Confidentiality and privacy policy

Last update september 25, 2023

PREAMBLE
The mission of the Maison des greffés Lina Cyr is to house and assist people from all regions of Quebec who are waiting for a transplant or who have received one.

We collect, use and disclose personal information for the purposes of soliciting contributions of various kinds, participating in events and providing information about our services, and employee files for payroll purposes. The confidentiality of this information is of the utmost importance to us.

We adhere to the highest ethical standards when handling all information, especially personal information.

This Privacy Policy is intended to help you better understand our practices regarding the collection, use, disclosure and retention of personal information. By agreeing to provide us with personal information (through our website, by completing a donation, purchase or event participation form by e-mail, in person or by telephone), you consent to the processing of your personal information as described in this Privacy Policy, and you authorize the Maison des greffés Lina Cyr, their third parties and service providers to process your personal information for the purposes set out below.

This Privacy Policy does not apply to third-party websites that may be accessed through links on our website, and the Maison des greffés Lina Cyr is not responsible for such third-party websites. If you follow a link to a third-party website, that site will have its own privacy policies that you should review before submitting any personal information.

WHO WE ARE AND WHAT WE DO
The Maison des greffés Lina Cyr provides accommodation and a safe transition period between hospital and home after surgery. It encourages exchanges between patients who share the same experience and enables them to be accompanied by a loved one who also benefits from affordable accommodation.

WHAT PERSONAL INFORMATION DO WE COLLECT?
We may collect and process various types of personal information during our business, including:

• • • Professional and/or personal contact information, such as first name, last name, address(es), e-mail address(es), date of birth and telephone number(s);
    • Biographical information such as job title, employer, professional and/or personal background, photos and video or audio content.
    • Marketing information and communication preferences, as well as related information such as dietary preferences, comments, and survey responses.
    • Information relating to contribution history, participation in organizational events, billing, and financial information, such as a billing address, bank account information or payment data.
    • Service-related information, such as details of services we have rendered to you.
    • Information about your professional background, networks, social involvement, professional affiliations, and family ties.
    • Recruitment information, such as curriculum vitae, education and employment history, details of professional affiliations and other information relevant to potential recruitment at the Maison des greffés Lina Cyr.
    • Website usage and other technical information, such as details about visits to our website, your interaction with our advertising and online content, or information collected through cookies and other tracking technologies.
    • Information provided to us by or on behalf of our residents or generated by us in the course of providing our services, which may, where relevant, include special categories of personal information (such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexual orientation, etc.).
    • Information such as your donation and community investment policy, your contributions, the recipient organizations and what, if anything, they are dedicated to, the recognition obtained, the decision-making process and the people involved in the organization and this process.
    • Any other personal information provided. Please note that if you provide us with personal information about other persons (for example, in the case of a reservation, information about a resident, your directors, officers, shareholders or beneficial owners), you must ensure that you have duly notified them that you are providing us with their information and that you have obtained their consent to such disclosure.
    • Where applicable, evidence of consent given to us (date, time, means), in circumstances where such consent is necessary for the processing of personal information.

We do not knowingly collect information from children or others under the age of fourteen (14). If you are a minor under the age of fourteen (14), please do not provide us with any personal information without the express consent of a parent or guardian. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we learn that we have collected personal information from minor children without verification of parental consent, we will take steps to delete that information from our servers.

HOW DO YOU SHARE YOUR PERSONAL INFORMATION WITH US?
You share your personal information with us, as follows:

• • • When you make a reservation by phone or through our website and newsletters.
    • When you register for fundraising activities.
    • When you make a donation to the Maison des greffés Lina Cyr in any form.
    • When you register as a volunteer at the Maison des greffés Lina Cyr.
    • In the course of providing services to you.

You also share publicly available information with us on public platforms, including our website.

HOW MAY WE USE PERSONAL INFORMATION?
We may use personal information in one or more of the following ways, with your consent or, where applicable, on another legal basis.

In each case, we indicate the purposes for which we use your personal information:

• • • In order to provide our services as well as for the conduct of our business, to administer and perform our services, including to perform our obligations arising from any agreement entered into between you and us.
    • To facilitate the use of our website and to ensure that the content is relevant and to ensure that the content of our website is presented in the most effective manner for you.
    • For marketing and philanthropic development purposes – to provide details of new services, information on developments in our organization and sector and invitations to events where an individual has opted to receive such information or to publicize the activities of the Maison des greffés Lina Cyr.
    • For research and development purposes (including security) – to conduct analyses to better understand our customers’ service and marketing requirements and to better understand our organization and develop our services and offerings.
    • For recruitment purposes – to enable us to process requests for access to our Board of Directors and to assess whether an individual meets the requirements of the position.
    • To meet our legal, regulatory or risk management obligations.
    • To prevent fraud and/or conduct other background checks that may be required at any time by applicable law, regulation and/or best practices (if false or inaccurate information is provided or fraud is found or suspected, information may be forwarded to fraud prevention organizations and may be recorded by us or such organizations). When processing special categories of personal information, we may also rely on important public interests (crime prevention or detection) or legally founded claims.
    • To enforce our rights, to meet our legal or regulatory reporting obligations, or to protect the rights of third parties.
    • To ensure we get paid – to collect payments owed to us and, where appropriate, to enforce such collections through debt collection agencies or other legal means (including legal proceedings).
    • In order to reorganize or change our organization – if we undertake a reorganization (for example, by merging, consolidating or divesting part of our organization’s mission), we may need to transfer some or all personal information to an applicable third party (or its advisors) as part of any due diligence process or transfer to such reorganized entity or third party for the same purposes as set out in this Privacy Policy or for the purposes of analyzing any proposed reorganization. In such a situation, we will take all possible steps to ensure the protection and security of personal information.

WITH WHOM MAY WE SHARE PERSONAL INFORMATION?
The Maison des greffés Lina Cyr is a non-profit organization, duly incorporated and recognized as a charitable organization, and therefore the personal information we collect may be shared with any entity. We may also share personal information with certain third parties, including the following:

• • • We use personal information only to fulfill the primary purpose and applicable legitimate purpose for which it was collected, or for purposes consistent with that primary purpose.
    • Volunteers of the Maison des greffés Lina Cyr for the purposes of recruiting human resources, volunteers and soliciting financial or other contributions.
    • Families in order to share the names of donors for in Memoriam donations.
    • Third-party service providers and/or partners, including those who provide us with donation solicitation, database analysis, Web site development, application development, hosting, maintenance, and other services.

These third parties may access or process personal information in the course of providing services to us. We limit the information we provide to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with these service providers require them to maintain the confidentiality of such information;

• • • Government authorities and law enforcement agencies, where required by applicable law. More specifically, we may disclose personal and other information if we are required to do so by tax or other laws, or if we believe in good faith that such disclosure is necessary to comply with applicable laws, in response to a court order or subpoena or government search warrant, or otherwise to cooperate with such government authorities and law enforcement agencies;

The organization uses the services of third-party sites, such as LinkedIn and Facebook, to promote its content and offers.

When you visit our website, these third parties may use cookies, web beacons or similar technologies on your hard drive to collect or receive information about your browsing on the website and elsewhere on the Internet. These technologies enable us to deliver relevant advertising targeted to your interests. You can consult cookies and delete them if you wish. You therefore have full control. We advise you to refer to your browser settings to make the appropriate changes.

If you would like third-party sites to store cookies on your hard drive-in order to offer you targeted advertising, you can activate this option.

For more information, please consult our Cookie Policy.

HOW LONG DO WE KEEP PERSONAL INFORMATION?
We will retain personal information only as long as necessary for the purposes set out in this Privacy Policy and to comply with our legal and regulatory obligations.
To find out more about how long we keep personal information, please contact us at the coordinates indicated in the “How to contact us” section.

WHERE DO WE STORE PERSONAL INFORMATION AND WHAT ABOUT DATA TRANSFERS OUTSIDE QUEBEC?
The Maison des greffés Lina Cyr uses computerized customer relationship management (CRM) technologies to manage, maintain and service all of the organization’s relationships and interactions with current and potential clients, donors and partners.

For legal and tax reasons, documents and personal information may also be stored at the reception desk or in a highly secure, restricted-access administrative office dedicated to archives.

The Maison des greffés Lina Cyr does not transfer or trade any of its data, whether confidential or not, outside the province of Quebec.

HOW DO WE PROTECT PERSONAL INFORMATION?
We follow the most rigorous and generally recommended industry standards to protect the information submitted to us, both at the time of transmission and once we have received it. We maintain appropriate physical, technical or administrative safeguards to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, misuse, or other unlawful forms of processing of personal information in our possession.

We have taken steps to ensure that the only employees who have access to your personal information are those who have a need to know or whose duties reasonably require them to know it.
However, no method of transmission over the Internet, nor any means of electronic storage, is 100% secure. We therefore cannot ensure or warrant the security of any information you transmit or provide to us, and you do so at your own risk. Nor can we guarantee that such information will not be accessed, obtained, disclosed, altered, or destroyed as a result of a breach of our physical, technical or administrative safeguards.

If you have reason to believe that your personal information has been compromised, please contact us as indicated in the “How to contact us” section.

In the event of a privacy incident involving your personal information, we will notify you as soon as possible after we become aware of the incident. We will take reasonable steps to minimize the risk of harm and to prevent similar incidents in the future.

WHAT RIGHTS DOES AN INDIVIDUAL HAVE WITH REGARD TO HIS OR HER PERSONAL INFORMATION?
Under certain circumstances and in accordance with applicable data protection laws, an individual has the following rights:

• • • Access: the right to ask whether we process information and, if so, to request access to personal information. Subject to applicable law and, where applicable, the payment of a monetary sum, the individual may thus receive a copy of the personal information we hold and certain other information concerning him or her.
    • Accuracy: we are required to take reasonable steps to ensure that personal information in our possession is accurate, complete, non-misleading and up to date.
    • Rectification: the right to request rectification of any incomplete or inaccurate personal information held by us.
    • De-indexing: the right to request that we stop disseminating their personal information or de-index any hyperlink attached to their name giving access to information if such dissemination causes them harm or contravenes the law or a court order (right to erasure or forgetting).
    • Anonymization: the fact that our organization may, instead of destroying personal information, anonymize it and use it only for serious and legitimate purposes (e.g., keeping information required for possible tax inspection purposes) (it may be simpler to destroy it than to anonymize it).
    • The right to be informed when you are the subject of a decision based exclusively on automated processing.
    • The right to be informed when identification, location or profiling technology is used, and of the means available to activate these functions.

Finally, it is also possible to lodge a complaint with a data protection supervisory authority, specifically in the country, province, or state in which you normally reside (in Quebec, the Commission d’accès à l’information), in which we are located or in which an alleged breach of data protection laws has occurred.

To exercise any of these rights, please contact us as indicated in the “How to contact us” section.

HOW DO WE USE COOKIES AND SIMILAR TECHNOLOGIES?
For detailed information about the cookies we use, please refer to our Cookie Policy below, which forms part of this Privacy Policy.

HOW TO CONTACT US
If you have any questions, comments or complaints about this Privacy Policy or your personal information, or if you wish to exercise your rights, file a complaint, or obtain information about our policies and practices regarding our service providers outside Canada, please contact our Privacy Officer by e-mail, telephone, or mail at the following coordinates:

La Maison des greffés Lina Cyr
To the attention of Micheline Cyr Asselin
Privacy Officer
micheline.asselin@maisondesgreffes.com
1989 Sherbrooke Street East, Montreal, Quebec, H2K 1B8, Canada

HOW DO WE UPDATE THIS PRIVACY POLICY?
We may change the content of our websites and the way we use cookies without notice, and therefore our Privacy Policy and Cookie Policy may change from time to time in the future. We therefore encourage you to review them each time you visit www.maisondesgreffes.com to stay informed about how we handle personal information.

This policy was last updated on October 25, 2023.

COOKIE POLICY

CONSENT
By using our site, you consent to the use of cookies in accordance with this cookie policy. You will have seen an invitation to do so on your first visit to this website; although it is not usually displayed on subsequent visits, you may withdraw your consent at any time by following the instructions below.

DISABLING COOKIES
Where the organization setting the cookie offers an automatic deactivation tool for that cookie or those cookies, we indicate the name of that organization, the category of cookies it is setting and a link to its automatic deactivation tool.

In all other cases, we indicate the name of the cookies themselves and their source as of the date of this Cookie Policy so that you can easily identify them and disable them if you wish using your browser controls.

If you do not agree to the use of cookies, please disable them by following the instructions for your browser at the following site (All About Cookies) or use an automatic disabling tool, if available. However, some services will not function as well if cookies are disabled.

After your initial visit to this website, we may change the cookies we use. This Cookie Policy will always tell you who is setting cookies, for what purpose and how to disable them if you check back from time to time.

WHAT TYPES OF COOKIES ARE USED BY THE MAISON DES GREFFÉS LINA CYR?
The categories of cookies used by La Maison des greffés Lina Cyr and its suppliers are described below.

STRICTLY NECESSARY COOKIES
These cookies are essential to enable you to navigate the website and access its functionalities.

Without these cookies, the services you request (such as page navigation) cannot be provided.

PERFORMANCE COOKIES
We use analytical cookies to analyze how our visitors use our website and to monitor website performance. This allows us to ensure a high-quality experience by personalizing our offering and quickly identifying and correcting any problems. For example, we may use performance cookies to track which pages are most popular, to establish which method of linking between pages is most effective and to determine why certain pages receive error messages.

We may also use these cookies to target items or services on the site according to their relevance to you based on your use of the website. We or our suppliers do not link the information collected by these cookies to your personal information.

WEBSITE FUNCTIONALITY COOKIES
We use cookies to provide you with certain functionality. For example, to remember the choices you make (such as your username, language or region) or to recognize the platform from which you access the site and to provide you with enhanced and more personal functionality. These cookies are not used to track your browsing on other sites.

TARGETING COOKIES
Targeting cookies (or advertising cookies) collect information about your browsing habits and are used to better target advertising to you and your interests. They are used by services provided by third parties, such as the Like or Share buttons. The “AddThis” cookies mentioned above are also examples of targeting cookies. Third parties provide these services in exchange for acknowledging that you have visited our website.

When you use LinkedIn, Facebook, or other available share buttons, you are directed to a page controlled by these companies, which may place cookies (including targeting cookies), and you will be subject to the cookie policies of LinkedIn, Facebook or another relevant website, respectively.

USE OF IP ADDRESSES AND DIGITAL LOGS
We may also use your IP address and browser type to help diagnose problems with our server, to administer our website and to improve the service we offer you. An IP address is a numeric code that identifies your computer on the Internet. Your IP address may also be used to gather broad demographic information.

We may use IP address verification to determine the domain from which you came (e.g., google.com) in order to better understand the demographics of our users. Information from these types of cookies and technologies is not combined with information about you from any other source and will not be used to determine your identity.

WEB BEACONS IN HTML AND WEBINAR E-MAILS
Our marketing e-mails contain a unique campaign-specific “web beacon” that notifies us if our e-mails are opened and, combined with other technology, verifies clicks on links within the e-mail. We may use this information for a variety of purposes, including to determine which of our e-mails are of most interest to you, and to ask users who do not open our e-mails if they wish to continue receiving them. The pixel will be removed when you delete the e-mail. If you do not want the pixel to be downloaded to your device, you should choose not to click on the links we send you. This information may be linked to your personal identity.

COOKIE POLICY DOES NOT COVER THIRD-PARTY WEBSITES
Please note that this Cookie Policy does not apply to, and we are not responsible for, the privacy practices of third-party websites that may be linked to or from this website.

CHANGES TO COOKIE POLICY
We may update this cookie policy from time to time and encourage you to review the policy from time to time to stay informed about how we use cookies.

This Cookie Policy was last updated on October 25, 2023.

DOCUMENT RETENTION AND DESTRUCTION POLICY

1. Objective
   The purpose of this policy is to provide procedures for the closure, retention and destruction of customer records maintained by the organization.

2. Definitions
3. In this policy, the following definitions apply:
   • • • “File Close Date”: the date on which the person responsible for a file has determined that the file is complete and from which he/she determines the destruction of the file.
       • File destruction date”: the date from which a file is destroyed.

3. Review and close the file
   • • • The organization appoints a person responsible for the application of this policy. Failing this, the organization’s General Management is responsible for applying this policy.
       • When a file is closed, the person in charge of the file determines its closing date and its destruction date. For files concerning donors and potential donors, it is agreed that the file must be destroyed after ten (10) years from the date of the donor’s last donation or last consent to the use of his or her personal information, whichever is later.
       • Before closing the file and sending any physical document or other property related to the file to an external storage site or shredding service, the person responsible for the file must take steps to remove from the file hard copies of documents that have been imaged or otherwise saved in the organization’s electronic library.
       • The organization keeps records identifying closed files, including the date of closure and, where applicable, the date of destruction.

4. Storage of closed files
   Closed, non-destroyed files are stored in a locked physical location to maintain confidentiality and protect them from damage or loss. They may also be stored on the following computer network on Excel.

5. Destruction of files
   • • • When the file manager closes the file and the file is ready for destruction (see section below), the destruction date is determined according to the organization’s standard as defined in section 5.2 unless the file manager determines that another destruction date would be more appropriate.
       • The organization retains closed files primarily to satisfy risk management concerns. Accordingly, it is prudent to keep the file closed for a period of time determined by any legal requirements.
       • The destruction date must be suspended in the following cases relating directly or indirectly to: a) an actual or potential claim against the organization, b) a request for disclosure of information concerning the file or donor concerned, c) government audits and investigations. This may be ordered by the person in charge of the file.
       • The file destruction date may be postponed at any time if necessary (for example, if a new consent is granted in the meantime).
       • This policy must be applied in a manner that ensures the confidentiality of personal information and compliance with applicable federal and provincial privacy legislation.
       • The organization maintains a register of destroyed files that includes the name of the donor, the file number, the file closing date, the file destruction date and the name of the person responsible for the file.

The organization destroys paper files and electronic files. Electronic information and data includes e-mail, drafts of documents on a server or document management system, document images or scanned documents, faxes (when no hard copy exists), voice mail, metadata and other case-related information or data that is saved and stored in electronic format (e.g., on servers, magnetic media, magneto-optical systems, compact disks, DVDs), servers, magnetic media, magneto-optical systems, compact discs, DVDs).

COMPLAINTS HANDLING POLICY
The purpose of this policy is to ensure that complaints are handled appropriately, consistently, and diligently. It is intended for any individual who is dissatisfied with the handling of his or her personal information.

Purpose of the policy
The purpose of the Complaints Handling Policy is to establish a fair and transparent procedure for handling complaints received by the Maison des greffés Lina Cyr. It is also intended to support the quality of our services and provide an opportunity for anyone to express dissatisfaction.

This document provides a framework for the receipt of complaints, the transmission of acknowledgement of receipt, the creation of a complaint file and the compilation of complaints received, all with a view to listening to our customers and ensuring continuous improvement.

Responsible
The person responsible for the application of this policy is the Privacy Officer of La Maison des greffés Lina Cyr. She acts as the person in charge and ensures that staff are adequately trained in this regard. The person in charge is also responsible for providing employees with all information required to comply with this policy.

The main duties of the person in charge are to:

• • • Ensure the application of this policy.
    • Ensure that an acknowledgement of receipt is sent to the complainant.
    • Investigate the claims made by the complainant.
    • Respond to the complainant.

Complaint
For the purposes of this policy, a complaint is the expression of at least one of the following three elements:

• • • Dissatisfaction with the Maison des greffés Lina Cyr by an individual who feels aggrieved.
    • A prejudice suffered as a result of an event, situation, act or omission with regard to the service provided by the Maison des greffés Lina Cyr.
    • A request for corrective action.

A complaint does not include any informal attempt to have a particular problem corrected, as long as the problem is dealt with as part of the regular activities of the Maison des greffés Lina Cyr and without a written complaint having been filed by an individual.

Receipt of complaint
Individuals wishing to file a complaint must do so in writing to the following address:

La Maison des greffés Lina Cyr
To the attention of Micheline Cyr Asselin
Privacy Officer
micheline.asselin@maisondesgreffes.com
1989 Sherbrooke Street East, Montreal, Quebec, H2K 1B8 Canada

• • • The communication must include the following information:
    • The complainant’s name
    • Address
    • Telephone number
    • E-mail or fax number, if applicable
    • The capacity of the complainant: In his/her personal name, as a Tutor or as the holder of parental authority
    • The grounds for the complaint.

All complaints are treated confidentially. Anonymous complaints are deemed not to have been received.

Any employee receiving a complaint must forward it, as soon as it is received, to the person responsible for applying the policy.

Any employee who receives a verbal complaint must inform the complainant of this policy and invite him or her to send the Maison des greffés Lina Cyr his or her complaint in writing.

The person in charge must acknowledge receipt of the complaint within five (5) business days of receipt.

The acknowledgement of receipt must contain the following information:

• • • A description of the complaint received, specifying the complaint against the Maison des greffés Lina Cyr, the prejudice or the corrective measure requested.
    • The name and contact information of the person responsible for handling the complaint.
    • In the case of an incomplete complaint, a notice containing a request for additional information to which the complainant must respond within a set period of time, i.e., five (5) working days, failing which the complaint is deemed to have been abandoned.
    • Complaints handling policy.

Creating a complaint file
To ensure fair and transparent processing, a separate file is created for each complaint. The file includes the following elements:

• • • The written complaint
    • The outcome of the complaint handling process (analysis and related documents)
    • The final written response to the complainant

Processing a complaint
The complaint handling process is initiated within a maximum of five (5) business days of receipt.

Complaints must be processed within a reasonable timeframe, i.e., within thirty (30) days of receipt of all the information required to investigate the complaint.

In the exceptional event that a complaint cannot be processed within the stipulated timeframe, the complainant must be informed of the reasons for the delay and of the Organization’s steps to date in processing the complaint. The complainant must also be informed of the timeframe within which the decision will be communicated.

Once the complaint has been examined and the analysis completed, the person in charge must send the complainant a final, written, reasoned response.

Effective date
This policy takes effect on October 25, 2023.

If you have any questions or comments regarding the handling of complaints, please contact the person in charge directly:

La Maison des greffés Lina Cyr
To the attention of Micheline Cyr Asselin
Privacy Officer
micheline.asselin@maisondesgreffes.com
1989 Sherbrooke Street East, Montreal, (Quebec) H2K 1B8 Canada