Section 1: Foreword
Relief collects, uses and discloses information for the purposes of providing our services. Privacy and security are essential to our relationships with our members. We adhere to the highest ethical standards when handling any and all information, especially of a personal nature.
- How their personal data is collected. Personal data is defined here as any information that makes it possible to identify a user. This may include first and last names, age, postal or email address, location or IP address (NB this is a non-exhaustive list);
- Their rights pertaining to this data;
- The person responsible for handling the personal data collected and processed;
- The recipients of this personal data; and
Section 2: Principles related to the collection and processing of personal data
In accordance with the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1), within Relief, personal information is:
- data regarding a natural person and that makes it possible to identify that person. It is data that is confidential in nature. Save exceptions, this data may not be communicated without the consent of the data subject (i.e., the person concerned).
- processed in a lawful, fair and transparent manner with respect to the data subject;
- collected for specified, explicit and legitimate purposes;
- adequate, relevant and limited to what is necessary for the purposes for which the data is collected;
- accurate and, if necessary, kept up to date. All reasonable steps must be taken to ensure that any personal data that is inaccurate, in view of the purposes for which it is processed, is erased or corrected without delay;
- kept in a form allowing the identification of data subjects for a period not exceeding that necessary for the purposes for which it is processed;
- processed in such a way as to ensure appropriate security of the data collected, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
Processing is lawful only to the extent that at least one of the following conditions is met:
- The data subject has consented to the processing of their personal data for one or more specific purposes;
- The processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the request of the data subject;
- The processing is necessary for compliance with a legal obligation to which the controller is subject;
- The processing is necessary to safeguard the vital interests of the data subject or another natural person;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of the official authority vested in the controller;
- The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject that require protection of personal data, in particular where the data subject is a child, prevail.
Section 3: Personal data collected and processed
Section 3.1: Data collected
When you visit our website or use our services and communicate with us, we collect a certain amount of personal information about you. We may collect and process different types of personal information in the course of our business and provision of services, including:
- identity information, such as last name, first name, or gender identity;
- contact details, such as name, postal address, email address and telephone number;
- biographical information such as job title, employer’s name, photos, and video or audio content;
- information on marketing and communication preferences, as well as related information such as food preferences, comments and survey answers;
- billing and financial information, such as billing address, bank account information, or payment data;
- service-related information, such as details about services we have provided to you;
- recruitment-related information, such as resume, education and employment history information, details on professional affiliations, and other information relevant to potential recruitment by Relief or to a third party association;
- website-use information and other technical information, such as details about visits to our websites, your interaction with our advertising and online content, or information collected through cookies and other tracking technologies;
- information provided to us by or on behalf of Relief members or that we produce in the course of our provision of services and which may, where relevant, include special categories of personal information (including racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health or sexual orientation, etc.);
- any other personal information provided. Please note that if you provide us with personal information about others (such as your customers, a family member, directors, officers, shareholders or beneficial owners), you must ensure that you have duly notified them that you are providing us with their information and that you have obtained their consent to such disclosure;
- where applicable, evidence of consent given to us (date, time and means), in circumstances where such consent is necessary for the processing of personal information;
- when we need special personal information within the meaning of Law 25.
We do not knowingly collect information from children or others 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 express consent of a parent or guardian. If you are a parent or guardian and you know that your children have provided us with personal information, please contact us. If we learn that we have collected personal information from minor children without verification of parental consent, we will take steps to remove that information from our servers.
Section 3.2: Use of personal information
We use your personal information to provide and improve our services to you. We also use it to meet our legal obligations. We may use personal information in any of the ways indicated below, with your consent or, where applicable, on another legal basis under the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1). In each case, we state the purposes for which we use your personal information:
- To provide our services and to carry on our business, to administer and perform our services, including to perform our obligations arising from any agreement entered into between you and us. Legal basis applicable under the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1).
- To respond to inquiries or other requests from individuals who visit our websites.
- To facilitate the use of our websites and to ensure that the content is relevant and that the content on our websites is presented in the most effective way for you and for your device.
- For marketing and business development purposes—to provide details on new services, information on related developments, and invitations to seminars and events where an individual has opted to receive such information.
- For research and development purposes (including from a security perspective)—to conduct analytics in order to better understand our members’ service and marketing requirements and to better understand our business and develop our services and offerings. You may unsubscribe at any time;
- For recruitment purposes—to allow us to process job applications and assess whether an individual meets the requirements of the position for which they may apply at Relief.
- In order to meet our legal, regulatory or risk management obligations—to comply with our legal obligations (conduct due diligence on a member / obtain information about a member; detect anti-corruption, sanction and reputational risks; and identify conflicts of interest).
- To prevent fraud and/or run other background checks that may be required at any time under applicable law or regulation and/or best practices (if false or inaccurate information is provided or if fraud is found or suspected, information may be forwarded to fraud prevention agencies and may be recorded by us or by such agencies).
- To enforce our rights, to meet our legal or regulatory disclosure obligations and/or to protect the rights of third parties.
Section 3.3 Sharing of personal information
We may provide your personal information to our service providers as well as to our partners. We may also disclose it to comply with a legal obligation or to assert our rights. We may also share personal information with certain third parties, including the following:
- third-party service providers and/or partners who provide website, app development, hosting, maintenance and other services to us. These third parties may have access to or process personal information as part of the services they provide to us. We limit the information we provide to these service providers to only information that is reasonably necessary to enable them to perform their duties, and the contracts we have with these service providers require them to preserve the confidentiality of such information;
- government authorities and law enforcement agencies where required by applicable laws. For greater certainty, we may disclose personal information and other information if we are required to do so by law or if we believe in good faith that such disclosure is necessary to comply with applicable laws, in response to a court order or subpoena or a search warrant from the Gouvernement du Québec, or otherwise to cooperate with such government authorities and law enforcement agencies;
- We will only use personal information to fulfil the primary purpose and applicable legitimate purpose for which it was collected, or for purposes consistent with that primary purpose.
Section 3.4: Method of data collection
We collect your personal information from you, and from our interactions with you, at the following times:
- When registering for our services;
- During participation in our services, training or other communications.
Section 3.5: Retention of personal information
Your personal information is currently hosted in Canada.
Section 4: Protection of personal information
We follow generally accepted industry standards to protect information submitted to us, both at the time of transmission and once we have received it. We maintain appropriate physical, technical or administrative safeguards to protect personal information against accidental destruction or destruction not in accordance with the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1) or other laws, accidental loss, modification, unauthorized disclosure or access, misuse or any other illegal form of processing of personal information in our possession. We have taken steps to ensure that the only Relief personnel subject to a duty of confidentiality who have access to your personal information are those who need to know it or whose duties reasonably require such information.
However, no method of transmission over the Internet or any means of electronic storage is 100% secure. Therefore, we cannot ensure or guarantee the security of any information you transmit or provide to us, and you do so at your own risk. We also cannot guarantee that such information will not be accessed, obtained, disclosed, modified or destroyed as a result of the violation of our physical, technical or administrative safeguards. If you have reason to believe that personal information has been compromised, please contact us using the contact details listed under “How to Contact Us”.
Section 5: Privacy officer and delegate
Section 5.1: Data controller
The necessary personal data is collected by Relief.
The privacy officer is Patrick Brault, who can be contacted at:
Mail: 418 Sherbrooke St. East, Suite 300, Montreal, Quebec, H2L 1J6;
Telephone: 514-529-3081, ext. 129;
Section 5.2: Data protection officer
If, after contacting us, you feel that your rights under the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1) have not been respected, you may contact the Commission d’Accès à l’Information du Québec.
Section 6: User rights regarding data collection and processing
Any user concerned by the processing of their personal data may exercise the following rights under the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1):
- Right of access, rectification and deleting of data;
- Right to data portability;
- Right to limit and oppose data processing;
- Right not to be the subject of a decision based exclusively on an automated process;
- Right to determine the fate of the data after death;
- Right to appeal to the Commission d’Accès à l’Information.
To exercise your rights, please send your letter to: Patrick Brault at 418 Sherbrooke St. East, Suite 300, Montreal, Quebec, H2L 1J6, or by email to: patrick.brault@Relief.ca
For the Privacy Officer to grant the request, the user may be required to provide them with certain information, such as first and last name, email address and telephone number.
Please contact us in the event of a complaint using the email address plainte.prp@Relief.ca or by writing to us at the following postal address: 418 Sherbrooke St. East, Suite 300, Montreal, Quebec, H2L 1J6.
Relief reserves the right to update this Policy at any time to ensure that it complies with applicable laws.
Any changes will not affect operations previously carried out with Relief, which remain subject to the Policy in force at the time of your registration and as accepted by the user.
The user is invited to read this Policy each time they use our services, without needing to be formally notified to do so.
This policy, issued on August 28, 2023, was updated on September 20, 2023.