Privacy Notice

The following is a summary of the privacy practices of the Fonds that are set out in this notice:*

What data we collect and how we use it

We collect your name, address, email address, age as well as financial and tax information in order to determine your eligibility for and manage your products and services, verify your identify, and prevent and detect fraud.

The Fonds may also collect data when you visit our websites, including your computer’s identification number (IP address) for personalized advertising and survey purposes.

Your consent

The Fonds wants to be transparent and to clearly inform you at the time of collecting your personal information how such data will be used in order to obtain your consent.

You may withdraw your consent to your personal information being used for purposes that are not essential to the management and administration of your products and services, such as for targeted advertising and survey purposes.

Security

Although the Fonds applies security measures to protect your personal information and reduce the risk of a breach, a certain risk remains and we cannot fully guarantee (100%) that your personal information will not be the subject of a data breach if our safeguard measures are breached. If you have reason to believe that your personal information has been compromised, please contact the office of the Chief Privacy Officer.

Your rights

You can view the personal information the Fonds has collected about you, verify its accuracy and modify it, if necessary, by sending your request to the Chief Privacy Officer, whose contact information is provided below.

To contact the Privacy Officer

The Chief Privacy Officer is responsible for ensuring the protection of personal data in the Fonds. The Privacy Officer can be contacted at:

  • 545 Crémazie Boulevard East, Montréal, Québec, Canada H2M 2W4.
  • prp@fondsftq.com

1. Why this Notice?

This privacy notice (the "Notice") sets out the privacy protection policies and practices applied by the Fonds de solidarité des travailleurs du Québec (F.T.Q.), FlexiFonds de solidarité FTQ Inc., Fonds locaux de solidarité FTQ, Fonds régionaux de solidarité FTQ, and Fonds immobilier de solidarité FTQ (together, the "Fonds").[1]

2. What personal information do we collect?

The Fonds only collects personal information that is necessary to carry out its activities, including information regarding your identity, such as your name, address, social insurance number, demographic information, such as your gender, age, tax information, information required for a redemption as well as information relating to the use of our websites.

3. Why do we collect your personal information?

The Fonds collects, uses and communicates your personal information for the purposes for which you have consented or as permitted by law. The purposes for which the Fonds collects your personal information are specified at the time it is collected, such as when a person completes an application form. You may request your personal information at any time.

The purposes for which the Fonds collects your personal information include:

  • confirming your eligibility for our products and services; 
  • managing your products and services; 
  • confirming your identity, verifying the accuracy of and updating your personal information;
  • assessing your integrity and skills as officer, shareholder or guarantor of a corporation in connection with an investment project;
  • preventing, detecting and controlling fraud and illegal activities such as money laundering or cyber threats;
  • complying with our regulatory and legal obligations;
  • communicating with you by telephone, mail or email;
  • managing our websites and online services, compiling usage trends and statistics, assessing performance and improving our services;
  • personalizing and adapting the browsing experience to your needs;
  • offering targeted advertising and surveys.

4. How will your personal information be collected?

Directly from you

Most of the personal information that we collect is provided directly by you, such as when you:

  • communicate with us (in person at a service point, by telephone, by email, etc.); 
  • apply for products and services of the Fonds;
  • send a request related to the Fonds (additional subscription, redemption request, etc.); 
  • provide your information as officer, shareholder or guarantor of a corporation in connection with an investment project;
  • provide comments or respond to surveys.

From third parties

The Fonds can also collect your personal information from third parties with your consent or as authorized by law.

Through our website and online services

The Fonds can also collect information when you visit our website or connect to our online services (My Online Account, Espace employeur or Espace RL), including your computer’s identification number (IP address).

An Internet Protocol (IP) address is a number or email address assigned by a user’s internet service provider to their devices. It indicates the origin and destination of the data.

The Fonds and some of its partner advertising networks may also collect other information about the use of its website by using small data files commonly known as "cookies." Cookies make it possible to recognize users when they access and browse our website. The Fonds and its partner advertising networks, as appropriate, use cookies to track a user’s browsing interests while on the website for targeted advertising purposes, in order to display banners when that user is visiting other websites. When required, the Fonds will request your consent before collecting such information.

5. Under what terms can we collect, use and share your personal information?

The Fonds collects, uses and shares your personal information on condition that it has obtained your consent in accordance with the applicable requirements, or without your consent as required by law, such as in the context of a penal or criminal proceeding.

6. How and when can you withdraw your consent?

You can withdraw your consent to your personal information being used by the Fonds for purposes that are not essential for the management and administration of your products and services, such as to deliver targeted advertising and surveys. If you wish, the Fonds will stop using your data for such purpose.

It is, generally, not possible to withdraw your consent to the use of your personal information for the purposes of the management and administration of your products and services without terminating your contract.[2]

Any request to withdraw consent must be sent to the office of the Chief Privacy Officer, whose contact information can be found in question 12.

7. Who do we share your personal information with?

Your personal information can only be accessed by staff members of the Fonds who require access to perform their duties.

The Fonds can share your personal information to partners or service providers under a service contract, or to public authorities, such as to:

  • any person acting for you with your consent; 
  • our agents and local representatives;
  • our service providers, such as advertising and technology solution providers;
  • your employer (if you have applied for Fonds products through your employer);
  • any public investigative body or law enforcement agency, such as authorities responsible for criminal and penal prosecutions;
  • the Commission d’accès à l’information du Québec (the authority responsible for the protection of personal data) and all persons legally authorized to obtain such data, such as securities commissions, self-regulatory organizations and the Financial Transactions and Reports Analysis Centre of Canada.

8. How do we retain your personal information and for how long?

The Fonds uses systems and technology service providers that safeguard and protect the confidentiality of your personal information.

Your personal information is usually stored in Québec. However, it is possible that the disclosure of personal information to certain technology solution providers could result in such data being transferred outside Québec. In such a case, the Fonds will verify compliance with the applicable personal data protection laws and practices in the given jurisdiction and ensure that your personal information is properly protected.

The Fonds keeps your personal information for the period necessary to fulfill the purposes for which it was collected and in accordance with the applicable legal retention periods, which may sometimes justify a longer retention period. The destruction or anonymization (removing personally identifiable information) shall be safely carried out.

Anonymization involves irreversibly modifying personal data so that it is impossible to identify a given individual from their data.

9. How do we ensure the protection and security of your personal information?

The Fonds applies security measures dependent on the sensitivity of your personal information for the purposes of protecting your personal information against loss or theft and against any unauthorized use.

The security measures applied by the Fonds include:

  1. Organizational measures, such as implementing a protection framework for the Fonds’s information assets including your personal information based on recognized standards, continuous security validation as well as regular information security awareness and training for the Fonds’s employees.
  2. Physical measures, such as restricted access to the Fonds offices and implementing passwords or two-factor authentication mechanisms to access the Fonds’s IT equipment, systems and internet networks.
  3. Technical measures, such as restricting access to your personal information to only those who need it to perform their duties, putting in place alerts when suspicious activity is detected and securely encrypting communications.

Although the Fonds applies a multitude of security measures to properly protect your personal information and reduce to a minimum the risk of any breach, a certain risk remains and we cannot fully guarantee (100%) that your personal information will not be the subject of a data breach if our security measures are breached. If you have any reason to believe that any personal information has been compromised, please contact the office of the Chief Privacy Officer, whose contact information can be found in question 12.

10. What are your rights with regard to your personal information?

The Fonds respects your legal rights with respect to your personal information and therefore applies procedures when processing the following requests:

Accessing and correcting your personal information: You can view the personal information that the Fonds has collected about you, verify its accuracy and modify it if necessary, subject to certain exceptions prescribed by law. Any requests to access or correct personal information are free of charge. However, reasonable fees may be charged to transcribe, reproduce or transmit your personal information. Your request to access or correct personal information must be sent to the office of the Chief Privacy Officer, using the contact information provided in question 12, and such requests will be processed no later than thirty (30) days following the date your written request is received by the Fonds.

Automated processing: If the Fonds implements a decision-making process that is based solely on the automated processing (without human involvement) of personal information, for example, a process with a specific effect on a person (termination of a contract, employment eligibility, etc.) that relies solely on an algorithm, you will be informed that you are the subject of such a process, the decision that was rendered and your right to submit comments regarding that decision. If requested, you can also be informed of the following elements:

  1. the personal information used to render the decision;
  2. the reasons that led to the decision; 
  3. your right to have the personal information used to render the decision corrected.

Data portability [To take effect in September 2024]: You can obtain, upon request, a copy of your personal information that was collected. If your personal information was computerized, you can ask that it be communicated to you in a structured, commonly used technological format if this does not involve any serious practical difficulties.

11. What if I have a question or want to file a complaint about my personal information?

Any questions regarding your personal information or complaints of any non-compliance with the principles set out in the Notice should be directed to the office of the Chief Privacy Officer, whose contact information can be found in question 12.

12. How do I contact the Fonds’s Privacy Officer?

The Chief Privacy Officer is responsible for ensuring the protection of your personal information.

Contact information for the office of the Chief Privacy Officer is as follows:

Mailing address: 545 Crémazie Boulevard East
Montréal, Québec, Canada H2M 2W4

Email address: prp@fondsftq.com

13. Can this Notice be amended and, if so, how can I find out about it?

The Fonds may from time to time amend the content of this Notice. In the event of any amendment, a notice will be posted on the websites of the Fonds and in our communication tools.

[1] This notice does not apply to employees and other personnel of the Fonds, including local representatives who are subject to an internal policy.

[2] The circumstances giving rise to a purchase-by-agreement, a redemption or to terminate contract are provided for in the simplified prospectus of Fonds de solidarité.

* As at September 22, 2022