Privacy Policy

Context

INDUSTRIES ÉMILE LACHANCE LTÉE is a for‑profit legal entity governed by provincial law that processes personal information in the course of its activities.

This policy aims to ensure the protection of personal information and to govern the manner in which INDUSTRIES ÉMILE LACHANCE LTÉE collects, uses, discloses, retains, destroys, or otherwise manages such information. It also seeks to inform any interested person about how INDUSTRIES ÉMILE LACHANCE LTÉE handles their personal information. In addition, it covers the processing of personal information collected by INDUSTRIES ÉMILE LACHANCE LTÉE through technological means.
Scope and Definitions

This policy applies to INDUSTRIES ÉMILE LACHANCE LTÉE, including its officers, employees, consultants, volunteers, and any other person who, in any manner, provides services on behalf of INDUSTRIES ÉMILE LACHANCE LTÉE. It also applies to INDUSTRIES ÉMILE LACHANCE LTÉE’s website, as well as all websites controlled and maintained by INDUSTRIES ÉMILE LACHANCE LTÉE.

It covers all types of personal information managed by INDUSTRIES ÉMILE LACHANCE LTÉE, whether relating to its clients (current or potential), consultants, employees, members, or any other individuals (such as visitors to its websites or otherwise).

For the purposes of this policy, personal information refers to information about an identifiable individual, either directly or indirectly. For example, this may include a person’s name, address, email address, telephone number, gender, banking information, health information, ethnic origin, language, and so on.

Sensitive personal information refers to information for which there is a high reasonable expectation of privacy, such as health information, banking information, biometric data, sexual orientation, ethnic origin, political opinions, or religious or philosophical beliefs.

As a general rule, a person’s professional or business contact information does not constitute personal information—for example, an individual’s name, title, address, work email address, or work telephone number. More specifically, and for the sake of clarity, under Québec’s Act Respecting the Protection of Personal Information in the Private Sector, as of September 22, 2023, sections 3 (collection, use, disclosure), 4 (retention and destruction), and 6 (data security) do not apply to information relating to a person’s performance of duties within an enterprise, such as their name, title, position, and the address, email address, and telephone number of their workplace.

These same sections also do not apply to personal information that is public by law, effective as of the date this policy comes into force.
Collection, Use and Disclosure

Most of the services and products we offer, including access to our websites, require us to collect only a limited amount of data. In such cases, we will ask you to provide your name, a means of contacting you (such as a telephone number or email address), and, where applicable, a mailing address or another form of geolocation information related to the delivery of products or the performance of services.

If you subscribe to one of our newsletters or request to receive marketing materials and information about our products and services, we will need your name, an email address, and details about your interests so that we can provide you with relevant information. The same data will be required if you request additional information about our products and services at events or in “offline” situations such as trade shows, or if you contact us by telephone.

If you are a current or potential business partner, we collect basic information about the individuals with whom we communicate, such as their names, titles, and contact details.

If you apply for a position with INDUSTRIES ÉMILE LACHANCE LTÉE, we will collect the information you provide through our websites or otherwise, such as your résumé and any forms you may complete.

INDUSTRIES ÉMILE LACHANCE LTÉE will also inform individuals, at the time personal information is collected, of any additional information gathered, the purposes for which it is collected, and the means of collection, as well as any other information required by law.

INDUSTRIES ÉMILE LACHANCE LTÉE applies the following general principles regarding the collection, use, and disclosure of personal information:

Consent:
- As a general rule, INDUSTRIES ÉMILE LACHANCE LTÉE collects personal information directly from the individual concerned and with their consent, unless an exception is provided by law. Consent may be obtained implicitly in certain situations—for example, when an individual chooses to provide their personal information after having been informed, through this policy, of the purposes for which it will be used and disclosed. Accordingly, this policy and the information it contains may be consulted by the individual at the time personal information is collected.
- Normally, INDUSTRIES ÉMILE LACHANCE LTÉE must also obtain the individual’s consent before collecting their personal information from third parties, before disclosing it to third parties, or before using it for secondary purposes. However, INDUSTRIES ÉMILE LACHANCE LTÉE may act without consent in certain circumstances provided for by law and under the conditions set out therein. The main situations in which INDUSTRIES ÉMILE LACHANCE LTÉE may act without consent are described in the relevant sections of this policy.
Collection:
- In all cases, INDUSTRIES ÉMILE LACHANCE LTÉE collects information only when it has a valid reason to do so. Furthermore, collection is limited to the information necessary to fulfill the intended purpose.
- Please note that INDUSTRIES ÉMILE LACHANCE LTÉE’s services and programs are not intended for minors, and more generally, INDUSTRIES ÉMILE LACHANCE LTÉE does not intentionally obtain personal information about minors (in such cases, information may not be collected from a minor without the consent of a parent or guardian).
- Collection from third parties. INDUSTRIES ÉMILE LACHANCE LTÉE may collect personal information from third parties. Unless an exception is provided by law, INDUSTRIES ÉMILE LACHANCE LTÉE will seek the individual’s consent before collecting personal information about them from a third party. When such information is not collected directly from the individual but from another organization, the individual may request that INDUSTRIES ÉMILE LACHANCE LTÉE disclose the source of the information collected.
In certain situations, INDUSTRIES ÉMILE LACHANCE LTÉE may also collect personal information from third parties without the individual’s consent if it has a serious and legitimate interest in doing so and (a) the collection is in the individual’s interest and it is not possible to obtain the information from them in a timely manner, or (b) the collection is necessary to ensure the accuracy of the information.

Such third‑party collection may be necessary to access certain products or services, or otherwise conduct business with INDUSTRIES ÉMILE LACHANCE LTÉE. When required, INDUSTRIES ÉMILE LACHANCE LTÉE will obtain the individual’s consent at the appropriate time.

Retention and Use:
- INDUSTRIES ÉMILE LACHANCE LTÉE ensures that the information it holds is up to date and accurate at the time it is used to make a decision relating to the individual concerned.
- INDUSTRIES ÉMILE LACHANCE LTÉE may use an individual’s personal information only for the purposes set out in this policy or for any other purposes disclosed at the time of collection. If INDUSTRIES ÉMILE LACHANCE LTÉE wishes to use this information for a different purpose, new consent must be obtained from the individual, and such consent must be explicit if the information involved is sensitive personal information. However, in certain circumstances provided for by law, INDUSTRIES ÉMILE LACHANCE LTÉE may use personal information for secondary purposes without the individual’s consent, for example:
  - when such use is clearly for the benefit of the individual
  - when it is necessary to prevent or detect fraud
  - when it is necessary to assess or improve security and protection measures.
- Limited access. INDUSTRIES ÉMILE LACHANCE LTÉE must implement measures to restrict access to personal information solely to employees and individuals within its organization who are authorized to access it and for whom the information is necessary in the performance of their duties. INDUSTRIES ÉMILE LACHANCE LTÉE will obtain the individual’s consent before granting access to any other person.
Disclosure:
- Generally, and unless an exception set out in this policy or otherwise provided by law applies, INDUSTRIES ÉMILE LACHANCE LTÉE will obtain the individual’s consent before disclosing their personal information to a third party. Furthermore, when consent is required and the information involved is sensitive personal information, INDUSTRIES ÉMILE LACHANCE LTÉE must obtain the individual’s explicit consent before disclosing it.
- However, the disclosure of personal information to third parties is sometimes necessary. Personal information may therefore be disclosed to third parties without the individual’s consent in certain circumstances, including but not limited to the following:
  - INDUSTRIES ÉMILE LACHANCE LTÉE may disclose personal information, without the individual’s consent, to a public body (such as a government entity) that collects it through one of its representatives in the exercise of its functions or in the implementation of a program under its management.
  - Personal information may be disclosed to service providers to whom disclosure is necessary, and this may occur without the individual’s consent. For example, this includes subcontractors engaged by INDUSTRIES ÉMILE LACHANCE LTÉE to carry out authorized mandates, as well as cloud service providers.
  - If necessary for the completion of a commercial transaction, INDUSTRIES ÉMILE LACHANCE LTÉE may also disclose personal information, without the individual’s consent, to the other party to the transaction, subject to the conditions provided by law.
- Disclosure outside Québec : Personal information held by INDUSTRIES ÉMILE LACHANCE LTÉE may be disclosed outside Québec, for example when INDUSTRIES ÉMILE LACHANCE LTÉE uses cloud service providers whose servers are located outside the province, or when INDUSTRIES ÉMILE LACHANCE LTÉE works with subcontractors located outside Québec.
Additional Information on Technologies Used:
- Use of cookies: Cookies are data files transmitted to a website visitor’s computer by their web browser when they access the site, and they can serve several purposes.
Websites controlled by INDUSTRIES ÉMILE LACHANCE LTÉE use cookies in particular:
- to remember visitors’ settings and preferences, such as language selection, and to enable tracking of the current session
- for statistical purposes, to understand visitor behavior, the content viewed, and to support improvements to the website
Websites controlled by INDUSTRIES ÉMILE LACHANCE LTÉE use the following types of cookies:
- Session cookies: These are temporary cookies stored in memory only for the duration of the website visit.
- Persistent cookies: These remain stored on the computer until they expire and are retrieved during the next visit to the site.
- Use of Google Analytics
Some INDUSTRIES ÉMILE LACHANCE LTÉE websites use Google Analytics to support continuous improvement. Google Analytics helps analyze how visitors interact with a INDUSTRIES ÉMILE LACHANCE LTÉE website. It uses cookies to generate statistical reports on visitor behavior and the content viewed.

Information generated through Google Analytics will never be shared by INDUSTRIES ÉMILE LACHANCE LTÉE with third parties.
- Other technological tools used
INDUSTRIES ÉMILE LACHANCE LTÉE also collects personal information through technological means such as web forms integrated into a website controlled by INDUSTRIES ÉMILE LACHANCE LTÉE (for example, its contact form), as well as through other form platforms or tools (e.g., Microsoft Forms).
Retention and Destruction of Personal Information

Unless a minimum retention period is required by applicable law or regulation, INDUSTRIES ÉMILE LACHANCE LTÉE will retain personal information only for the period necessary to fulfill the purposes for which it was collected.

Personal information used by INDUSTRIES ÉMILE LACHANCE LTÉE to make a decision about an individual must be retained for at least one year following the decision, or for up to seven years after the end of the fiscal year in which the decision was made if it has tax implications—for example, circumstances related to the termination of employment.

At the end of the retention period, or when the personal information is no longer needed, INDUSTRIES ÉMILE LACHANCE LTÉE will ensure that it is either:
1. destroyed, or
2. anonymized (meaning it can no longer, in an irreversible manner, identify the individual, and it is no longer possible to establish a link between the individual and the personal information) so that it may be used for serious and legitimate purposes.
The destruction of personal information by INDUSTRIES ÉMILE LACHANCE LTÉE must be carried out securely to ensure the protection of such information.

This section may be supplemented by any policy or procedure adopted by INDUSTRIES ÉMILE LACHANCE LTÉE regarding the retention and destruction of personal information, where applicable. Please contact INDUSTRIES ÉMILE LACHANCE LTÉE’s Privacy Officer (identified in this policy) for more information.
Responsibilities of INDUSTRIES ÉMILE LACHANCE LTÉE

As a general rule, INDUSTRIES ÉMILE LACHANCE LTÉE is responsible for protecting the personal information it holds.

The Privacy Officer of INDUSTRIES ÉMILE LACHANCE LTÉE is the Operations Manager. This individual is generally responsible for ensuring compliance with applicable legislation governing the protection of personal information. The Privacy Officer must approve the policies and practices governing personal information management. More specifically, this person is responsible for implementing this policy and ensuring that it is known, understood, and applied. In the event of the Privacy Officer’s absence or inability to act, INDUSTRIES ÉMILE LACHANCE LTÉE’s Management Accountant will assume the responsibilities of the Privacy Officer.

Members of INDUSTRIES ÉMILE LACHANCE LTÉE’s staff who have access to personal information or who are otherwise involved in its management must ensure its protection and comply with this policy.

The roles and responsibilities of INDUSTRIES ÉMILE LACHANCE LTÉE employees throughout the personal information lifecycle may be further detailed in any other policy adopted by INDUSTRIES ÉMILE LACHANCE LTÉE for this purpose, where applicable.
Data Security

INDUSTRIES ÉMILE LACHANCE LTÉE is committed to implementing reasonable security measures to ensure the protection of the personal information it manages. The security measures in place correspond, among other factors, to the purpose, quantity, distribution, format, and sensitivity of the information. This means that information considered sensitive (see the definition in section 2) must be subject to stronger security measures and must be more rigorously protected. In particular, and in accordance with what was previously mentioned regarding limited access to personal information, INDUSTRIES ÉMILE LACHANCE LTÉE must implement the necessary measures to impose restrictions on the use rights of its information systems so that only employees who require access are authorized to access them.
Rights of Access, Rectification, and Withdrawal of Consent

To exercise their rights of access, rectification, or withdrawal of consent, the individual concerned must submit a written request to INDUSTRIES ÉMILE LACHANCE LTÉE’s Privacy Officer at the email address provided in the following section.

Subject to certain legal restrictions, individuals may request access to their personal information held by INDUSTRIES ÉMILE LACHANCE LTÉE and request that it be corrected if it is inaccurate, incomplete, or ambiguous. They may also require that the dissemination of personal information concerning them cease, or that any hyperlink attached to their name allowing access to such information through technological means be deindexed when the dissemination of that information contravenes the law or a court order. They may do the same—or require that the hyperlink be reindexed—when certain conditions provided by law are met.

INDUSTRIES ÉMILE LACHANCE LTÉE’s Privacy Officer must respond in writing to such requests within 30 days of receiving the request. Any refusal must be justified and accompanied by the legal provision supporting the refusal. In such cases, the response must indicate the remedies available under the law and the time limits for exercising them. The Privacy Officer must assist the requester in understanding the refusal if needed.

Subject to applicable legal and contractual restrictions, individuals may withdraw their consent to the disclosure or use of the information collected.

They may also ask INDUSTRIES ÉMILE LACHANCE LTÉE what personal information has been collected from them, which categories of individuals within INDUSTRIES ÉMILE LACHANCE LTÉE have access to it, and the applicable retention period.
Complaint Handling Process

Reception

Any individual who wishes to file a complaint regarding the application of this policy or, more generally, the protection of their personal information by INDUSTRIES ÉMILE LACHANCE LTÉE must do so in writing by contacting INDUSTRIES ÉMILE LACHANCE LTÉE’s Privacy Officer at the email address provided in the following section.

The individual must provide their name, contact information (including a telephone number), as well as the subject and reasons for their complaint, with sufficient detail to allow INDUSTRIES ÉMILE LACHANCE LTÉE to evaluate it. If the complaint is not sufficiently specific, the Privacy Officer may request any additional information deemed necessary to assess the complaint.

Processing

INDUSTRIES ÉMILE LACHANCE LTÉE is committed to handling all complaints confidentially.

Within 30 days of receiving the complaint—or within 30 days of receiving any additional information deemed necessary by INDUSTRIES ÉMILE LACHANCE LTÉE’s Privacy Officer to process it—the Privacy Officer must evaluate the complaint and provide a written, reasoned response by email to the complainant. This evaluation will determine whether INDUSTRIES ÉMILE LACHANCE LTÉE’s handling of personal information complies with this policy, with any other policies and practices in place within the organization, and with applicable legislation or regulations.

If the complaint cannot be processed within this timeframe, the complainant must be informed of the reasons for the delay, the status of the complaint’s review, and the reasonable additional time required to provide a final response.

INDUSTRIES ÉMILE LACHANCE LTÉE must maintain a separate file for each complaint it receives. Each file must contain the complaint, the analysis and supporting documentation for its evaluation, and the response sent to the individual who submitted the complaint.
Approval

This policy is approved by INDUSTRIES ÉMILE LACHANCE LTÉE’s Privacy Officer, whose business contact information is as follows:

Privacy Officer:

Louis Lachance, Operations Manager
424, route 279, Saint-Damien-de-Buckland, QC G0R 2Y0
Email : info@iel-lachance.com

For any request, question, or comment regarding this policy, please contact the Privacy Officer by email.
Publication and Amendments

This policy is published on INDUSTRIES ÉMILE LACHANCE LTÉE’s website, as well as on all websites controlled and maintained by INDUSTRIES ÉMILE LACHANCE LTÉE to which this policy applies, with respect to the personal information collected through those sites. This policy is also communicated by any means appropriate to reach the individuals concerned.

We reserve the right to update this Policy at any time. The most recent version of the Policy may be consulted by visiting our website. Your use of our website may also be subject to additional terms described in the Terms of Use and elsewhere on the site.

Notes : Please note that the use of the masculine gender is intended solely to simplify the text and facilitate reading.

A version of this text is available in English. However, the French version prevails in the event of any interpretive dispute.

Last updated: December 17, 2025