agents, lawyers or other representatives for compliance with the legal obligations to which we are subject or for the establishment, exercise or defence of legal claims, whether in legal proceedings or administrative or extrajudicial proceedings;
  • To any other person as permitted and/or required by law.

If the User does not wish his or her personal information be communicated to third parties or partners, he or she can object it at any time by contacting us.                                                                 

3 – SITUATIONS WHERE WE DO OR DO NOT NEED YOUR CONSENT

We only use your personal information with your consent or as permitted by law. We obtain your consent to collect, use and disclose your personal information when:

  • You request a product or service; 
  • We need to use your information for a purpose other than that for which you have already given your consent;
  • You interact with us.  

However, we do not obtain your consent for every interaction with you. For example, if we use your personal information for a purpose related to the purpose for which you have given your consent. In addition, we do not obtain your consent in certain situations provided for by law, to: 

  • Comply with a court order or other binding request;
  • Assert a claim;
  • Investigate a breach of contract or violation of law;
  • Prevent, stop or detect fraud.

4 – YOUR RIGHTS REGARDING YOUR INFORMATION AND HOW TO EXERCISE THEM

Your main rights under the current privacy laws and regulations are:

  • The right of access;
  • The right to rectification;
  • The right to de-indexation;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to portability of personal information;
  • The right to lodge a complaint with a supervisory authority; and
  • The right to withdraw your consent.

You have the right to obtain confirmation whether or not we are processing your personal information and, if so, access to this information, as well as to certain additional information. This additional information includes details of the purposes of the processing, the categories of personal information concerned and the recipients of the personal information. Provided that the rights and freedoms of others are not affected, we will provide you with a copy of your personal information. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

In certain circumstances, you have the right to obtain the erasure of your personal information within a reasonable time. These circumstances are as follows: the personal information is no longer necessary in relation to the purposes for which it was collected or is otherwise processed; you withdraw your consent to consent-based processing; you object to the processing under certain applicable privacy rules; the processing is carried out for direct marketing purposes; the personal information has been processed unlawfully. However, there are exclusions to the right to erasure. General exclusions include the following cases where processing is necessary: 

  • The exercise of the right to freedom of expression and information; 
  • To comply with a legal obligation; or 
  • For the establishment, exercise or defence of legal claims.

It is important that the personal information we hold about you is accurate and up to date. Please notify us of any changes to your personal information that we hold about you. 

If you wish to review, verify, correct or withdraw your consent to the use of your personal information, you may also email us at contactcnd@cnd-m.org to request access, correction or deletion of the personal information that you have provided to us. We may not grant a request to change information if we believe that such change would violate any law or legal obligation or would render the information incorrect. 

You have access to some of your personal information and can make changes in the FirstClass intranet which is accessible on the Platform. In addition, we will provide you with access to your personal information, subject to the exceptions provided by applicable privacy legislation. Some examples of these exceptions are:

  • Information protected by professional secrecy.
  • Information that is part of a formal dispute resolution process.
  • Information about another person that would reveal his or her personal information or confidential business information.
  • Information that is prohibitively expensive to provide.

If you are concerned about our processing or wish to correct the information that you have provided to us, you may contact our Privacy Officer at contactcnd@cnd-m.org.

Right to withdraw your consent. Where you have given your consent to the collection, use and transfer of your personal information, you may have the legal right to withdraw your consent in certain circumstances. To withdraw your consent, if applicable, contact us at contactcnd@cnd-m.org. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact of this withdrawal to help you make your decision.

Requests relating to your personal information. We may request specific information from you to help us confirm your identity and rights under applicable laws, and to provide you with the personal information that we hold about you or make any changes that you have requested. Once you have asserted your personal information rights, we will process your request within 30 days as required by law. If the delay is longer than 30 days, you will be informed.

Applicable privacy laws may permit or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased or anonymized your personal information in accordance with our personal information retention obligations and practices. If we cannot provide you with access to your personal information, we will tell you why, subject to any legal or regulatory restrictions.

5 – SECURITY AND STORAGE OF YOUR PERSONAL INFORMATION

Security

The personal information that the Congregation collects is stored in a secure environment. The Congregation has adopted appropriate measures to preserve the confidentiality of personal information and to protect it against loss or theft, as well as unauthorized access, communication, reproduction, use or modification, taking into account, in particular, its sensitivity and the purposes for which it is used. In addition, the Congregation requires that every employee, agent or representative of the Congregation abide by this Policy.

To ensure the security of the User’s personal information, the Congregation uses, among others, the following measures:

  • HTTPS
  • Secure Sockets Layers (SSL) protocol;
  • WordPress security;
  • Protected access to servers and computers;
  • Firewall;
  • Use of password-protected data networks;
  • Quebec server.

Therefore, the Congregation undertakes to maintain a high degree of security by integrating the latest technological innovations to ensure the confidentiality of the User’s transactions to ensure the protection of his or her personal information and prevent it from being accessed, used or disclosed without permission.

However, since no mechanism offers maximum security, there is always some risk when using the Internet to transmit personal information. 

The Congregation maintains an up-to-date privacy incident log and will contact the User whose personal information is the subject of such an incident and presents a risk of serious harm.

Storage

The User’s personal information will not be retained beyond the reasons for which it was collected. The Congregation adheres to the retention period established by this Policy, which is in accordance with the applicable privacy laws and regulations. 

6 – ADDITIONAL MATTERS

Anti-spam

The Congregation respects the requirements of Canada’s anti-spam legislation (CASL). The User understands that he or she may consent expressly or tacitly to receive messages from the Congregation.

To unsubscribe from the mailing list of our electronic communications, simply click the “Unsubscribe” button at the bottom of our email messages. Please note that each time we send you an email, we give you the opportunity to unsubscribe from our mailing list.

Automated decision-making 

The Congregation does not process any personal information in an automated manner, and we do not use your personal information for automated decision-making purposes. 

Children under 14 years of age 

Our Platform is not intended for persons under the age of 14. No one under the age of 14 may provide personal information to the Platform or on the Platform without parental consent. If you are under 14, do not use or provide personal information on this Platform or on or through any of its features. Do not register on the Platform, make purchases through the Platform, use the interactive or public commenting features of this Platform or provide us with information about yourself, including your name, address, telephone number, email address or username that you may use. If we learn that we have collected or received personal information from minors under the age of 14 without parental consent, we will delete that information. If you believe that we hold information about someone under the age of 14, please contact us at contactcnd@cnd-m.org.

Applicable law

This Policy is governed by applicable Quebec and Canadian laws. These laws apply without giving effect to any principle relating to the conflict of laws. 

Divisibility

Each provision of this Policy forms a separate whole such that court decision that any provision of this Policy is void or unenforceable does not affect the validity or enforceability of the other provisions of this Policy. 

7 – CHANGES TO THIS POLICY 

We occasionally update this Policy. Continued use of the Platform constitutes the User’s agreement to this Privacy Policy and its updates. If we make significant changes to the way we process our users’ personal information, we will notify you by email or by a notice on the Platform’s home page.

However, when the Consumer Protection Act applies, the Congregation will notify the Users of the Platform thirty (30) days prior to the effective date of the change hereto. If the User refuses these changes and wishes to terminate the contract, he or she will have no later than thirty (30) days following the entry into force of the changes to send a notice to the Congregation and resolve, without charge or penalty, his or her obligations to the Congregation.

8 – TO CONTACT US 

You may exercise the rights provided for in this Policy or address any other questions or complaints regarding the Congregation’s privacy practices by contacting us at the following address:

By mail: 

Privacy Officer

2330 Sherbrooke Street West, Montreal H3H 1G8

Quebec, Canada

By email: contactcnd@cnd-m.org

We have procedures in place to receive and respond to complaints or inquiries regarding our handling of personal information, our compliance with this Policy and applicable privacy laws. To discuss our compliance with this Policy, please contact the Privacy Officer using the contact information indicated above.