Privacy Policy

Privicy policy

Last update of this policy : October 9, 2025

Law 25 : An Act to modernize legislative provisions as regards the protection of personal information

Document link : https://www.cai.gouv.qc.ca/uploads/pdfs/CAI_LAI_Version_ADMIN.pdf?v=1707829153

Welcome on SADC-HS’s  web site  https://www.sadchs.qc.ca/, which includes all current and future subdomains and pages. 

Please note that SADC-HS is very concerned about protecting your privacy and the security of your personal information. For SADC-HS, complying with Act 25 is not only a legal requirement, but also a way to strengthen the trust of its members, Canada Economic Development (CED)  and partners. Please carefully review the policy and guidelines on access to information.   

In an increasingly connected and digitized world, the protection of personal information has become a major concern in Quebec. Consequently, the national parliament has responded to this need by updating its privacy laws with the Act to modernize legislative provisions  relating to personal information protection, better known as “Law 25”.  This one was adopted in September 2022. This Act is based on European regulations such as the General Data Protection Regulation (GDPR). 

A few définitions  :

Before to go ahead with the details, here are a few terms you should be familiar with when reading this Policy.​

Law 25: An Act Respecting the Protection of Personal Information of Quebec Citizens. 

This law aims to protect your personal information and privacy in the place where you live and/or work. This law requires organizations to verify the identity of requesters to make sure that the personal information transmitted belongs to the correct person. As well, including ensuring that it does not fall into the hands of unauthorized individuals or organizations without your consent. 

Personal Information : Is information that we collect from you, about you, or about third parties, which, alone or in combination with other data, can be used to identify an individual.  The equivalent European term is “personal data,” which is defined as “any information relating to an identified or identifiable natural person.”  This can be as simple as your name or email address, or something more complex such as an online identifier (usually a string of letters and/or numbers) that is associated with you.  

Any reference to “Personal Information” in this Policy also means personal data.​ 

1- Scope of Application 

This Privacy Policy (the “Policy”) applies to all personal information of service users and employees, including the SADC-HS website, where the organization may collect, use, or disclose personal information in the course of its activities. These include registration or sign-up forms, surveys, as well for job offers. 

2 – Agreement 

Your consent to the collection, use, and disclosure of your personal information may be given tacitly (by providing a valid ID card) or expressly, including in writing, verbally, or through technological means. When SADC-HS processes sensitive information (including credit checks), she will ask for your express or tacit consent in accordance with the law. You have the right to withdraw your consent to any potential collection, use, or disclosure at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  Furthermore, SADC-HS may no longer be able to respond to your requests, assist you with your project efforts, or even continue the project evaluation and hiring process for your application, as the case may be.If this is the case, it will inform you when you withdraw your consent. 

Note: In law, the term “tacit” generally refers to an agreement that is implied, not expressed by a yes or no but which confirms acceptance. 

3 –  Collection of personal information 

Personal information means any information that relates to an individual and allows that individual to be identified, directly or indirectly (section 2; 2021, c. 25, s. 102). 

The personal information covered by this Policy includes any information reasonably necessary to achieve the purposes described in section 4, and may include: 

– Your title, full name, and contact information, such as email address, phone number, mailing address, preferred language for communication, preferred means of communication, etc.; 

– Demographic data, including age, date of birth, and gender; 

– Transactional information, such as your choice of support services, your pre- and post-project follow-up appointments, your history of requests to SADC-HS, etc.; 

– Information relevant to your billing, including billing address, payment method, credit card number, and payment history. 

– Your credit rating (also known as credit score), collected from credit agencies. 

– Data relating to the use of SADC-HS services (including its website, applications, or other digital platforms that it makes or will make available to you), including the date, average time spent, number of visits, browsing history, and other analytical data on how you view its web page. This data is collected and stored by cookies and other similar technologies. 

– Preference data, which allows users to customize the behavior or display of certain features of our services. This data is collected and stored by cookies and other similar technologies.  

– Technical data, including your IP (Internet Protocol) address, geographic location, the Internet service provider you use, device ID, and other technologies on the devices you use that interact with the website, applications, or other digital services available now or in the future. This data may be collected and stored by cookies and other similar technologies. 

– Data related to social media accounts, including information associated with your social media accounts and associated profiles, such as name, username, email address, profile photo, date of birth, and gender; 

– If you apply for a job at SADC_HS, all information that may appear in a resume and in any other relevant documentation or correspondence produced or communicated as part of the recruitment process. 

4. Use of personal information (section 2, paragraph 4)

SADC-HS uses personal information for various relevant purposes in order to provide services within the framework of its activities, including support for financing projects and technical assistance to organizations, cooperatives (COOPs), Non-Profit Organizations (NPOs), individuals or any other legal form, but only to the extent reasonably necessary to achieve these objectives and within the limits of the law. 

In particular, SADC-HS uses your personal information for the following purposes: 

– To respond to your communications, if applicable, including any requests for services or information, and any complaints; 

– To provide you with the services you choose, bill you for them, and collect payment if necessary; 

– To validate your identity when reasonably necessary and ensure that your information is accurate and up to date; 

– To verify your eligibility for a support service you request. 

– To conduct analyses, surveys, or request your feedback in order to better understand the needs and preferences of our customers and the market; 

-To improve our services or develop new ones; 

-To better understand your needs, interests, and habits and offer you services that may be of interest to you, or to personalize your experience with our services, particularly with regard to their content and related recommendations. 

-To remember and apply your preferences as a service user; 

-To improve our services or develop new ones; 

-To maintain our business relationship with you and to manage our activities responsibly and in compliance with the law; 

-To detect, eliminate, or prevent fraud or any other illegal activity; 

-To secure and ensure the proper functioning of he’s services (including her website, applications, and other digital services that she owner or may own in the future) and her information assets (including our databases, servers, and networks);​ 

-To ensure compliance with her terms of service and to enforce them when necessary, including to assert her rights and defend her legitimate interests;​ 

5. Job Applications 

By submitting your application for a job at SADC-HS, your personal information will be used for the purposes of the evaluation and hiring process, if applicable (see article 3.4 – 2021, c. 25, a. 103 for more information on this subject); 

-To comply with its legal obligations and regulatory requirements, such as collecting, creating, and inferring various personal information about you. This includes all information that may appear in a resume and in any other relevant documentation or correspondence produced or communicated as part of the recruitment process, such as: 

-Identification information, such as name, address, phone number, email address, etc. 

-Professional information, such as employment history, job titles, responsibilities, achievements, and professional references.

-Academic information, e.g., degrees, certificates, transcripts, and other educational qualifications. 

-Relevant demographic information, e.g., date of birth, nationality, residency status, and other demographic information. 

-Financial information, such as current and expected salary, benefits, and other types of compensation. 

-Verification information, such as reference check results, background checks, and work permits. 

-Performance information, such as skill assessments, skill test results, and other performance evaluations. 

-Documentation relevant to the application file, such as cover letters, application forms, and answers to interview questions, correspondence, interview notes, and other communications related to the recruitment process, etc. 

-This information is collected and used for the purpose of evaluating your application, verifying your qualifications, and making informed recruitment decisions. 

-SADC-HS committed to protecting the confidentiality and security of your personal information throughout the recruitment process in the same way as any other personal information covered by this Policy. 

6. Disclosure of Personal Information

SADC-HS may disclose your personal information to third parties (financial partners, Economic Development Canada, financial auditors) with your tacit or express consent or as permitted or required by law, including in the following circumstances: 

 -To any person authorized to act as your agent, upon reasonable verification; 

-To a credit reporting agency to assess your credit worthiness; 

-To collection agencies for the collection of overdue invoices appearing on your account; 

– To competent courts, law enforcement agencies, and other persons or entities responsible for enforcing the law or otherwise authorized by law to collect or compel the disclosure of such information,  including for investigative or judicial purposes. For example, SADC-HS can be compelled to disclose personal information in response to a search warrant, subpoena, or court order in accordance with the law. 

– SADC-HS can also disclose personal information when necessary to assert our rights and exercise legal claims or to assert a defense against such claims,  to prevent actual or alleged losses or to avoid bodily injury or property damage. 

-In the event of a merger with another entity. In such a case, SADC-HS can transfer your personal information to a third party for the purposes of the commercial transaction in question,  subject to applying the safeguards required by law in such contexts. 

– In cases where you have already given your consent to the disclosure to the third-party recipient, a financial institution, an insurance company, a social network, or any other technology service provider that you authorize to process your personal information);​ 

-To comply with our legal obligations and regulatory requirements;​ 

7. Transfer of personal information outside Quebec/Canada​

SADC-HS aims to expand her business customers by collaborating with economic actors outside its area of ​​influence on circular economy and carbon credit projects. 

As such, your personal information may be stored and processed in Quebec or other Canadian provinces. In some cases, it may also be transferred and hosted outside Quebec or Canada.In some cases, it may also be transferred and hosted outside Quebec or Canada.  

Where applicable, we will take all reasonable measures to ensure that the personal information transferred is adequately protected in accordance with applicable legislation.  

Please note that your personal information may be subject to the laws of the countries or territories to which it is transferred. 

8. Retention and Destruction of Personal Information

SADC-HS will only retain personal information for as long as is reasonably necessary to fulfill the purposes for which it was collected and used, as described in this Policy or disclosed to you at the time of collection.  

Subject to any longer retention period required by law or for legitimate legal or business purposes to the extent permitted by law. For example, SADC-HS can retain some of your personal information, even after you are no longer a customer, for tax and financial record-keeping purposes, for security or fraud prevention reasons.  

When this information is no longer needed, it is destroyed, de-identified, or anonymized in accordance with applicable legal requirements. 

9. Protection of personal information

SADC-HS implements administrative, technical, and physical security measures to protect the confidentiality, integrity, and availability of the personal information it manages. 

These measures are designed to prevent unauthorized access, use, modification, disclosure, or destruction, loss, and any other breach of the protection of this personal information. They also apply when SADC-HS destroys your personal information. 

In addition, SADC-HS grants access to your personal information to his employees, agents, subcontractors, and suppliers only on a strict need-to-know basis in order to fulfill the specific roles and functions we have assigned to them.  

SADC-HS educates and trains its employees on the protection of personal information. 

Your personal information is disclosed to third parties (financial partners, Economic Development Canada, financial auditors), including our agents and suppliers, and is protected by the contracts it has entered into with them. 

Employees’s SADC-HS, as well as her collaborators whom we call upon to achieve the objectives described in this Policy, are ALL required to keep your personal information confidential in accordance with best practices and to destroy it securely in accordance with Section 9 of this Policy. 

Please note that the security of your information is also your responsibility. You shout be responsible for keeping your passwords safe. The SADC-HS recommends that you do not share them and do not use the same password for multiple accounts.  In addition, she advise you not to disclose personal information in public or semi-private areas of the website, such as comment sections and discussion forums, which other people can view. 

In the event of a breach of your personal information, such as unauthorized access, use, or disclosure, or loss,SADC-HS has  policies and processes in place to contain the incident and restore the security of our information systems, investigate the causes, and review our protective measures to improve them as necessary and prevent similar incidents in the future. In addition, SADC-HS complies  with all applicable requirements for notification to you and the relevant authorities.  

Where appropriate, SADC-HS will provide you with the information you need to understand the significance of the situation and take the necessary steps to reduce the risk of harm that may result. 

10. Access and correction rights ( c. 25, s. 123.)​

You may request  that SADC-HS provide you with  a copy of the personal information it holds about you and correct any information that is incomplete, inaccurate, ambiguous, or outdated, subject to the exceptions and conditions applicable under the law.   To the extent possible, SADC-HS will provide you or a third party of your choice with the computerized personal information it has collected from you and that is covered by your request in a structured and commonly used technological format. To exercise any of the above rights or any other rights conferred on you by law, you must contact the manager of SADC-HS, Ms. Valérie Dubé, in writing. She will respond in writing to all legitimate requests within 30 days of receipt (c. 25, s. 124.).  If she could not unable to comply with your request, she will explain her decision and inform you of the remedies available to you, as well as the time limits within which you must act. 

11. Changes to this Policy

This Policy may be amended at any time to reflect changes in applicable laws or in our practices regarding the processing and protection of personal information. SADC-HS will post any updates on its website and will take reasonable steps to notify you, whether by notice on our website, by email, by text message, on your invoice, or by other means.

12. To contact us

If you have any questions, comments, requests, or complaints regarding this Policy and the protection of your personal information, please contact Ms. Valérie Dubé, Senior Director of SADC-HS, either by: 

Phone : ​ Office  : 418-672-6333, poste 2​ 

By mail : vdube@sadchs.qc.ca ​  

To the attention of  : Mme Valérie Dubé​ 

340, rue Gagnon, Saint-Ambroise, QC, G7P 2R1​