Privacy Policy

Privacy Policy

Propulsio 360° Business Consultants L.L.P. would like to inform you about how we use the information we collect when you visit our website or retain our services. This Policy is intended to define and help you understand our practices regarding the collection, use, disclosure and retention of personal information.

1. Who are we and what is our commitment?

Propulsio 360 is a Montreal-based law and business advisory firm offering legal and business services to individuals and businesses.

Propulsio 360 is the “controller” of the personal information of its website visitors and clients (“you”, “your” or “yours”). Propulsio 360 is committed to protecting the privacy of the personal information entrusted to us. We recognize that privacy is an essential element of public trust.

By providing us with personal information, you agree to its processing as set out in this Privacy Policy, and you authorize Propulsio 360, its third parties and service providers to process your personal information for the purposes set out below.

1.1 Links to websites

Please note that the Propulsio 360 website may contain links to websites operated by third parties, including links contained in the “Blog” web page; these links are provided solely for your convenience. Propulsio 360 has no control over third-party websites. Any personal information you transmit through these sites is subject to the privacy policies of those sites. Therefore, Propulsio 360 is not responsible for any link contained in our website.

2. What is “personal information”?

In this Policy, “personal information” means any information (regardless of format) about an individual that directly or indirectly identifies the individual, such as name, home address, date of birth, etc. Personal information that has been anonymized or otherwise altered is considered to be “personal information”. Information that is anonymized or aggregated and cannot be associated directly or indirectly with an identifiable individual is not considered personal information.

3. What personal information do we collect and how?

We may collect certain personal information about you in the following circumstances:

• When you contact us, for example through the e-mail addresses available on our Web site or by telephone, we collect your identifiers and contact information, including your name, telephone number and e-mail address, as well as the information contained in your request.
• When you visit our offices or take part in our events, we collect your name and e-mail address.
• When you give us a mandate, we collect contact information as well as billing information such as a billing address, bank details or other payment system data.
• In the course of providing our services, any information you provide to us or that is made available to us, including, but not limited to, your social insurance number, information about dependents, spouses or beneficiaries, financial information, banking information and information about your employees.
• When you interact with our social media accounts, such as Facebook, Instagram and LinkedIn, for example if you “like” our page or make comments or enter into communication with us, we may collect certain information about you, such as your name. The information we collect depends on what these social networks share with us and the privacy settings you have selected. We suggest you consult the privacy policies of these social networks to learn more.
• When you apply for a job with Propulsio 360, we collect the information contained in your application, including your name, e-mail address, telephone number, work experience and references.
• Any other personal information provided. Please note that if you provide us with personal information about other persons (such as your customers, employees, directors, officers, shareholders or beneficial owners), you must ensure that you have duly notified them that you are providing us with their information and have obtained their consent to such disclosure of information for the intended uses.

We do not knowingly collect personal information from children under the age of 14, unless such information is necessary to provide services to our customers. If you are a child under the age of 14, please do not provide us with any personal information without the express consent of a parent or guardian. If you are a parent or guardian and you are aware that your children under the age of 14 have provided us with personal information, please contact us. If we become aware that we have collected personal information from children under the age of 14 without verification of parental consent, we will take steps to delete such information.

3.1 Do we receive personal information from third parties?

We may obtain personal information from third parties, both private and public (such as business partners, government authorities, financial institutions, etc.). Any personal information that is not collected directly from you will be collected in accordance with the requirements of applicable legislation.

4. How do we use your personal information?

We collect, use and disclose personal information for the purposes identified at the time of collection or as permitted by law. This includes, but is not limited to, the following means and purposes:

• To respond to your inquiries when you contact us.
• Establish and maintain business relationships with our customers, including account administration and billing.
• To provide professional legal and business services.
• Comply with applicable ethical and legal requirements, including verification of potential conflicts.
• To develop our business and for marketing purposes, including event registration and promotional emails.
• To recruit staff and evaluate your application for employment.
• Any other purpose for which you have consented at the time of collection or which is permitted by law.

In accordance with applicable legislation, Propulsio 360 limits the collection of personal information to that which is strictly necessary to fulfill the purposes for which it is collected.

5. Who may have access to your personal information?

Your personal information may be shared with the following persons in order to achieve the purposes indicated in the section above or otherwise with your consent:

• Propulsio 360 employees who have the authority and actual need to access personal information in order to perform their duties.
• Certain entities that assist us in providing our services, such as third-party service providers who assist us in, including but not limited to, email, accounting, services related to our website, data storage and IT support. These service providers have access to the personal information they need to perform their tasks, and may not use this information for any purpose other than to carry out their mandate. They are required to maintain the confidentiality of such information.

We may also share personal information in other situations, such as with government authorities, when required by law.

6. Consent

In most cases, Propulsio 360 will obtain the necessary personal information directly from you, with your consent. Subject to exceptions provided by law.

By voluntarily providing us with your personal information, you consent to its collection, use and disclosure in accordance with this Policy. In some cases, your consent may be “implied”, meaning that your agreement is presumed based on your action or inaction at the time of collection, use or sharing of your personal information. We generally obtain your consent when we want to use personal information for a new purpose or for a purpose other than those identified at the time of collection in this Privacy Policy, in accordance with applicable privacy laws.

Please note that you may refuse to provide us with personal information. You may also withdraw your consent to the collection, use and disclosure of your personal information in accordance with this Policy by providing us with written notice, subject to legal or contractual restrictions. Withdrawal of your consent may affect our ability to provide you with certain services or to process your requests where the use and/or disclosure of your personal information is necessary. In certain circumstances, legal requirements may also prevent the withdrawal of your consent.

7. What are your privacy rights?

Depending on the applicable laws, you may have the right to:

• Obtain access to, rectify or delete any personal information we hold about you.
• Withdraw your consent (if applicable), as indicated in section 6 of this Policy.
• Receive more information about Propulsio 360’s processing of your personal information, including the categories of persons who have access to your information, how long it is kept and the source of the information.
• To be informed of a decision based exclusively on automated processing (if applicable)

To exercise your rights, please contact our Privacy Officer at the e-mail address indicated under section 11 of this Policy “Contact us”.

8. How and for how long do we keep your personal information?

We keep your personal information only as long as it is required for the purposes identified in this Policy, or longer if required by law or by regulatory or professional standards. When the intended use of personal information has been completed, the information is destroyed, deleted or made anonymous, unless there is a legal obligation to retain it. In such cases, the personal information is deleted as soon as we have fulfilled our professional or legal obligations.

Information stored outside Canada

Wherever possible, we try to keep your personal information in Quebec. However, information stored on our service providers’ servers may be located outside Quebec or Canada, and may therefore be subject to the laws of other jurisdictions, including any laws permitting access by government authorities.

Where applicable, we ensure that we have put in place appropriate security measures and contractual arrangements to protect your personal information in accordance with applicable privacy laws.

9. Governance rules and other measures to protect personal information

Reasonable physical, technical and/or administrative safeguards and security measures have been implemented and are maintained to protect all personal information in Propulsio 360’s custody or control from unauthorized access, use, modification, disclosure, accidental loss or unlawful processing.

Propulsio 360 has also adopted policies and practices to ensure the protection of your personal information, including :

• The appointment of a Privacy Officer who ensures compliance with applicable privacy laws.
• Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle, limiting their access to this information on a need-to-know basis.
• Employee training on privacy and information security.
• A process for handling complaints and requests relating to the protection of personal information, including any confidentiality incident involving personal information.
• Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate safeguards and security standards.

More information about our approach to protecting your personal information is available upon request.

10. Changes to this Policy

We may review and update this Policy as necessary to keep up with changes in our practices and applicable legislation. Please refer to the “Effective Date” at the top of this page to see when this Policy was last revised. If the changes we make are material, we will highlight them where required by law, including through a notice on our website. We encourage you to visit this page regularly for the latest information on our privacy practices. Your continued use of our Web site and services after the revised Policy has been posted constitutes your acceptance of the revised Policy.

11. How to contact us

If you have any questions about this Policy or about Propulsio 360’s management of personal information in general, you may submit a written request to our Privacy Officer:

Philippe-Antoine St-Pierre Gilbert

• Lawyer, Privacy Officer
• Propulsio 360° Business Consultants L.L.P.
• E-mail address: info@propulsio360.com