Privacy Policy
1. INTRODUCTION
Capitalized terms have the meaning that appears when hovered out.
LLP ("", "", "" or "our") is committed to protecting the personal information it collects in the course of its business activities and relationships. This Privacy Policy (the "Policy") describes in clear and simple terms how complies with its privacy obligations and more specifically the practices regarding the collection, use, disclosure, retention and destruction of personal information collected by from, among others, 's customers, employees of those customers, parties involved in our customer files, as well as visitors to 's website, our suppliers and subcontractors.
The Policy also describes the data protection rights of data subjects.
Our Privacy Officer is responsible for ensuring compliance with and implementation of the Policy:
Privacy Officer
1100 René-Lévesque Blvd. West, 25th floor
Montréal (Québec) H3B 5C9
Canada
Tel.: 514 397-8500
Email: ar@bcf.ca
Rest assured that have implemented internal practices concerning the management of your personal information. These practices include, in particular, guidelines concerning :
- The security of your personal information;
- Managing and preventing confidentiality incidents;
- Performing privacy impact assessments;
- Retention of your information throughout its life cycle.
Our commitment to is clear:
- Be concise, clear and transparent;
- Obtain your consent when necessary;
- Allow to exercise your rights regarding your personal information;
- Protect the confidentiality of your personal information.
2. SCOPE of the policy
The Policy applies to personal information collected in the course of all our activities. In particular, it applies to personal information collected when become a customer of ours, when visit our website and when contact by any other means of communication.
Our Policy does not apply to the collection, use, disclosure or retention of your personal information by other websites, although certain links on our website may allow to access the content of third parties. We are not responsible for their privacy policies, and encourage to read any privacy notices or policies governing such third parties.
3. PERSONAL INFORMATION COLLECTED BY AND PURPOSES FOR WHICH IT IS COLLECTED, USED, RETAINED AND DISCLOSED
Personal information is any information about a natural person that allows that person to be identified directly or indirectly, either separately or in combination with other information. In some cases, the law that applies to your information may provide a separate definition. For greater clarity, personal information is any information that makes it possible to identify :
- directly a person, for example, an identifier such as a name, location data, government ID; or
- indirectly through the combination of several specific elements specific to its physical, physiological, genetic, psychological, economic, cultural or social identity.
We collect personal information as described in this Policy, including information necessary to offer our services, to comply with our ethical and professional obligations, to manage our business and to maintain and establish commercial relationships. In addition, subject to the exceptions provided by applicable laws, obtaining your consent is the legal basis on which collect and process your personal information.
Below are the categories of personal information collect and examples of each category. This information is all collected for specific purposes, which are also detailed below.
3.1 collects
collects and processes the following :
1. Identity and Contact Data, including your name, address, telephone number, copies of identity papers and email address;
2. Financial and Payment Data, including the email address of billing contact, billing postal address, bank details, amount invoiced and overdue;
3.Commercial and customer profile Information, including customer number and Information about your preferences related to our services;
4. Information required for legal advice and other services, including background to our discussions with , email exchanges.
For example, in the context of representation in employment-related matters, including disputes involving allegations of discrimination, information about health stat, race, religion or sexual orientation may be material to representation;
Representations on tax or social security matters may also require to collect personal information, such as when advise on the eligibility of certain disabilities for social security or tax benefits.
5. Physical access information, including Information about visiting our offices.
6. Technical Data, including information collected during your visits to our website, the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating systems and platforms. To learn more about our use of cookies or similar technology please check our Cookies Policy;
7. Physical Access Data, relating to details of your visits to our premises;
8. Information about your digital interactions : including information about your devices, route and navigation history, duration of visits, Internet Protocol (IP) address, connection information and the type of device used. To learn more about our use of cookies, please visit our Cookie Policy .
If provide with personal information about anyone other than yourself, must ensure that they understand how their personal information will be used and that they have given permission to disclose their personal information to .
3.2 Purposes for which personal information is collected
collects, uses, retains and discloses personal information only to the extent necessary for the purposes detailed in this Policy or as required by applicable law. If were to collect, use, retain or disclose a data subject's personal information for purposes other than those identified in this Policy, will obtain the data subject's consent before processing his or her information, except in circumstances permitted by applicable laws.
We collect your personal information, to the extent permitted by applicable laws, in order to:
Purposes for which collects are as follows:
(a) To identify . When wish to register as a new customer, require certain information in order to identify . This information will be used to comply with our ethical and professional obligations, to retrieve your file and to ensure that your information is associated with your account when wish to benefit from our services.
In general, collect identity and contact information for this purpose. In some cases, your information may also be used to authenticate .
(b) Provide our services and carry out our activities. When do business with , it is necessary for to process some of your information in order to carry out our activities, including: fulfill our ethical and professional obligations, determine your eligibility for our services, advise according to your needs, register as a customer, provide and administer legal or other services or solutions, as directed by or your company and administer and manage our relationship with , including accounting and other measures related to the quality of our business relationship. In addition, in the course of providing our services, may conduct due diligence reviews on behalf of our clients in certain cases. These audits require to collect, verify and disclose personal information.
(c) To communicate with . As part of our business relationship with , may need to communicate with from time to time. In addition to exchanges that take place in the normal course of your file, may need to inform of changes to our policies.
In addition, if sign up to receive e-mail communications (e.g. newsletters), will contact . Please note that may unsubscribe from such communications at any time.
(d) To manage our risks. It is necessary for to take certain preventive actions as part of the risk management of our activities in order to avoid, in particular, financial losses, breakdowns in operational services and internal and external fraud. To this end, : monitor suspicio activity and ensure the security of our communications and other systems to prevent security threats, fraud and other criminal or malicio activity, monitor access to our offices and use sophisticated software and technological tools.
(e) Meet our legal and regulatory obligations. In operating our business and due to the nature of our activities, must comply with certain ethical, professional, legal and regulatory obligations. We are therefore obliged to collect your information in order to comply with our ethical and professional obligations, comply with the Income Tax Act, protect in the case of claims or legal actions and conduct due diligence and conflict research.
(f) To send offers, newsletters, bulletins or any other communications by e-mail, paper mail or telephone. In order to offer a more personalized service, may use your personal information to send offers concerning our services, articles or training likely to meet your needs, newsletters or surveys. To adequately personalize these communications, may analyze your personal information for profiling purposes. This enables to avoid sending communications that do not correspond to your expectations.
Please note that will only send these communications if have, where required by law, chosen to receive them and have the opportunity to withdraw your consent at any time.
3.3 Operating the website
To ensure that the content on our Web site is presented in an effective manner, need to monitor activities on the Web site. These analyses may involve certain personal information. To learn more about our use of cookies, please see our Policy regarding cookies.
4. CIRCUMSTANCES SURROUNDING THE COLLECTION OF PERSONAL INFORMATION
The circumstances under which may collect personal information about include the following:
4.1 Collection of personal information directly from the individuals concerned
In most cases, will collect personal information directly from the individual concerned. For example:
-When or your company seek legal advice or other services from ;
-When or your company offer to provide services to ;
-When personal information is provided to by a third party because are the subject of legal or other advice that have been asked to provide to that third party, or your information is otherwise considered by that third party (for example, if are asked to provide advice in connection with an employment dispute or when are the subject of an investigation or due diligence that have been asked to conduct);
-When communicate with by telephone, e-mail, through our website or by other means, or when provide other information directly to , including in conversations with our professionals, consultants or any other member of the team;
-When register for or participate in our training or other events or subscribe to our mailing lists so that can send information, including information about training and events;
-When provide services to and, for security reasons, need to verify your identity (for example, when access our computer or technological systems).
4.2 Collection of personal information from third parties
will only collect personal information about a data subject from third parties with the consent of the data subject or as permitted by applicable laws.
In certain circumstances, may be required by or to collect, use, retain or disclose the personal information of an individual without that individual's knowledge or consent.
5. RETENTION OF PERSONAL INFORMATION
The personal information collect is retained only as long as necessary to fulfill the purposes set out in this Policy and to comply with our legal and regulatory obligations. We have implemented internal procedures and policies to ensure that your personal information is subject to a specified retention schedule and that it is securely destroyed or, where permitted by law, anonymized once this period has elapsed.
If have any questions regarding the conservation of your personal information, please contact our Privacy Officer.
6. DISCLOSURE OF PERSONAL INFORMATION
In some cases, your personal information will be disclosed outside our company. Except in the case of judicial or quasi-judicial proceedings, or within the limits provided by applicable laws, strives to comply with the standards set forth in applicable laws.
We never sell your personal information, and disclose it only in the cases provided for by applicable laws and the cases provided for in this Policy.
Your personal information may be communicated to:
6.1 Our service providers and partners
In order to carry out certain purposes described in the Policy, do business with service providers to whom may communicate or give access to your personal information as required for the fulfilment of their contractual duties.
However, rest assured that are taking commercially reasonable measures to:
-Maintain the confidentiality of your personal information;
-Ensure that information is used only for the purpose of providing the service;
-Restrict access to personal information only to those employees who need access to it in order to perform their duties;
-Ensure that the Provider does not retain any personal information when it is no longer required for the performance of the service, except for that contained in backup systems which will be deleted according to the Provider's predetermined deletion cycle;
-Ensure that the service provider contacts immediately in the event of a confidentiality incident or any attempt to do so.
The categories of service providers with whom do business include:
1. IT and technical services (e.g. Microsoft 365, IManage, Elite 3E and Litera); ;
2. Cloud hosting service (e.g. Microsoft Azure);
3. Communications and marketing firms;
4. Accounting firms;.
5. Law firms, mediators and other legal professionals;
6. Printing service;
7. Security service;
8. Mail delivery service and bailiffs;
9. Any other service provider required to carry out the mandates entrusted to .
6.2 Our different legal entities within the same group
We may share some of your personal information with other legal entities within our group when necessary.
6.3 Courts, law enforcement authorities, regulators, government officials or prosecutors
More specifically, may disclose your personal information to comply with a search warrant, to respond to an investigative body, to comply with a court order, if believe disclosure is necessary to comply with applicable laws, if required by law, to pursue a legal claim or to assert a defence.
6.4 Other third-party entities
From time to time, may need to disclose your personal information to other third parties in certain specific circumstances, always within the limits authorized by applicable laws or after obtaining your consent, for example:
-As part of a business transaction (a merger, an acquisition by another company, obtaining a loan or financing, for example);
-In the event of insolvency or bankruptcy.
7. DISCLOSURE OF PERSONAL INFORMATION OUTSIDE QUEBEC OR CANADA
Many of the suppliers deal with and other third parties to whom disclose your personal information operate outside Quebec and Canada. We do not share your personal information unless it is adequately protected.
8. SAFETY MEASURES
We have adopted security measures to protect personal information in our possession.
1. Technical measures such as strong internal passwords, two-factor authentication, privileged access management, application of Zero Trust controls, encryption of data at rest and in transit, access logging and the use of Security Information and Event Management (SIEM) technology, 24/7 Security operations Center (SOC) service, endpoint detection and response (EDR) security, detective and preventive controls data leakage prevention (DLP), and installation of ethical walls according to circumstances.
2. Administrative measures such as nternal policies and training on the protection of personal information, confidentiality commitments, audits of practices and policies and ISO27001:2022 certification;
3. Material measures such as lock filing cabinets, access to offices restricted by access card, surveillance cameras, physical presence during business hours and other physical measurements of our locations;
takes reasonable steps to prevent unauthorized access, use or disclosure of personal information, as well as the loss of personal information or any other breach in the protection of such information (a "Privacy Incident").
Any Privacy Incident, whether potential or actual, is taken seriously and managed in accordance with applicable laws.
However, please be aware that the transmission of information over the Internet is not completely secure. While will do its best to protect a data subject's personal information, cannot guarantee the security of information transmissions over the Internet. Once have received information from a data subject, will apply our security measures to prevent any Privacy Incidents.
If believe that your personal information has been compromised, or if have any concerns in this regard, invite to contact the Privacy Officer.
9. RIGHTS OF PERSONS CONCERNED
is committed to being transparent about its policies and encourages to contact the Privacy Officer with any questions may have.
9.1 Our service providers and partners
Subject to the exceptions set out in the applicable laws, have the right to request a copy of the personal information hold about or to consult that information. You may exercise your right of access by contacting the Privacy Officer. Please note that:
-Access to your personal information is free of charge. However, in certain circumstances, such as if the request is excessive or unfounded, may charge an administration fee for transcribing, reproducing or transmitting your personal information, or if require additional copies. We will inform of any such charges before processing your request.
-We generally respond to all requests for access within 30 days of receipt of any necessary information. When are unable to grant access, or if additional time is required to fulfill a request, will notify in writing.
9.2 Correcting your personal information
If consider that your personal information is inaccurate or incomplete, may rectify it by contacting the Privacy Officer .
In this regard, makes reasonable efforts to ensure that the personal information maintain about is as accurate, complete and up-to-date as possible. To assist in maintaining your personal information and to ensure that it is accurate and up-to-date, may inform of any changes in the information have provided to by contacting directly the person in charge of your file at or by contacting the Privacy Officer.
9.3 Obtain information on the processing of your personal information
You have the right to obtain additional information relating to the processing of your personal information. If do not find the answer to your questions in the Policy, can contact the Privacy Officer.
9.4 Withdraw your consent
When give your consent for secondary purposes, i.e. purposes that are not essential to offering our services, may withdraw your consent at any time, without consequence.
Please note, however, that certain personal information is essential to the provision of our services. For example, certain information such as your contact and banking information must be provided to as part of the services provided by the company. Failure to provide this information will hinder 's ability to provide the requested service, implement your instructions or carry out a contract have with or are attempting to enter into. In this event, may have to cancel our engagement with . You will, however, be notified should this situation arise.
9.5 Right of refusal and right to limit the processing of your personal data
In certain circumstances, also have the right to object to the processing of your personal information and to ask to block, erase or limit access to your personal information. You also have the right to ask to limit the use of your personal information in certain circumstances. Please note that will evaluate any such request in accordance with our ethical and professional obligations and that, in certain circumstances, it may not be possible to comply with your request.
9.6 Right to erase your personal information
You have the right to request the erasure of your personal information when it is no longer required for the purposes for which it was collected, when there is no longer a legal obligation to retain it, or when, for example, your personal information has been used unlawfully. Please note that will evaluate any such request in accordance with our ethical and professional obligations and that, in certain circumstances, it may not be possible to comply with your request.
9.7 Right to the portability of your personal information
You have the right to request that certain of your personal information be transmitted to , or directly communicated to another organization responsible for processing, in a structured, commonly used and machine-readable format.
9.8 Dissatisfaction with the management of your personal information
If have any questions, concerns or dissatisfaction with this Policy or with 's management of your personal information, may contact our Privacy Officer the Commission d'accès à l'information or any other competent authority.
10. POLICY UPDATE
This Policy replaces all previo versions. The history of previo versions of the Policy can be obtained by request to our Privacy Officer.
The Policy may be updated at our sole discretion to reflect changes in our practices and applicable laws. When the Policy is updated, a notice will be posted on the home page of our Web site. When changes are of a material nature or require your consent, will notify by e-mail if have your e-mail address.
1. INTRODUCTION
Capitalized terms and expressions not otherwise defined shall have the meaning assigned to them in Article 2.
s.e.n.c.r.l. (“” and “” or “”) has developed this policy regarding Cookies and other digital identifiers as defined below (the “Policy”) in order to describe to all visitors (“”) to the www.bcf.ca website (“Website”) 's practices with respect to the use of Cookies on its Website.
Our Privacy Officer (the “Privacy Officer”) is responsible for ensuring compliance with and implementation of the Policy:
Privacy Officer
1100 René-Lévesque Blvd. West, 25th floor
Montréal, Québec H3B 5C9
CANADA
Phone: 514 397-8500
E-mail: ar@bcf.ca
2. DEFINITIONS
“Employees” means all members of 's management, associates, professionals, all administrative and support staff of as well as consultants and contractors who may be assimilated to employees of .
“” means any identified or identifiable individual about whom collects personal information, including, but not limited to, 's customers, customers' employees, current, former and prospective employees, as well as visitors to 's Website, suppliers and subcontractors.
“Website” refers to the www.bcf.ca website.
“Cookies” are files containing an identifier (a series of letters and numbers) sent by a Web server to a Web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies are “persistent” when they are stored by a Web browser and remain valid until their scheduled expiry date unless they are deleted by the user before that date. Cookies are designated “temporary” when they expire at the end of the user's browsing session. Although Cookies generally do not contain personally identifiable information about a user, personal information that maintains about a user may be linked to or obtained from the information contained in Cookies.
3. THE COOKIES WE USE
We use categorized Cookies in the following ways and for the purposes detailed below:
a) Necessary - Necessary Cookies are crucial to the basic operation of the Website. Without them, the Website would not function as intended. These Cookies are also used, among other things, for the general security of the Website. The necessary Cookies used by are:
- ASP.NET_Sessionld
- _RequestVerificationToken
- ARRAffinity
- ARRAffinitySameSite
- bcf#lang
- CookieYes
b) Functional - Functional Cookies allow to perform certain functionalities such as sharing Website content on social media platforms, collecting comments and other third-party functionalities. These Cookies indirectly collect information that can be used to identify a . The functional Cookie used by is :
- bcfLogoAnimation
c) Analytical - Analytical Cookies are used to understand how interact with the Website. These Cookies help provide information about the number of visitors, bounce rate, source of traffic, etc. These Cookies are:
- _ga
- _ga_*
- SC_ANALYTICS_GLOBAL_COOKIE
- Pardot
- _gid
- Ipv682813
- gat_gaTrackerName
d) Performance - Performance Cookies are used to understand and analyze key performance indicators of the Website, which helps provide a better visitor experience. As of the date of this Policy, does not use any Performance Cookies.
e) Advertising - Advertising Cookies are used to provide visitors to the Website with personalized advertisements based on previously visited pages and to analyze the effectiveness of the advertising campaign. These Cookies indirectly collect information that may identify a . The advertising Cookies used by are:
- visitorld
- visitor_id*
- visitor_id*-hash
4. COOKIES USED BY OUR SERVICE PROVIDERS
4.1 uses service providers to process personal information collected on 's behalf. These service providers use Cookies that may be stored on your computer when visit the Website.
uses Google Analytics as a tool to analyze the use of the Website. Google Analytics collects information about the use of the Website using Cookies. The information collected is then used to create reports on the use of our website. We invite to consult Google's privacy policy at the following address: https://policies.google.com/privacy?hl=en
5. COOKIE MANAGEMENT
5.1 In addition to the banner allowing to accept, refuse and set Cookies on the Website, most browsers allow to refuse to receive Cookies and to delete Cookies. How to do this is specific to each browser and version. However, can obtain up-to-date information on how to block and delete Cookies via these links:
a) https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDeskt (Chrome);
b) https://support.mozilla.org/en/kb/activer-desactiver-cookies-preferences (Mozilla);
c) https://www.opera.com/help/tutorials/security/cookies/ (Opera);
e) https://support.apple.com/en-ca/guide/safari/welcome/mac (Safari); and
5.2 However, please note that blocking access to all Cookies may adversely affect the quality of your experience and of use of our Website.
6. LINKS TO THIRD-PARTY WEBSITES
's website includes links to other websites that are governed by privacy and Cookie use practices that may differ from those of . If a visits or transmits personal information to any of these websites, is not responsible, as such information and use of Cookies by third parties are governed by the policies of such third parties. Please read the privacy and Cookie policies posted on any third party website visit through the Website before submitting personal information to such third parties or accepting Cookies from them.
7. UPDATE AND REVISION
This Policy may be changed from time to time by , in its sole discretion and without notice or liability to any or any other person.