Privacy Policy

01Scope

This Privacy Policy applies to personal information we collect through sequrit.ca, primarily through our contact form, together with the consent-preference storage and third-party technologies described below.

It does not apply to third-party websites, platforms, or services that may be linked from our website and that are governed by their own terms and privacy policies. It also does not apply to any separate signed agreement governing an actual engagement, which may contain its own confidentiality and data-handling terms.

02Person in charge of personal information protection

The person in charge of personal information protection at JPL SERVICES-CONSEILS ET SOLUTIONS WEB INC. (operating as SequrIT) is Jean Pierre Levac, acting as Privacy Officer.

To reach the Privacy Officer, write to privacy@jplsolutions.ca.

For any question about this policy or about how your personal information is handled, contact the Privacy Officer at that address before escalating to a regulatory body.

03What personal information we collect

We collect personal information only when you voluntarily submit our contact form. This site has no accounts, no payment processing, and no file uploads, and we collect no personal information through any other means.

Information you provide through the contact form:

• Your name
• Your work email address
• Your organization (optional)
• The nature of your need (selected from a dropdown)
• A free-text message describing your situation
• Your preferred language

04How we collect personal information

We collect personal information directly from you, and only when you complete and submit the contact form. We do not collect personal information automatically through tracking cookies (we set none), through an account system (we have none), or from any third-party source.

Some technical information is generated automatically by the act of visiting the site. That technical information is generated by our hosting, web-font, and consent-tool providers, and is described in the Cookies and similar technologies section and the Analytics and third-party services section below. We do not collect it directly ourselves.

05Why we collect and use personal information

We collect and use the information from the contact form to:

• Respond to your inquiry
• Understand and scope the IT services you are requesting
• Communicate with you throughout the engagement, if one proceeds
• Meet applicable legal obligations

Server and technical logs generated automatically when you visit the site, described below, are used separately, to prevent abuse and maintain the security of the site. That purpose applies to the technical log data, not to the contact-form submission itself.

We do not use your information for advertising, profiling, or automated decision-making, or for any purpose beyond those listed above.

06Consent

We obtain your consent to the collection described in this policy at the time of contact-form submission, through the disclosure displayed on the form itself.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to respond to your inquiry or to provide services you have requested.

To withdraw consent, contact the Privacy Officer at privacy@jplsolutions.ca.

Separately, a consent banner on the site lets you set preferences for optional analytics and marketing technologies. That mechanism is described in the next section.

07Cookies and similar technologies

This website does not set tracking cookies. When you first visit, a consent banner lets you indicate your preferences for optional analytics and marketing technologies. As of the effective date of this policy, no analytics or marketing scripts are active on this site. The consent categories are in place in preparation for possible future use. If and when we activate those technologies, only categories you have consented to will be loaded. You can update your preference at any time using the consent button shown on the page.

Consent storage: we store your consent preference in your browser's local storage, a browser mechanism that is technically distinct from cookies, so that we do not ask again on every visit. This item holds only your preference and is not used for tracking.

Consent tool: the consent banner is provided by the Silktide consent manager, loaded from the jsDelivr content delivery network. When your browser requests the tool's files, that network receives your IP address as part of the technical request. We do not control and do not have access to any data that network may log from this request.

08Analytics and third-party services

As of the effective date of this policy, we do not use any analytics tool, and no traffic-measurement or behavioral-tracking technology is active on this site.

We use the following categories of third-party service providers to operate the site itself:

• Hosting and contact-form handling
• Email delivery for messages sent through the contact form
• Web fonts
• Delivery of the cookie-consent tool

The specific providers, their location, and the data each receives are described in the Cross-border processing section below. These providers act on our behalf and do not use your personal information for their own purposes beyond providing their services to us.

09Disclosure of personal information

We may disclose personal information:

• To our personnel and any subcontractor who needs it to respond to your inquiry or deliver a

service you have requested

• To the service providers described in this policy, acting on our behalf
• In connection with a proposed or completed merger, sale, financing, reorganization, or

acquisition, subject to appropriate protections

• Where required or permitted by law, court order, or regulatory request
• Where necessary to protect our rights, property, safety, or the safety of others
• With your consent or at your direction

We do not sell personal information.

10Cross-border processing

Your personal information may be communicated to the following service providers, all of which operate at least in part outside Quebec:

• Netlify, Inc. (United States): our hosting provider. Contact-form submissions you send through

this site are received and processed by Netlify's infrastructure before being routed to us.

• Google LLC (United States): serves web fonts on this site. Your IP address may be received by

Google when fonts load.

• jsDelivr (Prospect One sp. z o.o., Poland, European Union): a content delivery network that

serves the files for our cookie-consent tool. Your IP address may be received by this network when those files load.

• Zoho Corporation (United States): our email provider. Inquiries you submit reach us through

Zoho's mail infrastructure.

Before personal information is communicated to a service provider outside Quebec, we assess whether it will receive protection adequate to Quebec standards, as Law 25 requires. These providers act as processors on our behalf and do not use your personal information for their own purposes beyond providing their services.

11Retention

We keep personal information you provide through the contact form only as long as necessary to respond to your inquiry and for reasonable follow-up, or as required by law. When the purpose is fulfilled and no legal obligation requires us to keep the information, we destroy, delete, or anonymize it.

Technical logs generated by our hosting, web-font, and consent-tool providers are retained according to those providers' own retention practices, which we do not control.

12Security safeguards

We apply reasonable administrative, technical, and physical safeguards designed to protect the personal information in our custody against unauthorized access, use, disclosure, modification, or destruction. We also contractually require our service providers to maintain appropriate safeguards.

No system is completely secure, and we cannot guarantee absolute security.

13Confidentiality incidents

In the event of a confidentiality incident presenting a risk of serious injury, we will notify the Commission d'accès à l'information and, where required, the affected individuals, in accordance with Law 25.

If you believe your personal information has been compromised, contact the Privacy Officer at privacy@jplsolutions.ca.

14Automated decision-making

We do not use personal information to render any decision based exclusively on automated processing. If that changes, we will provide the notices required by applicable law before doing so.

15Your rights

Under Law 25, you have the following rights with respect to personal information we hold about you:

• Access: the right to be informed of and to access the personal information we hold about you.
• Rectification: the right to have inaccurate, incomplete, or ambiguous information corrected,

and to have information collected in violation of the law deleted.

• Withdrawal of consent: the right to withdraw your consent to the collection, use, or

communication of your information, subject to legal or contractual constraints and reasonable notice.

• De-indexing and cessation of dissemination: the right to request that we stop disseminating

your personal information, or that hyperlinks associated with your name be de-indexed, where that dissemination contravenes the law or a court order.

• Data portability (in force since September 22, 2024): the right to receive the personal

information you provided to us in a structured, commonly used technological format, and, where technically feasible, to have that information communicated directly to another enterprise at your request.

• Complaint: the right to lodge a complaint with the Commission d'accès à l'information du Québec

(CAI) at www.cai.gouv.qc.ca.

To exercise any of these rights, contact the Privacy Officer at privacy@jplsolutions.ca. We will respond within the timeframe required by law, generally 30 days, with one possible extension. We may need to verify your identity before responding.

16Children's privacy

This site and the services it describes are directed at business professionals. We do not knowingly collect personal information from individuals under the age of 14.

17Third-party websites

Our website may contain links to third-party websites or services. We are not responsible for their privacy practices, content, or terms. Review their policies separately.

18Changes to this policy

If we make material changes to this policy, we will update the effective date at the top of this page. We encourage you to review this page periodically.

19Contact

For any question, request, or complaint about this policy or about how your personal information is handled:

Privacy Officer: Jean Pierre Levac. JPL SERVICES-CONSEILS ET SOLUTIONS WEB INC., doing business as JPL Digital Growth Group and as SequrIT. 68 montée Tourlognon, Baie-Saint-Paul, Québec G3Z 2E8, Canada. Email: privacy@jplsolutions.ca.

For general inquiries not related to privacy, use the contact form at sequrit.ca or write to growth@jpldigital.ca.

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