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IDEKA’S PRIVACY AND PERSONAL INFORMATION GOVERNANCE POLICY

The company Ideka Services Conseils inc. (hereafter “Ideka”) commits to collect, use, disclose, store and destroy your Personal Information, regardless of the format in which it is held or accessed, in accordance with this policy (hereafter “Policy”).

This Policy also discloses the roles and responsibilities of Ideka’s personnel from the collection to the destruction of your Personal Information.

If you have any questions about your Personal Information and, after reading the Policy, your questions remain unanswered, you may contact Marie-Josée Tremblay, Ideka’s Privacy Officer, at the following e-mail address: confidentialite@ideka.ca. 

Ideka may, at its discretion, change the Policy from time to time. If a change is made to the Policy, you will be notified, as appropriate. Once notified, your continued use of the BOM mobile application following the effective date of the amended Policy will constitute your consent to the Policy as amended.

Definitions

In this Policy, the following definitions are applicable :

  1. “Government Authority(ies)” means a) any government, any ministry, any court, any tribunal, any arbitration organization, any commission, any agency, any council or any multinational office, federal, provincial, state, regional, municipal or local; b) any subdivision, agent, commission or any authority of any of the above entities; c) any quasi-governmental or private organization exercising any power of regulation, administration, expropriation or any taxing authority under the direction of or on behalf of the above entities, including any private organization mandated to provide public services;
  2. “Personal Information” means any information that relates to a natural person and allows, directly or indirectly, that person to be identified;
  3. “Privacy Officer” means the Privacy Officer appointed by Ideka who ensures compliance and enforcement of the Act, who can be reached by e-mail at: confidentialite@ideka.ca; and
  4. “Act” means the Act respecting the protection of personal information in the private sector, chapter P-39.1, and any subsequent amendments or modifications thereto.

Consent

By submitting your Personal Information to Ideka, you consent to the collection, use, disclosure, retention, and destruction of your Personal Information by Ideka in accordance with this Policy.

Purposes for Which Personal Information is Collected

Ideka collects your Personal Information for the following purposes: 

  1. respond to your requests, questions or contact you regarding this Policy;
  2. provide services to a wide range of customers by analyzing all application requests;
  3. refer and link a potential candidate with a compatible employer following our review of an application; 
  4. send you potential job offers or contact you regarding a job application corresponding to the profile of your application;
  5. contact you regarding a job offer or service in connection with a job application corresponding to the profile of your application;
  6. improve its website, BOM mobile application and services. Ideka may also use your Personal Information to customize your experience or display content according to your preferences;
  7. send you advertising material or additional information about our services, surveys, contests, promotions and special offers for marketing purposes. However, you are free to choose not to receive advertising or marketing material at any time;
  8. conduct market and performance research with a view to improving customer service and the quality of services on its website and BOM mobile application; and
  9. prevent and detect fraud or evaluate and improve protection and security measures. In particular, Ideka may use the information to protect its business, its customers, its website or its BOM mobile application.

Ideka will use your Personal Information only for the purposes set out in this Policy and will obtain your consent for any other use not set out in this Policy unless otherwise permitted by law.

Ideka may also contact you when it receives your Personal Information from a third party who has referred you for a potential job opportunity. In such cases, steps are taken to ensure that the third party sending Ideka your Personal Information has obtained your consent to the collection and disclosure of your Personal Information. Upon request, you will be informed of the source of this information.

How Your Personal Information is Collected 

Ideka collects your Personal Information when :

  1. you create a customer profile on its website;
  2. you create a customer profile or connect via another platform (e.g. Facebook, Google, Instagram, etc.) on the BOM mobile application;
  3. you apply for a job via the website, e-mail or any other means of communication;
  4. you click on an advertisement that Ideka has placed on a third-party website;
  5. you complete a survey, enter a contest or other promotion; and
  6. you contact Ideka by e-mail, telephone, or any other means of communication.

When Ideka collects your Personal Information from another person who operates a business, you may contact the Privacy Officer to be informed of the source of such information. 

Ideka may also collect your Personal Information when it receives it from a third party who has referred you to a potential job opportunity. 

Statutory Right of Access and Rectification

Ideka undertakes, at your request, to confirm the existence of your Personal Information, to communicate it to you and to allow you to obtain a copy of it in a structured and commonly used technological format. 

You have the right to demand that Personal Information that is inaccurate, incomplete, or ambiguous be rectified, or that it be deleted if its collection, communication, or storage is not authorized by law. 

You have the right to require Ideka to stop disclosing your Personal Information if such disclosure is in violation of the law, a court order or in the event that the following conditions are met: i) the disclosure causes you serious harm to your reputation or privacy, ii) this harm clearly outweighs the public interest in knowing this information or the interest of any person in expressing themselves freely, and iii) the requested cessation of disclosure does not exceed what is necessary to avoid the perpetuation of the harm.  

In all cases, your request for access or rectification must be made in writing, providing proof of your identity as the person concerned by the Personal Information. The Privacy Officer undertakes to respond to your written request within 30 days of receipt. 

Access to your Personal Information is free of charge, except where reasonable fees may be charged for transcription, reproduction or transmission. 

In the event of a refusal to grant your request, the Privacy Officer undertakes to give reasons for his or her decision and to inform you of the provision of the law on which the refusal is based, the remedies available to you and the time limit within which they may be exercised. The Privacy Officer undertakes to provide you with the assistance required to help you understand the refusal.

The Privacy Officer undertakes to issue, free of charge, a copy of your modified or added Personal Information or, as the case may be, an attestation of the suppression of your Personal Information. It also undertakes to notify, without delay, any person who has received the information in the six months preceding the request of the person concerned and, where applicable, the person from whom the information was obtained.

The Privacy Officer undertakes to keep the Personal Information that is the subject of your request for access or rectification for the time required to enable you to exhaust your legal remedies.

Right to Withdraw Your Consent 

You have the right to withdraw your consent to the disclosure or use of your Personal Information by Ideka at any time. To do so, please contact the Privacy Officer using the contact information provided in this Policy.  

Personal Information Automatically Collected Through the Website – Cookies 

Ideka collects Personal Information provided by cookies. Cookies are data files that are commonly stored on your device when you use websites and online services. They are used for the efficient operation of websites and can provide information and help personalize services. 

You can choose to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you wish to disable the use of cookies, you can do so from your browser’s preferences menu. It is possible to disable cookies or use the private browsing mode when using the website services. However, please note that by refusing to accept cookies, the use of the website may be considerably affected. 

Disclosure of Your Personal Information

Ideka wants you to understand with whom it shares the Personal Information it collects about you when you use its services. Consequently, Ideka shares your Personal Information with the following people: 

  1. Clients – When Ideka is mandated by a company to perform a service contract, i.e. to find or identify a potential employee or service provider for an employment or service offer by a customer, your Personal Information collected is communicated to this customer in order to establish a potential employment or service provider relationship. In such cases, procedures are put in place to ensure the secure communication of your Personal Information.  
  2. Authorized Service Providers –  Ideka may share your Personal Information with service providers who perform services on Ideka’s behalf. These service providers may have access to your Personal Information for the sole purpose of performing their functions. In such cases, security measures will be put in place to ensure the confidentiality of your Personal Information.
  3. Business Partners – Ideka may share your Personal Information with its business partners in order to provide services to you. In such cases, security measures will be put in place to ensure the confidentiality of your Personal Information. 
  4. Business Transaction – As part of a significant Ideka transaction, such as a sale of all or a portion of the stock of Ideka, a merger, or a sale of assets. Any third party to whom Ideka discloses your Personal Information will be required to agree to use such Personal Information in accordance with this Policy unless you indicate otherwise.
  5. Government Authorities – Ideka may share your Personal Information with government authorities when required to do so by any applicable law or regulation.

Ideka must obtain your consent to communicate or transmit your Personal Information to a third party not covered by this Policy, except where it is justified in doing so by virtue of an exception provided for by law.

Notwithstanding your consent to the communication of your Personal Information to the categories of people listed above, Ideka undertakes to use its best efforts to obtain your express consent prior to transmitting your application to a potential employer.  

Your Personal Information may be disclosed outside Quebec. In such cases, Ideka undertakes to conduct a privacy impact assessment and to make the disclosure only if the assessment demonstrates that the Personal Information disclosed is adequately protected. In such cases, the disclosure of the Personal Information will be subject to a written agreement that takes into account the results of such assessment and any terms and conditions agreed to in order to mitigate the risks identified in such assessment. 

Storage of Your Personal Information 

Personal Information collected by Ideka will be stored in secure locations and on servers controlled by Ideka, which are located either at our offices or at the offices of our third party service providers. 

Although we have measures in place to ensure the protection and confidentiality of your Personal Information when it is communicated to a third party covered by this Policy, the third party’s retention of your Personal Information remains subject to the third party’s privacy policy and Ideka cannot be held responsible for the third party’s retention measures. 

Safety Measures 

Ideka takes appropriate security measures, including physical, electronic, technological and organizational measures to protect your Personal Information.

To this end, the BOM mobile application has privacy settings that ensure the highest level of confidentiality, without any intervention on your part.

Ideka also has various internal measures related to the protection of Personal Information, including this Policy and access controls based on the role of each employee within the company.

Duration of Conservation of Personal Information

Your Personal Information will be stored indefinitely as long as required by law or as long as necessary for the purposes set out in this Policy.

Ideka has a legitimate interest in retaining your Personal Information for future referral purposes or to follow up with a job application. 

Once the purposes for which your Personal Information was collected have been fulfilled, it will be destroyed or anonymized by Ideka, subject to any retention period required by law. 

Ideka adheres to industry standard principles for making Personal Information anonymous and irretrievable. 

Ideka may retain some of your account information for analytical and accounting purposes, as well as for record-keeping integrity and fraud prevention purposes, to collect fees charged, to enforce the Terms of Use, to take any action Ideka deems necessary to protect the integrity of the Website or its BOM mobile application, or as otherwise permitted by law. In addition, if any of your information has been provided with your consent to third parties, the use and retention of your information will be subject to the policies of those third parties and Ideka will not be liable for any such use or retention.

Complaints Handling

If you have any complaints regarding the protection of your Personal Information or its use by Ideka, please contact the Privacy Officer at the e-mail address indicated on the first page of this Policy. The Privacy Officer will respond to your complaint by e-mail as soon as possible. 

Staff Roles and Responsibilities

Ideka implements access controls to ensure that only employees authorized by Ideka have access to your Personal Information. These authorized employees need to know or have access to your Personal Information in order for Ideka to provide its services. 

The Privacy Officer is responsible for ensuring that this Policy is respected and implemented. She also ensures that all authorized Ideka employees are familiar with the Policy and that they use Personal Information in accordance with its provisions. Authorized employees are adequately trained in the implementation of this Policy and in the procedures surrounding the protection and confidentiality of your Personal Information. 

Access to and Means of Accessing Your Personal Information

If you have any questions regarding the access or the use of your Personal Information by Ideka, please contact the Privacy Officer at the e-mail address indicated on the first page of this Policy.

Personal Information of Minors

Ideka does not collect Personal Information from minors under the age of 14, except with the written consent of a parent or legal guardian. 

Precedence

In the event of any inconsistency between this Policy and the Act, the provisions of the Act shall prevail. 

Policy last updated: October 18th, 2023