Privacy Policy
Context
CLUB PISCINE is committed to respecting your privacy and protecting your personal information. In the course of using our services, Club Piscine may collect, and you may provide, personal information. The purpose of this policy is to inform users of the services offered by Club Piscine about the following:
- How their personal information is collected and processed;
- What rights they have regarding their information;
- Who is responsible for the processing of the personal information collected and processed;
- To whom this information is disclosed;
- The use of cookies by Club Piscine on its websites.
Applicable Laws
In the course of using our services, CLUB PISCINE may collect, and you may provide, personal information. The collection, use, disclosure, and retention of your personal information are governed by the Act Respecting the Protection of Personal Information in the Private Sector (CQLR, c. P-39.1).
Personal Information
Any information relating to an individual that can be used to identify them is considered personal information. Your personal information may include, but is not limited to, your first and last name, date of birth, home address, telephone numbers, gender, email address, family status information, and information you provide when creating a profile to subscribe to one of our services.
However, information related to an individual's position within a business, such as their name, title, job function, business address, business email address, and business telephone number, will not be considered personal information.
Our Commitment
We have established and implemented internal policies and procedures designed to adequately protect the personal information in our possession, regardless of its format or medium. These policies and procedures are reviewed regularly.
We make our employees aware of the importance of protecting personal information by requiring training on the subject and by periodically issuing directives emphasizing their role and responsibilities in this regard.
Purpose of Information Collection
In the course of our activities, we collect your personal and confidential information only to enable us to provide the requested services in an appropriate and personalized manner. In all cases, the disclosure of your personal and confidential information will be subject to confidentiality obligations and compliance with applicable laws.
Consent
Subject to the exceptions and requirements of applicable laws, we will not disclose or share your personal information with any third party without your consent.
By using our services, you consent to the collection, use, and disclosure of your personal and confidential information in accordance with this policy. The form of consent may vary depending on the context or the service requested.
Your consent may be requested from, among others:
- A representative of our executive management or a franchisee for contractual purposes;
- A representative of our Human Resources department;
- A representative of one of the services you wish to subscribe to;
- A primary service provider where Club Piscine acts as, or retains the services of, a subcontractor.
You may withdraw your consent at any time, subject to certain legal or contractual restrictions.
In certain specific circumstances, we may collect, use, or disclose personal information without informing you or obtaining your consent. Such circumstances may arise, among other situations, when it is impossible or impractical to obtain your consent for legal, medical, or security reasons, or when the information is required for the investigation of a potential breach of contract, or to prevent or detect fraud.
Before disclosing personal information about another individual to us, you must obtain that individual's consent regarding the disclosure and processing of such personal information in accordance with this policy.
Personal Information Concerning Minors
Personal information concerning a minor under the age of 14 will not be collected from the minor without the consent of the parent or legal guardian.
Limits on Collection, Use, and Disclosure
We limit the collection, use, and disclosure of your personal information solely to the purposes that have been communicated to you. Personal information is accessible only to those within Club Piscine who require it in the performance of their duties.
If you submit personal information on one of our websites for publication, we will publish and may use that information in accordance with the permissions you grant us.
Limits on Use
- To provide the requested service;
- To verify your identity and respond to your requests for information;
- To improve our service offerings;
- To operate and improve our website and solutions while understanding user behavior and usage patterns;
- To provide any complementary services associated with the requested service;
- To comply with legal and regulatory requirements;
- To monitor customer service quality and prevent errors and fraud;
- To send electronic communications, including newsletters, promotions, and updates from Club Piscine and its franchisees;
- To deliver personalized digital advertising on third-party platforms such as Meta and Google, based on your preferences and online behavior.
Disclosure
We may disclose your personal information to any of our employees, professional advisors, suppliers, subcontractors, or affiliates to the extent reasonably necessary to provide the requested services and for the purposes described in this policy.
As a general rule, we do not disclose your personal information. However, we may occasionally share your personal information with certain suppliers or agents in order to provide the services you have requested. In all cases, we comply with the restrictions and requirements imposed by law when disclosing personal information. In some circumstances, such disclosure is subject to a written agreement and a security assessment demonstrating that your personal information receives protection equivalent to that implemented within Club Piscine.
Your personal information will not be disclosed to third parties except as provided in this Privacy Policy, as required or permitted by law, or as ordered by a competent court.
We do not sell your personal information to third parties.
Privacy Impact Assessment
A Privacy Impact Assessment (PIA) regarding the use of personal information by our services and/or systems is conducted before personal information is collected by Club Piscine. Where transfers outside Québec are involved, the impact of such transfers is also assessed.
International Data Transfers
The information we collect may be stored, processed, and transferred in any country where Club Piscine or its subcontractors provide services, in order to allow us to use the information in accordance with this policy.
The information we collect may be transferred to or processed in the following countries: the United States of America and certain countries within the European Union.
Personal information that you publish on our website or submit for publication may be available worldwide via the Internet. We cannot prevent the use or misuse of such information by third parties.
You expressly consent to the transfer of personal information as described in this section.
Non-Personal Information
We automatically collect certain non-personal information using third-party analytics tools such as Google Analytics to help us understand how visitors use our web services; however, none of this information can be used to identify you. The following information may be collected, stored, and used:
- Information about your computer, including your IP address, geographic location, browser type and version, and operating system;
- Information about your visits to and use of our websites, including referral source, duration of visit, page views, and navigation paths;
- Information generated during your use of our website, including when, how often, and under what circumstances you use it.
Cookies
Club Piscine and its affiliated web services use cookies. Cookies are small data files stored on your computer or mobile device when you visit a website or application. They are used to enhance your user experience by recording certain information. By using Club Piscine's web services, you consent to this use.
Cookies We Use on Our Websites
We use cookies for the following purposes:
a) Authentication: We use cookies to identify you when you visit and navigate our website and web platforms. Cookies collected for these purposes are used for connection and session management.
b) Personalization: We use cookies to store information about your preferences and to enable us to tailor our services to your needs. Cookies used for these purposes help maintain your preferred language when using Club Piscine websites.
Cookies Used by Our Service Providers
In certain situations, some of our services may be provided by external service providers who may use cookies that are stored on your computer or mobile device.
Managing Cookies
You may configure your browser or device to refuse cookies or delete them after they have been stored. Please consult your browser's or device's Help section for instructions. Please note that deleting or refusing cookies may affect your user experience.
For more details, please refer to the Cookie Management Policy available on our website.
Retention of Information
When your personal information is no longer required, it is destroyed in accordance with the law and our records retention policy. In certain circumstances, we may anonymize personal information that we retain.
Your personal and confidential information is retained, directly or through subcontractors, only for as long as necessary to fulfill the purposes for which the services were requested and to satisfy applicable legal and regulatory requirements. We require our subcontractors to adhere to confidentiality commitments and to implement policies equivalent to this one. Access to your personal and confidential information is restricted to individuals who require access in the performance of their duties.
Accountability
We are responsible for the personal information in our possession or under our control, including information entrusted to third parties for the purpose of providing requested services. We require these third parties to maintain strict confidentiality and security standards.
We adhere to the principles established by law. We have implemented policies and guidelines that ensure the protection of your privacy. The Privacy Officer oversees this privacy policy and the various privacy frameworks within the organization.
Our staff are informed and properly trained regarding policies and practices relating to personal information protection.
Security Measures
We have implemented several security measures with respect to the personal and confidential information we hold in order to protect it against loss, theft, unauthorized access, disclosure, use, or modification, including the measures described below:
Privacy Impact Assessments
CLUB PISCINE conducts Privacy Impact Assessments for all projects involving the acquisition, development, or redesign of information systems or electronic service delivery that involve the collection, use, disclosure, retention, or destruction of personal information. These assessments document the serious and legitimate interest in using personal information.
Secure IT Environments
Infrastructure and equipment are hosted in secure facilities located in North America. Where it is not possible to host a solution or service in Québec, we ensure that security measures equivalent to or greater than those required under this Policy are implemented.
Access to Club Piscine web services is secured through SSL certificate technology (HTTPS).
Access Management
Only employees whose duties require access to personal or confidential information are granted such access. Data access is logged and monitored.
Training and Awareness
Our employees and partners are trained and made aware of the importance of protecting your personal information.
Confidentiality Commitment
Our employees are required to sign confidentiality agreements. Security audits are conducted by firms specializing in information security.
Destruction
CLUB PISCINE ensures both physical and technological security for the personal information it retains in order to guard against accidental destruction, loss, disclosure, and improper destruction.
We retain your personal information only as long as necessary for the purposes for which it was collected. We must destroy or anonymize this information in accordance with the law and our retention schedule. When destroying or anonymizing personal information, we take appropriate measures to ensure confidentiality and prevent unauthorized access throughout the destruction or anonymization process.
Management of Privacy Incidents
If Club Piscine has reason to believe that a privacy incident involving personal information has occurred and that there is a risk of serious harm resulting from the incident, Club Piscine will promptly notify the Commission d'accès à l'information and any individual whose personal information is affected. It may also notify any person or organization capable of reducing that risk, disclosing only the personal information necessary for that purpose and without the individual's consent. In all cases, a record of the incident will be maintained for reference purposes.
Request for Access, Withdrawal, or Correction
Subject to any legal, regulatory, or contractual restrictions, you may request access to, correction of, or deletion of the personal information we hold about you.
We will provide such information within a maximum of 30 days from receipt of the written request and in a structured, commonly used technological format. Fees may apply to process your request.
In certain circumstances, we may refuse to provide the requested information. Exceptions to your right of access include situations where disclosure cannot be made for legal or security reasons.
These limitations are described in the Act Respecting the Protection of Personal Information in the Private Sector (CQLR, c. P-39.1).
You may verify the accuracy and completeness of your personal information and, where applicable, request corrections. Any correction request will be handled in accordance with the law.
Data Portability
The user has the right to request the portability of personal information held by Club Piscine to another organization.
Restriction and Objection to Data Processing
The user has the right to request restriction of, or object to, the processing of their data by Club Piscine. Club Piscine may refuse such a request only where it can demonstrate legitimate and compelling grounds that override the user's interests, rights, and freedoms.
Decisions Based Solely on Automated Processing
The user has the right not to be subject to a decision based exclusively on automated processing where such decision produces legal effects concerning them or similarly significantly affects them.
Requests, Complaints, and Questions
We are committed to responding to your questions and concerns regarding the protection of your personal information. If our response does not satisfy you, you may contact the Privacy Officer using the contact information provided below.
Contact Information
Any request or complaint concerning the protection of personal information must be directed to the Privacy Officer at the address below:
Privacy Officer
CLUB PISCINE
888 Boul. Industriel
Bois-des-Filion, Québec J6Z 4V1
Email: vieprivee@clubpiscine.ca
If the Privacy Officer decides not to respond to a user's request and the user wishes to challenge that decision, or if they believe one of their rights has been infringed, they may contact the Commission d'accès à l'information du Québec.
Review and Approval
This Policy comes into effect upon its adoption by the Access to Information and Privacy Protection Committee and may be revised at any time by the Privacy Officer.
Amendments may be proposed by various Club Piscine stakeholders and must be submitted in writing to the Access to Information and Privacy Officer.
CLUB PISCINE reserves the right to modify this Policy at any time. Any changes will be published on Club Piscine's web platforms. Your continued use of the services following publication of the changes constitutes your acceptance of the revised Policy.
This Policy should be reviewed at least every two years to ensure its continued relevance in light of CLUB PISCINE's mission, user activities, and any significant changes to legislation or regulatory requirements.
Effective Date
This Policy takes effect on August 30, 2024. It supersedes and replaces all previous policies and frameworks relating to the protection of personal information.
