Déclaration de confidentialité (CA)

1. Person in Charge of Processing

This privacy policy is published by Lanaudière Économique (hereinafter "we," "us," or "our"), a nonprofit organization operating in the Lanaudière region of Quebec. We are subject to Quebec Law 25 — formally known as An Act to modernize legislative provisions as regards the protection of personal information (S.Q. 2021, c. 25) — which governs how we collect, use, disclose, and protect the personal information of anyone who visits our website or interacts with our organization.

This policy applies to all personal information collected through our website and through any other means by which you interact with us. By using our website, you acknowledge that you have read and understood this policy.

2. Personal Information Collected

We collect only the personal information that is reasonably necessary for the purposes described in this policy. The categories of personal information we collect are as follows:

  • Navigation and device identifiers: IP address, device identifiers, pages visited, session duration, approximate geographic location, and browsing behavior. This information is collected automatically when you visit our website.
  • Consent preferences: Your cookie consent choices (stored as a preference record tied to your browser session). This information is collected and managed by our consent management platform.

We do not knowingly collect sensitive personal information such as health data, financial account numbers, or government-issued identification numbers through our website.

3. Purposes of Processing

We use the personal information we collect for the following purposes:

  • Consent management (Essential — legal basis: legal obligation and legitimate interest): We record and honor your cookie consent choices using Moelleux, a consent management platform operated by Horizon-Cumulus (9322-8310 Québec inc.), based in Joliette, Quebec. This is strictly necessary for us to comply with Quebec Law 25's consent requirements. A preference cookie named moelleux_{site_key} is stored in your browser for up to 13 months to remember your choices. Your IP address and consent preferences are stored in Quebec (OVH, Beauharnois, Quebec).
  • Audience measurement and website improvement (Analytics — legal basis: consent): With your consent, we use Google Analytics 4 to understand how visitors use our website — which pages are visited, how long sessions last, and general navigation patterns. This helps us improve the content and structure of our site. Google Analytics 4 collects device identifiers, IP address, pages visited, session duration, browsing behavior, and approximate location. This data is transferred to Google's servers in the United States. You may withdraw your consent at any time using the cookie preference tool available on our website.

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects.

4. Third Parties and Processors

We share personal information only with the third-party service providers listed below, and only to the extent necessary to fulfill the purposes described in this policy. We do not sell your personal information.

Service Purpose Category Transfer Outside Quebec
Moelleux (by Horizon-Cumulus) Cookie consent management and privacy policy hosting. Consent records and the policy itself are hosted in Quebec (OVH, Beauharnois). Essential No — data remains in Quebec
Google Analytics 4 Audience measurement and visitor behavior analysis. Analytics Yes — United States (see Section 5)

5. Transfers Outside Quebec

Quebec Law 25 (section 17) requires us to be transparent about any transfer of personal information outside Quebec and to ensure that the information receives adequate protection in the destination jurisdiction.

Google Analytics 4 (United States): When you consent to analytics cookies, your navigation data (including device identifiers, IP address, pages visited, session duration, browsing behavior, and approximate location) is transferred to and processed by Google LLC on servers located in the United States. The United States does not have privacy legislation that is considered equivalent to Quebec Law 25. Google relies on standard contractual clauses and its own data processing terms to provide contractual safeguards for this transfer.

Prior to enabling Google Analytics 4, we conducted a Privacy Impact Assessment (PIA — also known in Quebec as an évaluation des facteurs relatifs à la vie privée, or EFVP) to evaluate the risks associated with this cross-border transfer and to confirm that appropriate safeguards are in place, as required by section 17 of Quebec Law 25.

All other personal information we collect — including consent records managed by Moelleux and any business communications handled through Horizon-Cumulus Email — is hosted and processed in Quebec.

6. Retention Period

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.

Data Type Retention Period Justification
Cookie consent preferences (Moelleux) 13 months Regulatory best practice for consent records; allows us to honor your choices without asking again on every visit.
Analytics data (Google Analytics 4) Up to 14 months (Google default, configurable) Audience measurement and trend analysis; retained only as long as needed to produce meaningful reports.
IP address (server logs) Up to 12 months Security monitoring and troubleshooting of technical incidents.

Once the applicable retention period expires, personal information is securely deleted or anonymized so that it can no longer be associated with an identifiable individual.

7. Your Rights

Under Quebec Law 25, you have the following rights with respect to your personal information. To exercise any of these rights, please contact our Person responsible for the protection of personal information (see Section 8).

  • Right of access: You may request a copy of the personal information we hold about you, along with information about how it is being used and with whom it has been shared.
  • Right of rectification: If any personal information we hold about you is inaccurate, incomplete, or ambiguous, you may ask us to correct it.
  • Right of erasure (right to be forgotten): You may ask us to delete personal information about you when it is no longer necessary for the purposes for which it was collected, subject to any legal retention obligations that may apply.
  • Right to portability: You may request that we provide you with the personal information you have provided to us in a structured, commonly used, and machine-readable format, or that we transmit it directly to another organization where technically feasible.
  • Right to withdraw consent: Where we rely on your consent as the legal basis for processing (for example, analytics cookies), you may withdraw that consent at any time without penalty by using the cookie preference tool on our website. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

We will respond to your request within 30 days of receipt, as required by Quebec Law 25.

If you are not satisfied with our response, you have the right to file a complaint with the Quebec Information Access Commission (CAI) at www.cai.gouv.qc.ca.

8. Person Responsible for the Protection of Personal Information

In accordance with section 3.1 of Quebec Law 25, Lanaudière Économique has designated a Person responsible for the protection of personal information who oversees compliance with this policy and handles requests related to your personal information.

You may contact this person for any question, concern, or request relating to your personal information or to this privacy policy. We are committed to responding within 30 days of receiving your request, as required by Quebec Law 25.

9. Effective Date and Versioning

This privacy policy takes effect on 17 juin 2026 and corresponds to version 1.

We may update this policy from time to time to reflect changes in our practices, in the services we use, or in applicable law. When we make material changes, we will update the effective date and version number above. We encourage you to review this policy periodically. Continued use of our website after a revised policy has been posted constitutes your acknowledgment of the updated terms.