Privacy policy

Last update: 2023-09-22

11864017 CANADA INC. (hereinafter referred to as ” Mofco ” or ” we “) believes that the protection of personal information is of paramount importance. It is for this reason that we have established this privacy policy (hereinafter referred to as the ” Policy “), the purpose of which is to protect your integrity and your right to decide whether or not to disclose your personal information.

This Policy sets out how Mofco collects, uses, discloses, processes and protects your personal information. By using our website https://www.mofco.ca/ (the ” Website “) or by transacting with us, you agree that we may collect, use, process, disclose and retain your personal information in accordance with the terms described herein. If you do not agree to abide by and be bound by this Policy, you are not authorized to visit, access or use our website, nor to share your personal information with us in connection with the mandates you entrust to us.

Our privacy practices comply with the following laws

    • The Personal Information Protection and Electronic Documents Act (PIPEDA – federal legislation)
    • Act respecting the protection of personal information in the private sector(Bill 25 – provincial legislation)

All personal information is collected in a fair and non-intrusive manner and with your consent. The personal information collected is accessible only to those persons required to fulfill the purposes for which it was collected. Mofco is committed to respecting the privacy of its customers, employees, applicants, and all visitors to its Website who voluntarily provide us with personal information. We are aware of the importance of protecting and managing the personal information you provide to us. This Policy will help you understand what information we collect, how it will be used and to whom it may be disclosed.

This Policy explains Mofco’s practices regarding information collected from its users via its Website.

1. MOFCO’S COMMITMENT TO THE TEN PRIVACY PRINCIPLES

In Canada, the “Fair Information Principles” concerning personal information are contained in a series of 10 principles developed by the Canadian Standards Association and enshrined in Canadian privacy legislation PIPEDA. Mofco adheres to the following 10 privacy principles:

Principle 1 – Responsibility

Mofco is responsible for personal information under its control and has designated a Privacy Officer who is accountable for Mofco’s compliance with this Policy and applicable laws.

Here are his contact details:

Privacy Officer
305B, St-Elzéar ouest
Laval, Quebec H7L 3N5
Contact form: http://loi25.mofco.ca

Principle 2 – Identifying Purposes

Mofco shall identify the purposes for which personal information is collected at or before the time the information is collected. Some of the purposes for which personal information is collected, used and/or disclosed are described in this Policy. In the event that we wish to collect, use and/or disclose personal information for purposes other than those contained in this Policy, Mofco undertakes to obtain your consent.

Principle 3 – Consent

Mofco is committed to obtaining your informed consent for the collection, use or disclosure of your personal information, except as provided by law.

Principle 4 – Limiting collection

Mofco will limit the collection of personal information, both with respect to the nature and amount of the information, to that which is necessary for the purposes identified by Mofco. Mofco will collect your personal information by fair and lawful means and not by misleading or deceiving you about the purpose for which we are collecting your personal information.

Principle 5 – Limiting Use, Disclosure and Retention

Mofco will not use or disclose your personal information for purposes other than those identified and for which it was collected, except with your prior consent or as permitted or required by law. Mofco will retain your Personal Information only for as long as is necessary to fulfill the purposes for which your Personal Information was collected.

In addition, our retention periods may be modified from time to time in response to legitimate interests (for example, to ensure the security of personal information, to prevent abuse and breaches or to prosecute criminals).

You can also rest assured that once the purpose for which the information was collected has been fulfilled, we will destroy or anonymize it in accordance with the law.

Principle 6 – Accuracy

If you have an account or have left comments on the site, you may request to receive a file containing all the personal data we have about you, including the data you have provided to us. You can also request the deletion of your personal data. This does not take into account data stored for administrative, legal or security purposes.

Principle 7 – Safety measures

Mofco will protect your personal information using security safeguards appropriate to the sensitivity of the information. Mofco is committed to following ISO 27001:2013 information security practices, ensuring rigorous and responsible management, without currently holding official certification.

Principle 8 – Transparency

Mofco will make available to you information about our policies and practices relating to the management of personal information.

Principle 9 – Individual Access

Subject to certain exceptions, Mofco undertakes, upon written request to our RPRPto disclose the existence, use and disclosure of your personal information and to provide you with access to that information. An individual shall be able to challenge the accuracy and completeness of the information held by us and have it amended as appropriate.

Principle 10 – The right to complain about non-compliance with the principles

You have the right to contact our RPRPwith a complaint regarding our compliance with this Policy.

2. CONSENT

2.1 This Policy applies to all information collected by and on behalf of Mofco, whether collected in writing, verbally or electronically or through any website operated by or on behalf of Mofco. By browsing the Website, or by transacting with Mofco, you consent to the collection and use of your personal information in accordance with the purposes described herein.

2.2 BY SUBMITTING PERSONAL INFORMATION TO MOFCO AND/OR BY BROWSING AND USING THE WEBSITE, YOU CONSENT TO MOFCO’S COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY AND SUBJECT TO THE TERMS AND CONDITIONS PERMITTED OR REQUIRED BY LAW.

3. CONSENT TO THE SHARING AND DISCLOSURE OF PERSONAL INFORMATION.

3.1 In addition to consenting to the terms and conditions of this Policy, including any relevant additional policies, you consent to Mofco sharing your personal information that you have provided to us on the terms and conditions set out herein.

4. NATURE OF THE INFORMATION WE COLLECT

4.1 ” Personal information ” means any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

4.2 Personal information includes, but is not limited to, a person’s first and last name, home address, home telephone number, cellular telephone number, e-mail address and employment information, such as may be found in a resume, background check information or references from previous employers.

4.3 ” Non-personal information ” means any information in the public domain. Information of a professional nature is considered non-personal and therefore not subject to special protection, and may be regularly shared with people both inside and outside Mofco. Information of a professional nature includes, but is not limited to: company name, address, e-mail address, business telephone number and is not considered personal information in some jurisdictions.

4.4 ” Sensitive Personal Information ” means Personal Information which, by its nature or the context in which it is used or disclosed, gives rise to a high reasonable expectation of privacy.

4.5 In the course of our activities, we may collect, process and use various types of personal information that you give us only if we are permitted to do so by law, including the information listed below:

    • contact information, such as your first and last name, e-mail address and telephone number, to subscribe to our newsletter;
    • contact information, such as your first and last name, e-mail address and job title, to register for our events;
    • contact information, such as your first and last name, e-mail address, telephone number, university, areas of interest, eligibility to complete the internship, CV and cover letter, to submit an unsolicited application to us; and
    • contact information, such as your first and last name, your e-mail address, your telephone number, the subject of your request and any other information you voluntarily submit to us when you use the “Contact” section.

5. INTERNET USERS – COOKIES, INTERNET PROTOCOL (IP) ADDRESSES AND BROWSING INFORMATION

5.1 Cookies – in addition to personal information, we use information gathering tools such as cookies on certain pages of our Website in order to analyze navigation on our Website. Cookies are pieces of information that a web site sends to an Internet user’s hard drive when he or she visits a web page. Cookies allow the site to remember important information that will make your visit to the site more useful. We use cookies to improve your subsequent visits. If you do not wish to receive cookies, or if you wish to set your browser to notify you each time a cookie is being sent, or if you wish to disable all cookies, use the Manage my cookies section and/or your browser options to do so. Your browser’s “Help” option can help you change your cookie preferences. Please note that by disabling cookies, you may not be able to take advantage of certain features available on our Website.

5.2 Cookies may cease to exist at the end of a browsing session (a browsing session is defined as the time at which the Internet user opens his/her browser to the time at which he/she leaves his/her browser) or cookies may be retained for a longer or even indefinite period.

5.3 Permanent cookies – these are stored on the user’s hard disk and survive the end of sessions, making it possible to save the user’s preferences or actions between different pages of the same website (or in some cases between different websites). Persistent cookies may be used for a variety of purposes, such as saving a user’s choices and preferences while visiting the Website.

5.4 For more information about cookies, including how to view the cookies that have been placed on your computer, how to manage cookies, how to prevent cookies from being placed and how to delete cookies, please visit the Manage My Cookies section of our Website. In this way, you can adjust your browser’s settings to suit your desired level of protection.

5.5 Internet Protocol (IP) address – An Internet Protocol (IP) address is assigned to your computer’s Internet connection by your Internet service provider. Mofco may use this address to diagnose problems with its Web servers, to manage its Website and to maintain contact with an Internet user while he is visiting its Website. The IP address of your connection may also be used to provide you with information based on the location from which you browse the website. Mofco does not associate your IP address with your personal information.

5.6 Browsing information – is used to measure interest in and use of certain parts of our Website and the effectiveness of certain promotional programs administered by or on behalf of Mofco. This information cannot be used to identify you, but rather to provide statistical data on the duration of your visit, the pages consulted and the order in which the pages were visited. Mofco performs statistical analysis of this browsing information in order to establish profiles of Internet users and determine their behaviour and characteristics. Mofco may share this information with third parties; however, none of this information can identify you or determine anything personal about you. 5.9 We also use the services of Google Analytics to collect navigation information on our Website. To stop being analyzed by Google Analytics during your Internet visits, please visit: tools.google.com/dlpage/gaoptout.

6. HOW WE USE YOUR PERSONAL INFORMATION

6.1 We use your personal information to facilitate the processing of requests you submit to us. We have taken great care to develop a Privacy Policy that is tailored to inform you about how we use your personal information.

6.2 Mofco may contact you directly by e-mail, mail or telephone for the purposes described herein, for example to offer you some of our new or existing services.

6.3 Mofco may use your Personal Information for the legitimate purposes described below:

    • provide you with services and carry out mandates;
    • allow you to subscribe to our newsletters;
    • to verify your identity and review your personal history, as permitted by law;
    • operate, maintain, supervise, develop, improve and offer all the functionalities of our Website;
    • to manage risk and operations;
    • to meet our obligations under applicable laws and regulations;
    • detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities;
    • send you communications in accordance with the law;
    • allow the function to apply for a job with Mofco; and
    • for any other purpose permitted or required by law.

6.4 Mofco will not use any personal information collected pursuant to this Policy or pursuant to any other law or regulation for any other purpose whatsoever unless it has obtained your prior consent, except in certain exceptional circumstances where Mofco reasonably and in good faith believes that it is required to do so by law.

7. SHARING OF PERSONAL INFORMATION

7.1 Mofco does not sell, transfer or assign any Personal Information to third parties. However, we may share personal information with our service providers, some of whom are located outside Quebec but within Canada, or in Europe, our consultants or our subsidiaries for our internal business needs. Except as described in this Policy, Mofco will not disclose any personal information to third parties unless requested to do so by the customer, the customer consents to such disclosure, or such disclosure is necessary or permitted by law.

7.2 We may share your personal information with our agents, affiliates or service providers who act for or on behalf of Mofco in the course of Mofco’s business, or with any person who processes the data in accordance with the purposes for which it was obtained (such as the maintenance of our secure databases). When we disclose your personal information to service providers, we enter into written contracts with them before disclosing your personal information to them, and we only provide them with the personal information they need to carry out their mandate. As part of these contracts with our service providers, we are committed to ensuring that the principles set out in this Policy are respected, and these service providers are required to use personal information in accordance with our instructions and only for the purposes for which it was provided. In addition, these service providers offer us sufficient guarantees that they implement adequate safeguards that are proportionate to the sensitivity of the personal information processed or communicated. When our service providers no longer need your personal information, we ask them to destroy it appropriately.

7.3 The personal information you provide to Mofco is considered to be an asset of the company and may be disclosed or transferred to a third party in the event of a sale (proposed or completed), lease, merger, or any other type of acquisition, sale, financing of all or part of Mofco or any business assets or shares of Mofco or any of its divisions, provided, however, that such disclosure or transfer shall not affect the products or services rendered to customers by the third party.

7.4 While we make reasonable efforts to maintain the confidentiality of personal information, Mofco reserves the right to disclose personal information to a third party under certain specific circumstances, including: to respond to requests from public and governmental authorities, to comply with law, regulation, search warrant, subpoena, legal process, court order or as otherwise required by law, to enforce our policies or contracts, in debt collection, to protect users of our sites from fraudulent or abusive use, in emergency situations where security is compromised, as determined by Mofco or otherwise when necessary to establish, exercise or defend against any legal action. In addition, from time to time, usage reports from our servers may be reviewed for security reasons; for example, to detect unauthorized activity on our Website. In this case, the data on the servers, including IP addresses, would be shared with the authorities so that they could identify users in connection with the investigation of unauthorized activities.

8. YOUR RIGHTS

8.1 As a data subject, you may exercise the rights set forth below by completing a request form at http://loi25.mofco.ca or by mail to the attention of our RPRP at the coordinates provided in section 13.1 of the Policy:

    • You have the right to access the Personal Information we hold about you and to request a paper copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;
    • You have the right to have the Personal Information we hold about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
    • You have the right to withdraw or change your consent to Mofco’s collection, use, disclosure or retention of your Personal Information at any time, subject to applicable legal and contractual restrictions.
    • You have the right to ask us to stop disseminating your Personal Information and to de-index any link attached to your name that gives access to this information if such dissemination contravenes the law or a court order; and
    • You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions set out in the applicable law.

In order to process your request, you may be asked to provide appropriate identification or to identify yourself in some other way.

9. LINKS TO EXTERNAL WEBSITES BELONGING TO THIRD PARTIES

9.1 Please note that our Website may contain links to other websites which are not affiliated with Mofco. Mofco has no control over these websites or their privacy practices, which may differ from those of our Website. This Policy cannot and does not apply to any external website. We do not endorse or make any representations about third-party websites. Personal information that you choose to give to third parties is not covered by this Policy. We encourage you to review the privacy policy of any company or website before submitting personal information. Third parties may choose to share the personal information they hold with Mofco; such sharing is subject to that third party’s privacy policy.

10. SENSITIVE PERSONAL INFORMATION

10.1 In the course of our business, it is unlikely, but not impossible, that in certain circumstances we may need to collect Personal Information considered to be of a sensitive nature, where it is strictly necessary for our operations. In this case, we ensure that we have your explicit consent to do so, in accordance with the law.

11. LIMITATION OF LIABILITY

11.1 Mofco undertakes to take all reasonable steps to ensure the confidentiality and security of personal information in accordance with technological standards appropriate to its sector of activity.

Notwithstanding the foregoing, you declare that you understand and acknowledge that no computer system offers absolute security and that there is always some degree of risk involved in transmitting personal information over the public network that is the Internet.

You agree that Mofco cannot be held responsible for any breach of confidentiality, hacking, virus, loss, theft, misuse or alteration of personal information transmitted or hosted on its systems or those of a third party. You also waive any claim in this respect, except in the case of gross negligence or wilful misconduct on the part of Mofco. Accordingly, you agree to hold Mofco and its officers, directors, affiliates and business partners harmless from any damages of any kind, whether direct or indirect, incidental, special or consequential, arising out of or in connection with the use of your Personal Information.

12. INDIVIDUALS UNDER 14 YEARS OF AGE

12.1 We do not knowingly collect or use Personal Information from persons under the age of 14. If you are under 14 years of age, you must not provide us with your Personal Information without the consent of your parent or guardian. If you are a parent or guardian and become aware that your child has provided us with Personal Information without consent, please contact us using the contact information provided in Section 13 above to request that we delete that child’s Personal Information from our systems.

13. OUR PRIVACY OFFICER

13.1 If you have any comments, questions or complaints, please do not hesitate to contact the Privacy Officer.

Privacy Officer
305B, St-Elzéar ouest
Laval, Quebec H7L 3N5
Contact form: http://loi25.mofco.ca

14. CHANGES TO OUR PRIVACY POLICY

14.1 This Privacy Policy is effective as of September 22, 2023. Mofco reserves the right to update this Privacy Policy at any time. When Mofco makes changes to this Privacy Policy, we will also change the “Last Updated” date as found at the top of the Mofco Privacy Policy. Mofco encourages you to periodically review this Privacy Policy to be informed of how Mofco is protecting your information and to be notified of any changes to the Privacy Policy. Your use of the Website following the posting of an amended version of the Privacy Policy constitutes your consent to be bound by such changes. This Privacy Policy is incorporated into all Terms and Conditions governing the various websites and all programs and services used or operated for or on behalf of Mofco. Any changes to this Privacy Policy will be effective immediately upon posting by Mofco.

15. CONDITIONS OF USE OF OUR WEBSITE

15.1 The terms and conditions governing your use of this Website can be found at https://www.mofco.ca/fr/mentions-legales/ (the “Terms”) and contain important provisions which declare and exclude Mofco’s liability in relation to your use of our Website. The Terms also contain provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute regarding your use of this Web site. All of these provisions apply to any disagreements or disputes that may arise in relation to the Privacy Policy and the collection, use and disclosure of your personal information. These Conditions have the same effect as if they had been reproduced in full in this Privacy Policy.