PRIVACY NOTICE
UPDATED: FEBRUARY 3, 2025
1. Introduction
S.F. Marketing Inc., hereinafter "SFM" or the "Organization", recognizes the importance of protecting Personal Information, i.e., any information about an individual that directly or indirectly identifies that individual ("PI").
This Privacy Policy (the "Policy") describes the measures applied by SFM to ensure the protection of the Personal Information it collects, uses, discloses and retains in the course of operating its Website (https://www.sfm.ca/) and its ongoing operational activities such as digiflexcables.com.
The purpose of this Policy is to comply with the provisions of the Act respecting the protection of personal information in the private sector (ARPPIPS), as amended by S.Q. 2021, c.25, and the Personal Information Protection and Electronic Documents Act (PIPEDA).
2. Policy Update and Amendments
This Policy may be amended from time to time to maintain SFM's compliance with the law and to reflect any changes to the process for collecting Personal Information.
Any changes to this Policy will be subject to prior notice which will specify:
The general purpose of changes to the Privacy Policy.
The date on which these amendments come into force.
Effective date: 02-03-2025
Last Updated: 02-03-2025
Approved by: Chief Privacy Officer
3. Personal Information Collected
SFM collects only the Personal Information that which is necessary for the purposes of its activities. This includes information relating to your identity, such as your surname, first name, address, telephone number and email address, as well as information relating to the use of the Website.
SFM collects Personal Information in the following ways:
Directly from you:
Most of the Personal Information is collected directly from you, including when you:
Fill out the contact form on the Website.
Make inquiries related to products and services.
Subscribe to the newsletter.
Register for web-based trainings.
Request discounts.
Indirectly, through third parties:
SFM may also collect your Personal Information from third parties or authorized representatives with your consent or if permitted by law.
Through cookies:
When you access the SFM Website, text files called "cookies" (hereinafter referred to as "cookies") are stored on your computer. These cookies may collect personal information such as your IP address and are intended in particular to improve your browsing experience as well as the content of the Website, to track traffic on all SFM’s Websites. However, SFM does not correlate the information obtained through these cookies with individual users. SFM does break down overall usage statistics according to the user's domain name, browser type and MIME type by reading this information from the browser string (information contained in each user's browser). SFM sometimes tracks and catalogs search terms entered by users on the search function, this tracking is never associated with individual users. We use tracking information to determine which areas of our sites users like and don't like, based on traffic to those areas.
Where required by law, SFM will seek your consent before collecting information through cookies.
4. Consent
SFM collects, uses and communicates Personal Information for the purposes identified at the time of collection, such as when an individual fills out a form via the Website's contact page, completes newsletter subscription, registers for web training and requests discounts.
The following are examples of the purposes for which SFM collects Personal Information:
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Whenever required by law, SFM will seek your consent prior to any use of your Personal Information.
5. Access and Communication of Personal Information
Personal Information is disclosed and accessible to SFM employees who reasonably need to know the information to fulfill the purposes set out in this Policy. All Personal Information stored on SFM's servers is secure and accessible only to employees who have the right to access it, in the course of their duties. The principle of least privilege is followed in granting access to Personal Information, depending on the role and responsibilities of the users.
Third parties (partners and suppliers) may also access the Personal Information collected to fulfill the purposes set out in this Policy. They will not be able to access Personal Information beyond what is reasonably necessary to fulfill the given purpose. Our service providers are contractually obligated to keep all information collected in the strictest confidence.
SFM may communicate your Personal Information to business partners, suppliers, government authorities and others during its business activities. These third parties include, but are not limited to:
Cloud solution providers, hosting data, servers or applications.
Marketing or advertising service providers.
Companies specializing in criminal background and credit checks.
Supervisory authorities such as the Commission d'Accès à l'Information.
Any other person authorized to obtain them by law.
SFM will not sell or share Personal Information with other third parties except in the following cases:
It is required by law.
The disclosure of Personal Information to a third party is required for a legal proceeding.
The disclosure of Personal Information to a third party is necessary to prove or protect legal rights.
In the context of a commercial transaction, to potential buyers.
To provide you with the services you expect.
6. Where Your Personal Information Is Stored
The servers containing the Personal Information are in Quebec, Canada. However, it is possible that the communication of Personal Information to certain technology solution providers may result in the transfer of such information outside of Québec. In such cases, SFM will first validate the laws and practices applicable to the protection of Personal Information in the relevant jurisdiction and take all reasonable measures to ensure that your Personal Information is adequately protected.
7. Retention Period and Disposal of Personal Information
SFM has put in place measures to ensure its compliance with the obligations to retain and dispose Personal Information.
Personal Information collected by SFM is not retained beyond what is necessary to fulfill the purposes for which it is collected.
Not withstanding the foregoing, SFM retains your Personal Information when required to comply with applicable legal obligations, in addition to those specific to the protection of personal information.
8. Safeguards for Personal Information
SFM implements physical, organizational, contractual and technological security measures to adequately protect Personal Information from theft, loss, unauthorized access, transfer, copying or alteration.
SFM employees are bound by confidentiality agreements. Training and awareness on information security and privacy are provided on a regular basis to SFM employees. Computer systems adhere to industry-recommended security frameworks and protocols.
9. Rights of the Individuals
As an individual whose Personal Information has been collected by SFM, you may exercise the following rights:
Right to Access, rectify or Complete Your Personal Information: SFM makes reasonable efforts to ensure that the Personal Information it collects is accurate and complete for the purposes for which it is used. You may review your Personal Information, verify its accuracy, and request rectification, if necessary, subject to exceptions provided by law. Your request for access or rectification must be sent to the Chief Privacy Officer using the contact information in section 10 and will be processed no later than thirty (30) days from the date of receipt of your written request.
Right to withdraw your consent: you may request to withdraw your consent for your Personal Information to be used by SFM for purposes that are not essential to the management and administration of its products and services.
It will generally not be possible to withdraw your consent to the use of your Personal Information for a purpose relating to the management and administration of products and services without terminating the business relationship.
Any request to withdraw consent must be communicated to the Chief Privacy Officer whose contact information can be found in section 10.
Before we can provide you with any information, correct any inaccuracies or delete any information, we may ask you to confirm your identity and provide further details (in a secure manner) to help us respond to your request.
Right to Lodge a Complaint: Any questions regarding your Personal Information or complaints regarding non-compliance with the principles set out in the Policy should be directed to the Chief Privacy Officer whose contact information are provided in section 10.
10. Chief Privacy Officer
The Chief Privacy Officer is responsible for ensuring the protection of your Personal Information, i.e., for taking all necessary measures to ensure your rights as described in the previous sections. Their contact details are as follows:
Chief Privacy Officer
prp-pdp@sfm.ca
325 Bouchard Blvd.Dorval (Quebec) H9S 1A9 Canada