In this Policy, the term "personal information" refers to any information collected by Valmetal Inc. ("Valmetal," "we," "our," and "us") that, alone or in combination with other information, can directly or indirectly identify an individual ("you," "your," and "yours"), excluding business contact information. "Business contact information" refers to information about an individual’s role within an organization, such as their first name, last name, title, position, as well as their business address, email address, and telephone number.
In accordance with the Act Respecting the Protection of Personal Information in the Private Sector (RLRQ, c. P-39.1) (the "Private Sector Privacy Act"), as amended by the Act to Modernize Legislative Provisions Respecting the Protection of Personal Information ("Law 25"), we implement policies and practices to govern our operations and ensure compliance with personal information protection requirements, including this Policy. This Policy, as well as any amended version of it, is subject to the laws applicable in the province of Quebec.
The primary purpose of this Policy is to provide you with information, in clear and simple language, about:
The methods we use to collect your personal information.
The categories of personal information we may collect and the purposes for which we collect it.
How we may use your personal information and the categories of third parties with whom we may share it.
Your rights regarding the personal information we hold, including the right to access your personal information, the right to rectify it under certain circumstances, and the right to withdraw your consent for its use and disclosure.
The security measures we have implemented to protect the confidentiality of your personal information.
How your personal information is retained, destroyed, and/or anonymized.
How you can contact us to address your questions, share your comments, or, if applicable, file a complaint related to this Policy or, more generally, how we handle your personal information.
We may collect your personal information through the following methods:
Automatically, when you visit our website, accessible via https://valmetal.com ("Website"), particularly through the use of cookies and similar technologies (collectively, "Digital Markers").
When you voluntarily provide personal information via the Website.
When you communicate with our authorized representatives (e.g., in-person meetings, videoconferences, emails, instant messaging, phone calls, faxes).
When you access the Website, we automatically collect the following information:
The IP address (“Internet Protocol”) of the device you use to access the Website;
The type and model of the device used to access the Website;
The browser you use (e.g., Chrome, Microsoft Edge, Firefox, Safari, Brave, Opera) to access the Website;
The browser language you use to access the Website;
The type and version of the operating system of the device you use to access the Website (e.g., Windows, MAC OS, Linux);
The date and time of your access to the Website;
The pages you view on the Website;
The searches you perform while browsing the Website; and
The URL address of the Internet site from which you access the Website.
Digital Markers are files stored on an Individual’s browser when they access the Website. These markers are used to facilitate or improve current and future interactions between the browser used and the server hosting the Website. For example, session cookies (commonly referred to as "cookies"), HTML5 storage specifications, invisible pixels, and embedded scripts are considered Digital Markers. To view the complete list of Digital Markers we use, please refer to the summary table attached as an appendix to this Policy.
We may collect certain personal information that you voluntarily provide during (i) your use of the Website and/or (ii) your interactions with our authorized representatives (e.g., in-person communications, videoconferences, emails, instant messaging, phone calls, faxes). The personal information we may collect includes the following:
Personal information that identifies you (first name, last name, and contact information, such as physical addresses, email addresses, and phone numbers) (for the purposes of this Section 2.3, referred to as "identification information");
Personal information necessary to (i) provide you with products and (ii) perform the services you have requested based on our service offerings (collectively, "Products and Services") (identification information);
Personal information provided as part of your job application submitted to us (identification information, spoken languages, educational background, professional experience and affiliations, and any other personal information voluntarily shared through a resume or cover letter);
Personal information provided as part of a transaction (business operation) you wish to carry out with us (identification information, payment methods, and payment details); and
Personal information contained in the exchanges that make up your communication history with us and our authorized representatives (in addition to all personal information listed in this Section 2.3, this may include consent records, notices, comments, and complaints).
Please note that you are responsible for obtaining the consent of any individual other than yourself before sharing their personal information with us. Similarly, we do not knowingly collect personal information about individuals under the age of fourteen (14) unless we have first obtained the explicit prior consent of a parent or guardian. If you believe that we hold such personal information that may have been collected involuntarily, please notify our Person in charge of the protection of personal information (contact details provided in Section 8 below) so that we can carry out the necessary verifications and, if applicable, securely destroy the personal information in question.
The "purposes" of collection refer to the reasons that justify our need to collect your personal information.
We may collect your personal information for the following purposes:
To identify you to enable appropriate interactions with you;
To create an internal file in order to provide you with Products and Services and, if you authorize us to do so, to deliver them;
To communicate with you to provide information related to our business and its Products and Services;
To send you newsletters;
To process any request or question you submit to us, including contacting you regarding such requests or questions;
To process any transaction (business operation) you carry out with us;
To process and evaluate your application, whether submitted spontaneously or in response to a job posting we have issued;
To conduct background checks;
To communicate with you to follow up on your application, request additional information about it, and/or inform you of any decisions we have made regarding your application;
To enable us to fulfill our obligations and exercise our rights as your employer or in any other relevant capacity;
To allow you to access the Website;
To measure the popularity of different components of the Website;
To identify the technology you use when accessing the Website (such as your operating system and browser) to assess compatibility and improve overall accessibility;
To identify the Internet websites from which you access the Website to evaluate the number of referrals obtained;
To identify the country from which you wish to access the Website to verify if access can be granted in compliance with applicable laws; and/or
Subject to the exceptions provided under the Private Sector Privacy Act, we will ensure that we obtain your consent before using your personal information for purposes other than those listed above.
Due to the use of certain Digital Markers (refer to the summary table attached as an appendix to this Policy), we may collect personal information using technology with functions that allow us to identify you, locate you, and create a profile about you. The functions enabling us to collect your personal information for identification, location, and profiling purposes are disabled by default. You may activate these functions by providing your explicit consent, either by clicking the appropriate button in the pop-up window that appears when you access the Website.
We may grant access to or disclose your personal information to the following individuals or entities:
Employees and representatives of our organization and entities within the same corporate group who need access to this personal information for one or more of the purposes outlined in Section 3 above;
Our service providers and external agents who provide us with transportation and shipping services, website services, application development, hosting, maintenance, and other technological services. These providers require access to personal information to fulfill their obligations under a service agreement or mandate concluded with us (e.g., web hosting or cloud service providers). Under such agreements, the relevant service provider or external agent is required to take appropriate measures to:
Ensure the confidentiality of the disclosed personal information;
Ensure the disclosed personal information is used solely for fulfilling the obligations outlined in the service agreement or mandate;
Ensure the disclosed personal information is not retained after the termination of the service agreement or mandate;
Notify us immediately of any breach or attempted breach of obligations related to the confidentiality of the disclosed personal information; and
Allow us to conduct any necessary verification related to the confidentiality of the disclosed personal information.
Your references, past and current employers, educational institutions you attended, governmental bodies such as law enforcement and ministries, to verify the truth, accuracy, and completeness of the information provided as part of your application, and to obtain additional information from these entities as necessary.
Any other individual or entity, as required or permitted by applicable legislation, or with your prior consent.
It is possible that we may disclose your personal information to individuals or entities in the above-listed categories who are located outside the province of Quebec. In such cases, we will conduct a privacy impact assessment in accordance with the Private Sector Privacy Act before any disclosure. We will only disclose your personal information if the privacy impact assessment demonstrates that the individual or entity in question can ensure adequate protection of the said personal information in accordance with generally recognized privacy protection principles.
We have adopted and implemented physical, technological, and administrative security measures designed to protect your personal information and reduce the risks of unauthorized and/or illegal access, use, disclosure, or destruction. Below is a brief description of these security measures:
Employee and partner selection process. We follow a process that takes our obligations regarding the protection of personal information into account when recruiting new employees who will handle personal information or when entering into service contracts or mandates involving the disclosure of personal information to third parties;
Confidentiality agreements and internal guidelines. All our employees who access to your personal information are required to sign a confidentiality agreement and comply with internal guidelines on the protection of personal information;
Training. We make efforts to ensure that each of our employees who may access personal information receives training on privacy protection, personal information security, and cybersecurity;
Access management and retention. We ensure that your personal information is only accessible to authorized employees and representatives who need access to perform their duties related to one or more of the purposes identified in Section 3 of this Policy. To achieve this, we have implemented mechanisms for managing access to personal information, including assigning distinct access rights based on employee roles. Additionally, we store your personal information on secure servers provided by our web or cloud hosting service providers;
Retention schedule. We have established a retention schedule to ensure that your personal information is not kept beyond the period needed to fulfill the purposes described in Section 3 of this Policy. Subject to any obligations under applicable legislation, your personal information will be securely destroyed within a reasonable timeframe after these purposes have been fulfilled;
Secure destruction process. We have implemented secure destruction processes for personal information whose retention period has expired. The data collected from the forms will be retained for a period of one year;
Management of privacy incidents. In the event of a privacy incident that poses a risk of serious harm to you, we will take the necessary steps to notify you in compliance with the Private Sector Privacy Act. The risk of serious harm is assessed based on criteria such as the sensitivity of the personal information involved, the anticipated consequences of its use, and the likelihood of it being used for harmful purposes; and
Complaint processing procedure. We have developed and adopted a specific procedure for handling complaints related to the processing of personal information within our organization. You are invited to review this procedure, which is accessible via the following hyperlink: Procedure for Managing and Processing Complaints Related to the Protection of Personal Information.
We regularly reassess the aforementioned security measures.
No organization can validly claim to be immune to the risk of a confidentiality incident involving personal information. Despite all our efforts to protect your personal information, we cannot guarantee that it is entirely safe from the risk of a confidentiality incident. If you believe that the protection of your personal information has been compromised, please contact us using the contact information provided in Section 8 of this Policy.
You have the right to access your personal information, which includes the following:
The right to obtain confirmation or information about whether we collect, use, disclose, or retain personal information about you;
The right to receive communication of the personal information we hold about you;
The right to review your personal information in our possession, including in-person access to this information during normal business hours or remotely, and to obtain a copy of it; and
The right to request communication of (or request that we communicate to a third party) your computerized personal information in a structured and commonly used technological format (except for information created or inferred from your personal information), unless fulfilling this right would cause significant practical difficulties for us.
Exercising your right of access is free of charge. If you request reproduction, transcription, or communication of your personal information, we may require you to pay reasonable fees not exceeding the cost of reproduction, transcription, or communication. An estimate of these costs will be provided to you prior to any reproduction, transcription, or communication.
Any request to exercise your right of access must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
You have the right to request rectification of your personal information held by us under the following circumstances:
The personal information about you is inaccurate or outdated;
The personal information about you is incomplete;
The personal information about you is ambiguous; and/or
The collection, communication, or retention of personal information about you is unauthorized or unjustified from a legal standpoint.
You may also request, under your right of rectification, the destruction of any personal information about you that is outdated or whose collection, communication, or retention is unauthorized or unjustified from a legal standpoint.
Any request to exercise your right of rectification must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
You have the right to withdraw your consent for the communication or use of your personal information in our possession. In such cases, you will be informed of the consequences of such withdrawal before it takes effect, enabling you to make an informed decision.
Any request to exercise your right of withdrawal must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
Any request to exercise a right under Section 6 of this Policy must meet the following criteria to be considered acceptable:
The request must be made in writing; and
The request must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy.
We must verify your identity before processing any request to exercise a right under Section 6 of this Policy.
If your request to exercise a right under Section 6 of this Policy is not sufficiently precise, or upon your request, we will assist you in identifying the personal information targeted by your request.
We must respond (favorably or unfavorably) to any request to exercise a right under Section 6 of this Policy within thirty (30) days of receiving it, subject to the possibility of verifying the identity of the requester.
We must issue a written decision regarding any request to exercise a right under Section 6 of this Policy. If the decision is unfavorable, we must provide reasons for the decision and specify the provision of the Private Sector Privacy Act on which the decision is based, as well as the remedies available to the requester and the time limits for pursuing them. We must also provide assistance to the requester, if requested, to help them understand the unfavorable decision, if applicable.
If we issue a favorable decision regarding a rectification request, we are required to provide the requester, free of charge, with a copy of any modified or added personal information or, as the case may be, a confirmation of the removal of personal information.
If you are dissatisfied with how our organization processes your personal information, you may file a complaint with our Person in charge of the protection of personal information, whose contact details are provided in Section 8 of this Policy. You are invited to consult our complaint-handling process, which is accessible via the following hyperlink: Procedure for Managing and Processing Complaints Related to the Protection of Personal Information.
To exercise any of your rights, ask questions, provide feedback, or file a complaint regarding this Policy or the processing of your personal information, please contact our Person in charge of the protection of personal information at:
Person in charge of the protection of personal information
Valmetal Inc.
12 Route 249
St-François-Xavier-de-Brompton
Quebec J0B 2V0 Canada
Telephone: 819-845-7824
Email Address: prp@valmetal.com
The effective date and the last update date of this Policy are indicated in the header on its first page. This Policy may be subject to amendments to reflect changes in applicable legislation, as well as updates to policies and practices governing our operations and privacy management, among other factors. To amend this Policy, we will post a notice of amendment in the section of the Website dedicated to this Policy and amendment notices, accessible via this link. If we have your email address, we will use it to send you the notice of amendment. The content of the amendment notice will take effect on the fifteenth (15th) day following its publication on the Website, unless there are reasons justifying a shorter timeframe.
In this Policy, the term "personal information" refers to any information collected by Valmetal St-François Inc. ("Valmetal," "we," "our," and "us") that, alone or in combination with other information, can directly or indirectly identify an individual ("you," "your," and "yours"), excluding business contact information. "Business contact information" refers to information about an individual’s role within an organization, such as their first name, last name, title, position, as well as their business address, email address, and telephone number.
In accordance with the Act Respecting the Protection of Personal Information in the Private Sector (RLRQ, c. P-39.1) (the "Private Sector Privacy Act"), as amended by the Act to Modernize Legislative Provisions Respecting the Protection of Personal Information ("Law 25"), we implement policies and practices to govern our operations and ensure compliance with personal information protection requirements, including this Policy. This Policy, as well as any amended version of it, is subject to the laws applicable in the province of Quebec.
The primary purpose of this Policy is to provide you with information, in clear and simple language, about:
The methods we use to collect your personal information.
The categories of personal information we may collect and the purposes for which we collect it.
How we may use your personal information and the categories of third parties with whom we may share it.
Your rights regarding the personal information we hold, including the right to access your personal information, the right to rectify it under certain circumstances, and the right to withdraw your consent for its use and disclosure.
The security measures we have implemented to protect the confidentiality of your personal information.
How your personal information is retained, destroyed, and/or anonymized.
How you can contact us to address your questions, share your comments, or, if applicable, file a complaint related to this Policy or, more generally, how we handle your personal information.
We may collect your personal information through the following methods:
Automatically, when you visit our website, accessible via https://valmetal.com ("Website"), particularly through the use of cookies and similar technologies (collectively, "Digital Markers").
When you voluntarily provide personal information via the Website.
When you communicate with our authorized representatives (e.g., in-person meetings, videoconferences, emails, instant messaging, phone calls, faxes).
When you access the Website, we automatically collect the following information:
The IP address (“Internet Protocol”) of the device you use to access the Website;
The type and model of the device used to access the Website;
The browser you use (e.g., Chrome, Microsoft Edge, Firefox, Safari, Brave, Opera) to access the Website;
The browser language you use to access the Website;
The type and version of the operating system of the device you use to access the Website (e.g., Windows, MAC OS, Linux);
The date and time of your access to the Website;
The pages you view on the Website;
The searches you perform while browsing the Website; and
The URL address of the Internet site from which you access the Website.
Digital Markers are files stored on an Individual’s browser when they access the Website. These markers are used to facilitate or improve current and future interactions between the browser used and the server hosting the Website. For example, session cookies (commonly referred to as "cookies"), HTML5 storage specifications, invisible pixels, and embedded scripts are considered Digital Markers. To view the complete list of Digital Markers we use, please refer to the summary table attached as an appendix to this Policy.
We may collect certain personal information that you voluntarily provide during (i) your use of the Website and/or (ii) your interactions with our authorized representatives (e.g., in-person communications, videoconferences, emails, instant messaging, phone calls, faxes). The personal information we may collect includes the following:
Personal information that identifies you (first name, last name, and contact information, such as physical addresses, email addresses, and phone numbers) (for the purposes of this Section 2.3, referred to as "identification information");
Personal information necessary to (i) provide you with products and (ii) perform the services you have requested based on our service offerings (collectively, "Products and Services") (identification information);
Personal information provided as part of your job application submitted to us (identification information, spoken languages, educational background, professional experience and affiliations, and any other personal information voluntarily shared through a resume or cover letter);
Personal information provided as part of a transaction (business operation) you wish to carry out with us (identification information, payment methods, and payment details); and
Personal information contained in the exchanges that make up your communication history with us and our authorized representatives (in addition to all personal information listed in this Section 2.3, this may include consent records, notices, comments, and complaints).
Please note that you are responsible for obtaining the consent of any individual other than yourself before sharing their personal information with us. Similarly, we do not knowingly collect personal information about individuals under the age of fourteen (14) unless we have first obtained the explicit prior consent of a parent or guardian. If you believe that we hold such personal information that may have been collected involuntarily, please notify our Person in charge of the protection of personal information (contact details provided in Section 8 below) so that we can carry out the necessary verifications and, if applicable, securely destroy the personal information in question.
The "purposes" of collection refer to the reasons that justify our need to collect your personal information.
We may collect your personal information for the following purposes:
To identify you to enable appropriate interactions with you;
To create an internal file in order to provide you with Products and Services and, if you authorize us to do so, to deliver them;
To communicate with you to provide information related to our business and its Products and Services;
To send you newsletters;
To process any request or question you submit to us, including contacting you regarding such requests or questions;
To process any transaction (business operation) you carry out with us;
To process and evaluate your application, whether submitted spontaneously or in response to a job posting we have issued;
To conduct background checks;
To communicate with you to follow up on your application, request additional information about it, and/or inform you of any decisions we have made regarding your application;
To enable us to fulfill our obligations and exercise our rights as your employer or in any other relevant capacity;
To allow you to access the Website;
To measure the popularity of different components of the Website;
To identify the technology you use when accessing the Website (such as your operating system and browser) to assess compatibility and improve overall accessibility;
To identify the Internet websites from which you access the Website to evaluate the number of referrals obtained;
To identify the country from which you wish to access the Website to verify if access can be granted in compliance with applicable laws; and/or
Subject to the exceptions provided under the Private Sector Privacy Act, we will ensure that we obtain your consent before using your personal information for purposes other than those listed above.
Due to the use of certain Digital Markers (refer to the summary table attached as an appendix to this Policy), we may collect personal information using technology with functions that allow us to identify you, locate you, and create a profile about you. The functions enabling us to collect your personal information for identification, location, and profiling purposes are disabled by default. You may activate these functions by providing your explicit consent, either by clicking the appropriate button in the pop-up window that appears when you access the Website.
We may grant access to or disclose your personal information to the following individuals or entities:
Employees and representatives of our organization and entities within the same corporate group who need access to this personal information for one or more of the purposes outlined in Section 3 above;
Our service providers and external agents who provide us with transportation and shipping services, website services, application development, hosting, maintenance, and other technological services. These providers require access to personal information to fulfill their obligations under a service agreement or mandate concluded with us (e.g., web hosting or cloud service providers). Under such agreements, the relevant service provider or external agent is required to take appropriate measures to:
Ensure the confidentiality of the disclosed personal information;
Ensure the disclosed personal information is used solely for fulfilling the obligations outlined in the service agreement or mandate;
Ensure the disclosed personal information is not retained after the termination of the service agreement or mandate;
Notify us immediately of any breach or attempted breach of obligations related to the confidentiality of the disclosed personal information; and
Allow us to conduct any necessary verification related to the confidentiality of the disclosed personal information.
Your references, past and current employers, educational institutions you attended, governmental bodies such as law enforcement and ministries, to verify the truth, accuracy, and completeness of the information provided as part of your application, and to obtain additional information from these entities as necessary.
Any other individual or entity, as required or permitted by applicable legislation, or with your prior consent.
It is possible that we may disclose your personal information to individuals or entities in the above-listed categories who are located outside the province of Quebec. In such cases, we will conduct a privacy impact assessment in accordance with the Private Sector Privacy Act before any disclosure. We will only disclose your personal information if the privacy impact assessment demonstrates that the individual or entity in question can ensure adequate protection of the said personal information in accordance with generally recognized privacy protection principles.
We have adopted and implemented physical, technological, and administrative security measures designed to protect your personal information and reduce the risks of unauthorized and/or illegal access, use, disclosure, or destruction. Below is a brief description of these security measures:
Employee and partner selection process. We follow a process that takes our obligations regarding the protection of personal information into account when recruiting new employees who will handle personal information or when entering into service contracts or mandates involving the disclosure of personal information to third parties;
Confidentiality agreements and internal guidelines. All our employees who access to your personal information are required to sign a confidentiality agreement and comply with internal guidelines on the protection of personal information;
Training. We make efforts to ensure that each of our employees who may access personal information receives training on privacy protection, personal information security, and cybersecurity;
Access management and retention. We ensure that your personal information is only accessible to authorized employees and representatives who need access to perform their duties related to one or more of the purposes identified in Section 3 of this Policy. To achieve this, we have implemented mechanisms for managing access to personal information, including assigning distinct access rights based on employee roles. Additionally, we store your personal information on secure servers provided by our web or cloud hosting service providers;
Retention schedule. We have established a retention schedule to ensure that your personal information is not kept beyond the period needed to fulfill the purposes described in Section 3 of this Policy. Subject to any obligations under applicable legislation, your personal information will be securely destroyed within a reasonable timeframe after these purposes have been fulfilled;
Secure destruction process. We have implemented secure destruction processes for personal information whose retention period has expired. The data collected from the forms will be retained for a period of one year;
Management of privacy incidents. In the event of a privacy incident that poses a risk of serious harm to you, we will take the necessary steps to notify you in compliance with the Private Sector Privacy Act. The risk of serious harm is assessed based on criteria such as the sensitivity of the personal information involved, the anticipated consequences of its use, and the likelihood of it being used for harmful purposes; and
Complaint processing procedure. We have developed and adopted a specific procedure for handling complaints related to the processing of personal information within our organization. You are invited to review this procedure, which is accessible via the following hyperlink: Procedure for Managing and Processing Complaints Related to the Protection of Personal Information
We regularly reassess the aforementioned security measures.
No organization can validly claim to be immune to the risk of a confidentiality incident involving personal information. Despite all our efforts to protect your personal information, we cannot guarantee that it is entirely safe from the risk of a confidentiality incident. If you believe that the protection of your personal information has been compromised, please contact us using the contact information provided in Section 8 of this Policy.
You have the right to access your personal information, which includes the following:
The right to obtain confirmation or information about whether we collect, use, disclose, or retain personal information about you;
The right to receive communication of the personal information we hold about you;
The right to review your personal information in our possession, including in-person access to this information during normal business hours or remotely, and to obtain a copy of it; and
The right to request communication of (or request that we communicate to a third party) your computerized personal information in a structured and commonly used technological format (except for information created or inferred from your personal information), unless fulfilling this right would cause significant practical difficulties for us.
Exercising your right of access is free of charge. If you request reproduction, transcription, or communication of your personal information, we may require you to pay reasonable fees not exceeding the cost of reproduction, transcription, or communication. An estimate of these costs will be provided to you prior to any reproduction, transcription, or communication.
Any request to exercise your right of access must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
You have the right to request rectification of your personal information held by us under the following circumstances:
The personal information about you is inaccurate or outdated;
The personal information about you is incomplete;
The personal information about you is ambiguous; and/or
The collection, communication, or retention of personal information about you is unauthorized or unjustified from a legal standpoint.
You may also request, under your right of rectification, the destruction of any personal information about you that is outdated or whose collection, communication, or retention is unauthorized or unjustified from a legal standpoint.
Any request to exercise your right of rectification must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
You have the right to withdraw your consent for the communication or use of your personal information in our possession. In such cases, you will be informed of the consequences of such withdrawal before it takes effect, enabling you to make an informed decision.
Any request to exercise your right of withdrawal must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
Any request to exercise a right under Section 6 of this Policy must meet the following criteria to be considered acceptable:
The request must be made in writing; and
The request must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy.
We must verify your identity before processing any request to exercise a right under Section 6 of this Policy.
If your request to exercise a right under Section 6 of this Policy is not sufficiently precise, or upon your request, we will assist you in identifying the personal information targeted by your request.
We must respond (favorably or unfavorably) to any request to exercise a right under Section 6 of this Policy within thirty (30) days of receiving it, subject to the possibility of verifying the identity of the requester.
We must issue a written decision regarding any request to exercise a right under Section 6 of this Policy. If the decision is unfavorable, we must provide reasons for the decision and specify the provision of the Private Sector Privacy Act on which the decision is based, as well as the remedies available to the requester and the time limits for pursuing them. We must also provide assistance to the requester, if requested, to help them understand the unfavorable decision, if applicable.
If we issue a favorable decision regarding a rectification request, we are required to provide the requester, free of charge, with a copy of any modified or added personal information or, as the case may be, a confirmation of the removal of personal information.
If you are dissatisfied with how our organization processes your personal information, you may file a complaint with our Person in charge of the protection of personal information, whose contact details are provided in Section 8 of this Policy. You are invited to consult our complaint-handling process, which is accessible via the following hyperlink: Procedure for Managing and Processing Complaints Related to the Protection of Personal Information.
To exercise any of your rights, ask questions, provide feedback, or file a complaint regarding this Policy or the processing of your personal information, please contact our Person in charge of the protection of personal information at:
Person in charge of the protection of personal information
Valmetal St-François Inc.
12 Route 249
St-François-Xavier-de-Brompton
Quebec J0B 2V0 Canada
Telephone: 819-845-7824
Email Address: prp@valmetal.com
The effective date and the last update date of this Policy are indicated in the header on its first page. This Policy may be subject to amendments to reflect changes in applicable legislation, as well as updates to policies and practices governing our operations and privacy management, among other factors. To amend this Policy, we will post a notice of amendment in the section of the Website dedicated to this Policy and amendment notices, accessible via this link. If we have your email address, we will use it to send you the notice of amendment. The content of the amendment notice will take effect on the fifteenth (15th) day following its publication on the Website, unless there are reasons justifying a shorter timeframe.
In this Policy, the term "personal information" refers to any information collected by Valmetal Inc. ("Valmetal," "we," "our," and "us") that, alone or in combination with other information, can directly or indirectly identify an individual ("you," "your," and "yours"), excluding business contact information. "Business contact information" refers to information about an individual’s role within an organization, such as their first name, last name, title, position, as well as their business address, email address, and telephone number.
In accordance with the Act Respecting the Protection of Personal Information in the Private Sector (RLRQ, c. P-39.1) (the "Private Sector Privacy Act"), as amended by the Act to Modernize Legislative Provisions Respecting the Protection of Personal Information ("Law 25"), we implement policies and practices to govern our operations and ensure compliance with personal information protection requirements, including this Policy. This Policy, as well as any amended version of it, is subject to the laws applicable in the province of Quebec.
The primary purpose of this Policy is to provide you with information, in clear and simple language, about:
The methods we use to collect your personal information.
The categories of personal information we may collect and the purposes for which we collect it.
How we may use your personal information and the categories of third parties with whom we may share it.
Your rights regarding the personal information we hold, including the right to access your personal information, the right to rectify it under certain circumstances, and the right to withdraw your consent for its use and disclosure.
The security measures we have implemented to protect the confidentiality of your personal information.
How your personal information is retained, destroyed, and/or anonymized.
How you can contact us to address your questions, share your comments, or, if applicable, file a complaint related to this Policy or, more generally, how we handle your personal information.
We may collect your personal information through the following methods:
Automatically, when you visit our website, accessible via https://valmetal.com ("Website"), particularly through the use of cookies and similar technologies (collectively, "Digital Markers").
When you voluntarily provide personal information via the Website.
When you communicate with our authorized representatives (e.g., in-person meetings, videoconferences, emails, instant messaging, phone calls, faxes).
When you access the Website, we automatically collect the following information:
The IP address (“Internet Protocol”) of the device you use to access the Website;
The type and model of the device used to access the Website;
The browser you use (e.g., Chrome, Microsoft Edge, Firefox, Safari, Brave, Opera) to access the Website;
The browser language you use to access the Website;
The type and version of the operating system of the device you use to access the Website (e.g., Windows, MAC OS, Linux);
The date and time of your access to the Website;
The pages you view on the Website;
The searches you perform while browsing the Website; and
The URL address of the Internet site from which you access the Website.
Digital Markers are files stored on an Individual’s browser when they access the Website. These markers are used to facilitate or improve current and future interactions between the browser used and the server hosting the Website. For example, session cookies (commonly referred to as "cookies"), HTML5 storage specifications, invisible pixels, and embedded scripts are considered Digital Markers. To view the complete list of Digital Markers we use, please refer to the summary table attached as an appendix to this Policy.
We may collect certain personal information that you voluntarily provide during (i) your use of the Website and/or (ii) your interactions with our authorized representatives (e.g., in-person communications, videoconferences, emails, instant messaging, phone calls, faxes). The personal information we may collect includes the following:
Personal information that identifies you (first name, last name, and contact information, such as physical addresses, email addresses, and phone numbers) (for the purposes of this Section 2.3, referred to as "identification information");
Personal information necessary to (i) provide you with products and (ii) perform the services you have requested based on our service offerings (collectively, "Products and Services") (identification information);
Personal information provided as part of your job application submitted to us (identification information, spoken languages, educational background, professional experience and affiliations, and any other personal information voluntarily shared through a resume or cover letter);
Personal information provided as part of a transaction (business operation) you wish to carry out with us (identification information, payment methods, and payment details); and
Personal information contained in the exchanges that make up your communication history with us and our authorized representatives (in addition to all personal information listed in this Section 2.3, this may include consent records, notices, comments, and complaints).
Please note that you are responsible for obtaining the consent of any individual other than yourself before sharing their personal information with us. Similarly, we do not knowingly collect personal information about individuals under the age of fourteen (14) unless we have first obtained the explicit prior consent of a parent or guardian. If you believe that we hold such personal information that may have been collected involuntarily, please notify our Person in charge of the protection of personal information (contact details provided in Section 8 below) so that we can carry out the necessary verifications and, if applicable, securely destroy the personal information in question.
The "purposes" of collection refer to the reasons that justify our need to collect your personal information.
We may collect your personal information for the following purposes:
To identify you to enable appropriate interactions with you;
To create an internal file in order to provide you with Products and Services and, if you authorize us to do so, to deliver them;
To communicate with you to provide information related to our business and its Products and Services;
To send you newsletters;
To process any request or question you submit to us, including contacting you regarding such requests or questions;
To process any transaction (business operation) you carry out with us;
To process and evaluate your application, whether submitted spontaneously or in response to a job posting we have issued;
To conduct background checks;
To communicate with you to follow up on your application, request additional information about it, and/or inform you of any decisions we have made regarding your application;
To enable us to fulfill our obligations and exercise our rights as your employer or in any other relevant capacity;
To allow you to access the Website;
To measure the popularity of different components of the Website;
To identify the technology you use when accessing the Website (such as your operating system and browser) to assess compatibility and improve overall accessibility;
To identify the Internet websites from which you access the Website to evaluate the number of referrals obtained;
To identify the country from which you wish to access the Website to verify if access can be granted in compliance with applicable laws; and/or
Subject to the exceptions provided under the Private Sector Privacy Act, we will ensure that we obtain your consent before using your personal information for purposes other than those listed above.
Due to the use of certain Digital Markers (refer to the summary table attached as an appendix to this Policy), we may collect personal information using technology with functions that allow us to identify you, locate you, and create a profile about you. The functions enabling us to collect your personal information for identification, location, and profiling purposes are disabled by default. You may activate these functions by providing your explicit consent, either by clicking the appropriate button in the pop-up window that appears when you access the Website.
We may grant access to or disclose your personal information to the following individuals or entities:
Employees and representatives of our organization and entities within the same corporate group who need access to this personal information for one or more of the purposes outlined in Section 3 above;
Our service providers and external agents who provide us with transportation and shipping services, website services, application development, hosting, maintenance, and other technological services. These providers require access to personal information to fulfill their obligations under a service agreement or mandate concluded with us (e.g., web hosting or cloud service providers). Under such agreements, the relevant service provider or external agent is required to take appropriate measures to:
Ensure the confidentiality of the disclosed personal information;
Ensure the disclosed personal information is used solely for fulfilling the obligations outlined in the service agreement or mandate;
Ensure the disclosed personal information is not retained after the termination of the service agreement or mandate;
Notify us immediately of any breach or attempted breach of obligations related to the confidentiality of the disclosed personal information; and
Allow us to conduct any necessary verification related to the confidentiality of the disclosed personal information.
Your references, past and current employers, educational institutions you attended, governmental bodies such as law enforcement and ministries, to verify the truth, accuracy, and completeness of the information provided as part of your application, and to obtain additional information from these entities as necessary.
Any other individual or entity, as required or permitted by applicable legislation, or with your prior consent.
It is possible that we may disclose your personal information to individuals or entities in the above-listed categories who are located outside the province of Quebec. In such cases, we will conduct a privacy impact assessment in accordance with the Private Sector Privacy Act before any disclosure. We will only disclose your personal information if the privacy impact assessment demonstrates that the individual or entity in question can ensure adequate protection of the said personal information in accordance with generally recognized privacy protection principles.
We have adopted and implemented physical, technological, and administrative security measures designed to protect your personal information and reduce the risks of unauthorized and/or illegal access, use, disclosure, or destruction. Below is a brief description of these security measures:
Employee and partner selection process. We follow a process that takes our obligations regarding the protection of personal information into account when recruiting new employees who will handle personal information or when entering into service contracts or mandates involving the disclosure of personal information to third parties;
Confidentiality agreements and internal guidelines. All our employees who access to your personal information are required to sign a confidentiality agreement and comply with internal guidelines on the protection of personal information;
Training. We make efforts to ensure that each of our employees who may access personal information receives training on privacy protection, personal information security, and cybersecurity;
Access management and retention. We ensure that your personal information is only accessible to authorized employees and representatives who need access to perform their duties related to one or more of the purposes identified in Section 3 of this Policy. To achieve this, we have implemented mechanisms for managing access to personal information, including assigning distinct access rights based on employee roles. Additionally, we store your personal information on secure servers provided by our web or cloud hosting service providers;
Retention schedule. We have established a retention schedule to ensure that your personal information is not kept beyond the period needed to fulfill the purposes described in Section 3 of this Policy. Subject to any obligations under applicable legislation, your personal information will be securely destroyed within a reasonable timeframe after these purposes have been fulfilled;
Secure destruction process. We have implemented secure destruction processes for personal information whose retention period has expired. The data collected from the forms will be retained for a period of one year;
Management of privacy incidents. In the event of a privacy incident that poses a risk of serious harm to you, we will take the necessary steps to notify you in compliance with the Private Sector Privacy Act. The risk of serious harm is assessed based on criteria such as the sensitivity of the personal information involved, the anticipated consequences of its use, and the likelihood of it being used for harmful purposes; and
Complaint processing procedure. We have developed and adopted a specific procedure for handling complaints related to the processing of personal information within our organization. You are invited to review this procedure, which is accessible via the following hyperlink: Procedure for Managing and Processing Complaints Related to the Protection of Personal Information.
We regularly reassess the aforementioned security measures.
No organization can validly claim to be immune to the risk of a confidentiality incident involving personal information. Despite all our efforts to protect your personal information, we cannot guarantee that it is entirely safe from the risk of a confidentiality incident. If you believe that the protection of your personal information has been compromised, please contact us using the contact information provided in Section 8 of this Policy.
You have the right to access your personal information, which includes the following:
The right to obtain confirmation or information about whether we collect, use, disclose, or retain personal information about you;
The right to receive communication of the personal information we hold about you;
The right to review your personal information in our possession, including in-person access to this information during normal business hours or remotely, and to obtain a copy of it; and
The right to request communication of (or request that we communicate to a third party) your computerized personal information in a structured and commonly used technological format (except for information created or inferred from your personal information), unless fulfilling this right would cause significant practical difficulties for us.
Exercising your right of access is free of charge. If you request reproduction, transcription, or communication of your personal information, we may require you to pay reasonable fees not exceeding the cost of reproduction, transcription, or communication. An estimate of these costs will be provided to you prior to any reproduction, transcription, or communication.
Any request to exercise your right of access must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
You have the right to request rectification of your personal information held by us under the following circumstances:
The personal information about you is inaccurate or outdated;
The personal information about you is incomplete;
The personal information about you is ambiguous; and/or
The collection, communication, or retention of personal information about you is unauthorized or unjustified from a legal standpoint.
You may also request, under your right of rectification, the destruction of any personal information about you that is outdated or whose collection, communication, or retention is unauthorized or unjustified from a legal standpoint.
Any request to exercise your right of rectification must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
You have the right to withdraw your consent for the communication or use of your personal information in our possession. In such cases, you will be informed of the consequences of such withdrawal before it takes effect, enabling you to make an informed decision.
Any request to exercise your right of withdrawal must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy, following the procedure described in Section 6.4 of this Policy.
Any request to exercise a right under Section 6 of this Policy must meet the following criteria to be considered acceptable:
The request must be made in writing; and
The request must be addressed to our Person in charge of the protection of personal information, whose contact information is provided in Section 8 of this Policy.
We must verify your identity before processing any request to exercise a right under Section 6 of this Policy.
If your request to exercise a right under Section 6 of this Policy is not sufficiently precise, or upon your request, we will assist you in identifying the personal information targeted by your request.
We must respond (favorably or unfavorably) to any request to exercise a right under Section 6 of this Policy within thirty (30) days of receiving it, subject to the possibility of verifying the identity of the requester.
We must issue a written decision regarding any request to exercise a right under Section 6 of this Policy. If the decision is unfavorable, we must provide reasons for the decision and specify the provision of the Private Sector Privacy Act on which the decision is based, as well as the remedies available to the requester and the time limits for pursuing them. We must also provide assistance to the requester, if requested, to help them understand the unfavorable decision, if applicable.
If we issue a favorable decision regarding a rectification request, we are required to provide the requester, free of charge, with a copy of any modified or added personal information or, as the case may be, a confirmation of the removal of personal information.
If you are dissatisfied with how our organization processes your personal information, you may file a complaint with our Person in charge of the protection of personal information, whose contact details are provided in Section 8 of this Policy. You are invited to consult our complaint-handling process, which is accessible via the following hyperlink: Procedure for Managing and Processing Complaints Related to the Protection of Personal Information.
To exercise any of your rights, ask questions, provide feedback, or file a complaint regarding this Policy or the processing of your personal information, please contact our Person in charge of the protection of personal information at:
Person in charge of the protection of personal information
Valmetal Inc.
12 Route 249
St-François-Xavier-de-Brompton
Quebec J0B 2V0 Canada
Telephone: 819-845-7824
Email Address: prp@valmetal.com
The effective date and the last update date of this Policy are indicated in the header on its first page. This Policy may be subject to amendments to reflect changes in applicable legislation, as well as updates to policies and practices governing our operations and privacy management, among other factors. To amend this Policy, we will post a notice of amendment in the section of the Website dedicated to this Policy and amendment notices, accessible via this link. If we have your email address, we will use it to send you the notice of amendment. The content of the amendment notice will take effect on the fifteenth (15th) day following its publication on the Website, unless there are reasons justifying a shorter timeframe.