Privacy Policy

0. Context

Abrasifs JJS Inc. values everyone’s right to privacy. This is why this Privacy Policy, aimed at ensuring the protection of your integrity and your right to protect your personal information, has been put in place. The purpose of this policy is to govern the use and collection of information on our website (https://www.jjscanada.ca/) and any information that you provide to us on a voluntary basis in the course of your participation in any service offered by JJS Abrasifs Inc., subject to any refusal that you may duly express to us in this regard.

For the above reason, Abrasifs JJS Inc. diligently complies with the requirements of Bill 25 and therefore adheres to the definitions related thereto.

The term “privacy incident” is defined as any unauthorized access, use or disclosure of personal information, as well as the loss or other breach of personal information.

In addition, the term “personal information” is therefore defined as any information, alone or in combination with other available information, about an individual that can be used to identify that individual, such as information about the individual’s financial, lifestyle or health situation.

However, an individual’s name, as well as their business contact information, i.e., title, address, telephone number and business email address are not personal information.

Personal information must be protected regardless of the nature of its medium and regardless of its form: written, graphic, audio, visual, electronic or otherwise.

1. Our responsibility

Abrasifs JJS Inc. is responsible for all personal information in its possession or control, including personal information that we receive directly – for example, from our customers and staff.

Abrasifs JJS Inc. adheres to good cybersecurity practices by conducting, in conjunction with our IT partner, a cyber risk management strategy aimed at applying a series of risk mitigation measures for our personal information.

We have also assigned a privacy officer, Ms. Isabelle Ekani-Onambélé, and have delegated certain cybersecurity responsibilities to our IT partner through a service offer related to Bill 25. The fulfillment of this service offering ensures the protection of privacy and personal information on behalf of JJS Abrasifs Inc. We have also posted on our website and /or informed our staff of the existence of our Privacy Policy and our Governance Policies and Practices regarding personal information, as well as the role that each must play in ensuring the protection of the personal information of our clients and team members. If you have any questions about our privacy practices, please do not hesitate to contact our Privacy Officer at ionambele@jjscanada.ca or 418-836-0557.

2. Purposes for Collecting Personal Information

Personal Information Regarding Employees and Potential Job Applicants

Abrasifs JJS Inc. collects, uses and discloses personal information about its team members in order to comply with laws, regulations and professional standards; provide them with benefits; administering performance management tools; administering, managing, monitoring and enforcing the programs and policies of Abrasifs JJS Inc. and its relations with its employees; and, generally, establishing, managing or terminating employment or association relationships.

Abrasifs JJS Inc. may also collect, use and disclose personal information about individuals who apply for employment with them. In the event that we are not in the hiring period or that your application for employment is not considered for any other reason, the information you send us will be immediately destroyed without even being consulted.

Although unusual, personal information may be collected without the knowledge of the individuals concerned, always to the extent permitted by law.

Customer Personal Information

Abrasifs JJS Inc. collects, uses and discloses most of its clients’ personal information in the course of providing services to them. This information is collected, used and disclosed in accordance with the laws and regulations in force in Québec, including Bill 25. Abrasifs JJS Inc. may also collect, use and disclose personal information about current or prospective customers for the purposes of business development or to improve our services and procedures.

Personal information may be collected without the knowledge or express consent of individuals, to the extent permitted by law.

3. Consent

Abrasifs JJS Inc. ensure, with the signature of a consent request, that it obtains the express consent of the individuals concerned before collecting, using or disclosing personal information, except as authorized or required by law.

By signing the consent request, if a customer provides us with personal information about a third party, that customer declares and warrants that they have obtained the third party’s consent to allow us to collect, use and disclose their personal information in the manner described in the Services Agreement.

The forms used to provide Abrasifs JJS Inc. staff with human resources services identify the purposes for which personal information is collected and to whom it may be disclosed.

Potential candidates for positions in the company are also informed of the purposes for which their personal information is collected, used and disclosed.

In the context of administering a survey, promotion and/or contest, Abrasifs JJS Inc. may use, subject to any refusal expressed on your part, personal information, as it will be provided to it on a voluntary basis, by sending message(s) or following participation in a survey, promotion or contest. The information collected for this purpose will primarily be used to contact you if you win. Promotions and/or contests offered by Abrasifs JJS Inc. may be subject to specific rules that will be more fully described in the context of the launch of any promotion or contest.

4. Collecting limitations

Abrasifs JJS Inc. collects, by legitimate and lawful means, only the personal information that it can reasonably deem necessary to meet its legal obligations and provide its services.

5. Limitation of Use and Disclosure

Abrasifs JJS Inc. uses and discloses your personal information only for the purposes for which it has obtained your consent, or as permitted or required by law. If Abrasifs JJS Inc. requires the use or disclosure of an individual’s personal information for a purpose not previously disclosed, Abrasifs JJS Inc. will first seek the consent of the individual concerned, unless the law requires or permits the use or disclosure of the personal information without the consent of the individual.

We retain personal information for as long as necessary for the fulfillment of the identified purposes, except as permitted or required by law. All records that contain personal information about employees and customers of Abrasifs JJS Inc. are destroyed when such information can no longer reasonably be considered necessary for legal, regulatory or administrative purposes.

6. Accuracy

In order to ensure that the personal information collected is relevant to the purposes for which it is used, JJS Abrasifs Inc. makes reasonable efforts to maintain the integrity of individuals’ personal information and to update it regularly.

Individuals affected by the personal information collected must contact the Privacy Officer in writing to make a request for rectification in the event that a change is required to their personal information held by the company.

7. Transparency

Abrasifs JJS Inc. may make information available to interested persons upon request about  its Privacy Policy and  its Governance Policies and Practices regarding  personal information. Abrasifs JJS Inc. is also committed to responding to any written request for information submitted to the Privacy Officer regarding matters related to its policies and practices relating to the management of personal information.

8. Access

Individuals have the right to inspect and obtain a copy of the personal information in our possession. To do so, they should contact the Privacy Officer.

The right to access personal information is subject to certain legal restrictions, and we will take reasonable steps to verify the appropriateness of the request and the identity of an individual before granting such access.

In most cases, applicants will receive a response within 30 days. If an individual has any concerns about access, we encourage them to contact the Privacy Officer at ionambele@jjscanada.ca or 418-836-0557.

9. Complaints

We know that it is important to ensure the protection of the privacy and personal information of the individuals involved. If you have any questions or concerns about your privacy and personal information, and the role we play in doing so, please contact our Privacy Officer at ionambele@jjscanada.ca or 418-836-0557.

Abrasifs JJS Inc. has put in place a procedure for receiving and handling complaints about this policy and its personal information handling practices. An individual about whom Abrasifs JJS Inc. has personal information may complain about non-compliance with this policy. Any complaint regarding the protection of personal information should be directed to the Privacy Officer at the address listed above. In most cases, applicants will receive a response within 30 days.

If an individual is not satisfied with Abrasifs JJS Inc.’s response to a complaint or with JJS Abrasifs Inc.’s policies and practices regarding the handling of personal information, he or she may file a complaint with the “Commission d’accès à l’information du Québec” on the commission’s website: https://www.cai.gouv.qc.ca/a-propos/nous-joindre/ .

10. Other documents related to Bill 25

Several other documents have been created in accordance with the new requirements of Bill 25. The following documents were drafted in collaboration with our IT vendor’s cybersecurity team:
          • Governance Practices and Policies regarding personal information
                   – This document may be made available, with an approval, upon request to any person making the request.
           • Privacy Incident Response Plan
                   – This document is available upon request to any employee or party concerned. 

11. Policy Updates

This policy shall be reviewed every three years. It will also need to be updated with any substantial changes to legislation or regulatory requirements.

 

Updated on December 1st, 2023