Protecting your privacy is very important to us. This Policy applies to and governs the collection, use and communication of your personal information whether you seek to be, are or were clients.
Urgel Bourgie / Athos is part of the Athos group, a family of affiliated companies with operations across Québec. This Policy therefore applies to personal information that is in our possession or that is under our control, including information that we may exchange with other Athos entities and information that we may transfer to a third party for warehousing or processing purposes. This Policy does not however govern third parties that you may be invited to contact, for example, through our website.
The purpose of this Policy is to explain how we collect, use and disclose the personal information you may provide to us and is meant to comply with the Canadian federal and provincial privacy laws.
- The collection of your personal information
Personal information is any information which relates to an individual and allows that individual to be identified, whatever the nature of its medium and whatever the form in which it is accessible, whether written, graphic, taped, filmed, computerized or other. Information concerning a company or a partnership is not personal information.
Your consent to the collection, use or disclosure of your personal information must be manifest, free and enlightened. It must be given for specific purposes. Depending on the nature and sensitivity of your personal information, your consent can be express and positive (express and positive consent may be oral, in writing or electronic) or implied (such as providing information voluntarily). Generally, we will seek your consent for the collection, use or disclosure of your personal information at the time of collection, except as otherwise required or in cases authorized by law.
Your consent can be withdrawn at any time, subject to legal and contractual restrictions and reasonable notice. Please note that if you choose to withdraw your consent, we may not be able to provide you with certain products or services.
We only collect personal information about you that is necessary for the purposes of establishing, managing and maintaining our relationship with you. For example, personal information may be collected when you request a product or service, or submit questions, comments or suggestions by telephone or electronically. Personal information may also be collected during the course of our relationship with you if it is necessary to allow us to provide to you ongoing service.
Personal information that is collected may include, but is not restricted to:
- identification information, such as your first and last name, your date of birth, your home address, your telephone number and your email address, as well as your social insurance number when it is required by law;
- financial information, such as your credit card and banking information;
- information regarding the beneficiary, if applicable, family members and friends;
- information regarding the products and services that you choose to acquire or benefit from;
- medical and other information required to complete governmental requirements and forms.
Generally, we will obtain your personal information directly from you. However, we may also collect personal information about you from outside sources with your consent or without your consent if the law so authorizes, such as when the collection from a third person is necessary to ensure the accuracy of the information you have provided, if the source is legally allowed to disclose personal information about you.
- The use and communication of your personal information
We may use your personal information for the following purposes:
- to identify you and establish and maintain our business relationship with you;
- to provide you with ongoing service, including when you choose to apply for one of our products or services online, to process your application and payment, and to ensure proper delivering;
- to improve our products and service offerings;
- to communicate with you when you submit questions, comments or suggestions and to provide you with information about our business, products and services that may be of interest to you;
- to administer contests;
- to prevent errors and fraud;
- to comply with our legal obligations.
Your personal information shall not be used for purposes other than those described above except with your consent or as required or authorized by law.
We recognize that, except in the cases and under the conditions described hereinafter and as authorized or required by law, the communication of your personal information requires your consent when your personal information is communicated to a third person.
According to the applicable legislation, for example, personal information about you may be communicated by us, without your consent, to the following persons:
- to our legal counsel;
- to a person or body having the power to compel communication of the information if it is required in the exercise of his or its duties or functions including to comply with a subpoena, a warrant or rules of the Court pertaining to the production of documents;
- to a person or body responsible, by law, for the prevention, detection or repression of crime or statutory offences who requires it in the performance of his or its duties and if the information is needed for the prosecution of an offence under applicable law;
- to a person to whom it is necessary to communicate the information under the applicable law;
- to a person who is authorized by law to recover debts on behalf of us and requires it for that purpose in the performance of his or its duties or to a person if the information is needed for the recovery of our claim.
Access within the company also does not require your consent but is strictly limited to the persons for whom such information is necessary for the performance of their functions and duties. Unauthorized access to or disclosure of your personal information by an employee is strictly prohibited and will result in appropriate disciplinary measures.
Similarly, the exchange of your personal information between Athos entities does not require your consent if the personal information is necessary to allow these entities to assist us for the purposes of establishing, managing and maintaining our business relationship. We may also share your personal information, without your consent, with our agents, mandataries, consultants, data processors and other service providers if the personal information is necessary to allow these entities to further assist us for the purposes of administering our relationship. In such cases, your personal information will be used exclusively to provide specific services and will be kept confidential in accordance with this Policy.
Please note that in the event that the third party to whom we disclose personal information about you is located in a foreign jurisdiction, local laws may otherwise allow your personal information to be accessed by third parties without your consent.
- Accuracy and safeguards
We have put in place a series of security safeguards that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored, in order to protect your personal information against loss and theft, as well as unauthorized access, disclosure, copying, use and modification.
These security safeguards include :
- physical measures, such as the use of fireproof vaults, locked cabinets and secure accesses to its establishments;
- organizational measures, such as round-the-clock personnel and limited access to more sensitive areas;
- technological measures, such as the use of a secure network and servers to transfer and to store electronic data, the use of passwords and continuously updated antivirus software.
We also take the necessary measures to ensure that all its managers and employees are informed on the contents of this Policy and understand that they are required to conform to it at all times.
We further recognize that it is important to keep personal information accurate, complete and up-to-date and takes reasonable steps to ensure the accuracy and completeness of the personal information it uses and discloses. However, you are responsible to inform us of any significant change in your personal information which may occur during the course of our business relationship.
We will keep your personal information for the time required to fulfill the identified purposes, its legitimate business purposes and to conform to the legislative requirements.
- Access and rectification requests
You have the right to request to consult and to obtain communication of your personal information which is contained in a file held by us. You can also request that information which is inaccurate, incomplete or equivocal be rectified and that information not justified by the purpose of the file be deleted.
All questions or concerns regarding this Policy or about the collection, use and disclosure of your personal information, including requests for access or rectification, should be made in writing to:
Urgel Bourgie / Athos
Attn: Customer Service
160 Graham Blvd.
Town of Mount Royal, QC
We will respond to every request for access and rectification within 30 business days of receiving the written request. In the event that we cannot provide access to or rectify your personal information, it will inform you of the reasons why, subject to any legal or regulatory restrictions, and it will provide you with any recourse available.
- Modifications to the Policy
We reserve the right to change this Policy at any time. We will do so by posting a revised Policy on our website. We recommend that you print a copy of this Policy for your records and review this section of our website periodically.