Privacy Policy

Updated2024

 

Thank you for visiting the Website (the“Site”) of CPDM (“CPDM ”,”“we” or “us”) and for your interest in the services we offer. Your privacy is important to us and we want you to feel comfortable visiting the Site. In view of this, we have created this Privacy Policy (the “Policy”). Please review it carefully.

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CPDM controls and operates the Site from its office in Canada and does not represent that materials on the Site are appropriate or available for use in other jurisdictions. CPDM treats personal information in accordance with applicable data protection and privacy laws and is committed to protecting the privacy of certain data that are collected from you and that you submit when you access the Site. We recognize the sensitive nature of much of the information with which we are entrusted on a daily basis, and we are committed to the highest standards of privacy. The following outline is intended to familiarize you with our policies regarding the collection, use, disclosure, maintenance, and protection of private information. The examples given are intended to be for illustrative purposes only, and therefore should not be considered a complete representation of our practices. By accessing and using the Site, you are indicating your agreement this Policy. If you have any questions or concerns about any of our practices, please contact us at info@cpdm-cpa.ca.

 

Who is this web site for?

This website is primarily for use by people located in Canada and for services delivered in this country. What is personal information?

Any information that can be used to identify you.

 

What personal information do you collect and use?

We collect and use any information that is necessary to provide the services required.

 

How do you make sure that my personal information is kept safe?

We have robust security systems and procedures in place to ensure that your information is safe from any foreseeable risk of breach or misuse.

 

How long do you keep this personal information?

We keep the information as long as we deem it necessary with regard to the purpose for which it was collected.

 

Who do you share this personal information with?

We may share this information with affiliates and third-party providers in relation with services you request from us, as well as with governmental entities and courts if we are compelled to.

 

How can I access my personal information or ask that it be corrected?

You can contact us to request access to all the personal information on you that we have. If some of this information is incorrect, you can ask us to correct it, which we will do within 30 days (whenever possible).

 

1. What are the purpose and the scope of this Policy?

This Policy applies to personal information hat CPDM collects in the course of operating its business in Canada, including through the Site.

The term “personal information” refers to information such as your name, email address, mailing address, or telephone number that can be used to identify you as well as information we collect and maintain in combination with information that can be used to identify you.

The Site is intended primarily for the use of persons located in Canada and for the delivery of services within this country. This Policy does not apply to any information that is exempted from the definition of “Personal Information” in applicable privacy legislation.

This Policy describes the types of personal information that CPDM collects, the methods of collection, and the purposes for which CPDM may use, share or disclose such information.

By using the Site, you consent to the collection, use and disclosure of personal information as set forth in this Policy.

1. Accountability

CPDM is accountable for all personal information under its control. This includes personal information under our direct control, as well as personal information that we may transfer to our affiliates or third-party service providers for any purpose that enables or facilitates our business operations. We use contractual or other appropriate means to require third parties that provide services on our behalf to maintain a level of privacy protection comparable to our own.

CPDM has designated a Privacy Officer who is accountable for the handling of all personal information under CPDMs’ control and for ensuring compliance with the principles set out in this Policy. The contact information of our Privacy Officer can be found at section 12 of this Policy.

1. What information do we collect about you?

Either before or when we collect personal information from you, we will explain how we intend to use and disclose it. We will limit the

collection of personal information to that which is necessary to accomplish the identified purposes for which it is collected and will use and disclose it only for those purposes. If we wish to use or disclose your personal information for a new purpose, we will obtain your prior consent, unless such consent is not required by law.

By using our Site, certain technical and other information is automatically disclosed by your computer to and logged by us (such as your network address, your browser type, and the website that referred you to our Site) for operational and security purposes and to better understand the usage of our Site. This means that when you visit the Site, our web server automatically records your IP address, your operating system version, the website from which you came to the Site, the type of browser software you are using, and so forth. It also records the pages you visit within the Site, on what date and for how long. Such information is used to help us improve the contents of the Site and to compile anonymous aggregated statistics about the use of the Site for internal and market research purposes. While all of this information can be associated with the IP address of your computer at the time you visited the Site, it will not be associated with you as an individual, or associated with any other information you may submit through the Site or that CPDM may store about you for any other purposes. We also collect information about your website usage by using cookies. For details, please refer to the Cookies section of this Policy.

 

1. How will we use the information about you?

Your information will be used for the purpose (i) indicated in this Policy at the time of its collection; (ii) that is evident from the circumstances; or (iii) that is provided for by law. It will be used to administer, support and obtain feedback on our services and to prevent breaches of security, the law or our contract terms.

In addition, we may use your personal information to administer your account, contests, promotions, and surveys, to provide customer service, to perform data analysis service, to protect against error and fraud, to protect the security and integrity of the Site and our business, to provide you with information about services you may request, and to meet legal requirements. We may also use it to market services which we think may be of interest to you (including by way of email) or to communicate with you. If you wish to opt out from receiving such communication, please inform us using the following email address: support@cpdm-cpa.ca.

Any communication or material transmitted to CPDM by electronic mail or other electronic device, including any data, questions, comments, suggestions or the like and that is not evidently confidential in nature will be treated as non-confidential and non-proprietary. You agree that CPDM may use such communication or material for the purposes outlined herein.

We will maintain the personal information you provide for so long as we, in our sole discretion, believe it is necessary or appropriate to carry out the purposes for which the information was collected, or to comply with applicable laws, contracts or other rules or regulations. Personal information that is no longer required to fulfill the identified purposes is destroyed or permanently deleted to prevent unauthorized parties from gaining access to it.

1. Consent

Depending on the circumstances and the sensitivity of the information, we may obtain your consent to the collection, use, and disclosure of your personal information in different ways. Express consent may be obtained verbally, online, or in writing. Implied consent may be obtained when you approach us to obtain information, inquire about or request services from us, or through your use of a service or the Site.

You may withdraw your consent to our collection, use, and disclosure of your personal information at any time, on reasonable notice, subject to legal or contractual restrictions. We will inform you of the implications of doing so. For instance, withdrawal of consent may make it impossible for us to provide certain services to you.

If you have opted into CPDMs’email list, you may unsubscribe from such emails by using the link contained therein or by contacting CPDMs’ customer service by any of the means indicated on the Site.

We will not refuse to provide a service to you if you choose not to provide us with your personal information unless the failure to provide such information makes the service impossible.

1. Information sharing ID at a transfer abroad

CPDM will not trade, rent, license or sell your personal information to third parties.

In the course of our normal business activities, we may disclose collected information to both affiliates and non-affiliated entities, as we deem necessary. We will not disclose your information for any purposes other than those in conjunction with the business activities requested of us, unless otherwise permitted or required by law. The business activities include the provision of administration and other related services and performing other functions of our business. Affiliated entities are those within the CPDM family of companies, while non-affiliated entities are those outside of the CPDM family of companies with which we conduct our activities. As CPDM is a global and worldwide acting company, we may disclose your personal information to other CPDM affiliates worldwide that may use such personal information for the purposes listed

in this Policy, but also agree to treat it in accordance with this Policy and applicable laws. Your personal information may be disclosed to third parties if we are required to do so by the law or because of an overriding interest of CPDM.

Your information may also be disclosed to third parties, including abroad, who act for us or on our behalf, for further processing in accordance with the purpose(s) for which it was originally collected. Your information may be lawfully processed by third parties for services delivery (e.g. evaluating the usefulness of the Site, marketing, data management or technical support). These third parties may only process your information in the same way as CPDM is permitted to process it. We require all service providers to keep your information confidential and secure, and to have privacy policies and practices with respect to personal information that are comparable to ours. In addition, we require that our service providers not use or disclose the personal information for any purpose other than providing the services on our behalf, except as may be required by law.

CPDM may transfer any information we have about you in connection with a potential or actual merger, amalgamation, acquisition, disposition or sale, of all or part of our business or assets.

1. Links to other websites

This Policy applies only to the Site. We may provide links to other websites which we believe may be of interest to you. However, due to the nature of the Internet, we cannot guarantee the privacy standards of such websites or assume responsibility for their contents.

1. Cookies

 

When you visit the Site, we may stores some data on your computer in the form of a“cookie.”

 

A cookie is a small piece of text that a website places in the cookie file of your browser and that allows the Site to recognize your personal computer next time you visit the Site.

Cookies by themselves do not disclose your email address or otherwise identify you personally. Cookies can not be used to run programs or deliver viruses to your computer. CPDM only uses cookies in accordance with applicable laws.

However, please be aware that disabling or deactivating cookies on any device may result in a reduced availability of the services provided by the Site or in parts of the Site no longer functioning properly.

For further information on cookies, visit www.allaboutcookies.org or www.aboutcookies.org.

 

1. Security measures to protect your personal information

CPDM uses appropriate security measures in order to reasonably protect our personal information against unauthorized access or alteration, accidental or intentional manipulation, loss, and destruction. For example, our employees are trained to understand the importance of confidentiality and are required to adhere to our privacy policies and procedures. Employees who violate these policies and procedures are subject to disciplinary action. We employ numerous practices to protect against the disclosure of information for purposes unrelated to the performance of our business functions or to individuals other than those who must use it in the course of their work activities. These practices include the use of password protection of computer files, email and voicemail, video surveillance, and other physical, electronic, and procedural safeguards.

1. Access to and accuracy of personal information

You may request access to your personal information, as well as an account of our use and disclosure of that information, by contacting our Privacy Officer in writing. In order to verify that the information is being released to the proper individual, you may be asked to identify yourself. We will respond to your request within 30 days and we will advise you in advance if a reasonable charge will be required for the communication of such information. Incertain circumstances, access to personal information may be denied. If we deny your request for access to your personal information, we will advise you in writing of the reason for the refusal, unless we are prohibited by law from doing so.

You are entitled to challenge the accuracy and completeness of your personal information and have it amended as appropriate. In most cases, CPDM relies on you to provide any updates to, or correction of, your personal information. Where personal information is used on an ongoing basis, CPDM undertakes to correct any information that is shown to be inaccurate, incomplete, or not up-to-date. Otherwise, we do not routinely update personal information unless it is necessary to fulfill the purposes for which the information is collected.

You may request that any of all of your personal information be destroyed or permanently deleted from our records. Upon such a request, CPDM will make reasonable efforts to do so, provided that the retention of such information is not required by law or for any other lawful business purpose, such as the investigation of claims or the defense of an action.

 

1. Changes to the Policy

 

CPDM reserves the right to change this Policy at any time, in which event the Site will contain a notice of the change. Changes will be effective immediately upon posting to the Site.

 

1. Contact Our Privacy Officer

 

If you wish to challenge our compliance with this Policy or have any questions, comments or concerns about this Policy or our privacy practices, please contact BG Communications’ Privacy Officer by using the contact information provided below. All complaints will be investigated. If CPDM finds a complaint to be justified, appropriate measures will be taken, including amending our policies and practices if necessary.

CPDM

555 Chabanel West, Suite 1523, Montréal, QC, H2N 2J2 Attn: Ioana Dana Munteanu, Privacy Officer

[Telephone:+ +1 438 333 5979]

[Email Address: info@cpdm-cpa.ca.]

 

If you are not satisfied with our response, you can refer the matter to the Office of the Privacy Commissioner of Canada (OPCC), which investigates complaints under the Personal Information Protection and Electronic Documents Act (PIPEDA). The OPPC can be reached at:

Office of the Privacy Commissioner of Canada 30 Victoria Street

Gatineau, QC, K1A1H3 1-800-282-1376

Website: http://www.priv.gc.ca

 

If you are located in Québec and are not satisfied with our response, you can also file a complaint with the Commission d’accès à l’information du Québec (“CAI”). The CAI investigates complaints under the Act respecting the protection of personal information in the private sector. The CAI can be reached at:

 

500 René-Lévesque Blvd. West, Suite 18.200 Montréal, QC, H2Z 1W7

514-873-4196

 

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This Policy is governed by the internal substantive laws of Québec and Canada, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the provincial and federal courts within Québec and Canada. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.