Privacy Policy - Seguin Morris

Adopted by Senior Management at Seguin Morris Inc.
Owner: Protection of Personal Information Officer (PPIO)

1 – PREAMBLE

Seguin Morris Inc. (hereinafter “Seguin Morris”) recognizes the importance of preserving privacy and is committed to protecting the personal information it collects and processes as part of its operations, including the personal information it collects when individuals consult or interact with its website (hereinafter “its Site”).

The purpose of the Confidentiality Policy (the “Policy”) is to describe the protection of personal information practices that Seguin Morris undertakes to apply in the course of its operations to ensure the protection of the personal information (“PPI”) it holds. The Policy is intended to ensure compliance with applicable requirements, including the Act respecting the protection of personal information in the private sector (Quebec), the Personal Information Protection Act (British Columbia), the Personal Information Protection and Electronic Documents Act (Canada), the Data Protection Act (Barbados) and recognized PPI practices.

2 – AREA OF APPLICATION

The Policy applies to any identified or identifiable individual from whom Seguin Morris collects personal information as part of its operations, including:

Visitors and users of its Site if personal information is collected;

Job applicants;

Anyone who contacts Seguin Morris;

Any person whose personal information is otherwise collected in connection with Seguin Morris operations.

For the purposes of this Policy, “personal information” means information regarding an individual that can directly identify the individual (e.g., last name, first name, email address) or indirectly (information that, combined with other information, identifies the individual).

3 – PROTECTION OF PERSONAL INFORMATION REQUIREMENTS

Protection of personal information practices at Sequin Morris are based on the following guiding principles:

1 – CONSENT

Prior to collecting, using and disclosing your personal information, Seguin Morris ensures that your consent is obtained in accordance with applicable requirements, unless there is an exception under the law (e.g., in the context of a criminal prosecution).

You may withdraw your consent to the use of your personal information by Seguin Morris for purposes that are not essential to the management and administration of the products and services offered, e.g., for the purpose of inviting you to participate in surveys or contests, sending you promotional communications, generating statistics or analyzing your data. If this is your wish, Seguin Morris will cease using your personal information for these purposes as soon as possible after receiving your withdrawal of consent request.

Generally, it is not possible to withdraw your consent to the use of your personal information for the management and administration of products and services without terminating your business relationship with Seguin Morris.

Any request for withdrawal of consent will need to be communicated to the Protection of Personal Information Officer, whose contact information can be found in section 4.

2 – COLLECTION

2.1 – Nature of the personal information collected

Seguin Morris only collects personal information that is necessary for the purposes of its operations and to which you have consented. This may include:

Your identifying information, such as your last name, first name, email address, mailing address and phone number;
Information that is necessary to optimizing your experience on its Site, such as your IP address, location or browsing data;
Personal information found in your résumé.

Seguin Morris ensures that the personal information it holds is current and accurate at the time it makes use of it.

2.2 – Means of collection

Directly from you

Most of the personal information Seguin Morris collects is the information you provide directly to it, including when you:

Contact Seguin Morris;
Browse on its Site;
Apply for a position online.

From a third party

Seguin Morris may also collect your personal information from authorized third parties or representatives with your consent or if authorized by law to do so.

Through cookies

When you access the Seguin Morris Site, cookies are placed on your computer. These cookies may collect personal information such as your IP address and are intended to improve your browsing experience and the content of its Site.

In order to better understand the usefulness of each of the cookies present on its Site, you will find a description of their functions below:

Strictly necessary cookies: these cookies are crucial for the Site’s basic functions and the Site will not function as intended without them. These cookies do not store any personal information;
Functional cookies: functional cookies enable certain features such as sharing the Site’s content and remembering your language choice. Blocking these cookies may have an impact on your experience and on certain features of the Site.

You will be able to change your login cookie preferences using the banner that appears when the Site opens.

3 – USE

Seguin Morris collects, uses and discloses your personal information only for the purposes for which you have consented or that are permitted by law. The purposes for which Seguin Morris collects your personal information are specified at the time of collection.

Seguin Morris collects your personal information for the following purposes:

Managing client files;
Establishing and maintaining communication with its clients;
Assessing the needs of clients (and prospective clients) and offering them products and services that meet their needs;
Managing and optimizing its Site and customizing and adapting your browsing experience;
Detecting and preventing fraud or other illicit activities;
Managing risks, security and regulatory compliance;
For job applicants, assessing your candidacy;
For employees, managing the employment relationship, including the employee file and benefits.

You can ask us for more details on these uses at any time.

4 – COMMUNICATION

Seguin Morris ensures that personal information held by Seguin Morris is accessible only to Seguin Morris employees, representatives or agents who require access in the course of their duties.

Seguin Morris may share your personal information with business partners, suppliers, government authorities and others as part of its operations. These third parties include:

Cloud solution providers used in the course of its operations, hosting data, servers or applications;
Marketing or advertising service providers;
Companies specializing in criminal background and credit checks;
Supervisory authorities such as the Commission d’accès à l’information;
Any other person authorized by law to obtain it.

Seguin Morris ensures that the confidentiality of your personal information is maintained when it is shared with third parties. Seguin Morris also agrees not to sell, transfer or lease your personal information to a third party.

5 – CONSERVATION AND DESTRUCTION

Seguin Morris retains your personal information for as long as is necessary for the purposes for which it was collected and in accordance with the applicable retention periods. Your personal information is generally held in Quebec. However, it is possible that sharing your personal information with certain providers may result in their transfer outside Quebec. In such cases, Seguin Morris will first validate the applicable privacy laws and practices within the applicable jurisdictions and will apply the necessary safeguards to ensure that your personal information is adequately protected.

When your personal information is no longer required to fulfill the purposes for which it was collected, Seguin Morris will destroy it using a process that maintains its confidentiality.

6 – SECURITY

Seguin Morris applies security measures commensurate with the sensitivity of the personal information it holds, the purpose of its use, its quantity, its distribution and its format. These security measures are designed to protect your personal information from unauthorized loss or theft, access, use or disclosure.

Security measures implemented by Seguin Morris include:

Administrative measures such as defining roles, assigning access and managing third parties;
Physical measures such as the installation of surveillance cameras and the management of access to its premises;
Technical measures such as the securing of IT access.

7 – YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

Seguin Morris respects your legal rights with respect to your personal information and applies procedures to that end.

Access, modifications and complaints

You have the right to view and verify the accuracy of your personal information held by Seguin Morris, and to make changes to it if necessary, subject to statutory exceptions.

You also have the right to request information on the processing of your personal information (e.g., uses, categories of third parties to whom it is disclosed, applicable retention periods, etc.) and to file complaints if such treatment is inconsistent with the principles set out in this Policy and applicable privacy laws and regulations.

Any request for access, modification or information, or any complaint regarding your personal information, must be communicated in writing to the protection of personal information officer whose contact information can be found below.

Seguin Morris undertakes to provide a response to the various requests set out above within thirty (30) days of the date of receipt.

Automated processing

If Seguin Morris implements a decision-making process that is based exclusively on the automated processing of personal information (non-human intervention), e.g., a process that has a specific effect on an individual (e.g., eligibility for employment) and based solely on an algorithm, you will be informed of the fact that you are subject to such a process, the decision that has been rendered, and your right to make representations regarding that decision. You will also be able to be informed of the following upon request:

The personal information used to make this decision;
The reasons that led to this decision;
Your right to have the personal information used to make this decision corrected;
Access to a person with the authority to review this decision, if applicable.

4 – PROTECTION OF PERSONAL INFORMATION OFFICER CONTACT INFORMATION

To exercise your privacy rights or ask questions regarding this Policy or how Seguin Morris handles your personal information, you may contact the Protection of Personal Information Officer in one of the following ways:

Email: privacy@seguinmorris.com
Phone: 1 819-776-3939
By mail:
Seguin Morris Inc.
Attn: Protection of Personal Information Officer
620 Vernon Street, Gatineau, QC J9J 3K5

5 – POLICY AMENDMENTS

Seguin Morris reserves the right to update this Policy at any time without notice. The applicable Policy may be consulted at any time on this Site. The date of the last update to this Policy is indicated at the bottom of this page.

Version	Implementation	Adoption Date	Description	Name and title of the lead
1.0	1st version	August 13, 2024	New policy	Katarina Veilleux, Human Resources Manager

This Policy sets out the principles and describes the protection of personal information practices at Seguin Morris Inc.