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Confidentiality and privacy policy

1. General information

a) Introduction

Purpose of this Policy. The protection of privacy is important to Transition Services Conseils Inc (hereinafter the "Company", "We", "Us", "Our"). For this reason, We have implemented safeguards and sound management practices for Your Personal Information in accordance with applicable laws in Quebec and Canada.

Supplement to Terms and Conditions. This privacy policy (the "Policy"), which should be read in conjunction with Our Terms and Conditions, describes Our practices with respect to the collection, use, processing, disclosure, retention and destruction of Personal Information of persons benefiting from Our Services, visitors to this Website and its users (hereinafter "You", "Your").

Consent. By using our website https://transitionsc.ca/ (the "Website") or any of Our Services, You agree that We may collect, use, disclose, communicate, disclose and retain (hereinafter "Process" or "Process") 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 may not visit, access or use Our Website or Services, or share Your Personal Information with Us.

Policy limitations. This Policy does not apply to Personal Information of the Company's employees, representatives and consultants, or any other person affiliated with the Company, or to any information that does not constitute Personal Information as defined by applicable laws in Quebec and Canada.


b) Privacy officer

Contact information for the Privacy Officer. All comments, questions and complaints regarding the Company's Privacy Policy and practices may be addressed to Our Privacy Officer at the following contact information:

Name : Franck Le Mauff

Title : Privacy Officer

Email : prp@transitionsc.ca

Address : 1305 Bd Lebourgneuf, Office 520, Québec City (Québec) G2K 2E4

2. Definitions

Definitions of certain notions and expressions. The following notions and expressions, when they appear with a capitalized first letter in the Policy, have the meaning attributed to them hereinafter, unless otherwise implied or explicit in the text:

"Company", "We", "Us", "Our": Transition Services Conseils.

"Service Provider" means any individual or entity that processes Personal Information on behalf of the Company. This includes third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services or to assist the Company in analyzing the use of the Services.

"Cookie Banner": pop-up window requesting Your consent to certain collection of Your personal information on the Website.

"Governance and Personal Information Management Policy": a document describing Our rules governing Our governance of Your Personal Information. These rules set out, among other things, the roles, and responsibilities of Our staff members throughout the life cycle of this information, a description of Our process for handling complaints relating to the protection of Your Personal Information, a description of Our privacy training and awareness activities and, where applicable, the safeguards to be taken with respect to personal information used or collected in connection with Our surveys.

"Personal information" means any information that relates to a natural person and allows that person to be identified, i.e., that directly or indirectly reveals something about that person's business, characteristics (e.g., abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour) or activities, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, sound, visual, computerized or other).

"Privacy Officer": the person responsible for the application of this Policy and whose contact information is identified in section 1 of this Policy.

"Services": Services refers to the Website applications, Our pages on social networks and any programs and services rendered to You therein such as:

  • Allow you to consult Our service offer;
  • To keep you informed about our activities;
  • Allow and invite You to apply for Our jobs;


"Website" means this website https://transitionsc.ca/.

"Cookies": Cookies are text files that are installed on Your computer or mobile device. These cookies may contain information about Your search history, the web pages You visit and Your web browser.

"Process", "Treatment": This term covers all operations that may affect or concern personal information, including: collection, use, storage, destruction, communication or transmission.

"You", "Your": The persons benefiting from Our Services, the visitors to the Website and all users having recourse to the Company's Services.

3. Personal Data Processing
3.1 Collection of Personal Information

Categories of information collected. In the course of Our activities, We may collect and process various types of Personal Information, including the information listed below:

  • Your contact details and login details, including Your first and last name, Your address, Your e-mail address, Your telephone number and Your postal code;
  • information necessary for the provision of Our Services, such as information concerning the Services We have rendered to You;
  • information that you choose to provide or transmit to Us, for example, when you communicate with Us by telephone or through Our Website, fill out a form, respond to surveys, apply for one of Our job offers or otherwise communicate with one of Our employees or representatives;
  • information collected automatically when using the Website and Our Services, including :
    • connection and other information about Your activities on the Website, such as Your IP address, the pages You have visited, the time and date of Your visits, the number of connections, the type of browser You use, the operating system of Your device and other hardware and software information;
    • geolocation data, a precise or approximate location determined from Your IP address or the GPS of Your device if you wish to locate our establishments (depending on the settings of Your device).

Receipt of Personal Information from Third Parties. Some service providers provide us with Personal Information such as :

  • Full names, addresses, e-mail addresses, telephone numbers and postal codes.

Limitation of processing to necessary and legitimate purposes. In each case, Personal Information is processed in accordance with the legitimate and necessary purposes listed in article 3.2 below.

3.2 Use of Personal Information

Purposes of Personal Information. We may use Your Personal Information for the purposes described below:

  • operate, maintain, supervise, develop, improve and offer the functionalities of Our Website; 
  • Introduce You to Us and provide Our Services;
  • perform Our contractual obligations to You;
  • develop, improve and offer new Services;
  • Send you messages, updates and security alerts; 
  • for marketing and business development purposes, if You have previously consented to the processing of Your Personal Information for these purposes;
  • answer Your questions and provide You with assistance as needed; 
  • carry out research, analysis and statistics relating to Our Company and Our Services;
  • optimize our digital advertising strategies; 
  • detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities; and
  • for any other purpose imposed or permitted by applicable law.
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3.3 Communication and Transfer of Personal Information.

Disclosure to third parties. We may transfer, disclose or provide access to Your Personal Information to Our employees (including marketing and sales departments) and Service Providers who need to know that information in order to operate Our Website, perform Our Services, conduct Our business or serve You. 

Safeguards for disclosure to third parties. We will only disclose Your Personal Information to Our Service Providers if they have previously agreed in writing to maintain the confidentiality of Your Personal Information in accordance with applicable laws and Our Information Governance Program through the implementation of various safeguards and information governance measures. These measures are proportionate to the sensitivity of the Personal Information processed or communicated. Without limitation, Our Service Providers may only use Your Personal Information in a confidential manner in accordance with Our instructions and only for the purposes for which it was provided. Furthermore, We only provide Our Service Providers with the Personal Information that is necessary for the performance of their mandate, and We require such Service Providers to destroy the Personal Information in an appropriate manner upon termination of the contract or as soon as its use is no longer necessary.  

3.3.1 Service providers and other third parties

Our Service Providers. Although We try to avoid sharing Your Personal Information with third parties, We may use Service Providers to perform various services on Our behalf, such as IT management and security, marketing, and data analysis, hosting and storage of data. We have defined below certain cases in which such sharing may take place:

Please note that this Cookie may identify You and may profile Your web activities in order to provide You with advertising that matches Your interests (targeted advertising);

This Cookie communicates to Google for the purposes identified in our "Cookie Policy" ;

Please note that Google Ads Cookies can identify You and profile Your web activities in order to provide You with advertising tailored to Your interests (targeted advertising);

This Cookie communicates to Google for the purposes identified in our "Cookie Policy" ;

  • We use the services of Microsoft Ads (Bing) to collect and store data in order to create user profiles using pseudonyms. For more information, consult the privacy policy from Microsoft;

This cookie communicates to Microsoft for the purposes identified in our” Cookie Policy ”;

  • We use the services of Meta (Facebook Pixel) to make it possible to understand and deliver ads, establish statistics and converse with customers and prospects. For more information, consult the privacy policy from Meta;

Please note that this Cookie can identify You and profile Your web activities in order to provide You with advertising tailored to Your interests (targeted advertising);

This Cookie communicates to Meta for the purposes identified in our "Cookie Policy";

  • We use the services of the Meta group's Facebook social network to communicate about Our Services. For more information, see Meta's privacy policy ;
  • We use the services of the LinkedIn social network to converse with customers and candidates or prospects for recruitment purposes. For more information, please consult LinkedIn's privacy policy ;
  • We use Microsoft services to store Our documents and e-mails. For more information, please see the privacy policy;

All categories of personal information identified in section 3.1 may be communicated or stored through this service.

  • We use the services of Webflow to host Our Website. For more information, please see the privacy policy;

All categories of personal information identified in section 3.1 may be communicated or stored through this service.

  • We use the services of Zoho to manage the recruitment of our employees. For more information, please consult the privacy policy;

All categories of personal information identified in section 3.1 may be communicated or stored through this service.

  • We use Metatracer on Our digital systems to facilitate the detection and management of Your personal information and that of Our employees, all to ensure Our compliance with privacy laws.
    Metatracer only collects identifiers as Personal Information.

3.2.2 Communication outside Quebec

Disclosure of Personal Information Outside Quebec. We may disclose Your Personal Information outside of Quebec and mandate an entity located outside of Quebec to collect, use or retain Your Personal Information on our behalf.

Safeguards when communicating outside Quebec. Before disclosing Your Personal Information to third parties outside the province of Quebec, We conduct a privacy impact assessment to evaluate the risks that may affect the security of Your Personal Information. This assessment also identifies appropriate security measures to reduce or eliminate these risks. The communication will then be subject to a written agreement binding these third parties to respect such measures. 


3.3.3 Compliance with legislation, responding to legal requests, preventing harm and protecting Our rights

Specific disclosures of Your Personal Information. We may disclose Your Personal Information when We believe such disclosure is authorized, necessary or appropriate, including: 

  • to respond to requests from public and governmental authorities, including public and governmental authorities outside Your country of residence; 
  • to protect Our business ; 
  • to comply with legal proceedings; 
  • to protect Our rights, the privacy of Our employees, officers and directors, Our security and Our property; 
  • to protect Your privacy and Your rights, or the privacy and rights of third parties; 
  • to enable Us to pursue available remedies or limit the damages We may suffer; and 
  • in accordance with applicable laws, including laws outside Your country of residence.

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3.3.4 Commercial transaction

Possibility of commercial transactions. We may share, transfer or communicate, in strict compliance with this Policy and the provisions of the Act respecting the protection of personal information in the private sector, RLRQ c P-39.1 (the "Private Sector Act") and the Act to modernize legislative provisions respecting the protection of personal information, LQ 2021, c 25 (the "Act 25", assented to on September 22, 2021), your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of the Business or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or any other business transaction, including in connection with the negotiation of such transactions). In such a case, We will inform you before Your Personal Information is transferred and is governed by another privacy policy.

3.4 Consents

Consent for Collection, Use or Disclosure of Personal Information. Unless otherwise required by law, the Company obtains Your consent to the collection, use and disclosure of its Personal Information. However, if You provide Us with Personal Information about other persons, You must ensure that You have duly notified them that You are providing Us with their information in addition to obtaining their consent to such disclosure. 

Consent requirements. We will seek Your manifest, free, informed and purposeful consent before using or disclosing Your Personal Information for purposes other than those set out herein. We will also seek Your express consent whenever sensitive Personal Information is involved in any of the Company's processing activities. We will ask for Your consent for each specific purpose in clear and simple terms, separate from any other information provided to You.

BY USING OUR WEB SITES, TRANSMITTING YOUR PERSONAL INFORMATION BY E-MAIL OR USING AN ONLINE FORM, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.

Refusal to use the Website. If You do not consent, please stop using the Websites. Except where otherwise provided by law, You may withdraw Your consent at any time upon reasonable notice. Please note that if You choose to withdraw Your consent to the collection, use or disclosure of Your Personal Information, certain features of our Website may no longer be available to You or We may no longer be able to offer You some of Our services.

3.5 Retention of Personal Information

Retention. Subject to applicable laws, We retain Your Personal Information only for the time necessary to fulfill the purposes for which such information was collected, unless You consent to Your Personal Information being used or processed for another purpose. As an indication, the duration of certain information may extend up to 7 years following the end of the Services rendered by the Company to You. In addition, Our retention periods may be modified from time to time due to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and violations or to prosecute criminals).

Inquiries. For more information on the periods during which Your Personal Information is kept, please contact our Privacy Officer using the contact details provided in article 1b) of this Policy.

4. Your rights

List of rights. As a data subject, You may exercise the rights set out below by contacting Our Privacy Officer in writing at the contact information provided in section 1b) of the Policy. Please note that We may ask You to verify Your identity before responding to any of these requests.  

  • You have the right to be informed of the Personal Information We hold about You, its use, disclosure, retention and destruction, subject to exceptions provided by applicable law;
  • You have the right to access Your Personal Information, to request a copy, including paper copies, of the documents containing Your Personal Information, subject to the exceptions provided for by applicable law, and to obtain, if applicable, additional details on how We use, communicate, store and destroy it by communicating a written request to Our Privacy Officer at the coordinates identified in section b) of this Policy;
  • You have the right to have the Personal Information We hold about You rectified, amended and updated if it is incomplete, equivocal, out of date or inaccurate by sending a written request to Our Privacy Officer at the contact information identified in section b) of this Policy;
  • You have the right to withdraw or modify Your consent to the collection, use and disclosure 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 which gives access to this information if such dissemination contravenes the law or a court order;
  • You have the right to request that Your Personal Information be communicated to You or transferred to another organization in a structured and commonly used technological format; 
  • The right to be informed of any privacy incident concerning Your Personal Information that could cause You serious harm. To this end, we keep a register of all privacy incidents and assess the harm they may cause;
  • 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.
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5. Questions and complaints

Complaints. You may address any complaints regarding Our privacy practices and policies by contacting our Privacy Officer using the contact information identified in section 1b).

Necessity to identify You. In order to process Your request, You may be asked to provide an appropriate identification document or to identify Yourself in some other way. 

Questions. You may also contact our Privacy Officer if you have any questions about this Privacy Policy.

6. Cookies and other tracking technologies

Use of Cookies. We use cookies and similar technologies (collectively, "Cookies") to help Us operate, protect and optimize the Website and the Services We offer. "Cookies" are small text files that are stored on Your device or browser. They enable us to collect certain information when You visit the Website, including Your preferred language, the type and version of Your browser, the type of device You are using and Your device's unique identifier.

Deletion of Cookies: While some of the Cookies We use are deleted after your browser session ends, other Cookies are retained on your device or browser to enable Us to recognize your browser the next time you visit the Website. The data collected via these Cookies is not intended to identify you. In particular, they are used to ensure that the Website functions properly, to improve users' browsing experience and to provide certain data that enables Us to better understand the traffic and interactions that take place on Our Website, as well as to detect certain types of fraud. Cookies do not harm your device and cannot be used to extract personal information.

Browser configuration. You can set your browser to notify you when you visit the Website, so that you can decide whether or not to accept some or all Cookies. Please note that disabling Cookies on your browser may adversely affect your browsing experience on the Website and prevent you from using some of its features. 

For further information. To learn more about how We use Cookies, please see Our "Cookie Policy".

Cookie policies. To learn more about how we use "Cookies", please see Our "Cookie Policy".

7. Safety measures

Objectives of Our Security Measures. We have implemented physical, technological and organizational security measures to adequately protect the confidentiality and security of Your personal information against loss, theft or any unauthorized access, infringement, disclosure, reproduction, communication, use or modification. These measures include : 

Administrative measures. On the administrative front, the adoption of a series of measures, policies and procedures as part of the implementation of our information governance program, including : 

  • govern the access, communication, retention, de-identification, destruction or anonymization of Personal Information;
  • determine the roles and responsibilities of Our employees throughout the life cycle of Personal Information and documents;
  • establish procedures for intervention and response in the event of a confidentiality incident;
  • govern the process for requests and complaints relating to the protection and handling of Personal Information.

Technical measures. On a technical level, the use of several means such as : 

  • the use of a secure server. All information is transmitted using Secure Socket Layer (SSL) technology;
  • use of backup systems, network monitoring software, etc. ;
  • a firewall system ;
  • the use of segregation of duties and access controls.

Incomplete list of measures. Given the public nature of this Policy, we have not provided an exhaustive list of the measures we are implementing.

‍Impossibility of guaranteeing a complete absence of risk. Despite the measures described above, We cannot guarantee the absolute security of Your Personal Information. If You have reason to believe that Your Personal Information is no longer secure, please contact Our Privacy Officer immediately using the contact details set out in section 1b) above.

8. Changes to this Privacy Policy

We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a change, We will post the revised version of the Privacy Policy and update the update date in the footer of the Privacy Policy. We will notify you reasonably in advance of the effective date of the new version of our Policy. If you do not agree to the new terms of the Privacy Policy, please do not continue to use Our Website and Services. If you continue to use Our Website or Services after the new version of our Policy becomes effective, your use of Our Website and Services will be governed by the new version of the Policy.

9. Links to third-party websites

Responsibility for Third Party Websites. From time to time, We may include on Our Website references or links to websites, products or services provided by third parties ("Third Party Services"). These Third-Party Services, which are not operated or controlled by the Company, are governed by privacy policies that are entirely separate from and independent of ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services we offer.  

10. Invisible ReCAPTCHA

Invisible reCAPTCHA analyzes activity on a web page function (e.g. mouse movements and typing patterns) to determine whether a user is a bot.

The invisible reCAPTCHA service may collect information from your device.  Information collected by reCAPTCHA is stored in accordance with its privacy policy.

11. Individuals under 14 years of age

Consent of minors under the age of 14. We do not knowingly collect or use Personal Information from persons under the age of 14. If You are under the age of 14, 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 You become aware that Your child has provided Us with Personal Information without consent, please contact Us using the contact details set out in section 1b) above to request that We delete that child's Personal Information from Our systems.

12. Applicable laws

The laws of Canada and Quebec, excluding its conflict of law rules, will govern this agreement and Your use of the Website. Your use of the Website may also be subject to other local, provincial, national or international laws.

Privacy policy Version 2 (26-07-2024)