Confidentiality Policy
Last updated: December 18th, 2023
In brief
Means
Personal information is collected:
- Automatically from visitors (hereinafter "Visitors") to the Fuel Digital Media website (hereinafter the "Website");
- Through the use of cookies; and
- From Visitors applying for a job via electronic forms.
Purposes
Personal information is collected and used for the following purposes:
- Promote Fuel Digital Media’s services;
- Promote the Website;
- Answer your questions (if applicable);
- To meet legal and regulatory requirements regarding the protection of personal information;
- Protect your rights (for example, to ensure that unauthorized third parties do not gain access to your personal information);
- Protect the property or security of Fuel Digital Media and the Site (for example, we may use your personal information in connection with a dispute between you and Fuel Digital Media or to identify and prevent access to our Site by "bots");
- Facilitate the use of our Website and improve its performance;
- Maintain our databases and administration systems;
- To ensure the functionality of the Website;
- Count the number of visits to the Site in order to measure its performance;
- Identify the most frequently visited pages of the Site in order to measure their performance, interest in them and the interest of our potential customers in our services;
- Identify the technology used (such as the operating system and browser used) by Visitors to ensure the Site and its content are compatible with them;
- Identify the referring web sites from which you visit our Site in order to assess their ability to provide us with visits to our Website;
- Evaluate the Site’s effectiveness in acquiring and retaining Visitors;
- To obtain or create statistics enabling us to evaluate the performance of the Website;
- To send informative communications about Fuel Digital Media’s services and activities;
- To ensure compliance with our Terms and Conditions, which can be accessed via the following hyperlink: Terms of use – Fuel Digital Media;
Communications
The personal information is communicated to :
- Our web or cloud host: WHC;
- To all entities identified in TABLE: List of cookies offered or used by third parties for the purposes that are identified.
Important information
Personal information is communicated outside Quebec.;
Personal information is used and communicated for profiling and identification purposes. The collection and use of personal information for profiling and identification purposes is deactivated by default. You can activate these functions by authorizing the collection of personal information for profiling purposes by approving the choice in the pop-up window that is communicated to you when you access our Website. You can also authorize this function in our privacy settings.
Your rights
The Act gives you the right to access, rectify and withdraw consent to your personal information. For more details on your rights, please refer to sections 8 to 11 of this Policy.
You may also make a complaint by following the instructions in section 12 of this Policy.
Implicit consent
All persons using the Website or communicating with Fuel Digital Media consent to the collection, use and communication of their personal information for the purposes set out above and to the entities set out above and referred to in the TABLE: List of cookies offered or used by third parties and in section 3.
Table of contents
- Consent
- How long do we keep personal information?
- How do we protect your personal information?
- Visitor’s choice
- How can you withdraw your consent to communication or use?
- How can I access my personal information?
- How can I correct my personal information?
- Procedure for requesting access, rectification and withdrawal of consent.
- Complaints procedure
- Amendments to this policy
- Beware of third-party websites
- Contact information for the Person in charge of the protection of personal information
CONFIDENTIALITY POLICY – Fuel Digital Inc.
Legal framework. In accordance with the Act respecting the protection of personal information in the private sector (RLRQ c P-39.1) as amended by the Act to modernize legislative provisions as regards the protection of personal information, Fuel Digital Inc. (hereinafter collectively “Fuel Digital Media”, “we” or “us”) implements means to protect your personal information.
Policy objectives. This privacy policy (the “Policy“) governs Fuel Digital Media’s privacy practices with respect to Personal Information that you voluntarily share with us in connection with your visit to Fuel Digital Media‘s website https://www.fueldigitalmedia.com (the “Website“), by communicating with us through social media or when you communicate with us using the means of your choice (e.g., telephone, email, etc.).
The main purpose of this Policy is to inform you about:
- Which personal information we collect from you and for what purposes;
- How we use your personal information;
- To whom we may communicate your personal information;
- What choices you have regarding the collection and use of your personal information;
- What type of security procedures are in place to protect your personal information;
- What are your rights with respect to this personal information (right of access, rectification and withdrawal of consent);
- How we store and destroy your personal information; and
- How to contact us if you have any questions, comments, or complaints.
2. What personal information do we collect and for what purposes?
2.1. Personal information collected automatically
Automatic collection. When you access the Website, our server automatically collects the following personal information:
- Your IP address;
- The browser you use (Chrome, Microsoft Edge, Firefox, Brave…);
- Your operating system (Windows, Mac OS…);
- The domain name of your Internet service provider;
- The date and time of your visit on the Website;
- The pages you visit on the Website; and
- The address of the website from which you access the Website.
Collection via cookies. Personal information may also be collected using cookies. A cookie is a small data file stored on the device of a visitor to the Website (hereinafter a "Visitor") by a server.
2.2. Personal information collected by third-party cookie
Third parties collecting personal information through cookies. Our Website uses cookies from Google (Google Analytics).
Communication outside Quebec. Some of these cookies will communicate Personal Information outside Quebec.
Table of cookies offered or used by third parties. For more details on the purposes and uses of personal information by these third parties, consult our TABLE: List of cookies offered or used by third parties.
TABLE: List of cookies offered or used by third parties
|
Third parties / sources of cookies |
Names of cookies used |
Declared purposes of cookies |
Links to relevant third-party documentation |
|
Google |
_gid _ga |
Creation of statistics on Website traffic. Assign a unique identifier to Website visitors in order to differentiate them and for statistical purposes. Count the number of visitors to each page |
Google’s privacy policy: How Google uses cookies: |
3. For what purposes do we collect your personal information and to whom do we communicate your personal information?
3.1. What are the purposes of personal information?
Purposes of personal information. We also collect information for the following purposes:
- Promote the Website;
- Answer your questions (if applicable);
- To meet legal and regulatory requirements regarding the protection of personal information;
- Protect your rights (for example, to ensure that unauthorized third parties do not gain access to your personal information);
- Protect the property or security of Fuel Digital Media and the Site (for example, we may use your personal information in connection with a dispute between you and Fuel Digital Media or to identify and prevent access to our Site by "bots");
- Facilitate the use of our Website and improve its performance;
- Maintain our databases and administration systems;
- To ensure the functionality of the Website;
- Count the number of visits to the Site in order to measure its performance;
- Identify the most frequently visited pages of the Site in order to measure their performance, interest in them and the interest of our potential customers in our services;
- Identify the technology used (such as the operating system and browser used) by Visitors to ensure the Site and its content are compatible with them;
- Identify the referring web sites from which you visit our Site in order to assess their ability to provide us with visits to our Website;
- Evaluate the Site’s effectiveness in acquiring and retaining Visitors;
- To obtain or create statistics enabling us to evaluate the performance of the Website;
- To send informative communications about Fuel Digital Media’s services and activities;
- To ensure compliance with our Terms and Conditions, which can be accessed via the following hyperlink: https://www.fueldigitalmedia.com/en/terms-of-use/ ;
- Communicate your information for the purposes and to the entities identified in TABLE: List of cookies offered or used by third parties.
New purposes (if applicable). We will notify you and ensure that we obtain any necessary consent to collect, use or communicate for any purposes other than those listed above, if applicable.
3.2 To whom do we communicate personal information?
Personal information hosted by WHC. We host your information at WHC.
Communication outside Quebec. Consequently, your personal information will be communicated outside Quebec for hosting purposes.
Cookies. The information collected by the cookies listed in the above-mentioned TABLE: List of cookies offered or used by third parties, is communicated to the entities and for the purposes identified therein.
Communication without consent permitted by law. We may also communicate your personal information without consent where permitted or required by applicable law.
Implied Consent. All persons who use the Website or who communicate with Fuel Digital Media on their own consent to the collection, use and communicate of their personal information for the aforementioned purposes and to the aforementioned entities (see sections 2 and 3).
5. How long do we keep personal information?
Destruction of personal information upon fulfillment of purposes, except where retention is required by law. In accordance with our procedures for the secure retention and destruction of personal information, we retain personal information only as long as necessary for the fulfillment of those purposes and to comply with our legal obligations. Thereafter, personal information will be destroyed in a secure and confidential manner.
6. How do we protect your personal information?
Security measures. We adopt physical, technological, and administrative safeguards to protect your personal information and reduce the risk of unauthorized and/or unlawful access, use, communication, and destruction. Without limiting the generality of the foregoing, we:
- Minimization: consciously limit the personal information we collect. We collect only the personal information necessary to fulfill the purposes identified in Section 3 – For what purposes do we collect your personal information and to whom do we communicate your personal information?
- Security filtering: carry out a security filtering process before authorizing any of our employees or representatives to access or process your personal information;
- Undertakings of confidentiality: require each of our employees and representatives who have access to your personal information to sign an undertaking of confidentiality;
- Training: ensure that each of our employees and representatives who have access to your personal information receives adequate training and vigilance with regard to privacy and the protection of personal information. We provide them with several annual training sessions designed to maintain this level of vigilance;
- Access logging: monitor digital access to your personal information by logging the operations performed on it;
- Limiting access: restrict access to your personal information to those employees who require such access in order to carry out one or more of the purposes listed in section 3 – For what purposes do we collect your personal information and to whom do we communicate your personal information?; and
- Retention Schedule: maintain a retention schedule to ensure that your personal information is promptly destroyed once its purposes have been fulfilled or any applicable legal retention period has expired.
Security measures for communications outside Quebec. Finally, before communicating any personal information outside Quebec, we assess the level of security offered by the recipient. We also carry out a privacy impact assessment to ensure that your personal information would benefit from adequate protection, particularly with regard to generally recognized privacy principles, the safeguards (including contractual safeguards) that the information would benefit from, and the legal regime of the state where the information would be communicated.
Changing cookie settings on your web browser. You can manage the handling of your personal information by cookies by modifying your browser settings. For more information about changing your browser settings, you can refer to the information provided by your browser. For example, you can find out here (if you use Google Chrome), here (if you use Mozilla Firefox) or here (if you use Microsoft Edge). However, your refusal to accept cookies may impair or limit your access to certain features of our Site.
8. How can you withdraw your consent to communication or use?
Your right to withdraw consent to communication or use. Subject to applicable law and contractual obligations, you may withdraw or change your consent to the use or communication of your personal information. To do so, please contact our Person in charge of the protection of personal information (see section 11- Procedure for requesting access, rectification and withdrawal of consent). However, if you withdraw your consent to certain uses or communications of your personal information, we may no longer be able to provide you with certain services or the quality of our services may be affected. We will inform you of the consequences of your choice before accepting your request to withdraw consent.
9. How can I access my personal information?
Content of the right of access. You have the right to access your personal information. As such, you may ask us to:
- Inform you of the existence of personal information concerning you;
- Receive communication of your personal information;
- Consult the personal information we hold about you by allowing you to view the information on-site during normal business hours or remotely and obtain a copy; and
- As of September 22, 2024 only, ask us to communicate any information collected from you (excluding personal information created or inferred from personal information about you) in a structured and commonly used technological format. As of September 22, 2024, you may also ask us to communicate your personal information to any person or organization authorized by law to collect personal information.
(Reasonable) Fees. A reasonable fee may be charged for the transcription, reproduction, or transmission of your personal information. We will advise you of such charges prior to transcribing, reproducing, or transcribing your personal information.
Applicable procedure. Any request for access must be communicated to our Person in charge of the protection of personal information in accordance with the procedure identified in section 11 – Procedure for requesting access, rectification and withdrawal of consent. Please note that the law may prevent us from accepting an access request for various reasons.
10. How can I correct my personal information?
The right of rectification. You may also send us a request to rectify your personal information in the following circumstances:
- Your personal information is inaccurate;
- Your personal information is incomplete;
- Your personal information is ambiguous;
- The collection, communication or retention of your personal information was not authorized by law.
Destruction of personal information. You may also ask us in a request for rectification to destroy any personal information collected or retained if the collection, communication, or retention of your personal information was not authorized by law.
Delivery of a copy or an attestation. If we grant your request for rectification, you may ask us to send you a copy of any personal information that has been changed or added, or an attestation of the removal of personal information, as the case may be.
Applicable procedure. Any request for rectification must be communicated to our Person in charge of the protection of personal information in accordance with the procedure identified in section 11- Procedure for requesting access, rectification and withdrawal of consent. Please note that the law may prevent us from accepting a request for rectification for various reasons.
11. Procedure for requesting access, rectification and withdrawal of consent.
Procedure. To be considered, all requests under sections 8 through 10 must be made in writing to Mr. John Sclapari, Fuel Digital Media’s Person in charge of the protection of personal information, by email at privacy@fueldigitalmedia.com.
Proof of identity required. You will need to prove your identity before we can accept your request.
Response times. We have a legal obligation to respond (favorably or unfavorably) to any request for access or rectification within 30 days of receipt and confirmation of your identity. We may refuse any request in accordance with applicable privacy laws.
Complaint Procedure. You may direct a complaint about our governance or privacy practices to Mr. John Sclapari, Fuel Digital Media’s Person in charge of the protection of personal information by email at privacy@fueldigitalmedia.com.
Duty to assist or questions. You may also contact our Person in charge of the protection of personal information if you have any questions regarding your rights of access, rectification, or withdrawal of consent. You may also request his assistance in order to better specify your requests for access, rectification or withdrawal of consent or, if applicable, to better understand the reasons for a refusal of any of these requests.
Complaints to the Commission d’accès à l’information. If you are not satisfied with our response to your complaint or to one of your requests for access, rectification or withdrawal of consent, you may submit a written complaint to the Commission d’accès à l’information du Québec. To do so, please consult the Commission d’accès à l’information du Québec complaint form, available here: https ://www.cai.gouv.qc.ca/diffuson-de-linformation/services-et-formulaires/.
Possible changes. We may amend this policy from time to time in accordance with applicable law. We will notify you of any changes to this policy by indicating, at the beginning of the policy, the date of the most recent changes. If we have your e-mail address, we will also send you a notice identifying any changes to this policy.
Implied Consent to Changes. Your continued use of the Website or provision of personal information to us following the posting of changes to this policy constitutes implied consent to the changes to this policy, subject to the provisions of applicable law.
14. Beware of third-party websites
Limited Liability. Fuel Digital Media is not responsible for any information that may be collected, used, or communicated by any third-party web site you visit, and Fuel Digital Media expressly disclaims any liability related to such collection, use, communication, or retention by such third party.
15. Contact information for the Person in charge of the protection of personal information
Questions or comments. If you have any questions or comments about this Policy or our practices with respect to your Personal Information, you may contact Mr. John Sclapari, Privacy Officer by e-mail at privacy@fueldigitalmedia.com.