In effect as of: September 26, 2023
Preamble
The Parc olympique is responsible for protecting the personal information we hold, whether we retain this information ourselves or via a third party, regardless of the form this information takes. To this end, the Parc olympique has taken security measures to protect this personal information proportional to its sensitivity and has put policies and rules in place to implement these.
This Olympic Park Privacy Policy (the “Policy”) covers rules of good governance that aim to determine the principles that the Parc olympique and our representatives should follow with respect to the handling of personal information. As such, the Policy sets forth the obligations of the Parc olympique under the Act respecting Access to documents held by public bodies and the Protection of personal information, RLRQ, c. S-2.1, (the “Act respecting access”), notably when it comes to the roles and responsibilities of those responsible for the access to and protection of personal information, the information access committee, the protection of personal information and information security (the “Access committee”), and Parc olympique employees.
1. Commitment
The Parc olympique is committed to protecting the privacy of your personal information. To this end, this Policy informs you of the type of personal information collected, the manner and purposes for which it is collected, and how it is shared, converted, destroyed, or anonymized.
2. Definitions
“Sports Centre”: Means the Centre sportif du Parc olympique.
“Access committee”: Means the Parc olympique’s Committee on access to information, the protection of personal information, and information security.
“Client”: Means any person who wishes to subscribe or sign up to one or several services provided by the Parc olympique.
“Pay station”: Means the payment terminals located at the entrance and exit of parking lots as well as the payment terminals located throughout the Olympic Park site.
“Act respecting access”: Means the Act respecting Access to documents held by public bodies and the Protection of personal information, RLRQ, c. A-2.1.
“Service provider(s)”: Means the following companies:
- Solutions Orbility Canada performs servicing and maintenance on the physical, technical, and digital equipment needed to manage services provided by the Olympic Park for Parking clients, as well as their subcontractor Siclade Informatique, and their “Axigap” software is used as a transactional site for online Parking services.
- Active Network Ltd. and their “ActiveNet” software is used as a transactional site for registering clients at the Parc olympique Sports Centre.
“Policy 04”: Means the Parc olympique policy on the management framework for information security.
“Personal information”: Means all information concerning a physical person that directly or indirectly can be used to identify that person, including their street address, email address, phone number, and any financial information.
“Parking”: Means all parking lots available within the Parc olympique site.
“Website”: Means the Parc olympique’s website, available at https://parcolympique.qc.ca/, where a Client can create a Client Account in order to purchase one or more services provided by the Parc olympique.
3. Consent
We collect and use your personal information within the framework of our interactions with you, whether it’s for services provided by the Parc olympique, activities provided by the Parc olympique, when using our online platforms, for example accessing or visiting the Parc olympique’s website at https://parcolympique.qc.ca/, creating a Client Account on our website, using the Parc olympique’s intranet or social media (the “Sites”), or when you communicate with us in other ways. You agree to this Policy and consent that your personal information will be collected, used, communicated, stored, and destroyed in accordance with the details outlined in this Policy.
The personal information requested is necessary in order for the Parc olympique to provide you with services and activities. You understand that certain features of our Sites and services would not be available or would be limited should you refuse or remove your consent for this Policy.
Only personal information needed to achieve a specific and identifiable goal linked to the Parc olympique will be collected. Your consent is provided for specific means and is expressly stated when it concerns sensitive information.
The Parc olympique will not collect any personal information from people under 14 years of age without the verified consent of their legal guardian.
4. Your right to withdraw consent
At any time, you can withdraw your consent to the communication or use of information collected. To do so, you must write to the Privacy Officer at the coordinates found in the “Contact Us” section. You request will be processed within twenty (20) days.
You can also unsubscribe by clicking on the box provided in the Client Account section.
5. Parc olympique member roles and responsibilities
5.1 Privacy Officer. The Parc olympique Privacy Officer ensures the enforcement and implementation of these rules and obligations by the Parc olympique when it comes to protecting private information. They also participate in the prevention and proper management of confidentiality issues as well as the complaints process, and issue the attestations and confirmations required by the Act respecting access.
5.2 Committee on access to information, the protection of personal information, and information security
The Parc olympique has created an Access Committee that’s responsible for ensuring that the policies, directives, procedures, and other internal rules as well as all related laws and regulations are adhered to by employees. The Access Committee reports to the Chief Executive Officer and is made up of individuals responsible for access to documents and the protection of private information as well as anyone whose expertise is required, including the Chief Information Security Officer (the “CISO”) and the Incident Management Officer (the “IMO”). Refer to the Parc olympique policy on the management framework for information security (the “Policy 04”), which describes their roles and functions in detail.
5.3. Employees. The Civil Code of Quebec contains provisions that imposes on employees certain obligations governing honesty and the protection of confidential information:
Art. 2088. The employee is bound not only to perform his work with prudence and diligence, but also to act faithfully and honestly and not use any confidential information he obtains in the performance or in the course of his work.
These obligations continue for a reasonable time after the contract terminates and permanently where the information concerns the reputation and privacy of others.
6. The purpose of collecting and using personal information
The Parc olympique can collect personal information for the following reasons, as well as for other purposes authorized by law:
- Your name, email address, and CV as well as any other personal information provided by email or via the Career Page on our website in order to hire personnel as well as process and select applications related to the position requirements.
- Your name, email address, and any other personal information provided when you communicate with the Parc olympique to obtain information related to the services we provide for client-service purposes.
- All personal information requested when creating and updating a Client Account on our website: Client’s name, address, email address, credit-card information, and transaction history. For a Client Account created to use the Parking services, the Parc olympique also collects and uses the vehicle’s model, colour, and licence plate. The Parc olympique collects and uses this personal information for client-service purposes, notably to allow Clients to purchase services online and better manage their needs and requests. The Parc olympique may also use this information for the statistical analysis of network usage.
- A Client’s name and email address in order to send, via electronic messages, news about the Parc olympique, exclusive offers, contests, promotions, and/or survey requests. These communications are carried out in compliance with all applicable laws. No promotional email will be sent to a Client without their prior consent, and they may remove their consent at any time by using the “unsubscribe” mechanism included in emails from the Parc olympique.
- The images of anyone captured and recorded by security cameras installed on the site, as well as in the Parc olympique installations for the purposes of security, management, and controlling access to Parking spaces.
- Audio recordings of a Client’s request for information or assistance, captured and recorded by the intercom system at the Parking entrance and exit terminals for client-service purposes (technical assistance and client-service improvement) for Parking lots.
- The licence plate of any vehicle that enters or exits the parking spaces, recorded by licence-plate readers at the entrance and exits of Parking lots, for the purposes of managing and controlling access to Parking lots and security.
7. Links to other websites
Websites suggest relevant links to other governmental and non-governmental websites. Any information exchanged is no longer subject to this Policy, but that of the website visited.
8. Use of cookies
On the websites, cookies can be used to make navigation simple, easy, and efficient. Users allow the use of cookies by default. You can also deactivate this function. Note, however, that this risks depriving you of certain website functionalities. You can also manually delete traces of your navigation stored in your history. Information automatically transmitted between computers includes pages visited, time spent, and your IP address. They are collected only for technological requirements inherent to online navigation.
9. Other data collected automatically
When you visit our websites, your browser transmits data to our server. This data is collected and stored internally by the Parc olympique or a third-party firm on behalf of our organization. This may include: the visitor’s IP address, the URL of the website that led you to ours, the date and time of the visit, pages visited, and information on the browser used. To improve the quality of user experience on our websites, different technological methods may be used. These methods may entail an automatic collection of data by the Parc olympique or third-party firms on behalf of our organization.
10. The use of targeted advertising technology
Our websites use technological methods for targeted advertising. This technique aims to target certain visitors who are interested by the content of our websites in order to present our advertising to them during their online navigation.
11. Cybermetrics
Cybermetrics is a method of collecting and measuring data with the goal of evaluating user behaviour on websites. The Parc olympique mainly uses cybermetric data to compile statistics and run reports on user navigation on our websites. Information collected by this tool includes: pages viewed, date, time, frequency and length of visits, links clicked, geographic position, type of operating system used, language, name of web provider, and IP address.
12. Use of web beacons
Web beacons are images integrated in our websites or emails. They are used primarily for statistical analysis. This method can also be used to follow and/or measure behaviour.
13. Posting comments on our websites
The Parc olympique regularly, albeit not continuously, moderates our websites. The Parc olympique never modifies comments. However, The Parc olympique reserves the right to hide certain comments, or delete comments that incite hatred or violence, contain personal information that enables a third party to be identified (address, phone number, email, etc.), or contains discriminatory remarks based on, amongst other things, race, gender, religion, nationality, or sexual orientation. The Parc olympique would like to remind users of the public nature of their comments on our websites, that their comments can be reproduced by third parties on other websites, and that the Parc olympique assumes no responsibility for the reuse of this information. Any external links suggested in the comments are not the responsibility of the Parc olympique.
14. Security measures
The Parc olympique has several measures in place to protect your personal information from access, use, unauthorized communication, the loss of personal information, and any other breach of such information, including:
- Limited access: Access to personal information is only provided to Parc olympique employees who require this information to perform their work. The Parc olympique takes reasonable steps to ensure these employees respect the confidential nature of the personal information they have access to.
- Restricted access:Access to personal information by authorized personnel is restricted by different access profiles. Depending on the sensitivity of the personal information, the Parc olympique applies authorization criteria that meets the highest security requirements.
- Servers: In general, the Parc olympique keeps personal information on servers located in Quebec that only we have authorized access to. However, it is possible that personal information is communicated outside of Quebec, for example when the Parc olympique has agreements with third parties, including Service Providers outlined above, whose servers are located in Canada or other countries.
- Employee training: The Parc olympique fosters awareness among employees when it comes to the privacy and confidentiality of these regulations and policies as well as through the following training program:
- After every hiring, ensures employees follow training on the introduction to the protection of personal information and cyber defence (mandatory videos).
- Sends awareness emails from the Privacy Officer.
- Sends awareness emails from the Information Technology Officer, as well as emails reminding employees of the risks, threats, and best practices for passwords, emails, the clean desk principle, physical safety, online privacy, protecting personal information, malicious codes, identity theft, access control, and so on.
- Upon request, meets with employees to discuss challenges to protecting personal information, including consent as well as information security.
15. Sharing of personal information
All Parc olympique employees and representatives can access personal information held by the Parc olympique if it is required to perform their work. An employee who requests a third party to collect personal or sensitive information on behalf of the Parc olympique must ensure that this third party complies with the provisions of Section 65 of the Act respecting access.
From time to time, the Parc olympique may communicate personal information we have compiled to third parties, including foreign service providers, when this is necessary to carry out a mandate or in the performance of a written contract that includes conditions stipulated by law. The Parc olympique may communicate your personal information, notably to:
- Commercial partners and third parties with which the Parc olympique enters into business relationships (including software designers and data processing and transaction Service Provides such as Solutions Orbility, Siclade Informatique, and Active Network Ltd.) in order to provide you with services.
- A financial institution, confidentially and only within the framework of the assignment of a right to receive or make a payment.
When confidential information is communicated within the framework of a mandate, or service/company contract, the Parc olympique will ensure that the following conditions are met:
- The mandate or contract is in writing.
- The mandate or contract contains a confidentiality clause and indicates the provisions of the Act respecting access that apply to the communication of personal information as well as the steps taken to ensure the confidential nature of that information, so that it is only used in the execution of a mandate or contract and will not be retained when the mandate/contract is completed.
- The third party and any of its employees who have access to this information must sign a confidentiality agreement before being given access to any personal information from the Parc olympique.
It is possible that some of your personal information may be transferred outside of Quebec and Canada. In such cases, the Parc olympique will ensure that all personal information is adequately protected and will only share personal information that’s needed to carry out our contracts.
The Parc olympique reserves the right to use or disclose personal information if we feel that the use or disclosure is needed to comply with legal obligations, safeguard rights, comply with any motion or request from a competent tribunal, or any other reason stipulated by the Act authorizing or demanding the disclosure of your personal information.
16. Security measures related to surveys
If you respond to a survey, the Parc olympique will know your opinion or response or any other information you choose to provide. It is possible that we use the information gathered from our survey results and share them on our website or other platforms. We will not use this information to identify you personally, and will process this data for statistical purposes and/or to optimize the client experience at the Parc olympique. The purpose and necessity to carry out these surveys as well as their ethics, notably when it comes to obtaining sensitive information, are taken seriously by the Parc olympique, who set the content and conditions. As well, survey answers remain anonymous.
17. Privacy impact assessments (PIAs)
The Parc olympique will assess the privacy impact of everyone involved, notably in the following contexts:
- Before engaging in any acquisition, information system development/redesign, or electronic service delivery project involving personal information.
- Before communicating personal information without the consent of those concerned to a person or organization that wishes to use this information for study, research, or statistical-production purposes.
- Before communicating personal information outside of Quebec, or entrusting to a person or organization outside Quebec the task of holding, using, or communicating this information on behalf of the Parc olympique.
18. Storing personal information
The Parc olympique will store personal information for the purposes outlined above for as long as it is needed to achieve those purposes.
As well, the Parc olympique may retain your personal information for an additional period if storing this information is reasonably necessary to meet our legal obligations, resolve any dispute, prevent any failure to comply with applicable laws, or to comply with the terms outlined in this Policy.
Once the purposes for which the storage of personal information have been satisfied, the Parc olympique must destroy or anonymize this information in order to use it for the purposes of public interest in accordance with the terms stipulated by the Act respecting access or any other act.
19. Access and correction
The Olympic Park will ensure that all personal or sensitive information we collect is up-to-date, accurate, and complete. To do so, our employees must document the last date on which the information has been corrected, modified, added to, or removed.
Anyone who has provided personal information can have free access to that information, within the limits outlined by law, by requesting a copy for a reasonable fee which they will be informed of beforehand. They may also request to rectify any personal information that’s inaccurate, incomplete, ambiguous, or unauthorized by law.
To exercise your right to access and correct personal information, you must make a verbal or written request and prove your identity as the person in question. The request must be addressed to the Parc olympique Privacy Officer at the following email address:
Mr. Denis Privé,
Privacy Officer
Denis.privé@parcolympique.ca
20. Complaint process
In compliance with the obligations outlined in the Act respecting access, we have established a complaint process for our privacy policy.
Anyone who is the subject of personal information that has been collected, used, communicated, or stored by the Parc olympique can lodge a complaint with the Privacy Officer in the event of a breach of obligations outlined in this Policy. The complaint must be in writing and indicate the nature of the alleged facts, the name of the person or persons involved, the date the incident took place, and the expected outcome.
The Privacy Officer will acknowledge receipt of the complaint and process the complaint within twenty (20) days. They will investigate the alleged facts themselves or outsource the investigation to someone else, notably an external resource. They will communicate with due diligence by writing to the person who lodged the complaint, without the obligation of divulging the results of the inquiry. The Parc olympique will examine all privacy complaints and take appropriate measures to resolve them.
For any such request, we invite you to communicate with Parc olympique Privacy Officer at the following email address:
Mr. Denis Privé,
Privacy Officer
Denis.privé@parcolympique.ca
21. Changes to the Policy
The Parc olympique can update and modify this Policy at any time.
If the Policy is modified, an amendment notice will be published on the Parc olympique website, indicating the date these modifications come into effect. The Parc olympique will call your attention to this modification notice by email or any other means.
The updated Policy, previous version, and modification notice will be available and accessible on the Parc olympique website.
The Parc olympique recommends that you review this Policy periodically.
22. Contact us
Mr. Denis Privé
Privacy Officer
Denis.privé@parcolympique.ca
4545 Pierre De-Coubertin Avenue
Montreal, Quebec H1V 3N7
514-252-4141 ext. 4643
23. When the Policy comes into effect
This Policy came into effect the day it was adopted by the CEO, on September 26, 2023. It was pre-approved by the Parc olympique Access committee on September 21, 2023.
Any modification or repeal of this Policy must be adopted by the CEO.
24. Discrepancies
In the event of any discrepancies or inconsistencies between this unofficial English translation and the French version of this Policy, the French version shall prevail.