Momento, brand of Innovair Solutions inc. (The "Company") acknowledges the importance of protection of personal information and takes seriously its use of this information.
It therefore agrees to collect, use, communicate and keep only the personal information required for carrying out its activities and within the framework of its business.
The Company has adopted a policy on the protection of personal information, applies it in the course of its business, and has appointed, in accordance with the "Act respecting the protection of personal information in the private sector" (the "APPIPS
") a person responsible for the protection of personal information and privacy within the company. The name and contact details of this person are provided at the end of this section.
When and how is personal information collected?
In the normal course of its activities and within the framework of its business and its provision of services, the Company collects certain personal information that is required for these purposes or any other relevant purpose if the criteria of the APPIPS and other applicable laws and regulations relating to personal information protection are met (collectively referred to as the "Act
"). Personal information may also be collected by the Company for the purposes of employment, customer research, collections, consultation, and business relations.
Personal information collected by the Company may relate to identity, contact details, health, social or family situation, employment, recruitment, financial information, training, or education of the individuals concerned, depending on the nature of the relationship between these individuals and the Company. Identification documents that include personal information may also be collected by the Company.
The Company ensures that the individuals whose personal information is being collected are notified and that they understand the reasons why their information is being collected.
The Company may collect personal information using technology that uses functions to identify, locate or build a profile of an individual. In this situation, the individual concerned will be asked to provide their consent in accordance with the Act. Information on the use of the Company's website and other technical information or on the website visitor's interaction may be collected.
In situations where the personal information collected by the Company is provided by a third party, namely a person other than the individual whose information is being collected, the person who provides the information must ensure that they have obtained the individual's consent and have notified them beforehand.
How will the personal information be used?
The personal information collected by the Company is used to provide services, ensure the smooth running of the Company and, in certain situations, to meet legal obligations arising from the Act. The personal information collected by the Company may also be required to fulfill its contractual obligations to its customers and third parties.
In what situations can personal information be shared by the Company?
The Company may share personal information that it has with third parties, including companies working as a subcontractor or service provider. These third parties may be outside the province of Quebec so that the personal information that the Company collects and retains may end up in a location with a different legal system than that of Quebec.
The contracts that the company concludes with third parties stipulate that they must preserve the confidentiality of personal information and require them to respect the Company's legal framework relating to the protection of personal information and privacy.
Subject to an exception provided for by the Act, consent will be requested from individuals whose personal information is collected if the Company needs to share with third parties any personal information not linked to its current operations and activities or which is not applicable to the purposes for which it was collected.
The Company may also share certain personal information that it holds as part of a commercial transaction or in other situations provided for in the Act. If the Company does not need to seek the consent of the individuals whose information is being shared, it will comply with the requirements of the Act to proceed with sharing the information.
In addition, the Company may be required to disclose certain personal information it holds to government authorities or law enforcement agencies.
What security measures are taken by the company regarding the personal information it has collected?
The Company implements policies and practices that set guidelines for business governance and the protection of personal information.
Personal information held by the Company is stored in secure places according to generally recognized practices, and access to this information is limited to employees who need to have access to it as part of their job roles.
Company employees are made aware of the importance of protecting personal information and the recommended steps to ensure confidentiality of this information is respected. As part of their roles, employees follow procedures that protect the confidentiality of personal information, and which promote best practices in this regard.
The Company ensures personal information is protected from the moment it is collected and implements security measures designed to protect the information from being used in a way that does not comply with the legislation in force, to avoid accidental losses, changes, disclosure or unauthorized access, misuse or any illegal form of use. However, the company cannot guarantee that the personal information it collects is completely protected against any breaches.
Where is the personal information collected by the Company stored?
Personal information can be held or transferred outside the province of Quebec, including in countries other than Canada where personal information regulations differ from those of Quebec and Canada. When information is outside Quebec or Canada, it is subject to the laws of the country where it is stored, and collection, communication, use and destruction of the information may be performed differently from provincial or federal requirements.
How long is personal information retained for?
Unless authorized or required by applicable laws, the Company only retains personal information for as long as necessary to achieve the purposes for which it has been collected, including for the purpose of meeting ethical, legal, tax, and accounting requirements or in matters of providing information to appropriate government authorities. At the end of this period, the personal information is destroyed, deleted or anonymized. Anonymized information cannot be used to identify the individual concerned and is irreversible.
In the event of a confidentiality breach involving personal information, the Company follows the provisions of the Act in force and takes reasonable measures to mitigate the risks that a breach may cause to the individuals affected by the confidentiality breach.
Complaints regarding confidentiality
Any person who believes that their personal information or that of another person has been the subject of:
· Access not authorized by the Act
· Use not authorized by the Act
· Sharing not authorized by the Act
· Loss or any other infringement of the protections provided for by the Act
is asked to file a complaint in writing to the Personal Information Protection Officer mentioned below.
The complaint must include the relevant details, namely the personal information concerned, the context, the potential or actual harm suffered, or which could be suffered, as well as the relevant dates. The details of the reported incident should be described as accurately as possible so that a response can be provided quickly.
Any employee who receives a complaint must forward it, upon receipt, to the Personal Information Protection Officer.
After receiving a complaint, the Company will comply with its internal complaints handling procedure, in order to handle the complaint fairly.
Personal Information Protection Officer
For any questions or comments regarding the way in which the Company processes personal information during its life cycle within the Company, or if you wish to assert your rights provided for in the Act regarding the protection of personal information, you can contact the Company's Personal Information Protection Officer:
Mr. Sylvain Claireaux CPA
Innovair Solutions inc.
180 3rd Avenue
L’Islet QC G0R 2C0