Website Privacy and Personal Information Protection Policy
1. General Information
a) Introduction
Protecting privacy is important to Service d’entretien Clean International Inc. and its affiliated entities (hereinafter referred to as the “Entity,” “We,” or “Our”). That’s why we have implemented safeguards and sound management practices to handle your Personal Information in accordance with applicable laws in Québec and Canada.
This Privacy Policy (the “Policy”), which must be read together with our Legal Notice, outlines our practices regarding the collection, use, processing, disclosure, and retention of Personal Information from our clients, visitors, and users. It applies to the Entity as a whole.
By using our website at https://www.cleaninternational.com/ (the “Website”) or any of our services, you agree that we may collect, use, process, disclose, and retain your Personal Information as described in this Policy. If you do not agree to be bound by this Policy, you are not authorized to visit, access, or use our Website or Services, nor to share your Personal Information with us.
This Policy does not apply to the Personal Information of the Entity’s employees, representatives, or consultants, or any other person affiliated with the Entity, nor to any information that does not qualify as Personal Information as defined under applicable Québec and Canadian laws.
b) Privacy Officer
Questions, comments, or complaints regarding this Policy and the Entity’s privacy practices may be directed to our Privacy Officer at the following coordinates:
Phone : 1-800-657-0928
Email : [email protected]
Address : 1006, rue Renault, Lévis (Québec) G6Z 2Y8
2. Definitions
The following words and expressions, when capitalized in this Policy, have the meanings assigned below, unless otherwise stated implicitly or explicitly in the text:
“Service Provider”: Any individual or legal entity that processes Personal Information on behalf of the Entity. This includes third-party companies or individuals employed by the Entity to facilitate the Services, provide the Services on behalf of the Entity, perform services related to the Services, or assist the Entity in analyzing the use of the Services.
“Personal Information”: Any information about an individual that allows them to be identified—that is, information that directly or indirectly reveals something about the person’s identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental abilities, personality, and behavior), or activities, regardless of the medium or form in which the information is accessible (written, graphic, audio, visual, computerized, or otherwise).
“Privacy Officer”: The person responsible for applying this Policy, whose contact details are provided in Section 1 of this Policy.
“Services”: Refers to the Website, our social media pages, and the services and products we offer.
3. Processing of Personal Information
3.1 Collection of Personal Information
As part of our operations, we may process various types of Personal Information, including the following:
- Contact details, such as your first and last name, email address, and phone number.
- Information related to products or services, such as details concerning the Services we have provided to you.
- Information you choose to provide or transmit to us, or communicate to one of our employees or representatives.
In all cases, this Personal Information is processed for the legitimate and necessary purposes outlined in Section 3.2 below.
3.2 Use of Personal Information
We may use your Personal Information for the following legitimate purposes:
- To operate, maintain, monitor, develop, enhance, and provide all functionalities of our Website.
- To present our Services to you.
- To fulfill our contractual obligations to you
- To send you messages, updates, and security alerts
- To respond to your inquiries and provide assistance as needed.
- To detect and prevent fraud, errors, spam, abuse, security incidents, and other harmful activities.
- For any other purpose permitted or required by law.
3.3 Disclosure of Personal Information
We may disclose your Personal Information to our employees (notably those in human resources and IT), contractors, consultants, agents, service providers, suppliers, and other trusted third parties (collectively, “Service Providers”) who require this information to help us operate our Website, conduct our business activities, or serve you—provided that these Service Providers have first agreed in writing to maintain the confidentiality of your Personal Information in accordance with applicable laws and our Information Governance Program.
We do not sell, trade, or otherwise disclose your Personal Information to third parties.
3.3.1 Service Providers and Other Third Parties
While we strive to minimize the sharing of your Personal Information with third parties, we may engage Service Providers to perform various services on our behalf—such as IT management and security, marketing, data analysis, hosting, and data storage. Below are examples of circumstances where such sharing may occur:
- We use the services of Algo Design for human resources management. Please refer to their privacy policy
- We use Facebook (Meta) to communicate about our services and products. Please refer to their privacy policy.
- We use LinkedIn for professional communications. Please refer to their privacy policy.
- We use Microsoft 365 to store documents. Please refer to their privacy policy.
- We use the services of Odoo for hosting our Website.
- We use Metatracer to ensure compliance with applicable privacy laws. Please refer to their privacy policy.
Before sharing your Personal Information with Service Providers located outside the province of Québec, or depending on the nature of the information being shared, we conduct a privacy impact assessment. We enter into written agreements with these Service Providers before disclosing any Personal Information and provide only the information necessary for them to fulfill their mandate.
These agreements ensure that the principles of this Policy are respected. Service Providers are required to treat Personal Information confidentially, follow our instructions, and use the information only for the intended purposes. We also ensure that appropriate safeguards are in place, proportionate to the sensitivity of the Personal Information processed or shared. Once our Service Providers no longer need your data, we require them to securely destroy it.
3.3.2 Compliance with Legislation, Response to Legal Requests, Prevention of Harm, and protection of Our Rights
We may disclose your Personal Information when we believe such disclosure is authorized, necessary, or appropriate, including in the following cases:
- To respond to requests from public and governmental authorities, including those outside your country of residence;
- To protect our operations;
- To comply with legal proceedings;
- To protect our rights, privacy, security, or property—and those of others, including you and third parties;
- To enable us to pursue available remedies or limit the damages we may sustain; and
- In accordance with applicable laws, including those outside your country of residence.
3.3.3 Business Transactions
We may share, transfer, or disclose your Personal Information, in strict compliance with this Policy and with the provisions of the Act Respecting the Protection of Personal Information in the Private Sector, CQLR c P-39.1 (the “Private Sector Act”), and the Act to Modernize Legislative Provisions Respecting the Protection of Personal Information, LQ 2021, c 25 (“Act 25,” assented to on September 22, 2021), in the event of a sale, transfer, or assignment, in whole or in part, of the Entity or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation, or any other business transaction, including during negotiations of such transactions). In such cases, we will inform you before your Personal Information is transferred and becomes subject to a different privacy policy.
3.4 Consent to the Use of Personal Information
Whenever possible, the Entity seeks to obtain consent directly from the individual concerned before collecting, using, or disclosing their Personal Information. However, if you provide us with Personal Information about other individuals, you are responsible for ensuring that they have been properly informed and that you have obtained their consent to such disclosure.
We will seek your express, explicit, free, and informed consent—provided for specific purposes—before using or disclosing your Personal Information for any purposes other than those described in this Policy. We will also obtain your explicit consent whenever sensitive Personal Information is involved in any of the Entity’s processing activities. Consent will be requested for each specific purpose in plain and clear language, and separately from other information communicated to you.
BY USING OUR WEBSITE OR TRANSMITTING YOUR PERSONAL INFORMATION BY EMAIL, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY.
If you do not consent, please stop using the Website. Unless otherwise provided by law, you may withdraw your consent at any time by providing reasonable notice. Please note that if you choose to withdraw your consent to the collection, use, or disclosure of your Personal Information, certain features of our Website may no longer be available to you, and we may no longer be able to provide you with some of our Services.
3.5 Retention of Personal Information
Subject to applicable laws, we retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, unless you consent to its use or processing for another purpose. As a reference, certain types of information may be retained for up to 7 years after the Entity has completed providing Services to you.
Additionally, our retention periods may be adjusted from time to time due to legitimate interests (for example, to ensure the security of Personal Information, prevent abuse or violations, or prosecute offenders).
For more information about how long your Personal Information is retained, please contact our Privacy Officer using the contact details provided in section 1b of this Policy.
4. Your Rights
As a data subject, you may exercise the rights listed below by contacting our Privacy Officer in writing, using the contact details provided in section 1b of this Policy. Please note that we may ask you to verify your identity before responding to any of these requests.
You have the right to:
- Be informed about the Personal Information we hold about you, including how it is used, disclosed, retained, and destroyed, subject to legal exceptions;
- Access your Personal Information and request a copy, including a paper copy of documents containing your Personal Information, subject to legal exceptions, and obtain additional details, where applicable, on how it is used, disclosed, retained, and destroyed;
- Request that we correct, modify, or update any Personal Information we hold about you if it is incomplete, ambiguous, outdated, or inaccurate;
- Withdraw or modify your consent to the collection, use, disclosure, or retention of your Personal Information at any time, subject to applicable legal and contractual restrictions;
- Request that we cease the dissemination of your Personal Information and de-index any link associated with your name that provides access to such information if its publication violates the law or a court order;
- Request that your Personal Information be communicated to you or transferred to another organization in a commonly used and structured digital format;
- Be informed of any privacy incident involving your Personal Information that may cause you serious harm. To that end, we maintain a registry of all privacy incidents and assess the potential harm they may cause;
- File a complaint with the Commission d’accès à l’information, subject to the conditions set out in applicable law.
To process your request, you may be asked to provide a valid form of identification or verify your identity in another manner.
5. Cookies and other tracking technologies
We use cookies and similar technologies (collectively, “Cookies”) to help operate, protect, and optimize our Website and the Services we offer. Cookies are small text files that are stored on your device or browser. They collect certain information during your visit to the Website, such as your preferred language, browser type and version, device type, and unique device identifier.
Some of the Cookies we use are deleted when you close your browser session, while others are retained on your device or browser to recognize your browser on your next visit to the Website. The data collected through these Cookies is not intended to identify you personally. Rather, it helps ensure the Website functions properly, enhances user navigation, provides insights into traffic and user interactions, and detects certain types of fraud. Cookies do not harm your device and cannot be used to extract your personal information.
You can configure your browser to notify you when Cookies are being placed during your visit, so that you can choose to accept or refuse them on a case-by-case basis, or block them entirely. Please note that disabling Cookies may affect your browsing experience and limit access to some of the Website’s features.
To learn more about how we use Cookies, please refer to our Cookie Policy.
6. Security Measures
The Entity has implemented physical, technological, and organizational security measures to adequately protect the confidentiality and security of your Personal Information against loss, theft, and unauthorized access, disclosure, reproduction, communication, use, or modification. These measures include:
Administrative safeguards, such as the adoption of various policies and procedures as part of our Information Governance Program, which:
- Govern access to, disclosure, retention, depersonalization (including anonymization), and, where applicable, the destruction of personal information;
- Define the roles and responsibilities of our employees throughout the lifecycle of Personal Information and related documents;
- Establish procedures for responding to and managing privacy incidents;
- Set out the process for handling requests and complaints related to the protection and processing of personal information.
Technical safeguards, such as:
- Use of a secure server. All sensitive information provided is transmitted using Secure Socket Layer (SSL) technology, then encrypted in our payment gateway providers’ databases, accessible only by authorized personnel with special access rights, who are required to keep the information confidential;
- Use of backup systems, network monitoring software, and more;
- Implementation of encryption systems, task segregation, access controls, and internal audits.
Please note that we do not publicly disclose all the security measures we use, in order to maintain their effectiveness.
Despite the measures described above, we cannot guarantee absolute security of your Personal Information. If you believe your Personal Information is no longer secure, please contact our Privacy Officer immediately using the contact information provided in section 1b above.
7. Changes to This Privacy Policy
We reserve the right to modify this Policy at any time, in accordance with applicable laws. If changes are made, we will publish the revised version of the Privacy Policy and update the revision date shown in its footer. We will also notify you by email at least thirty (30) days before the effective date of the new version of our Policy.
If you do not agree with the new terms of the Privacy Policy, we encourage you to stop using our Website and Services. Continued use of our Website or Services after the new version takes effect will indicate your acceptance of the updated Policy.
8. Individuals Under the Age of 14
We do not knowingly collect or use Personal Information from individuals under the age of 14. If you are under 14, you must not provide us with any Personal Information without the consent of your parent or legal guardian.
If you are a parent or guardian and you discover that your child has provided us with Personal Information without your consent, please contact us using the information provided in section 1b so that we may delete the child’s Personal Information from our systems.
9. Applicable Laws
This Policy is governed by the laws of Canada and the province of Québec, excluding their conflict of law rules. Your use of the Website may also be subject to other local, provincial, national, or international laws.