Privacy and personal information protection policy
1. Introduction
Les Cuisines de l’Air Culin-Air Inc. is a Canadian company located in Quebec that provides logistics and catering services for airline meals. Respecting your privacy and protecting your personal information are very important to us. Therefore, we have implemented this Policy, which governs the collection, use, disclosure, retention, and destruction of personal information, whether collected by technological means or otherwise. This Policy also describes how we protect personal information and the process established for handling complaints.
2. Application and definitions
This Policy applies to Les Cuisines de l’Air Culin-Air Inc., including its officers, employees, consultants, and any other person who otherwise provides services to Les Cuisines de l’Air Culin-Air Inc.
It covers the personal information of customers (potential, current, or former), job applicants, employees (current or former), and any other individuals, including visitors to the website located at https://www.culinair.ca/ (the “Site”).
For the purposes hereof and as defined by the Act respecting the protection of personal information in the private sector (the “Act”), personal information is information that relates to a natural person and that allows, directly or indirectly, that person to be identified. Examples include first and last name, mailing address, email address, telephone number, gender, banking information, health information, ethnic origin, language, information relating to the use of our Site, including technical information about visits or any other information collected through cookies, and any other personal information that you consider useful to provide to us (the “Personal Information”). A person’s professional or business contact information and personal information that is in the public domain are not considered Personal Information.
BY PROVIDING PERSONAL INFORMATION TO LES CUISINES DE L’AIR CULIN-AIR INC. OR ITS SUPPLIERS, THROUGH OUR WEBSITE, BY PHONE, BY EMAIL, IN PERSON, OR BY ANY OTHER MEANS, YOU CONSENT TO THE COLLECTION, USE, DISCLOSURE, RETENTION, AND DISPOSAL OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS POLICY.
3. Consent, collect, usage, and communication
3.1 Consent
As a general rule, Les Cuisines de l’Air Culin-Air Inc. will obtain Personal Information directly from you, with your consent, subject to exceptions provided for by law. Personal Information will only be used for the purposes for which it was collected, unless we obtain your consent.
If you consent or when permitted by law, Les Cuisines de l’Air Culin-Air Inc. may also collect Personal Information from third parties.
Les Cuisines de l’Air Culin-Air Inc. will not collect, use, or disclose Personal Information without your consent unless it is authorized or required to do so by law.
Please note that you have the right to refuse to provide us with Personal Information. You also have the right, subject to reasonable notice and applicable legal and contractual restrictions, to withdraw your consent to the use of Personal Information already collected by contacting our Privacy Officer at the contact details provided in section 15. Refusal to provide information or withdrawal of your consent may prevent us from providing or continuing to provide you with our services or information about them.
IMPORTANT: If you provide us with Personal Information about other individuals, you represent that you have the authority to do so and, where applicable, that you have obtained the necessary consent, and you acknowledge that such information may be used in accordance with this Policy.
3.2 Collect and usage
Without limiting the scope of the following, Les Cuisines de l’Air Culin-Air Inc. will collect and use Personal Information for the purposes determined at the time the information is collected, subject to compliance with the Act. Collection will be limited to information that is necessary for the purposes determined.
Below is a non-exhaustive list of the information that Les Cuisines de l’Air Culin-Air Inc. may collect. With the exception of Personal Information about employees, job applicants, certain customers, and information that may be collected when you use our Site, the information collected and managed by Les Cuisines de l’Air Culin-Air Inc. is of a professional nature.
3.2.1 Users of the Site or interaction with us by email
When you browse our Site or interact with us via email, we may collect information about you as described below, some of which is collected automatically:
- When you submit an inquiry, we may collect information about you, such as your first and last name, email address, specific request, and information related to your use of our Site.
- Connection data, which may include your IP address, the pages you visit on the Site, the date and time of your visit to the Site, the address of the web page you visited before using the Site, the URL that directed you to our Site, your browser type and settings, information about your device (such as brand, model, and operating system), information about your browser configuration, language preferences, unique identifiers, and cookies.
- Usage data and analytics, which may include the frequency of connection, the features you use, the duration and timing of use, and the different types of activities undertaken by users, and demographic information we may ask you for, such as your gender and age.
- If you wish to obtain additional information about our services, use our features, register for an event, webinar, or contest, or download certain content, we may ask you to provide us with your contact information, such as your name, phone number, and email address, as well as certain information about your needs or preferences.
- Customer support questions, general comments you choose to provide.
- Any other Personal Information provided.
This information is collected to help us learn more about your needs, preferences, and interactions with our Site and the services offered on it, to compile statistics, and to conduct market and performance studies to help us evaluate our Site and services, measure our performance, and improve the experiences and services we offer. It is not associated with a specific individual unless you have requested a product or service or have voluntarily provided Personal Information.
3.2.2 Blogs, forums and other social medias
The Site may host various blogs, forums, and other social media applications or services that allow you to communicate content to other users (collectively, “social media applications”). Any Personal Information and other information you disclose using a social media application may be read, collected, and used by other users of that social media application over which we have little or no control. Therefore, we are not responsible for the use, misuse, or misappropriation by another user of Personal Information or any other information you disclose using a social media application.
3.2.3 Clients (potentials, currents or formers)
When you request information about our products and services, request a quote, and/or purchase products, we may collect information about you as described below:
- Your last name, first name, mailing address, phone number, email address, banking information, language, and any other information deemed relevant.
This information is collected in order to:
- Manage your file, communicate with you, and maintain your customer account;
- Process payments;
- Send information about various products and services offered or information you have requested, or to respond to your inquiries and questions;
- Communicate with you (by phone, alert, email, mail, or otherwise) and provide you with advertising material and additional information about our services, products, surveys, contests, promotions, and special offers, as well as offer our customer service;
- Conduct statistics, market research, and performance studies to help us evaluate our Site, Applications, and services, measure our performance, and improve the experiences and services we offer.
3.2.4 Job applicants and employees (currents or formers)
When you apply for a job at Les Cuisines de l’Air Culin-Air Inc., we collect Personal Information about you by email, telephone, or in person, as described below:
- Your last name, first name, date of birth, social security number, mailing address, phone number, email address, banking information, language, and any other information deemed relevant.
This Personal Information is collected for the purpose of managing communications with the applicant and managing the employee’s file.
3.2.5 Surveys, events, and marketing information
If you choose to participate in our surveys, contests, events, and requests for information, we may collect information about you in connection with the survey, contest, request for information, or event, including your name, email address, phone number, and general information about you that you choose to provide. We may also use your personal information for marketing purposes.
3.2.6 Phone calls
If you contact us by phone, we may record the call and ask you to provide your contact details, such as your name, address, phone number, and email address.
3.2.7 Visits to our offices
If you visit our offices, you may be asked to register as a visitor and provide your name, email address, phone number, and the time and date of your arrival.
3.3 Communication
Les Cuisines de l’Air Culin-Air Inc. limits the communication and disclosure of your Personal Information for purposes other than those mentioned above, but please note the following clarifications and exceptions:
3.3.1 Application of the law
We may share your Personal Information to respond to law enforcement requests, court orders, or other legal proceedings, or if we believe that such disclosure is necessary to investigate, prevent, or respond to illegal activities, fraud, physical threats, or as required by any other applicable law or regulation, and to the extent necessary to protect the property, interests, and rights of Les Cuisines de l’Air Culin-Air Inc.
3.3.2 Archive service
We may share your Personal Information with a company whose business is the preservation of documents for their general informational value.
3.3.3 Our employees and authorized service providers
Our employees may have access to your Personal Information in order to help us provide services to you. They access and use this Personal Information in accordance with our instructions, only if they need to know such information, and under strict confidentiality and security obligations. Please be assured that we ensure that our employees handle this information with the necessary discretion and rigor, and comply with this Policy and applicable legal and regulatory requirements.
When you provide Personal Information to Les Cuisines de l’Air Culin-Air Inc., you grant us the right to share your Personal Information with authorized service providers that we deem acceptable and who will use this information to help us respond to your requests and perform services. Please note that we will only share Personal Information necessary for the use of these third-party services, solely for the purpose of providing you with services, and we will ensure that these authorized providers agree to keep this information confidential and secure.
Service providers retain the information they need to perform the functions for which they were appointed, and we do not authorize these third parties to use or disclose your Personal Information for their own marketing or other purposes.
3.3.4 Commercial transaction
Les Cuisines de l’Air Culin-Air Inc. may be involved (1) in the sale or lease of all or substantially all of its business and/or assets, (2) in the modification of its legal structure through merger or otherwise, (3) in a transaction to obtain a loan or any other form of financing, and (4) in any other similar transaction (individually and collectively, the “Transaction”). As part of this Transaction, we may transfer or disclose your Personal Information to the current or potential contracting organization, but we will require that organization to agree to protect the confidentiality of your Personal Information in a manner equivalent to this Policy.
3.3.5 Explicit consent
Les Cuisines de l’Air Culin-Air Inc. may also disclose your Personal Information if you request or expressly consent to it.
4. Your personal information and third-party websites
Our Site may contain links to independent third-party websites. These third-party sites (“Third-Party Sites”), whose links are provided solely for your convenience, are not under our control and may be governed by their own privacy policies. Les Cuisines de l’Air Culin-Air Inc. does not guarantee and is not responsible for the collection, use, storage, and disclosure of your Personal Information by Third-Party Sites. Les Cuisines de l’Air Culin-Air Inc. assumes no responsibility for your use of these Third-Party Sites or your access to Third-Party Sites through our Site. By using our Site or accessing third-party Sites through our Site, you release Les Cuisines de l’Air Culin-Air Inc. from any liability for the actions, practices, and omissions of these third parties.
5. Transfer of personal information abroad
We strive to keep your personal information in Quebec. However, in the future, we may engage third-party service providers to process, manage, and host personal information on our behalf that may be located outside of Canada. As a result, some of your personal information may be transferred to another province or country and may be subject to the laws of that province or country.
However, we ensure that we protect the Personal Information in our custody, including Personal Information entrusted to a supplier located in Quebec or abroad. Our policies and practices regarding the protection of Personal Information require that a written commitment be signed by this service provider to comply with its obligation to preserve the confidentiality and security of the Personal Information entrusted to it. This includes, in particular, implementing robust and effective security measures, but also prohibiting the disclosure, transfer, or use of your Personal Information to others in accordance with the applicable legislation in the province of Quebec regarding the protection of personal information.
6. Protection of personal information
We take appropriate measures to ensure the confidentiality of Personal Information and to protect such Personal Information from loss, unauthorized access, disclosure, copying, use, or modification, taking into account, in particular, the sensitivity of the information and the purposes for which it is intended.
Les Cuisines de l’Air Culin-Air Inc. uses commercially reasonable and appropriate physical, electronic, and managerial procedures and generally accepted industry standards to safeguard and secure the Personal Information we collect.
Furthermore, the Personal Information we hold is therefore only accessible to individuals who are authorized to view it and who consult it only when necessary in the performance of their duties.
To this end, we ensure that access to our offices and computer equipment is restricted, that our staff is trained, and that our agents and suppliers of goods and services who have access to Personal Information are required to sign confidentiality agreements and implement security measures deemed equivalent.
Please note, however, that since no mechanism offers maximum security, using the Internet to transmit, create, or host Personal Information always involves some risk.
If you believe that your Personal Information has been compromised, we invite you to contact our Privacy Officer at the contact details provided in Section 15 of this Policy.
7. Minors
Les Cuisines de l’Air Culin-Air Inc. does not knowingly collect Personal Information from individuals under the age of 18.
If a minor under the age of 14 wishes to use our Site, our services, or contact us in any other way, the collection of Personal Information from that minor will not be permitted without the consent of the parent or guardian. If we learn that we have unintentionally collected Personal Information from individuals under the age of 14 without obtaining the consent of the parent or guardian, we will ensure that this information is deleted from our records as quickly as possible. If you are the legal guardian or custodian of a minor under the age of 14 and you know that your minor child has provided Personal Information, please contact our Privacy Officer at the contact details listed in Section 15 of this Policy so that we can take the necessary action.
8. Retention period
Les Cuisines de l’Air Culin-Air Inc. will store and retain your Personal Information for as long as necessary for the purposes set out in this Policy and to ensure that we comply with our legal and regulatory obligations. You may withdraw or modify your consent to our use of your Personal Information at any time, or request that we permanently delete it, subject to conditions imposed by law.
We only retain your Personal Information for as long as is reasonably necessary for the purposes set out in this policy, or longer if required by law. When Personal Information is no longer required to be retained, either because the purpose for which it was collected has been fulfilled or because you have withdrawn your consent to its retention, it will be permanently deleted or archived from our database.
If you would like to learn more about how long your Personal Information is retained, please contact our Privacy Officer, whose contact details are provided in clause 14 of this Policy.
9. Access, correction, updating of personal information, and withdrawal of consent
You have the right to access your Personal Information and obtain copies of it. You also have the right to update, rectify, and correct any Personal Information that you believe is inaccurate or incomplete. You may also request that the dissemination of Personal Information about you be stopped or that any hyperlink associated with your name that allows access to this Personal Information by technological means be de-indexed, when its dissemination contravenes the Act or a court order. You may do the same, or request that the hyperlink providing access to the Personal Information be reindexed, when certain conditions provided for by the Act are met.
To do so, please submit a written request to this effect by writing to the Privacy Officer at the address indicated in section 15, who will respond in writing within 30 days of receiving any request in this regard.
If you wish to obtain copies of your Personal Information, we may require you to pay a minimal fee, which will be disclosed to you in advance, simply to cover the costs of transcription, reproduction, and/or transmission.
Subject to legal and contractual restrictions, if applicable, you may withdraw your consent to the use or disclosure of Personal Information collected about you at any time.
10. Electronic communications (emails)
Your email address may be used to send you electronic communications from time to time, such as advertising material or documents regarding services that we believe may be of interest to you. You may ask us to stop sending you electronic communications at any time by contacting the Privacy Officer at Les Cuisines de l’Air Culin-Air Inc. using the contact information provided in section 15 of this Policy or by following the “unsubscribe” instructions at the bottom of these communications, if applicable.
11. Cookies and other tracking technologies on our site, through our services, and in email communications
We use common information gathering tools, such as usage data collection tools, cookies, and similar technologies to automatically collect information that may contain Personal Information from your computer or mobile device when you browse our Site, our Applications, or interact with emails we have sent to you.
By accessing and browsing our Site, you consent to the use of cookies in accordance with the terms of this Policy and the Site’s Terms of Use. You can control and manage cookies in various ways. Please note that deleting or blocking cookies may negatively impact your user experience and that certain parts of our Site may no longer be fully accessible. Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, which are often found in your browser’s “Tools” or “Preferences” menu.
12. Changes to this policy
Les Cuisines de l’Air Culin-Air Inc. reserves the right to make changes to this Policy at any time. These changes will be posted on the Site and will take effect immediately upon posting. We will take reasonable steps, as necessary, to notify you of any significant changes. You may contact our Privacy Officer at the address or numbers listed in Section 15 of this Policy to obtain a current copy of the Policy.
13. Terms of use
The Terms of Use of the Site, available on the Site, contain important provisions that disclaim and exclude the liability of Les Cuisines de l’Air Culin-Air Inc. and other persons with respect to your use of the Site, its content, and any services that may be offered on it, as well as provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute concerning your use of the Site. Each of these provisions also applies to any dispute that may arise in connection with this Policy and the collection, use, retention, and disclosure of your Personal Information, and they have the same force and effect as if they had been reproduced verbatim in this Policy.
14. Complaint handling process
14.1 Reception
Any complaint regarding the application of this Policy must be made in writing to the Privacy Officer of Les Cuisines de l’Air Culin-Air Inc., at the email address indicated in the following section.
The complaint must contain the complainant’s name, contact information, including a telephone number, as well as the subject matter and reasons for the complaint in sufficient detail to enable Les Cuisines de l’Air Culin-Air Inc. to assess it. The privacy officer may request any additional information he or she deems necessary to assess the complaint.
14.2 Treatment
Please note that Les Cuisines de l’Air Culin-Air Inc. is committed to treating all complaints received confidentially, subject to obtaining the opinions and recommendations of our advisors. Once the complaint has been received, along with all additional information deemed necessary and required by the privacy officer, Les Cuisines de l’Air Culin-Air Inc. will have thirty (30) days to review it. At the end of the analysis, the privacy officer must send the complainant a written response explaining the reasons why the complaint was accepted or rejected.
Les Cuisines de l’Air Culin-Air Inc. undertakes to make every reasonable effort to process each complaint within thirty (30) days. However, in the event that the complaint cannot be handled within this time frame, the complainant will be informed of the reasons for the extension, the status of the complaint, and the reasonable time frame required to provide a final response.
A separate file will be created for each complaint received, if applicable. The file must contain the complaint, the analysis and supporting documentation for its assessment, and the response sent to the person who filed the complaint.
You may also file a complaint in writing with the Commission d’accès à l’information – Direction de la surveillance at the following address: 900-2045 Stanley Street, Montreal, Quebec, H3A 2V4, or by email at [email protected]. However, we invite anyone interested to first contact the person responsible for the protection of personal information and wait until Les Cuisines de l’Air Culin-Air Inc. has completed its complaint handling process.
15. Questions, comments, and privacy officers
Les Cuisines de l’Air Culin-Air Inc. is responsible for the Personal Information in its custody or control and has designated an officer to ensure compliance with this Policy and applicable laws regarding the protection of Personal Information.
If you have any questions or comments regarding this Policy and Les Cuisines de l’Air Culin-Air Inc.’s practices regarding Personal Information, please contact our Personal Information Protection Officer at the following address:
Mrs Julia Pageau-Pouliot
Privacy Officer
9553 ch. de la Côte-de-Liesse Dorval
Montréal (QC) H9P 1A3
Email: [email protected]
Versions and changes
Version 1.0 effective as of September 22. 2023