At Fondation Stéphan Crétier, we understand the importance of privacy and are committed to protecting your personal data. This Privacy Notice informs you of how we treat your personal data when you visit our website (regardless of where you visit from) and explains your privacy rights. Fondation Stéphan Crétier has designed this Policy to meet the requirements of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), the Act respecting the protection of personal information in the private sector (Quebec) (“PIPEDA”) and to comply with the following ten privacy principles, as well as the General Data Protection Regulation (GDPR) and all other applicable laws.
The purpose of this Privacy Notice is to inform you about how Fondation Stéphan Crétier collects, discloses and uses your personal information when you use this website, including information you provide through this website, namely when you sign up for our Newsletter or participate in a contest.
This website is not intended for children and we do not knowingly collect data from children.
It is important that you read this Privacy Notice together with any other Privacy Notice or Fair Processing Notice that we may provide on certain occasions when we collect or process personal data about you so that you are fully aware of how and why we use your data. This Privacy Notice supplements the other notices and is not intended to replace them.
Fondation Stéphan Crétier operates various initiatives and activities, including the Bolo Program, specific details of which are available on this website. This Privacy Notice is published on behalf of Fondation Stéphan Crétier. Accordingly, when we refer to “Fondation Stéphan Crétier”, “Bolo Program”, “we”, “us” or “our” in this Privacy Notice, we are referring to Fondation Stéphan Crétier and all relevant initiatives and activities, including the Bolo Program. Fondation Stéphan Crétier controls and is responsible for this website.
We have appointed a Chief Privacy Officer (CPO) to oversee matters relating to this Privacy Notice. If you have any questions about this Privacy Notice, including any request to exercise your statutory rights, please contact the CPO by email at [email protected].
For Quebec residents
If you prefer, you can contact our Privacy Officer by mail:
ATTN: Responsable de la protection des Renseignements Personnels
1250, boul. René-Lévesque Ouest, 20e étage
Montréal (Québec)
H3B 4W8
Other individuals within Fondation Stéphan Crétier may be delegated to act on behalf of the CPO or to assume responsibility for the day-to-day collection or processing of personal data.
You have the right to file a complaint at any time with the competent authority responsible for data protection issues. However, we would like to have the opportunity to discuss your concerns with you before you discuss them with the competent authority. Please contact us first.
It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. By clicking on these links or activating these connections, third parties may collect or share data about you. We have no control over these third-party websites and are not responsible for their privacy statements. When you leave our website, we invite you to read the privacy notice of each website you visit.
Personal data or personal information means any information about a person that allows that person to be identified. It does not include data from which the identity has been removed (anonymous data).
We may collect, use, store and transfer various types of personal data about you, which we have grouped together as follows:
We also collect, use and share aggregated data such as statistical or demographic data for serious and legitimate purposes. Aggregated data may be derived from your personal data, but it is not considered personal data because it is anonymized, meaning that it does not directly or indirectly identify you. For example, we may aggregate your usage data to calculate the percentage of users accessing a particular website feature. However, if we combine aggregated data with your personal data or link them so that they can directly or indirectly identify you, we treat the combined data as personal data, which is used in accordance with this Privacy Policy.
We do not collect any special or sensitive categories of personal data about you (this includes information about your race or ethnic origin, religious or philosophical beliefs, sex life and sexual orientation, political opinions, trade union membership, health information and genetic and biometric data). We also do not collect information on criminal convictions and offences.
Where we are required to collect personal data by law or under the terms of a contract we have entered into with you, and you fail to provide such data when requested by us, we may be unable to perform the contract we have entered into or are attempting to enter into with you (for example, to supply services to you). In this case, we may have to cancel a service we provide to you, but we will inform you of this at the time. If withdrawing your consent necessarily involves terminating the contract between us, you understand that certain contractual consequences may apply.
We use a variety of methods to collect the data you provide to us or about yourself, including:
We only use your personal data where permitted by applicable law. Most often, we use your personal data in the following circumstances:
We will obtain your consent to process your personal data for the purpose of sending you direct advertising communications from third parties by email or text message. You have the right to withdraw your consent to the sending of advertisements at any time by contacting us at [email protected].
We have set out below, in table form, a description of all the ways in which we plan to use your personal data. Please note that we may process your personal data for more than one legitimate reason depending on the specific purpose for which we use your data. Please contact us at [email protected] if you require specific information about the legal basis on which we process your personal data.
| Objective/Activity | Data type |
| To register as a new follower | a) Identity b) Contact details |
| To manage our relationship with you, including : a) Inform you of any changes to our terms and conditions or Privacy Policy b) Ask you to leave a comment or answer a survey | a) Identity b) Contact details c) Profile d) Marketing and communications |
| To enable you to take part in a contest | a) Identity b) Contact details c) Date of birth d) Use e) Marketing and communications |
| To manage and protect our organization and this website (including troubleshooting, data analysis, testing, system maintenance, support, communication and data hosting) | a) Identity b) Contact details c) Computer data |
| To provide you with relevant website content and advertisements and to measure or understand the effectiveness of the advertising we provide to you | a) Identity b) Contact details c) Profile d) Use e) Marketing and communications f) Computer data |
| To make suggestions and recommendations on goods or services that may be of interest to you | a) Identity b) Contact details c) Computer data d) Use e) Profile |
We strive to offer you choices regarding certain uses of personal data, particularly in marketing and advertising. We have established the following personal data control mechanisms:
We may use your identity data, contact data, computer data, usage data and profile data to form an opinion about what may be of interest to you. This is how we decide which services may be relevant to you (what we call marketing).
You will receive marketing communications from us if you have requested information from us, or provided us with your contact information when you signed up for a promotion or service and if, in each case, you do not opt out of receiving such marketing.
We will obtain your express consent before sharing your personal data with any company outside Fondation Stéphan Crétier for marketing purposes.
You may ask us or third parties to stop sending you marketing messages at any time by visiting our website and requesting to unsubscribe, or by contacting us at any time at [email protected].
When you choose not to receive these marketing messages, this does not apply to personal data provided to us as part of a product or service purchase, warranty registration, product or service experience or other transactions.
You can set your browser to refuse all or certain cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or may not function properly. For more information on the cookies we use, please see our Cookie Policy.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us at [email protected].
If we need to use your personal data for purposes unrelated to the purpose, we will inform you and explain the legal basis for doing so.
Please note that we may process your personal data without your knowledge or consent, in accordance with the aforementioned rules, where required or permitted by applicable law.
We may need to share your personal data with the parties listed below for the purposes set out in the table in provision 4.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not authorize our third-party service providers to use your personal data for their own purposes. We only allow them to process your personal data for specific purposes and in accordance with our instructions.
We share your personal data within Fondation Stéphan Crétier. This may mean the transfer of your data within and outside the European Economic Area (EEA). Also, if you are a data subject to PIPEDA in Quebec, you understand that it is possible that your personal data may be hosted outside Quebec, either by being communicated within Fondation Stéphan Crétier or by being communicated to a third party within a category of third parties identified in this policy that would have its servers outside Quebec.
We ensure that your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
Whenever we transfer your personal data outside the EEA, we will ensure, as far as is reasonably possible, that they benefit from a similar degree of protection.
We have implemented appropriate security measures to prevent your personal data from being accidentally lost or used, accessed, modified or communicated in an unauthorized manner. In addition, we restrict access to your personal data to employees, agents, contractors and other third parties who need to know it for business purposes. They will only process your personal data in accordance with our instructions and are subject to an obligation of confidentiality. Despite these measures, you understand that it is impossible to guarantee that we will not be the victim of a confidentiality incident affecting your personal data.
We have procedures in place to deal with any suspected personal data breach and will notify you and any relevant regulatory body of a breach if we are legally required to do so.
We will retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including any retention requirements under applicable law.
In determining the appropriate retention period for personal data in accordance with the specific purposes for which it was collected, we take into account the amount, the nature of the sensitivity of the personal data, the potential risk of harm arising from the unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the possibility that we may achieve those purposes by other means, as well as applicable legal requirements.
Under certain circumstances, you can ask us to delete your data: see below for more information.
In certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.
In some cases, you have rights under data protection laws in relation to your personal data concerning the following:
If you wish to exercise any of the above rights, please contact your designated CPO for further information at [email protected].
There is no charge for accessing your personal data (or for exercising any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Furthermore, we may refuse to comply with your request in such circumstances.
We may need to ask you for specific information to help us confirm your identity and guarantee your right to access your personal data (or to exercise one of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who does not have the right to receive it. We may also contact you to request further information regarding your request in order to expedite our response.
Fondation Stéphan Crétier is committed to protecting your personal information throughout its life cycle in accordance with its privacy practices and in compliance with the requirements of applicable laws.
To this end, in addition to our privacy policy, Fondation Stéphan Crétier has adopted an internal data governance policy that sets out the principles governing the protection of personal data in the context of its operations.
The objectives of our internal governance policy are:
Because respecting your personal data is everyone’s business at Fondation Stéphan Crétier, our CPO is supported by a team that is fully aware of personal data protection and the rights of those concerned.
Every member of our staff has a role to play in ensuring that we act in accordance with our data protection program. In fact, every member of our staff is called upon to:
Fondation Stéphan Crétier recognizes the importance of the protection, confidentiality, and security of the personal data it processes in the course of its activities, and of making its employees and partners aware of this.
Fondation Stéphan Crétier has prepared best practice and prohibited practice guidelines regarding how we may process your personal data, for example:
Fondation Stéphan Crétier has implemented a process to respond to and handle privacy incidents.
Under this process, Fondation Stéphan Crétier must take reasonable steps to reduce the risk of serious harm and review its practices to prevent similar privacy incidents in the future.
Fondation Stéphan Crétier documents all privacy incidents in its Privacy Incident Log and will adapt its privacy program as necessary following a privacy incident.
Legitimate interest means our business interest in conducting and managing our business to enable us to offer you the best service and the best and safest experience. We ensure that we consider and balance any potential impact on you (positive and negative) and your rights to process your personal data for the purposes of our legitimate interests. We will not use your personal data for activities where the consequences to you outweigh our interests (unless we have obtained your consent or are otherwise required or permitted by law). You can find out more about how we assess our legitimate interests in relation to the impact on you of particular activities by contacting us.
Contract performance means the processing of your data where this is necessary for the performance of a contract to which you are a party or to take steps, where you so request, prior to entering into such a contract.
Compliance with a legal or regulatory obligation means processing your personal data where this is necessary to comply with a legal or regulatory obligation to which we are subject.
Other Fondation Stéphan Crétier providers / affiliates acting as joint controllers or processors and located in various international locations.
You have the right to do the following:
Request access to your personal data (commonly referred to as a “data access request”). This allows you to receive a copy of the personal data we hold about you and to check that we are processing it legitimately.
Request the correction of any personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of any new data you provide.
Request the deletion of your personal data. This allows you to ask us to delete or withdraw personal data when we have no valid reason to continue processing it. You also have the right to ask us to delete or withdraw your personal data if you are successful in exercising your right to object to processing (see below), if we have processed your information unlawfully or if we are required to delete your personal data to comply with local law. Please note, however, that we may not always be able to accept your request for deletion for specific legal reasons, which will be notified to you, where applicable, at the time of your request.
To object to the processing of your personal data where we rely on a legitimate interest (or that of a third party) and your particular circumstances prompt you to object to the processing on the basis of this ground, as you consider that it adversely affects your fundamental rights and freedoms. You also have the right to object if we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate grounds for processing your information that override your rights and freedoms.
Request the restriction of the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following cases: a) if you want us to establish the accuracy of the data; b) when our use of the data is unlawful, but you do not want us to delete it; c) if you need us to retain the data, even if it is no longer necessary for us, because you need to formulate, assert or contest legal claims; or d) you have objected to our use of your data, but we need to verify whether we have legitimate and compelling reasons to use it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party chosen by you, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to automated information that you have initially authorized us to use, or if we have used this information to enter into a contract with you.
Withdraw your consent at any time where we rely on your consent to process your personal data. However, this will not affect the legitimacy of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will notify you if this is the case at the time you withdraw your consent.
Fondation Stéphan Crétier reserves the right to modify this Privacy Notice at any time, without notice, by posting the modified Privacy Notice on its website. Please check back frequently.