HUMANO DISTRICT DEVELOPMENT LIMITED PARTNERSHIPits subsidiaries and affiliates (hereinafter referred to as ” HDD ”) wish to explain their practices regarding the management of Personal Information (hereinafter defined) collected in the course of its activities, among others, on their websites or web platforms, on their social network accounts (including Facebook, Instagram, Twiter and Linkedln) on any mobile application or in paper format.
HDD is placing an increased emphasis on the protection of the Personal Information it collects in the course of its activities. Therefore, HDD has adopted a Policy on the Protection of Personal Information whose objective is to govern the collection, retention, conservation, use, communication and destruction of Personal Information regardless of the medium and format in which it is accessible: writen, graphic, audio, visual, computerized or other, pursuant to section 3.2 of the Act respecting the protection of personal information in the private sector (the “ Act”). As such, the Privacy Officer (hereinafter designated) ensures that this Policy is respected and complies with the Act and any relevant legislation at all times.
“User” means an individual who (i) uses our Site, (ii) communicates in any way with HDD, (iii) participates in an HDD survey, sweepstakes, contest or promotion, (iv) is a member of a program, including an HDD email or newsleter mailer, or (v) accesses, uses or purchases any other service offered by HDD.
“Collection” means HDD’s act of collecting, acquiring or obtaining a User’s Personal Information, in any manner and by any means, including from third parties, where permited by law.
“Personal Information” has the meaning defined in section 2 of the Policy.
“Privacy Officer” refers to Ms. Isabelle Beauséjour as mentioned in section 11 of this Policy.
“Site” refers to https://humanodistrict.ca
Personal Information Covered
Personal Information is any information that concerns a User and that allows them to be identified (“Personal Information”). Therefore, the name, age, sex, address, income, social insurance number, financial information, telephone number, among others, when they permit the User to be identified, constitute Personal Information under this Policy. Among all the Personal Information concerning a User, HDD collects only that which is necessary for its activities.
Means used for collection
The means used to collect Personal Information may be conventional or electronic. At all times, HDD takes the necessary means to respect the privacy of Users and uses only lawful means of collecting Personal Information.
In order to use certain features of the Site, HDD may ask Users for Personal Information, which is necessary to provide the various services. Where possible, HDD indicates which Personal Information is required through mandatory and optional fields.
The User’s consent is required for the collection, use and disclosure of Personal Information by HDD, except where permitted by law. Such consent must be manifest, free, informed and given for specific purposes. This consent can be given through various media (written, technological, etc.)
In certain cases specifically provided for by law, consent is not required for the use and disclosure of Personal Information, including where the use or disclosure is necessary for the purposes of sections 18 and following of the Act.
HDD uses and discloses the acquired Personal Information only for the purposes for which it was collected, unless the User consents, or as required or permitted by law. In the course of performing its services, HDD must, in certain circumstances and subject to legal requirements, disclose the Personal Information it holds to its agents, business partners or service providers when the exercise of a mandate or the performance of a service or business contract that HDD entrusts to this person requires the use of Personal Information. When disclosing Personal Information, HDD employs a process that promotes the protection, security and confidentiality of Personal Information by using, where possible, channels to establish and support an effective mechanism.
HDD retains and conserves the Personal Information it holds only for as long as necessary for the purposes for which it was obtained, subject to additional retention periods provided by law. HDD uses means of protecting Personal Information that are reasonable given the sensitivity and purpose of the use of the Personal Information.
As part of its operations, HDD may retain all correspondence in order to confirm the instructions of its customers, to ensure the quality of its services as well as to allow it to exercise, when necessary, its right to supervise the performance of its employees.
When the purposes for which the Personal Information collected are fulfilled, and upon expiry of the conservation period provided for by law, HDD destroys the personal information in a secure manner, including taking measures to prevent a third party from gaining access to the Personal Information.
HDD protects the Information using technical, physical and administrative security measures to reduce the risk of loss, fraudulent use or access by third parties, unauthorized disclosure or modification of Personal Information.
7.1 Place of conservation
All Personal Information collected is stored in restricted filing cabinets or is protected, including by electronic security systems, as applicable.
Access to Personal Information held by HDD is restricted to employees whose duties require the use of such Personal Information, as well as to subcontractors whose mandate or contract performance requires access to and/or use of Personal Information.
If an employee is teleworking, they must ensure that they are working in a location where (i) when Personal Information is stored online, their screen is not accessible to third parties; (ii) where Personal Information is kept in paper format, the Personal Information shall not be available for access by third parties. In all cases, the employee must refrain from working in a public place.
7.3 Security Program
HDD ensures the security of Users’ data by implementing stronger protection of Personal Information using technical physical and logical security measures to guarantee its integrity as well as its confidential and secure treatment. The security programs used by HDD are proportionate to the nature of the Personal Information collected and the significance of HDD’s activities.
8.1 Right not to provide Personal Information
At any time, subject to legal or contractual restrictions, it is possible for a User to withdraw consent to the collection, use and disclosure of Personal Information. However, such a withdrawal could result in a lower quality service offer or a less efficient and/or adapted service. Sometimes, services cannot be rendered, depending on the nature of the missing Personal Information.
8.2 8.2 Right to access and have Personal Information corrected
In accordance with the Act and similar provincial legislation, the User has a right of access to Personal Information concerning them. Any request for access, modification or deletion of a User’s Personal Information must be made in writing by a person proving their identity in accordance with sections 30 and 31 of the Act and be sent to the Privacy Officer via the email or postal address indicated in section 11 titled “Contact Us” below. Any request for access may be subject to a reasonable fee to cover the costs incurred for the transcription, reproduction or transmission of Personal Information we hold about the User.
To make a complaint under this Policy, you must make a complaint in writing and forward it to the address mentioned in section 11 below.
HDD handles complaints as follows:
This Policy is effective as of the date at the top of the Policy. Our Policy may be updated from time to time. We advise Users to consult it frequently.
The person responsible for ensuring compliance with and implementation of this Policy, as well as the Act, is Isabelle Beauséjour (the “Privacy Officer”).
If you have any questions, inquiries regarding this Policy or a complaint, please contact the Privacy Officer by email or mail at:
Humano District Development Limited Partnership
Attention: Isabelle Beauséjour
1820 Galt Street West, Suite 242A