Privacy policy
Preamble
We value your privacy and are committed to protecting the Personal Information we collect.
Purpose and Application
This document is our Privacy Policy, Data Protection and Web Privacy Notice and describes how we collect, use and disclose your Personal Information.
This policy applies to all users of the website. By choosing to browse our site, you consent to the collection and use of your Personal Information in accordance with this policy and applicable privacy laws.
Definitions
The definitions below are intended to serve as a guide to ensure that everyone has a common understanding of terms that might otherwise be open to interpretation:
Website
Means the company’s website that references this Policy.
Privacy Incident
The unauthorized access, use or disclosure of Personal Information or the loss of Personal Information or any other breach of the protection of Personal Information.
A privacy incident can therefore take many forms: intrusion by a third party into an organization’s computer system, a ransomware attack, loss of data caused by a virus or a computer flaw, extraction of data by an employee or an unauthorized person, etc.
Profiling
The collection and use of Personal Information to assess certain characteristics of an individual, including for the purpose of analyzing the individual’s job performance, economic status, health, personal preferences, interests or behaviour.
Personal Information
Any Information about an individual that directly or indirectly identifies that individual, such as a name, geolocation data, an online tracking identifier, or one or more specific characteristics relating to the physical, physiological, mental, economic, cultural or social identity of that individual.
Why we collect your Personal Information
When you browse our website, we collect your Personal Information only for purposes for which we have first obtained your consent, except where permitted or required by law. The primary purposes for which we collect your Personal Information are as follows:
- To facilitate communication
- To comply with various company policies
- To protect our interests
- To meet our business objectives
- To send you marketing communications
- To improve our various services
- To prevent cyber security incidents and/or fraud
- To administer our databases
- To comply with any legal or contractual obligations of the company
- Etc.
Types of Information We Collect
We may collect (if applicable) the following Personal Information:
- Name, address, gender and telephone number
- Date of birth
- Social Insurance Number (SIN)
- Resume
- Banking information
- Identification
- Marital status
- Geolocation
- Information on spouse and dependents
- Etc.
We may also obtain Personal Information through geolocation and/or profiling technologies. However, these technologies are always disabled by default. If it is necessary to use any of these methods, we will first obtain your consent.
Use of Cookies
On our website, we use Google Analytics. This is a tool for analyzing the traffic and use of our website, allowing us to improve the experience offered on it and the tools it contains. Google Analytics uses cookies to analyze your activities on the site.
For more details on how the collected Information or data is used by Google, we invite you to consult the Google Privacy Policy and Terms of Use. You can also disable the sending of your activity data to Google Analytics by installing the browser add-on provided.
Whom We Share Your Personal Information With
We may share your Personal Information with third parties or service providers for the purposes stated above or as otherwise described in this policy. We will not sell or rent your Personal Information to third parties or trade Personal Information with third parties. However, we may disclose Personal Information where permitted or required by law.
Categories of service providers with access to your Personal Information include service providers engaged for:
- Payroll and time management
- Security camera and building door access database management
- IT support
- Financial audits
- Human resources software or development
- Website hosting
- Website hosting
If you would like more information about our service providers, please contact the Privacy Officer listed below.
Protection of your Personal Information
We ensure that we take all necessary security measures to protect the Information we collect and we keep it for a period of time that respects our legal obligations and only for the purposes necessary.
Some situations are beyond our control and a cybersecurity incident involving a data breach could still occur. By using our website, you consent to such a possibility and acknowledge that we will not be liable for any damages that may result from such an incident.
Your Consent
Your consent may be express or implied, depending on the circumstances and the sensitivity of the Personal Information in question. Generally, we will seek your consent at the time of collection and if we want to use your information for a purpose for which you did not consent at the time of collection, we will obtain your consent before using your Personal Information.
By accepting this Policy, you consent to the collection of your Personal Information by the Company. You also understand that you may at any time, upon request, be informed of the Personal Information collected about you, the categories of persons who have access to such information within the company, the length of time such information is retained, and the contact information of the Privacy Officer, if required.
Your rights regarding your Personal Information
At any time, you may make a request to the Privacy Officer to:
- Access the Personal Information we have collected about you
- Withdraw your consent to the collection, disclosure and retention of your Personal Information
- Ask us how your Personal Information was collected by the company
In some cases, we may refuse to provide you with the Personal Information requested or we may redact (black out) certain information from the materials we provide to you.
Privacy Officer
For all access requests, questions, requests for information or to report an incident, we invite you to contact the Privacy Officer, Directrice Affaires juridiques, at the following coordinates:
- E-mail: mdube@thornhillcapital.ca
- Mailing address: 2550, boulevard Daniel Johnson, bureau 510, Laval (Québec) H7T 2L1, to the attention of the Privacy Officer
- Phone: 514-975-9841
Once your request has been sent, we will respond to you within 30 days of the date we receive your request at the contact information provided above.
Modifications
We reserve the right to modify this policy when required. When we make modifications to this policy, they are effective immediately.