Confidentiality Policy

1. GENERAL CONSIDERATIONS

1.1. Objective

2. What information do we collect?

3. How do we collect your information?

4. How do we use personal information?

5. With whom do we share personal information?

6. For how long do we retain personal information?

7. Where do we store personal information and information transferred outside of Quebec?

8. How do we protect personal information?

9. What rights does a person have over their personal information?

10. How do we use cookies and similar technologies?

11. How should people communicate with us?

12. How do we update this policy?

1. GENERAL CONSIDERATIONS

1.1. Objective

The Fondation Charles-Bruneau is an organization that works to collect financing. We collect, use and disclose information on a daily basis for purposes of delivering our services, including the solicitation of contributions in various forms, and participation in events, draws and lotteries. Keeping information confidential is important to us. We uphold the most rigorous ethical standards pertaining to the treatment of all information, particularly personal information.

This Policy on the Protection of Personal Information aims to make it easier to understand our practices in relation to the collection, use, disclosure and retention of personal information. By providing us with personal information (through our Web site, by completing an event participation form or a donation form, online, by email, in person or by telephone), you agree to have the said information treated in accordance with the provisions set out in this Confidentiality Policy, and you authorize the Fondation Charles-Bruneau, its third parties and service providers to handle your personal information for the purposes set out below (see Point 4).

This Policy on the Protection of Personal Information does not apply to third-party Web sites that can be accessed by clicking on the links on the current Web site, and the Fondation Charles-Bruneau assumes no responsibility for such third-party Web sites. Such is the case when you make a donation, for example. In the latter case, you are redirected to a transactional Web site, since the Fondation does not collect or retain information on credit cards, including credit card numbers. If you click on a link to a third-party Web site, the Web site in question will have its own policies concerning the protection of personal information that you must carefully read before submitting your personal information.

2. What information do we collect?

Personal information includes any information concerning an individual that makes it possible to identify that person. It does not include anonymous data, i.e., data that has been de-identified. We can collect, use, store and transfer different types of personal information concerning you in the course of our activities and the delivery of our services, including:

Professional and/or personal contact information, such as a first name, last name, address, email address, date of birth, and telephone number.
Biographical information, such as a job title, the name of an employer, professional and/or personal development details, photos, and video or audio content.
Biometric information, such as clothing size (for equipment provided as part of our events), preferences / restrictions / dietary allergies and other medical conditions to know about in case of emergency and required for your safety when you participate in an activity or an event organized by the Fondation Charles-Bruneau.
Information related to marketing and communications preferences, and related information, including on dietary preferences, as well as comments and responses to surveys.
Information related to the history of contributions, participation in events held by the organization, billing and financial information, such as a billing address, bank account information, or payment data. We do not retain information on credit cards, including credit card numbers.
Information related to services, such as details concerning services that we have provided to you.
Information on your professional career, networks, social involvement, professional affiliations and family ties.
Information concerning recruitment, such as a curriculum vitae, information on schooling and work history, details concerning professional affiliations, and other information relevant to potential recruitment by the Fondation Charles-Bruneau.
Information on the use of the Web site and other technical information, such as details concerning visits to our Web sites, your interaction with our advertising and our online content, or information collected by means of cookies and other tracking technologies.
Information concerning your donation and community investment policy, your contributions, the beneficiary organizations and their goals, if applicable, the recognition received, the decision-making process, and the people involved in the organization and this process.
Any other personal information provided. Please note that if you provide us with personal information on other people (e.g., clients, administrators, directors, shareholders or actual owners), you must duly notify the latter that you are sharing their personal information, and you must secure their consent to communicate such information.
If applicable, proof of consent provided to us (date, time, means), under circumstances where consent is required to handle personal information.

We will not knowingly collect information from children or people under the age of 14. If you are a minor under the age of 14, please do not provide us with personal information without the expressed consent of a parent or guardian. If you are a parent or a guardian and you know that your children have provided personal information, please contact us. If we find out that we have collected personal information from a minor child without first checking if parental consent has been given, we will ensure that this information is deleted from our servers.

3. How do we collect your information?

We collect your personal information directly from you and in the course of our interactions with you, as follows:

When you register for events or activities and subscribe to newsletters.
When you make a donation to our organization, regardless of its form.
When you submit an application for a vacant position.
When you register as a volunteer with our organization.
When we deliver services to you.
When your child is registered as a hero or a paired child.

We also collect information that is accessible to the public, notably on public platforms, including on our Web site.

4. How do we use personal information?

We can use personal information in one of the manners cited below, with your consent or, if applicable, on another legal basis. In each case, we specify the reasons for which we are using your personal information:

To provide our services and conduct our affairs, and to administer and deliver our services, including to fulfil our obligations stemming from any agreement concluded between you and the Fondation.
To ensure the safety of participants, employees and volunteers involved in the presentation of our activities and events.
To confirm with families that they consent to pairing children with our participants as part of our events and activities.
To facilitate the use of our Web sites and ensure that the content is relevant, and to ensure that the content on our Web sites is presented in the most effective manner for you and your device.
For business development purposes: To provide details on our mission and our offers, along with information on the development of our organization and our sector, and invitations to events when a person chooses to receive such information.
For purposes of philanthropic prospecting, by issuing calls for donations or inviting you to renew a donation. At all times, we stop communicating with donors who no longer wish to receive this type of communication. You can withdraw your consent to having us contact you by using the contact information shown in the section entitled “How should people communicate with us?”
For purposes of research and development (including from a safety standpoint): To conduct analyses aimed at gaining a more accurate socio-demographic portrait of our community, our donors and the participants in our events, and to develop our services and offers.
For recruitment purposes: To process job applications and determine if an applicant meets the requirements of the position for which they may submit an application to the Fondation Charles-Bruneau.
To meet our legal, regulatory or risk management obligations.
To prevent fraud and/or carry out other background checks that may be required at any time under law or the applicable regulations and/or in accordance with best practices (if false or inaccurate information is provided or if fraud is observed or suspected, information could be transmitted to fraud prevention organizations and could be saved by the Fondation or by other such organizations). When we process special categories of personal information, we can also base ourselves on elements that hold significant public interest (prevention or detection of crimes) or on claims based in law.
To ensure that our rights are respected, to meet our legal or regulatory obligations pertaining to the communication of information, or to protect the rights of third parties.
To ensure that we are paid: To recover payments owed to us and, if applicable, to carry out related collections by calling upon debt collection agencies or resorting to other legal means (including legal proceedings).
To reorganize or change our organization: If we undertake a reorganization (e.g., by merging, consolidating and assigning part of our organization’s mission), we may have to transfer personal information, in part or in full, to an applicable third party (or its advisors) under any due diligence process or any transfer to the said entity stemming from a reorganization or to the said third party for the same purposes as those set out in this Policy on the Protection of Personal Information or for purposes of analyzing any proposed reorganization. In such a situation, we will take all the means possible to ensure the protection and security of personal information.

5. With whom do we share personal information?

The Fondation Charles-Bruneau is a legal person (a non-profit organization duly incorporated and recognized as a charity). We can share personal information with certain third parties, including the following:

Volunteers and employees of the Fondation Charles-Bruneau, for human resources and volunteer recruitment purposes, and for purposes of soliciting financial or other contributions.
Third-party service providers and/or partners, notably those who could provide us with services, including donation solicitation, database analysis, Web sites, the development of applications, hosting, maintenance, secure oversight, and other services. These third parties could have access to personal information or could handle personal information as part of the services they provide to us. We limit the information that we provide to these service providers to information that is reasonably required for them to perform their duties, and the contracts that we enter into with these service providers require that they uphold the confidentiality of the said information.
Government authorities and law enforcement agencies, when required under the applicable laws. For greater accuracy, we can divulge personal information and other information if we are required to do so by law, notably under taxation laws, or if we believe in good faith that such a disclosure is necessary to comply with the applicable laws, in response to a court order or a subpoena to testify, or to a search warrant from the government, or otherwise to collaborate with such government authorities and law enforcement agencies.

We will use personal information for the sole purpose of meeting the main objective and the legitimate applicable objective for which the information was collected, or for purposes that are compatible with the said main objective.

The organization uses the services of third-party sites, such as Google and Facebook, to promote its content and offers.

When you visit our Web site, these third parties may use cookies, Web bugs or other similar technologies on your hard drive to collect or receive information concerning your navigation on the Web site and elsewhere on the Internet. These technologies allow the user to disseminate relevant and targeted advertising based on your interests. You can view the cookies and clear them if you wish. You have full control, therefore. We would advise you to refer to the parameters on your Web browser to make the appropriate changes.

If you want third-party Web sites to store cookies on your hard drive so that they can offer you more targeted advertising, you can activate this option.

For further information, please view our Policy on Cookies (under construction).

6. For how long do we retain personal information?

We retain personal information only for the duration required to serve the purposes set out under this Policy on the Confidentiality of Personal Information, and to meet our legal and regulatory obligations.

To find out more about the duration applicable to the retention of personal information, please contact us using the contact information shown under the heading “How should people communicate with us?”

7. Where do we store personal information and information transferred outside of Quebec?

Personal information collected is stored in a secure and recognized database. It is also kept on our Web sites and servers.

The personal information that we collect and store on our database and on our Web sites is saved on servers located within the province of Quebec. The information kept on our servers (Office 365) is saved on servers located in and outside Quebec, but still within Canada.

All documents containing personal information that could be printed is kept in a secure location, such as in file cabinets.

8. How do we protect personal information?

We comply with widely accepted standards in the sector to ensure the protection of personal information shared with us, both at the time that it is transmitted to us, and after receiving it. We apply the proper physical, technical and administrative measures to protect personal information against destruction that is accidental or non-compliant with the applicable laws, and against accidental loss, alteration, unauthorized disclosure or access, poor usage, or any other illegal form of handling personal information in our possession. We have taken measures to guarantee that the only staff members who have access to your personal information are those who require it or whose duties reasonably require knowledge of this information.

All staff at the Fondation sign a confidentiality agreement pertaining to the personal information to which they may have access in the performance of their duties. Electronic information is kept in a secure database and on the Fondation’s servers. Several restricted-access servers make it possible to better manage and protect more sensitive information. In addition, physical files are kept in the Fondation’s premises and, depending on their nature, in locked file cabinets.

However, no method of transmission by Internet and no electronic storage is 100 percent secure. While we take the security measures required to ensure the protection of personal information and any reasonable measures given their sensitivity, in particular, their ultimate use, quantity, distribution and support, we cannot ensure or guarantee the security of information that you transmit or provide to us, and you do so at your own risk. Nor can we guarantee that such information will not be viewed, obtained, disclosed, altered or destroyed due to the violation of our physical, technical or administrative protection measures. If you have reason to believe that personal information has been compromised, please contact us using the contact information shown under the heading entitled “How should people communicate with us?” In the event that there is an incident concerning the confidentiality of your personal information, we will undertake to notify you as soon as possible after learning about the incident. We will take reasonable measures to reduce the risk of harm and prevent a recurrence of subsequent incidents of the same nature.

9. What rights does a person have over their personal information?

Under certain circumstances and in compliance with the laws applicable to the protection of data, a person has the following rights:

Access: The right to request whether we handle personal information and, if applicable, to request access to the personal information in question. Subject to the applicable right and, where relevant, payment of a monetary sum to cover the fees incurred for transcription, reproduction and transmission, the person can also receive a copy of the personal information that we hold as well as other information concerning them. The amount due can vary, depending on the request, and is transmitted beforehand to the person submitting a request for access to such information.
Accuracy: We are required to take reasonable measures to ensure that the personal information in our possession is accurate, complete, not misleading, and up to date.
Rectification: The right to request that any incomplete or inaccurate personal information that we hold be rectified.
Dereferencing: The right to request that their personal information no longer be disseminated, or to request that any hyperlink attached to their name and providing access to information be dereferenced if its dissemination could cause them harm or violate the law or a court order (right to erasure or right to be forgotten)
Anonymization: The fact that our organization can anonymize personal information for use, rather than destroy it, but solely for serious and legitimate purposes (e.g., retention of information required for an eventual tax audit).
The right to be informed when you are subject to a decision founded exclusively on automated processing.
The right to be informed when there is recourse to an identification, localization or profiling technology and the means available to activate these functions.

Lastly, it is also possible to file a complaint with a data protection authority, specifically in the country, province or state in which you normally reside (in Quebec, the Commission d’accès à l’information), in which we are located, or in which an alleged breach of data protection laws was committed.

In order to exercise any of these rights, please contact us in the manner shown under the heading entitled “How should people communicate with us?”

10. How do we use cookies and similar technologies?

The Fondation’s Web sites use cookies to help you effectively navigate and perform certain functionalities. Detailed information on all the cookies can be found under each consent category accessible on the Web sites. An automatic banner display lets you manage or refuse cookies.

Cookies categorized as “necessary” are stored on your browser, as they are essential for allowing basic functionalities on the Web site. We also use third-party cookies to help us analyze how you use this Web site, register your preferences, and provide you with relevant content and advertising. These cookies will only be stored on your browser with your prior consent.

You can choose to activate or disable these cookies in part or in full, but disabling some of them may affect your browsing experience.

11. How should people communicate with us?

To submit questions, comments or a complaint concerning the Policy on the Protection of Personal Information or concerning personal information, exercise your rights, file a complaint (please view our Complaint Policy) or receive information on our policies and practices concerning service providers outside of Canada, please contact our privacy protection agent by email at directiongenerale@charlesbruneau.qc.ca, by telephone (1-877-256-0404) or by postal mail at the following address:

Fondation Charles-Bruneau

To the attention of Rébecca Dumont

Responsible for the protection of personal information

4515 Rue de Rouen

Montreal QC H1V 1H1

12. How do we update this policy?

We can alter the content of our Web sites and the way that we use cookies without prior notice. Consequently, our Policy on the Protection of Personal Information and our Policy on Cookies could be amended on occasion in the future. We encourage you to review these policies each time you visit the Web site, therefore, to stay informed about the manner in which we handle personal information.

This policy was last updated on July 26, 2023.