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PERSONAL INFORMATION GOVERNANCE POLICY

1. Purpose of This Policy

The purpose of this personal information protection policy is to inform users of our website about the personal data we collect, along with the following information, where applicable:

  • The personal information we collect
  • How the collected data is used
  • Who has access to the collected data
  • The rights of website users
  • The website’s cookie policy

This privacy policy operates in conjunction with the general terms and conditions of use of our website.

2. Applicable Law

This policy complies with the Act Respecting the Protection of Personal Information in the Private Sector, CQLR c P-39.1.

3. Scope and Application

We are committed to protecting the privacy of your personal information. Because we obtain information about you through our services, including the Réseau Capital website (http://www.reseaucapital.com), we believe it is important that you understand how we collect and use this information.

Réseau Capital reserves the right to change this policy at any time without notice. The current version of the policy is available on our websites, and its effective date is indicated there. If changes that materially alter the privacy risk are made to the policy, you will be notified through a notice posted on the homepage of our websites. If you continue to use our websites after such changes take effect, you will be deemed to have accepted these changes. We recommend that you review this policy regularly.

The Réseau Capital website may contain links to third-party sites. Our privacy policy is in no way connected to that of other third-party sites.

4. Consent

Users agree that, by using our site, they consent to:

  • the terms set out in this privacy policy, and
  • the collection, use, and retention of the data listed in this policy.

5. Personal Information Collected

The term “personal information” refers to any information that allows you to be personally identified. This information may include, among other things, your name, mailing address, telephone number, email address, Internet (IP) address, age, sex, marital status, health information, financial situation, credit card data, and credit history. However, personal information does not include your name, job title, or business address and business telephone number in your capacity as an employee of an organization.

Personal Information Collected Automatically / Cookies and Conversion Pixels

We do not collect any data automatically on our site.

We may use Google Analytics for statistical purposes. Google Analytics uses cookies to collect statistical data in aggregate form, in order to analyze how visitors use the website. These cookies are used to retain non-personally identifiable data. If you do not wish to transmit information to Google Analytics, you can choose to disable the use of your data by using the browser add-on for opting out of Google Analytics, available here: https://tools.google.com/dlpage/gaoptout. For more information about Google Analytics and its privacy policy, we invite you to review the privacy policy, available here: http://www.google.com/intl/fr-CA/policies/privacy/.

If you set your browser to warn you before accepting cookies, you will receive a warning message for each cookie. You can disable or delete cookies by configuring your browser accordingly. However, if you disable or delete cookies, certain portions of the functionality or of the website may not work properly.

Personal Information Collected by Non-Automatic Means

We may also collect the following personal information when you perform certain functions on our site:

  • First and last name
  • Email

This information may be collected through the following methods:

  • Job applications
  • Newsletter sign-ups
  • Interest or feedback forms
  • Purchases and event registrations
  • When you send us an email or contact Réseau Capital by telephone

Please note that we collect only the information that helps us achieve the objective stated in this policy. We will not collect additional data without first informing you.

6. Retention Period for Personal Information

User data will be retained for a period of: 10 years.

We will ensure that users are notified if their data is retained longer than this period.

7. Use of Personal Information

We use only the personal information that is necessary to fulfill the purposes set out in this policy or otherwise disclosed at the time of collection.

We use your personal information to properly process your requests and to present you with the information you wish to consult. We also use any information you provide voluntarily in order to provide our products and services properly. We may also use the information we have collected to add personalized elements to our services or to plan their content more appropriately, based on users’ interests.

In accordance with our Email Policy, we may use your personal information to send you promotional or informational emails regarding Réseau Capital’s activities or news, always with the aim of offering you the best possible service.

You can use the various links contained in each of our emails to set your email subscription preferences and unsubscribe, or to contact us.

8. Disclosure of Your Personal Information

Authorized Réseau Capital staff members may access the personal information collected about you when necessary to carry out their duties related to the services and in accordance with the purposes set out in this policy.

We may add you to a Réseau Capital mailing list or listserv if you instruct us to do so. In that case, you retain the ability, at any time, to ask us to remove your name from it.

Subject to what is otherwise provided in this policy, we do not disclose your personal information to anyone outside Réseau Capital without your express consent, except for the following third parties and only if they have implemented appropriate security safeguards to ensure at least the same level of security as ours:

  • our suppliers whose services have been retained to carry out certain functions on our behalf (e.g., website management). Réseau Capital takes the necessary measures to ensure that these suppliers process your information solely for the purposes determined by Réseau Capital.

The only exception is where required by law or court order. We will provide your information to government authorities if they need this information and request it.

9. Retention and Security of Your Personal Information

We retain the personal information collected hereunder only for as long as necessary to achieve the purposes for which it was collected. After this period, we ensure its anonymity and protect it against unauthorized access or disclosure.

We retain your file ourselves. In addition, we take and apply adequate security measures to preserve the private or confidential nature of your information.

10. Protection of Your Personal Information

All data stored in our system is well secured and is accessible only to our employees. Our employees are bound by strict confidentiality agreements, and a breach of such an agreement would result in the employee’s dismissal.

While we take all reasonable precautions to ensure that our user data is secure and that users are protected, there is always some risk of harm. The Internet as a whole can sometimes be insecure, and therefore we are unable to guarantee the security of user data beyond what is reasonably practicable.

11. General Information and How to Exercise Your Rights

You have the right to know the purpose of the collection and processing by Réseau Capital of the personal information concerning you, as well as the right to access this information, update it, or correct it. You may at any time withdraw your consent to the use and retention of your personal information by Réseau Capital, request the deletion of your personal information, or object to its processing by Réseau Capital. In such a case, however, you may no longer be able to access, in whole or in part, our services or certain of their features. You also have the right to the portability of your personal information.

To exercise the rights described above, or if you have any questions or comments regarding this policy, contact us.

To learn more about the protection of personal information on the Internet, visit the websites of the Commission d’accès à l’information du Québec and the Office of the Privacy Commissioner of Canada.

Officer Responsible for the Protection of Personal Information:

President and Chief Executive Officer

Email: inforeseau@reseaucapital.ca

Effective Date: June 12, 2023

EMAIL POLICY

Subscribers to Réseau Capital’s email communications are active members or clients of Réseau Capital, subscribers via our Réseau Capital websites, professionals whose business sector is closely related to one of our services and who have expressed their interest by sending us their email address via a business card or by telephone, or who have prominently published their email address without any notice specifying that they do not wish to receive any unsolicited email at that address.

All emails sent by or on behalf of Réseau Capital or any of its services bear the mailing address, telephone number, and website address of Réseau Capital.

A hyperlink to an unsubscribe mechanism is included at the bottom of all electronic communications. The page accessible through this hyperlink also allows you to modify your subscription preferences.

The list of email addresses of subscribers to Réseau Capital’s electronic communications will never be rented or sold, whether in whole or in part, unless your consent has first been obtained to that effect.