Personal information protection policy and confidentiality policy

1. Context

Complexe funeraire Lachance inc.is a company incorporated in Quebec that processes personal information as part of its activities.

This policy aims to ensure the protection of personal information and to govern the way in which Complexe funeraire Lachance inc. collects, uses, communicates, stores and destroys them or otherwise manages them. In addition, it aims to inform anyone interested on how Complexe funeraire Lachance inc. processes their personal information. It also covers the processing of personal information collected by Complexe funeraire Lachance inc. by technological means.

1. Application and definitions

This policy applies to Complexe funeraire Lachance inc., which includes in particular its directors, employees, consultants, volunteers, as well as to any person who otherwise provides services on behalf of Complexe funeraire Lachance inc.. It It also applies to the website of Complexe funeraire Lachance inc., as well as all websites controlled and maintained by Complexe funeraire Lachance inc..

It covers all types of personal information managed by Complexe funeraire Lachance inc., whether it is the information of its clients, potential or current, its consultants, its employees, its members or any other persons (such as visitors to its websites or other).

For the purposes of this document, personal information is information which concerns a natural person and which allows, directly or indirectly, to identify them. For example, this could be a person’s name, address, email address, telephone number, gender or banking information, health information, ethnic origin, language , etc.

Sensitive personal information is information for which there is a high degree of reasonable expectation of privacy, e.g. ex. health information, banking information, biometric information, sexual orientation, ethnic origin, political opinions, religious or philosophical beliefs, etc.

Generally speaking, an individual’s professional or business contact information does not constitute personal information, for example an individual’s name, title, address, email address or work telephone number. More particularly and for the sake of precision, within the meaning of the Act respecting the protection of personal information in the private sector of Quebec, and as of September 22, 2023, sections 3 (collection, use, communication), 4 (conservation and destruction ) and 6 (data security) do not apply to information about a person relating to the exercise of a function in a company, such as their name, title, function, as well as address, l email address and workplace telephone number.

These same paragraphs also do not apply to personal information that has a public nature under the law, as soon as this policy comes into force.

1. Collection, use and communication

As part of its activities, Complexe funeraire Lachance inc. may collect different types of information for different purposes. The types of information that Complexe funeraire Lachance inc. could collect, their use (or intended purpose) as well as the means by which the information is collected are indicated in Appendix A of this policy.

Complexe funeraire Lachance inc. will also inform the individuals concerned, at the time of collecting personal information, of any other information collected, the purposes for which it is collected and the means of collection, in addition to other information to be provided as required by law.

Complexe funeraire Lachance inc. applies the following general principles regarding the collection, use and disclosure of personal information:

Consent:

• Generally speaking, Complexe funeraire Lachance inc. collects personal information directly from the person concerned and with their consent, unless an exception is provided for by law. Consent may be obtained implicitly in certain situations, for example, when the individual decides to provide their personal information after having been informed by this policy on the use and communication for the purposes indicated therein (see Appendix See for more details). Thus, this policy and the information it contains may be consulted by the person concerned at the time of collection of personal information.
• Normally, Complexe funeraire Lachance inc. must also obtain the consent of the data subject before collecting their personal information from third parties, before communicating it to third parties or for any secondary use thereof. However, Complexe funeraire Lachance inc. may act without consent in certain cases provided for by law and under the conditions provided for therein. The main situations where Complexe funeraire Lachance inc. may act without consent are set out in the relevant sections of this policy.

Collection:

• In all cases, Complexe funeraire Lachance inc. only collects information if it has a valid reason to do so. Furthermore, the collection will only be limited to the necessary information needed to fulfill the intended purpose.
• Please note that the services and programs of Complexe funeraire Lachance inc. do not target minors, and more generally, Complexe funeraire Lachance inc. does not intentionally obtain personal information from minors (in these cases, information cannot be collected from them without the consent of a parent or guardian).
• Collection from third parties. Complexe funeraire Lachance inc. may collect personal information from third parties. Unless there is an exception provided for by law, Complexe funeraire Lachance inc. will request the consent of the person concerned before collecting personal information concerning them from a third party. In the event that such information is not collected directly from the person, but from another organization, the person concerned may request the source of the information collected from Complexe funeraire Lachance inc..

In certain situations, Complexe funeraire Lachance inc. may also collect personal information from third parties, without the consent of the person concerned, if he or she has a serious and legitimate interest in doing so and a) if the collection is in the interest of the person and it is not not possible to do so with them in a timely manner, or b) if this collection is necessary to ensure that the information is accurate.

Also, Complexe funeraire Lachance inc. may collect personal information indirectly, notably by using:

• Clover. Clover has its owntermsand itsown privacy policy, which can be consulted for more information.
• Global payments. Global payments has its owntermsand of his ownPrivacy Policy, which can be consulted for more information.
• Stripe.Stripe has its ownterms and privacy policy, which can be consulted for more information.

This collection through third parties may be necessary to use certain services or programs, or to otherwise do business with Complexe Funeraire Lachance inc. When required, Complexe Funeraire Lachance inc. will obtain the consent of the person at the appropriate time.

Possession and use:

• Complexe funeraire Lachance inc. ensures that the information it holds is up to date and accurate when it is used to make a decision relating to the person concerned.
• Complexe funeraire Lachance inc. may only use an individual’s personal information for the reasons stated herein or for any other reasons provided at the time of collection. As soon as Complexe funeraire Lachance inc. wants to use this information for another reason or another purpose, new consent must be obtained from the person concerned, which must be obtained expressly if it concerns sensitive personal information. However, in certain cases provided for by law, Complexe funeraire Lachance inc. may use the information for secondary purposes without the individual’s consent, e.g. ex. :
  • when this use is clearly for the benefit of that person;
  • when necessary to prevent or detect fraud;
  • when necessary to evaluate or improve protection and security measures.
• Limited access. Complexe funeraire Lachance inc. must put in place measures to limit access to personal information only to employees and persons within its organization who have the authority to read it and for whom this information is necessary in the performance of their duties. Complexe funeraire Lachance inc. will seek the individual’s consent before granting access to any other person.

Communication:

• Generally, and unless an exception indicated in this policy or otherwise provided for by law, Complexe funeraire Lachance inc. will obtain the consent of the person concerned before communicating their personal information to a third party. In addition, when consent is necessary and when sensitive personal information is involved, Complexe funeraire Lachance inc. must obtain the explicit consent of the person before communicating the information.
• However, the communication of personal information to third parties is sometimes necessary. Thus, personal information may be communicated to third parties without the consent of the person concerned in certain cases, in particular, but not exclusively, in the following cases:
  • Complexe funeraire Lachance inc. may communicate personal information, without the consent of the person concerned, to a public body (such as the government) which, through one of its representatives, collects it in the exercise of its responsibilities or the implementation of a program whose he has the management.

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• • Personal information may be transmitted to its service providers to whom it is necessary to communicate the information, without the consent of the person. For example, these service providers may be event organizers, subcontractors of Complexe funeraire Lachance inc. designated for the execution of mandates in the programs administered by Complexe funeraire Lachance inc. and cloud service providers. In these cases, Complexe funeraire Lachance inc. must have written contracts with these suppliers which indicate the measures they must take to ensure the confidentiality of the personal information communicated, that the use of this information is made only within the framework of the execution of the contract and that they cannot retain this information after its expiration. In addition, these contracts must provide that suppliers must notify the person responsible for the protection of personal information at Complexe Funeraire Lachance inc. (indicated in this policy) of any violation or attempted violation of the confidentiality obligations concerning the personal information communicated and must allow this manager to carry out any verification relating to this confidentiality.

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• • If this is necessary for the purposes of concluding a commercial transaction, Complexe funeraire Lachance inc. could also communicate personal information, without the consent of the person concerned, to the other party of the transaction and subject to the conditions provided for by law.

• Communication outside Quebec: It is possible that personal information held by Complexe funeraire Lachance inc. be communicated outside Quebec, for example, when Complexe funeraire Lachance inc. uses cloud service providers whose server(s) are located outside Quebec or when Complexe funeraire Lachance inc. deals with subcontractors located outside the province.

Additional information on the technologies used:

• Use of cookies
  Cookies are data files transmitted to a website visitor’s computer by their Web browser when they visit that site and can serve several purposes.

The websites controlled by Complexe funeraire Lachance inc. use cookies in particular:

• To memorize visitor settings and preferences, for example for the choice of language and to allow monitoring of the current session.
• For statistical purposes to know the behavior of visitors, the content consulted and to enable the improvement of the website.

The websites controlled by Complexe funeraire Lachance inc. use the following types of cookies:

• Session cookies: These are temporary cookies that are stored in memory for the duration of the website visit only.
• Persistent cookies: They are kept on the computer until they expire and they will be retrieved the next time you visit the site.

Certain connection cookies may be deactivated by default and visitors may choose to activate these functions or not, when consulting the websites of Complexe funeraire Lachance inc..

It is also possible to activate and deactivate the use of cookies by changing the preferences in the settings of the browser used.

• Use of Google Analytics

All sites under the control of Complexe funeraire Lachance inc. use Google Analytics to enable continuous improvement. Google Analytics makes it possible, in particular, to analyze the way in which a visitor interacts with a Complexe funeraire Lachance inc. website. Google Analytics uses cookies to generate statistical reports on the behavior of visitors to these websites and the content consulted.

Information from Google Analytics will never be shared by Complexe funeraire Lachance inc. to third parties.

It is possible to install abrowser add-on to disable Google Analytics.

• Other technological means used

Complexe funeraire Lachance inc. also collects personal information through technological means such as web forms integrated into a website controlled by Complexe funeraire Lachance inc. (for example, its contact form, its membership form to become a member, its form to register for the newsletter and seminars), questionnaires accessible online on its platforms and applications, as well as other Forms platforms or tools (e.g. Microsoft Forms).

If Complexe funeraire Lachance inc. collects personal information by offering a technological product or service that has confidentiality settings, Complexe funeraire Lachance inc. must ensure that these settings provide the highest level of privacy by default (cookies are not affected).

1. Retention and destruction of personal information

Unless a minimum retention period is required by applicable law or regulation, Complexe funeraire Lachance inc. will only retain personal information for as long as necessary to achieve the purposes for which it was collected.

Personal information used by Complexe funeraire Lachance inc. to take a decision relating to a person must be kept for a period of at least one year following the decision in question or even seven years after the end of the tax year in which the decision was taken if it has implications tax, for example, the circumstances of an end of employment.

At the end of the retention period or when the personal information is no longer necessary, Complexe funeraire Lachance inc. will ensure:

1. to destroy them; Or
2. to anonymize them (i.e. they no longer irreversibly allow the person to be identified and it is no longer possible to establish a link between the person and the personal information) to use them for serious and legitimate purposes.

The destruction of information by Complexe funeraire Lachance inc. must be done securely to ensure the protection of this information.

This section may be supplemented by any policy or procedure adopted by Complexe funeraire Lachance inc. concerning the retention and destruction of personal information, where applicable. Please contact the person responsible for the protection of personal information at Complexe funeraire Lachance inc. (indicated in this policy) for more information.

1. Responsibilities of Complexe funeraire Lachance inc.

Generally speaking, Complexe funeraire Lachance inc. is responsible for the protection of the personal information it holds.

The person in charge of the protection of personal information at Complexe funeraire Lachance inc. is the president of the organization. He must, generally speaking, ensure compliance with applicable legislation regarding the protection of personal information. The manager must approve the policies and practices governing the governance of personal information. More specifically, this person is responsible for implementing this policy and ensuring that it is known, understood and applied. In the event of the absence or inability to act of this person in charge, the president will assume the functions of the person in charge of the protection of personal information.

The staff members of Complexe funeraire Lachance inc. having access to personal information or being otherwise involved in its management must ensure its protection and comply with this policy.

The roles and responsibilities of employees of Complexe funeraire Lachance inc. throughout the life cycle of personal information may be specified by any other policy of Complexe funeraire Lachance inc. in this regard, where applicable.

1. Data security

Complexe funeraire Lachance inc. undertakes to implement reasonable security measures to ensure the protection of the personal information it manages. The security measures in place correspond, among other things, to the purpose, quantity, distribution, medium and sensitivity of the information. Thus, this means that information that can be qualified as sensitive (see the definition provided in section2) will need to be subject to greater security measures and will need to be better protected. In particular, and in accordance with what was previously mentioned regarding limited access to personal information, Complexe funeraire Lachance inc. must put in place necessary measures to impose constraints on the rights to use its information systems so that only employees who must have access to them are authorized to access them.

1. Rights of access, rectification and withdrawal of consent

To assert their rights of access, rectification or withdrawal of consent, the person concerned must submit a written request to this effect to the person responsible for the protection of personal information at Complexe funeral Lachance inc., at the email address indicated at the next section.

Subject to certain legal restrictions, the persons concerned may request access to their personal information held by Complexe funeraire Lachance inc. and request their correction in the event that they are inaccurate, incomplete or ambiguous. They may also demand the cessation of the dissemination of personal information concerning them or that any hyperlink attached to their name allowing access to this information by technological means be deindexed, when the dissemination of this information contravenes the law or to a court order. They can do the same, or even require that the hyperlink allowing access to this information be reindexed, when certain conditions provided for by law are met.

The person in charge of the protection of personal information at Complexe funeraire Lachance inc. must respond in writing to these requests within 30 days of the date of receipt of the request. Any refusal must be reasoned and accompanied by the legal provision justifying the refusal. In these cases, the response must indicate the remedies under the law and the time limit for exercising them. The manager must help the applicant understand the refusal if necessary.

Subject to applicable legal and contractual restrictions, data subjects may withdraw their consent to the communication or use of the information collected.

They can also ask Complexe funeraire Lachance inc. what personal information is collected from her, the categories of people at Complexe funeraire Lachance inc. who have access to it and their retention period.

1. Complaint handling process

Reception

Any person who wishes to make a complaint relating to the application of this policy or, more generally, to the protection of their personal information by Complexe funeraire Lachance inc., must do so in writing by contacting the person responsible for the protection of personal information. personal information from Complexe funeraire Lachance inc., at the email address indicated in the following section.

The individual must indicate their name, contact details, including a telephone number, as well as the subject and reasons for their complaint, giving sufficient detail so that it can be evaluated by Complexe funeraire Lachance inc. .. If the complaint made is not sufficiently precise, the person responsible for the protection of personal information may request any additional information that he considers necessary to be able to evaluate the complaint.

Treatment

Complexe funeraire Lachance inc. undertakes to treat any complaint received confidentially.

Within 30 days following receipt of the complaint or following receipt of all additional information deemed necessary and required by the person responsible for the protection of personal information at Complexe Funeraire Lachance inc. to be able to process it, the latter must evaluate it and formulate a reasoned written response by email to the complainant. This evaluation will aim to determine whether the processing of personal information by Complexe funeraire Lachance inc. complies with this policy, any other policies and practices in place within the organization and applicable legislation or regulations.

In the event that the complaint cannot be processed within this period, the complainant must be informed of the reasons justifying the extension of the deadline, the progress of the processing of his complaint and the reasonable time necessary to be able to provide him with a final answer.

Complexe funeraire Lachance inc. must create a separate file for each complaint addressed to it. Each file contains the complaint, the analysis and documentation supporting its assessment, as well as the response sent to the person who made the complaint.

It is also possible to file a complaint with theCommission for access to informationof Quebec or any other supervisory body regarding the protection of personal information responsible for the application of the law concerned by the subject of the complaint.

However, Complexe funeraire Lachance inc. invites any interested person to first contact their personal information protection manager and to wait for the end of the processing process by Complexe funeraire Lachance inc..

1. Approval

This policy is approved by the person responsible for the protection of personal information at Complexe Funeraire Lachance inc., whose business contact details are as follows:

Responsible for the protection of personal information:

Denis Lachance
President

152, rue du Curé-Rondeau,

Notre-Dame-des-Prairies, QC

J6E 1G8

For any request, question or comment within the framework of this policy, please contact the manager by email info@cflachance.ca .

1. Publication and modifications

This policy is published on the website of Complexe funeraire Lachance inc., as well as on all websites controlled and maintained by Complexe funeraire Lachance inc., to which this policy applies, in relation to the personal information contained therein. are collected. This policy is also disseminated by any means likely to reach the people concerned.

Complexe funeraire Lachance inc. reserves the right to modify this policy at any time.

Complexe funeraire Lachance inc. must also do the same for all modifications to this policy, which must also be the subject of a notice to inform the persons concerned.

*Notes: Please note that the use of the masculine gender is intended to simplify this policy and make it easier to read.

Table of versions and changes:

Version	Effective on	Changes since the last version
1.0	August 23, 2023	SO – First version
2.0

Annex A

Here is a non-exhaustive list of the types of information that Complexe funeraire Lachance inc. could collect, their use, or the intended purpose, as well as the means by which the information is collected. So, this includes, but is not limited to, the following.

Please note that most personal information managed by Complexe funeraire Lachance inc. is personal information of customers, employees, job applicants and consultants.

Relationship with Complexe funeraire Lachance inc., services, program, etc.	Type of personal information	End of collection / uses	Way of collecting information (means)
	Any of this information, where necessary:	Used for:	Can be collected:
Clients and deceased	name Address phone number e-mail banking information sex Date of birth certain health problems Weight Place of birth Place of birth registration Parents’ names Place of death Date of death Marital status Spouse Information Wedding information Registrant Information Information on participation/registration in different public schemes social Security number	establish and manage customer relationships (and obtain a means of communication) provide a service in compliance with applicable laws collect information as part of a program (e.g. pre-arrangements without paying out of pocket) respond to a request for information in our sphere of activity know the preferred language of communication ensure payment of costs related to services or programs subscribing to the Complexe funeraire Lachance inc. newsletter.	by means of web forms integrated into a website controlled by Complexe funeraire Lachance inc., questionnaires accessible online on its platforms and applications, as well as other platforms or technological form tools. by email (directly or via an attached document or other type of form) from third parties (e.g. Clover, Global Payment, Stripe, CallRaill)
Job applicants and employees	name phone number e-mail banking information social Security number date of birth address	managing communications with the candidate or employee ensure the functioning of the payroll system	by email by telephone
Consultants	name phone number e-mail banking information address	managing communications with the consultant billing	by email (directly or via an attached document: Word, PDF, etc.)
Service Providers	name phone number e-mail banking information language	mandate management paying bills, know the languages ​​in which they can provide services	by means of web forms integrated into a website controlled by Complexe funeraire Lachance inc. by email
Complexe funeraire Lachance Network inc. (ecosystem actors)	name phone number e-mail bank details (when necessary) language	future communications registration for activities organized by Complexe funeraire Lachance inc. and cybersecurity expertise portals surveys the creation of data banks for these future communications and to know the expertise of the network know the preferred language of communication	by means of web forms integrated into a website controlled by Complexe funeraire Lachance inc. and other forms technology platforms or tools (e.g. Microsoft Forms) from third parties (e.g. Eventbrite and Events.com for banking details)
Partners of Complexe funeraire Lachance inc.	name phone number e-mail bank details (when necessary)	establish the partnership (signing partnership agreements) the collaboration	by email (directly or via an attached document or other type of form)