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Privacy Policy
Version 1.1 (March 24, 2025)
Preamble
This usage policy applies to all stakeholders accessing or using the websites of Kezber & Associates Inc. or its affiliated entities, including Netlinux (9333-7806 Québec Inc.). To simplify reading, the term “Kezber” will be used to refer to all of these entities.
Kezber collects, uses, discloses, and retains various types of personal information, in accordance with the Civil Code of Québec and the Act Respecting the Protection of Personal Information in the Private Sector.
1-Application
This policy applies to all confidential and personal information collected by Kezber, in accordance with the Act Respecting the Protection of Personal Information in the Private Sector, as well as any other applicable law or regulation.
In this policy, the terms “we,” “our,” and “us” refer to Kezber, including its head office.
This policy does not apply to information relating to legal persons or of public nature, that is, known to the public and accessible by legal means, as this type of information is not covered by the law.
2-Objectives
Through this policy, Kezber aims to describe its practices in the handling of personal information concerning its employees, website visitors, and individuals who communicate with us through various means of communication (telephone, internet, email, fax, or others).
This policy aims to:
-Protect the personal information of the public and our employees;
-Guide staff on Kezber’s practices regarding the handling of personal information.
3-What is personal information?
Personal information refers to data about a natural person that allows them to be identified, such as their name, address, date of birth, and social insurance number.
Sensitive personal information, such as medical, intimate, or financial data, is considered sensitive due to the high degree of reasonable expectation of privacy it carries.
We treat all forms of personal information the same way—that is, with the highest level of confidentiality, without discrimination as to their source or sensitivity.
4-Kezber’s commitment to confidentiality
Kezber is committed to respecting the privacy and personal information of its clients, employees, and anyone who communicates with us. To this end, Kezber undertakes to take all necessary measures to preserve the confidentiality of the personal information it possesses.
More specifically, Kezber commits to:
-Training its staff in the protection of personal information;
-Assessing privacy risks;
-Implementing all necessary means to protect personal information;
-Obtaining individuals’ consent when required;
-In the event of a privacy incident, recording the incident, notifying affected persons if needed, investigating the incident’s circumstances, and taking the necessary steps to prevent recurrence;
-Responding promptly to questions, requests, and complaints regarding personal information and its protection.
5-Privacy incident
A privacy incident is any unauthorized access, use, or disclosure of personal information, as well as the loss of personal information or any other breach of the protection of such information.
In accordance with the law, Kezber has implemented all measures deemed necessary to prevent such incidents and has prepared a response plan in case of a privacy incident.
In the case of a privacy incident where the level of risk of harm to personal information is deemed serious, notice will be sent to the Commission d’accès à l’information and the concerned individual will be promptly notified.
We also maintain a register in which all privacy incidents are recorded.
6-Transparency
a. We are committed to providing and explaining to anyone who requests it:
The purposes of data collection;
The means used for collection;
Their rights to access and rectify that data;
Their right to withdraw consent to our data collection.
b. When needed, we will provide:
The names of third parties or categories of third parties for whom the data is collected;
The names of third parties to whom it is necessary to disclose the information;
An explanation about the possibility of the data being disclosed outside of Québec.
c. Upon request, we also inform them of:
The personal information collected about them;
The categories of persons who have access to that information within the organization;
The retention period for that information;
The contact information of the privacy officer.
d. Upon request, we will transmit all collected information concerning them in simple and clear language.
Kezber does not use any automated personal information processing systems, and therefore no decisions are based on such systems.
7-Identification, location, and profiling
Kezber uses technologies to automatically profile users of its website. When a user visits the website, Kezber automatically collects certain information about the device used, including web browser, IP address, time zone, and installs certain cookies on the device. Additionally, when a user navigates the website, Kezber collects information on the web pages or products viewed, on websites or search terms that referred the user to our website, and on how the user interacts with the site.
8-Consent
Since September 22, 2023, new rules govern consent for the collection, communication, or use of personal information:
Consent must be obtained for each of these purposes, in simple and clear terms.
When we present a written request for consent, it will be distinct from any other information provided.
Except where otherwise provided, we may not use personal information for a purpose other than that set out in the consent.
Express consent must be obtained before using sensitive personal information for a purpose different from that intended at the time of collection.
However, under the law, your consent is not required when we use your personal information as part of the mandate assigned to us, for completing a commercial transaction, for the provision of services you have requested, or when its use is clearly for your benefit.
9-Personal information collection
a. Automatic collection
As mentioned in section 7, Kezber automatically collects information about users of its website.
b. Information collected
Here is the list of personal information collected by Kezber:
Clients
Kezber collects no personal information about its clients, as they are all legal persons (companies) and thus not subject to the law.
Website visitors
-Web browser information;
-IP address;
-Time zone;
-Information on viewed web pages or products;
-Information on referring websites or search terms;
-Information on how the user interacts with our website.
Recruitment (via website forms or others)
-First name;
-Last name;
-Email address;
-Phone number;
-Information on the resume;
-Information on the cover letter;
-Any other personal information provided in the application;
-Any other personal information provided in a recruitment file submitted by a third party, if applicable.
10-Digital cookies
When you visit the site, we automatically collect certain information about your device, including your web browser, IP address, time zone, and some of the cookies installed on your device. Additionally, as you browse the site, we collect information on the web pages or products you view, the websites or search terms that referred you to the site, and how you interact with the site. We refer to this automatically collected information as “device information”.
We collect device information using the following technologies:
a. “Cookies” are data files placed on your device or computer and often include an anonymous unique identifier. To learn more about cookies and how to disable them, visit https://www.allaboutcookies.org/fr/;
b. “Log files” track actions occurring on the site and collect data including your IP address, browser type, internet service provider, referring and exit pages, and date/time stamps;
c. “Web beacons,” “tags,” and “pixels” are electronic files used to record information on how you browse the site.
11-Use of personal information
The information collected is used to:
Website visitors
-Automatically profile users of our website.
Recruitment
-Communicate with the applicant.
12-Disclosure and sharing of personal information
Personal information in our possession will never be disclosed to third parties without the prior express consent of the person concerned, except by court order, legal obligation, or in accordance with the law.
Furthermore, we share your personal information with third parties to help us use your personal data, as described in section 7. Kezber has clients with online stores on its servers, which are also subject to the Act Respecting the Protection of Personal Information in the Private Sector.
We may also use Google Analytics to help us understand how website visitors use the site.
However, an individual’s consent is not required when we use their personal information in the context of an assigned mandate, a commercial transaction, the provision of services requested, or when its use is clearly for their benefit.
13-Retention and security of personal information
We retain personal information only for as long as necessary and in accordance with our legal obligations. Information may be stored in paper or digital formats, but not necessarily both.
All digital personal information we retain is stored on secure cloud/local servers.
Our entire local network is protected by passwords, a modern and up-to-date firewall, and up-to-date antivirus software. Backups are performed daily to a third-party cloud system. Data stored in this service is password protected and encrypted during both transmission and storage.
Physical servers are located in a locked room with a smart card system.
Finally, we also use the SharePoint platform for digital document sharing.
14-Destruction of personal information
Personal information is destroyed when the purposes for which it was collected or used are fulfilled, subject to any retention period required by law.
More specifically, Kezber has a personal information retention and destruction policy that specifies the type of personal information and the associated destruction timeframe. Kezber invites you to consult this policy for more details.
Digital personal information is destroyed when deleted from all our servers, computers, mobile devices, storage devices, and backup copies.
Any physical document containing personal information will be destroyed by shredding.
Any storage device containing personal and/or confidential information will be destroyed internally by shredding or by a specialized third-party company.
15-Privacy settings of technology products and services
The only technology product or service we offer to the public is our website. This site collects personal information, but we ensure that, by default, our website offers the highest possible level of privacy.
As for data sharing services, we use SharePoint. This platform is encrypted both during data transmission and storage. We share information only with the concerned individuals, who are the only ones with access. This access is protected by a unique password. This represents the highest level of confidentiality possible on this platform.
16-Right to de-indexing
Any person may request that their personal information no longer be published or that any hyperlink related to such information be de-indexed.
However, Kezber does not publish personal information nor associate personal information with hyperlinks.
17-Disclosure of personal information outside Québec
In accordance with the law, before disclosing personal information outside Québec, a privacy impact assessment will be conducted.
If the assessment demonstrates that the information will benefit from adequate protection, it may be transmitted, subject to a written confidentiality agreement with the person(s) to whom the information will be transmitted, in accordance with the law.
18-Disclosure of personal information to facilitate the grieving process
As of September 22, 2023, the law authorizes us to disclose a deceased person’s personal information to their spouse or a close relative if this information is likely to assist that person in the grieving process, unless the deceased had provided written refusal of this right of access.
19-Collection of personal information about a minor under the age of 14
Personal information about a minor under the age of 14 is never collected from the minor without the consent of the holder of parental authority or the guardian, unless the collection is clearly for the benefit of the minor.
20-Access, roles and responsibilities of staff members
All Kezber staff members are responsible for maintaining the security and confidentiality of personal information in our possession throughout the entire lifecycle of that information. Access to employee personal information is restricted to management, human resources, and accounting staff.
In addition, staff members who have access to personal information are bound by a confidentiality agreement requiring them to respect the confidentiality of the personal information to which they have access.
The person responsible for the protection of personal information, who ensures that Kezber complies with and implements the applicable principles under the Act Respecting the Protection of Personal Information in the Private Sector, must:
-Identify and implement the policies and practices governing Kezber’s methods in terms of personal information protection;
-Ensure that Kezber has implemented and approved policies and practices for the retention and destruction of personal information;
-Define and approve the roles and responsibilities of staff members throughout the lifecycle of personal information;
-Define and approve a complaint handling process regarding personal information protection;
-Be consulted from the beginning of any development or redesign project involving information systems or electronic service delivery involving the collection, use, disclosure, retention, or destruction of personal information, with respect to the privacy impact assessment of any acquisition project;
-Be proactive at every stage of implementing a system acquisition, development or redesign project or electronic service delivery within Kezber in order to suggest, where appropriate, measures for personal information protection and related frameworks according to the requirements of the Act;
-Record communications when an incident poses a risk of serious harm and a Kezber person must notify any person or organization likely to reduce the risk, disclosing only the necessary personal information;
-Be consulted when a Kezber person assesses the risk that harm may be caused to a person whose personal information is involved in a confidentiality incident;
-In the exercise of a mandate, be notified of any violation or attempted violation by anyone of any of the confidentiality obligations relating to the disclosed information and carry out any verification regarding this confidentiality;
-Certify in writing the cessation of disclosure of the personal information or the de-indexing or re-indexing of the hyperlink;
-Respond in writing to any access or correction request, promptly and within the timeframe set by the Act Respecting the Protection of Personal Information in the Private Sector;
-Assist in identifying requested personal information;
-Be involved in managing a privacy incident using the applicable policies;
-Establish a process for handling complaints related to personal information protection.
In this case, the person designated for this role is Mr. Alan Kezber, President.
21-Portability of personal information
Any person has the right to request that a copy of their computerized personal information collected from them be provided, unless the request raises serious practical difficulties. This personal information will be sent to you within 30 days in a structured, commonly used technological format. We may also, upon your request, disclose this personal information to any person or organization authorized by law.
22-Complaint process
If you wish to send us your questions or comments regarding this policy or its application, please contact the person responsible for the protection of personal information.
If you wish to file a complaint, you may contact the Commission d’accès à l’information du Québec by clicking the following link: https://www.cai.gouv.qc.ca/a-propos/nous-joindre.
However, we invite you to first contact Kezber’s privacy officer.
23-Modification of this policy
We reserve the right to modify this policy at any time. We will inform you of changes by indicating the date of the last update at the beginning of this policy. You are responsible for reviewing it in a timely manner to check for changes.
We strongly recommend that you read this policy to fully understand how your information will be used. Any modifications to this policy will apply to personal information collected before the effective date of the modified version, as well as to those collected on or after that date.
24-Person responsible for the protection of personal information
Alan Kezber
President
817, rue Principale Ouest, suite 400
Magog (Québec) J1X 2B4
Kezber © 2025 - All rights reserved by Signé François Roy.
