1. Identity of the controller
CFI Industries Inc. (legal name: 10330787 Canada Inc., NEQ 1172965064 — owner: Yanick Laberge), hereinafter "CFI", "we", "our", is a Quebec company headquartered at 1360 6e Rang N, Saint-Bruno (Quebec) G0W 2L0. We are responsible for protecting personal information collected on this site, in accordance with the Act to modernize legislative provisions as regards the protection of personal information (Quebec Law 25, CQLR c. P-39.1), the Personal Information Protection and Electronic Documents Act (PIPEDA, S.C. 2000, c. 5, Canada) and Canada's Anti-Spam Legislation (CASL, S.C. 2010, c. 23).
2. Privacy officer (Law 25, s. 8.1)
In accordance with section 8.1 of Law 25, CFI Industries has appointed Yanick Laberge as privacy officer. Any communication regarding your personal information (request for access, rectification, withdrawal of consent, cessation of processing, de-indexing or portability) must be sent in writing to:
[email protected] · 418 321-1675 · 1360 6e Rang N, Saint-Bruno (Quebec) G0W 2L0. We will respond within 30 days of receiving your complete request.
3. Internal governance policy (Law 25, s. 3.2)
CFI Industries has adopted an internal governance policy for personal information that frames the collection, use, disclosure, retention, and destruction of data. This policy includes:
• roles and responsibilities of staff with access to personal information across its full lifecycle;
• a process for handling complaints related to personal information protection;
• an ongoing training and awareness program on Law 25 obligations;
• incident notification procedures;
• a periodic compliance review.
A summary of this policy is available upon written request to the privacy officer.
4. Categories of personal information collected
We collect only what is strictly necessary for the identified purposes:
(a) Contact form: full name, email address, phone number, request type, message content.
(b) Application form (careers): full name, email, phone, position applied for, preferred region, years of experience, declared certifications, resume, cover letter (if provided), availability message.
(c) Technical data: IP address (truncated to 24 bits in logs), browser and OS type, pages visited, date and time of visits, referral source.
(d) Cookies: technical session identifiers and, subject to your explicit consent, anonymized analytics cookies.
No category of sensitive personal information within the meaning of section 59 of Law 25 (ethnic origin, political opinions, religious beliefs, health, sexual orientation, biometric data, genetic data) is collected.
5. Purposes of processing (Law 25, s. 8 and 12)
Pursuant to section 14 of Law 25, your consent must be manifest, free, informed and given for specific purposes. It is requested separately from any other information, in clear and simple language, and for each specific purpose.
Your personal information is used exclusively for the following purposes:
• Responding to your inquiry or quote request;
• Preparing a quote, contracting a project, providing after-sales service;
• Evaluating your application if you apply for a position;
• Improving the security, performance and user experience of the site;
• Complying with our legal, accounting and tax obligations;
• Defending our rights in case of dispute.
We will not reuse this information for other purposes without obtaining additional consent, in accordance with section 12 of Law 25.
6. Disclosure to third parties and transfers outside Quebec
We never sell, rent or trade your personal information. We may disclose your information to the following third parties, only for the identified purposes:
Technical sub-processors:
• Netlify Inc. (hosting and forms) — data transiting through servers in the United States. Netlify is ISO 27001 certified and complies with the EU-US Data Privacy Framework.
• Google LLC (Google Fonts typeface, where applicable) — anonymous technical data only.
Privacy impact assessment (Law 25, s. 3.3): before any transfer of personal information outside Quebec, we conduct a privacy impact assessment to verify that the receiving jurisdiction offers equivalent protection, and we put appropriate contractual clauses in place. For more information, contact the privacy officer.
Legal authorities: we may be required to disclose your information in response to a court order, warrant or legally binding request.
7. Retention period
In accordance with the minimization principle (Law 25, s. 23):
• Contact form data: 24 months after last exchange, then irreversibly deleted or anonymized.
• Application form data and resumes: max. 24 months after receipt, or destroyed on request.
• Technical logs: 13 months maximum.
• Session cookies: deleted when browser is closed.
• Analytics cookies: 13 months maximum.
Contractual data (invoices, contracts, project-related correspondence) is kept for 7 years to comply with our tax and accounting obligations (Tax Act, s. 35.1).
8. Your rights (Law 25, s. 27 to 33)
You have the following rights regarding your personal information:
•
Right of access — obtain a copy of the information we hold about you;
•
Right to rectification — correct inaccurate, incomplete or ambiguous information;
•
Right to withdraw consent — withdraw your consent at any time, without retroactive effect;
•
Right to cessation of dissemination and
de-indexing ("right to be forgotten") — request that the dissemination of your information cease or that a hyperlink leading to it be de-indexed, under section 28.1 conditions;
•
Right to portability — receive in a structured, commonly used technological format the computerized information you have provided to us;
•
Right to information on automated decisions — be informed if a decision concerning you is based exclusively on automated processing.
To exercise these rights, write to
[email protected], specifying the nature of your request and attaching proof of identity. We respond within 30 days.
9. Cookies and similar technologies
Our site uses:
•
Essential cookies required for the site to function (remembering your FR/EN language choice, secure form processing) — do not require consent (s. 8.1, Law 25);
•
Analytics cookies anonymized (where applicable) — loaded only after your explicit consent via the banner at the bottom of the screen.
You can change your choice at any time by clicking "Cookie Preferences" in the footer, or by clearing cookies via your browser settings. See our
detailed cookie policy.
10. Security measures (Law 25, s. 10)
CFI implements reasonable technical and organizational measures to protect your information from loss, theft, unauthorized access, disclosure, copying, use or modification:
• Encrypted TLS 1.3 connection (HTTPS mandatory throughout the site);
• Hosting with an ISO 27001 compliant provider;
• Access to data restricted to authorized personnel based on their duties;
• Personnel training on personal information protection;
• Encrypted backups and access logging.
No system being infallible, we cannot guarantee absolute security.
11. Privacy incident notification (Law 25, s. 3.5)
In the event of a privacy incident presenting a serious risk of harm (theft, leak, unauthorized access, unauthorized loss or destruction), CFI: (a) immediately takes measures to reduce the risk; (b) promptly notifies Quebec's Commission d'accès à l'information (CAI); (c) notifies the affected individuals; (d) records the incident in the register provided for by law. You will be notified by email at the address provided.
12. Marketing and electronic communications (CASL)
In accordance with Canada's Anti-Spam Legislation (CASL), we will not send you any commercial electronic message without your prior express consent. Each marketing communication includes a free and functional unsubscribe mechanism. You may revoke your consent at any time by clicking the "Unsubscribe" link or by writing to
[email protected].
13. Minors
Our site is not intended for persons under 14 years of age (the threshold for required parental consent under section 4.1 of Law 25). We do not knowingly collect information about children. If you are a parent or guardian and suspect your child has provided us with information, write to us: we will delete it immediately.
14. Modifications to this policy
This policy may be amended to reflect legislative, technological or operational changes. The last update date is indicated at the top of the document. In the event of substantial modification, we will notify you by email or via a clearly visible notice on the site before it takes effect.
15. Remedies and complaints
If you believe CFI Industries has not respected your rights or has not responded adequately to your request, you may:
1. File a written complaint with the privacy officer:
[email protected];
2. File a complaint with the
Commission d'accès à l'information du Québec (CAI) — Quebec Bureau: 525, boul. René-Lévesque Est, bureau 2.36, Quebec (QC) G1R 5S9 —
cai.gouv.qc.ca · 1 888 528-7741;
3. For information of federal scope or interprovincial transfers, file a complaint with the
Office of the Privacy Commissioner of Canada —
priv.gc.ca · 1 800 282-1376.
16. Governing law and jurisdiction
This policy is governed by the laws in force in the Province of Quebec and applicable federal laws of Canada. Any dispute relating to its interpretation or execution falls under the exclusive jurisdiction of the courts of the Chicoutimi judicial district, Quebec, subject to administrative remedies provided by law (CAI, federal Commissioner).