1. Context
This policy aims to ensure the protection of personal information and to frame the way in which Jeux modul’air collects, uses, discloses, retains, and destroys it or otherwise manages it. Moreover, it seeks to inform anyone interested in how Jeux modul’air, in partnership with BOURRASQUE, processes their personal information. It also concerns the processing of personal information collected by Jeux modul’air through technological means, in collaboration with BOURRASQUE.
2. Scope and Definitions
This policy applies to Jeux modul’air, which notably includes its executives, employees, consultants, volunteers, as well as any other person who otherwise provides services on behalf of Jeux modul’air. It also pertains to the Jeux modul’air website, as well as all websites controlled and maintained by Jeux modul’air.
It covers all types of personal information managed by Jeux modul’air, whether it be information about its current or potential customers, consultants, employees, members, or any other individuals (such as website visitors or others).
For the purposes of this policy, personal information is information about an individual that directly or indirectly identifies them. For instance, this could be the name, address, email address, phone number, gender, or banking details of a person, information about their health, ethnic origin, language, etc.
Sensitive personal information is information for which there is a high degree of reasonable expectation of privacy, e.g., health details, banking information, biometric data, sexual orientation, ethnic origin, political views, religious or philosophical beliefs, etc.
Generally, a person’s business or professional contact details do not constitute personal information, for example, a person’s name, title, address, email address, or work phone number. More specifically, and for clarity, as per the Personal Information Protection Act in the private sector of Quebec, and starting from September 22, 2023, sections 3 (collection, use, disclosure), 4 (retention and destruction), and 6 (data security) do not apply to information about a person relating to the performance of a role in a company, such as their name, title, role, and the address, email, and phone number of their workplace.
The same sections also do not apply to personal information that is public by law, from the effective date of this policy onwards.
3. Collection, Use, and Disclosure
In the course of its operations, Jeux modul’air may collect various types of information for various purposes. The types of information that Jeux modul’air might collect, their intended use, and the means by which they are collected are detailed in Annex A of this policy.
Jeux modul’air will also inform the concerned individuals, at the time of collecting personal information, of any other information gathered, the purposes for which they are collected, and the means of collection, in addition to other mandatory information required by law.
Jeux modul’air adheres to the following general principles regarding the collection, use, and disclosure of personal information:
Consent
Generally, Jeux modul’air collects personal information directly from the concerned individual with their consent unless a legal exception applies. Consent may be implied in certain situations, for example, when an individual provides their personal information after being informed by this policy about its use and disclosure for the purposes specified herein (refer to Annex A for more details). Therefore, the individual can review this policy and its contents at the time of data collection.
Typically, Jeux modul’air must also seek the individual’s consent before collecting their personal information from third parties, disclosing it to third parties, or using it for secondary purposes. However, Jeux modul’air can act without consent in specific cases allowed by law. Key situations where Jeux modul’air may act without consent are highlighted in the relevant sections of this policy.
Collection
In all cases, Jeux modul’air only collects information when there’s a valid reason and limits the collection to what’s necessary for the intended purpose.
Please note that Jeux modul’air’s services and programs are not intended for minors, and generally, Jeux modul’air does not intentionally collect personal information regarding minors. In such cases, the data can’t be gathered without consent from a parent or guardian.
Collection from third parties: Jeux modul’air may collect personal information from third parties. Unless a legal exception applies, Jeux modul’air will seek the individual’s consent before collecting personal information concerning them from a third party. If such information isn’t directly collected from the individual but from another organization, the individual can ask Jeux modul’air about the source of the collected data. In certain scenarios, Jeux modul’air may also collect personal information from third parties without the individual’s consent if there’s a significant and legitimate interest, such as a) if collecting the data benefits the individual and can’t be obtained in a timely manner or b) if necessary to ensure the accuracy of the information. Also, Jeux modul’air may indirectly collect personal information using platforms like: TidioChat, MailChimp, Cyberimpact, Mailersend, Stripe, Paypal, Twilio, Zeffy – each having its own terms and privacy policy that can be consulted for further details.
Collecting through third parties might be necessary for availing certain services or programs, or otherwise doing business with Jeux modul’air. When required, Jeux modul’air collects the individual’s consent at the appropriate time.
Retention and Use
Jeux modul’air ensures that the information it holds is up-to-date and accurate when making decisions related to the concerned individual.
Jeux modul’air can only use an individual’s personal information for the reasons specified in this policy or any other reasons provided during collection. If Jeux modul’air wishes to use this information for another purpose, new consent from the concerned individual must be obtained, expressly if it’s sensitive personal information. However, in certain legally permitted scenarios, Jeux modul’air can use the information for secondary purposes without the individual’s consent, e.g., if clearly benefiting the individual, necessary for fraud prevention or detection, or necessary to evaluate or enhance security measures.
Limited Access: Jeux modul’air must implement measures restricting access to personal information only to those within its organization who need to know it. Jeux modul’air will seek the individual’s consent before granting access to anyone else.
Disclosure
Generally, unless an exception is noted in this policy or legally allowed, Jeux modul’air will obtain the individual’s consent before disclosing their personal information to a third party. Additionally, when consent is required and it involves sensitive personal information, Jeux modul’air will need explicit consent before disclosure.
However, sometimes disclosing personal information to third parties is necessary. Thus, personal information might be disclosed without the individual’s consent in specific cases, notably but not exclusively, in the following situations:
Jeux modul’air can disclose personal information, without the individual’s consent, to a public entity (like the government) collecting it in its official capacity or for a program it oversees. Personal information might be shared with service providers who need the information, without the individual’s consent.
For example, these might be event organizers, Jeux modul’air’s subcontractors, or cloud service providers. In such cases, Jeux modul’air must have written contracts with these providers detailing measures to ensure data confidentiality, use of data only for contract fulfillment, and no retention of data post-contract expiration. Also, these contracts must stipulate that providers must notify Jeux modul’air’s data protection officer (mentioned in this policy) of any breach or attempted breach of confidentiality obligations and allow audits for data confidentiality.
If necessary for a business transaction, Jeux modul’air might also disclose personal information without the individual’s consent to another transaction party, subject to legal conditions.
Disclosure Outside of Quebec: Personal information held by Jeux modul’air might be disclosed outside of Quebec, for example, when Jeux modul’air uses cloud service providers with servers located outside Quebec or when working with subcontractors outside the province.
Additional Information on Used Technologies: Use of Cookies: Cookies are data files transmitted to a website visitor’s computer by their web browser when visiting the site and can serve various purposes. Websites controlled by Jeux modul’air use cookies to:
- Remember visitor settings and preferences, such as language choice and to track the current session.
- For statistical purposes to understand visitor behavior, viewed content, and improve the website. Websites controlled by Jeux modul’air use the following types of cookies:
- Session cookies: Temporary cookies stored only for the website visit duration.
- Persistent cookies: Stored on the computer until they expire and are retrieved during the next site visit. Some cookies might be disabled by default, and visitors can choose to enable these functions or not while browsing Jeux modul’air’s websites. Also, you can activate or deactivate cookie usage by adjusting browser settings.
Use of Google Analytics
Jeux modul’air’s site uses Google Analytics for continuous improvement. Google Analytics primarily analyzes how a visitor interacts with a Jeux modul’air website. Google Analytics uses cookies to generate statistical reports on visitor behavior and viewed content. Information from Google Analytics won’t be shared by Jeux modul’air with third parties. It’s possible to install a browser add-on to disable Google Analytics.
Other Technological Means Used
Jeux modul’air also collects personal information using technological means, such as embedded web forms on a Jeux modul’air-controlled website (e.g., contact form, membership registration form, newsletter and seminar signup), online surveys on its platforms and apps, and other form platforms (e.g., Microsoft Forms). If Jeux modul’air collects personal information by offering a technological product or service with privacy settings, it ensures these settings provide the highest level of default privacy (excluding cookies).
4. Retention and Destruction of Personal Information
Unless a minimum retention period is required by applicable law or regulation, Jeux modul’air will retain personal information only for as long as necessary to fulfill the purposes for which they were collected.
Personal information used by Jeux modul’air to make a decision regarding an individual must be retained for at least one year following that decision or even seven years after the end of the fiscal year in which the decision was made if it has tax implications, such as circumstances involving termination of employment.
Upon reaching the end of the retention period or when the personal information is no longer necessary, Jeux modul’air will ensure: to destroy them; or to anonymize them (meaning they no longer, in an irreversible manner, allow the identification of the individual and it’s no longer possible to establish a link between the individual and the personal information) for use for significant and legitimate purposes.
The destruction of information by Jeux modul’air must be done securely to ensure the protection of this information.
This section can be complemented by any policy or procedure adopted by Jeux modul’air concerning the retention and destruction of personal information, as applicable.
Please contact the personal information protection officer of Jeux modul’air (indicated in this policy) to learn more.
5. Responsibilities of Jeux modul’air
In general, Jeux modul’air is responsible for the protection of the personal information it holds.
The personal information protection officer of Jeux modul’air is the director of operations of the organization. He or she must generally ensure compliance with applicable legislation regarding the protection of personal information.
The officer must approve the policies and practices governing the management of personal information. Specifically, this person is tasked with implementing this policy and ensuring it is known, understood, and applied. In the absence or inability of this officer to act, the president of Jeux modul’air will assume the functions of the personal information protection officer.
Staff members of Jeux modul’air with access to personal information or otherwise involved in its management must ensure its protection and comply with this policy.
The roles and responsibilities of Jeux modul’air employees throughout the life cycle of personal information may be specified in any other Jeux modul’air policy on this subject, as applicable.
6. Data Security
Jeux modul’air commits 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. Thus, this means that information that can be qualified as sensitive (see the definition provided in section 2. Application and Definitions) must be subject to greater security measures and must be better protected. Specifically, and in accordance with what was previously mentioned about limited access to personal information, Jeux modul’air must implement necessary measures to impose constraints on the rights of use of its information systems so that only employees who need to have access are authorized to do so.
7. Rights of Access, Correction, and Consent Withdrawal
To assert their rights of access, correction, or consent withdrawal, the concerned individual must submit a written request for this purpose to the personal information protection officer of Jeux modul’air, at the email address indicated in the following section.
Subject to certain legal restrictions, individuals can request access to their personal information held by Jeux modul’air and request its correction if it is inaccurate, incomplete, or ambiguous. They can also demand the cessation of the dissemination of personal information concerning them or that any hyperlink attached to their name that provides access to this information through technological means be de-indexed when the dissemination of this information violates the law or a court order. They can do the same, or also demand that the hyperlink providing access to this information be re-indexed when certain conditions provided by law are met.
The personal information protection officer of Jeux modul’air must respond in writing to these requests within 30 days of the receipt of the request. Any refusal must be justified and accompanied by the legal provision justifying the refusal. In such cases, the response must indicate the remedies under the law and the time limit to exercise them. The officer must assist the applicant in understanding the refusal if necessary.
Subject to applicable legal and contractual restrictions, individuals can withdraw their consent to the communication or use of the collected information.
They can also ask Jeux modul’air what personal information is collected from them, the categories of people within Jeux modul’air who have access to it, and its retention period.
8. Complaints Handling Process Reception
Any person wishing to file a complaint regarding the application of this policy or, more generally, about the protection of their personal information by Jeux modul’air, must do so in writing by addressing the personal information protection officer of Jeux modul’air, at the email address indicated in the following section.
The individual must provide their name, contact information, including a phone number, as well as the subject and reasons for their complaint, providing sufficient details for it to be evaluated by Jeux modul’air. If the filed complaint is not specific enough, the personal information protection officer may request any additional information deemed necessary to evaluate the complaint.
Processing
Jeux modul’air commits to handling every received complaint confidentially.
Within 30 days of receiving the complaint or after receiving all the additional information deemed necessary and required by the personal information protection officer of Jeux modul’air to process it, the officer must evaluate it and provide a written, reasoned response by email to the complainant. This evaluation will determine if Jeux modul’air’s handling of personal information complies with this policy, any other policy and practice in place within the organization, and the applicable legislation or regulation. If the complaint cannot be processed within this period, the complainant must be informed of the reasons justifying the extension, the progress status of their complaint processing, and the reasonable time required to provide a definitive response.
Jeux modul’air must create a separate file for each complaint addressed to it. Each file contains the complaint, the analysis, supporting documentation for its evaluation, and the response sent to the person originating the complaint.
It is also possible to file a complaint with the Quebec Access to Information Commission or any other personal information protection oversight body responsible for enforcing the law concerned by the subject of the complaint.
However, Jeux modul’air invites any interested party to first contact its personal information protection officer and await the conclusion of the processing by Jeux modul’air.
9. Approval
This policy is approved by the personal information protection officer of Jeux modul’air, whose business contact details are as follows:
Personal Information Protection Officer:
Daniel Marcotte
1435 5e rang de Wendover, Saint-Cyrille-de-Wendover (Québec) J1Z 1S5
Technological Personal Information Officer:
BOURRASQUE
A/S RESPONSABLE NUMÉRIQUE
126 RUE DES URSULINES MATANE QUÉBEC G4W 1H1
For any requests, questions, or comments related to this policy, please contact the digital officer by email.
10. Modifications
Versions and changes:
- 1.0 – Effective since 2023-09-21
- First publication
Appendix A
Here is a non-exhaustive list regarding the types of information that Jeux modul’air might collect, their use, or the intended purpose, as well as the means by which the information is collected. This includes, but is not limited to, the following items. Please note that most of the personal information managed by Jeux modul’air relates to employees, job applicants, and consultants. For other categories of individuals listed in the table below, the provided information is, in most cases, of a professional or business nature (see Section 2. Application and Definitions regarding professional contact details).
A- Relationship with Jeux modul’air, services, program, etc. Client Type of personal information:
- Name
- Phone number
- Postal address
- Language
- Banking details (when necessary) Purpose of collection / uses: Establish and manage relationships with clients and provide a means of communication, deliver a service, gather information as part of a program, support program, protection of personal data). Note that it is sometimes necessary to communicate the provided information to the targeted program to respond to an inquiry. Method of collecting information: Through web forms integrated into a website controlled by Jeux modul’air
B- Relationship with Jeux modul’air, services, program, etc. Job applicants and employees Type of personal information:
- Name
- Phone number
- Postal address
- Social security number
- Date of birth
- CV (employment experiences) and reference letters
- Language Purpose of collection / uses:
- Managing communications with the applicant or employee
- Ensuring the operation of the payroll system Method of collecting information: Through web forms integrated into a website controlled by Jeux modul’air, and online questionnaires.
C- Relationship with Jeux modul’air, services, program, etc. Members (individuals and organizations) Type of personal information:
- Name
- Phone number
- Banking details
- Language Purpose of collection / uses:
- Registration as a member, future communications, billing, registration for activities organized by Jeux modul’air, and portals (member area). Method of collecting information: Through web forms integrated into a website controlled by Jeux modul’air.