Privacy Policy

1. Introduction

At Harmonie Construction, legally incorporated as 12122715 Canada Inc. (“we,” “our,” or “us”), we place great importance on your privacy and data protection. For this reason, we have implemented processes on our website to obtain your informed and explicit consent when you share personal data with us.

This privacy policy (the “Policy”) describes our privacy practices for the activities outlined below. In accordance with your rights, we inform you how we collect, store, access, and otherwise process information related to individuals. In this Policy, personal data (“Personal Data”) refers to any information that, alone or in combination with other available information, can identify an individual.

We are committed to protecting your privacy in accordance with the highest level of regulation in this area. As such, we comply with the obligations set forth by the regulations below:

• Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation;
• Quebec’s Act respecting the modernization of legislative provisions as regards the protection of personal information (Bill 25).

Scope

This policy applies to Harmonie Construction’s websites, domains, applications, services, and products.

This policy does not apply to third-party applications, websites, products, services, or platforms that may be accessed via links not hosted by Harmonie Construction that we may provide to you. These sites are owned and operated independently of us, and they have their own distinct privacy and data collection practices. Any Personal Data you provide to these sites will be governed by the third party’s own privacy policy. We cannot accept responsibility for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of these sites.

Processing Activities

This policy applies when you interact with us by performing any of the following actions:

• Using our application and services as an authorized user;
• Visiting one of our websites that links to this privacy statement;
• Receiving any communication from us, including newsletters, emails, calls, or text / SMS messages.
  

2. Personal Data We Collect

What Personal Data We Collect

When you use our products and/or features, including our website, we collect the following types of Personal Data:

• Account information such as your name, email, and password;
• Mobile device-specific identifiers such as make and model, IMEI, and phone number;
• Location data;
• Feedback, such as customer support or reviews;
• Content, such as messages, comments, audio files, or documents.
  

How We Collect Your Personal Data

We collect personal data from the following sources:

• From you. You may provide us with your account information, demographic data, content, and feedback. This data may be provided, in particular, when you:
• Create an account on our website;
• Use our website;
• Create content through our products or services;
• Express an interest in our products or services;
• Subscribe to our newsletter;
• Complete a voluntary market survey;
• Contact us with an inquiry or to report a problem (by phone, email, social network, or messaging service);
• When you log in to our website via social networks;
• Fill out forms.

• Through automated technologies or interactions. When you interact with our website, we may automatically collect the types of data listed below. We collect this data using cookies, server logs, and other similar technologies. Please refer to our cookies section (below) for more details.
• Device data concerning your equipment;
• Usage data concerning your actions and browsing habits;
• Contact data when tasks performed via our website remain unfinished. We collect this data using cookies, server logs, and other similar technologies. Please refer to our cookies section (below) for more details.

• Via third parties. We may receive Personal Data about you from various third parties, including:
• Device and usage data from third parties, including analytics service providers such as Google;
• Account information from social media platforms when you log in to our website using these social media platforms;
• Content from communication services, including email providers and social networks, when you give us permission to access your data on these third-party services or networks;
• Account information from third parties, including organizations (such as law enforcement agencies), associations, and groups, that share data for fraud prevention and detection purposes; and
• Account information from technical service providers.

If you provide us, or our service providers, with Personal Data relating to other individuals, you declare that you have the authority to do so and acknowledge that it will be used in accordance with this Policy. If you believe your Personal Data has been provided to us inappropriately, or to otherwise exercise your rights regarding your Personal Data, please contact us using the information provided in the “Contact Us” section below.

Device and Usage Data

When you visit a Harmonie Construction website, we automatically collect and store information about your visit using browser cookies (files we send to your computer) or similar technology. We use the Axeptio tool to ensure that cookies are launched only after receiving your consent for this purpose. You can use the icon located at the bottom left of our site to modify your cookie consent. You can also instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The help feature of most browsers will provide information on how to accept cookies, disable them, or notify you upon receiving a new cookie. If you do not accept cookies, you may not be able to use certain functions of our Service, and we recommend leaving them enabled.

We also process information when you use our services and products. This information may include:

• Login information
• IP address
• Timestamps
• Location information
• Web terms or searches that led you to the site
• Time zone

Data We Collect from Third Parties

We may receive your Personal Data from third parties such as companies subscribing to Harmonie Construction’s services, partners, and other sources. This Personal Data is not collected by us but by a third party and is subject to the distinct privacy and data collection policies of the third party concerned. We have no control or influence over how your Personal Data is processed by third parties. As always, you have the right to review and rectify this information. If you have questions, you should first contact the relevant third party for more information about your personal data. If this third party does not respond to your rights, you may contact Harmonie Construction’s Data Protection Officer (contact details at the end of the Policy).

Our websites and services may contain links to other websites, applications, and services managed by third parties. The information practices of these other services, or of social networks hosting our branded social media pages, are governed by the third parties’ privacy statements, which you should consult to better understand their privacy practices.

Purpose and Legal Basis for Processing Your Personal Data

We collect and use your Personal Data with your consent to provide, maintain, and develop our products and services and to understand how to improve them.

These purposes include:

• To build a safe and secure environment;
• To verify or authenticate your identity;
• To investigate and prevent security incidents such as breaches, attacks, and hacking
• To enable you to access Harmonie Construction’s services and create accounts.

When we process your Personal Data to provide a service, we do so because it is necessary to fulfill contractual obligations. All the aforementioned processing is necessary within the scope of our legitimate interests to provide services, maintain our relationship with you, and protect our business, for example, against fraud. Consent will be necessary to initiate services with you. New consent will be required if changes are made to the type of data collected. Under our contract, if you do not give your consent, certain services may not be available to you.

We also use your Personal Data for the following secondary purposes, provided you have given us your explicit prior consent:

• To organize and provide advertising and marketing;
• To send you newsletters and other marketing communications about current and future products, programs, and services, events, contests, surveys, and promotions that we organize or that are hosted on our behalf;
• To organize events or register participants and plan meetings for events;
• To communicate with you about services.

Third-Party Tools

We use these third-party tools to store your information:

• Funnel.io
• ScoreApp
• WordPress
• Zapier
• Zoho

International Data Transfer and Storage

Where possible, we store and process data on servers located in the general geographical region where you reside (note: this may not be in the country where you reside). Your Personal Data may also be transferred to and stored on servers residing outside your state, province, country, or other governmental jurisdiction where data laws may differ from those in your jurisdiction. We will take appropriate measures to ensure that your Personal Data is processed securely and in accordance with this Policy and applicable data protection legislation. You can find more information on these clauses here: https://eur-lex.europa.eu/legal-content/fr/TXT/?uri=CELEX%3A32021D0914

Sharing and Disclosure

We will only share your personal data with third parties in the manner described in this policy or as defined at the time of personal data collection.

We also use Google Analytics to help us understand how our customers use the site. You can learn more about how Google uses your personal data here: https://www.google.com/intl/fr/policies/privacy/

You can also disable Google Analytics here: https://tools.google.com/dlpage/gaoptout?hl=fr

We may also use your personal data to provide you with targeted marketing through advertisements or communications (such as newsletters).

For more information on how targeted advertising works, you can visit the Network Advertising Initiative (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/

Legal Requirement

We may use or disclose your Personal Data to comply with a legal obligation, in response to a request from a public or governmental authority, or in connection with legal or court proceedings, to prevent any loss of life or injury, or to protect our rights or property. Where possible and practical, we will inform you in advance of such disclosure.

Service Providers and Other Third Parties

We may engage third-party service providers, independent contractors, agencies, or consultants to deliver and help us improve our services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers, and others, but only to maintain and improve our services. For more information on the recipients of your Personal Data, please contact us using the information in the “Contact Us” section below.

3. Cookies

What are cookies?

A cookie is a small file containing information that your browser stores on your device. The information contained in this file is generally shared with the site owner as well as with potential partners and third parties to that business. The collection of this information may be used as part of the site’s operation and/or to improve your experience.

How We Use Cookies

We use cookies to offer you the best possible experience. Our cookies are separated into different categories to allow for easier selection based on your preferences. Through Axeptio, you can give your explicit consent to all our cookies, to only certain categories, or to only certain cookies within each category. To make this selection, you can click on the icon located in the bottom left corner of each website page. Cookies will not be activated until you have given your explicit consent for them to be. You can refuse all non-essential cookies (all cookies except those strictly necessary) without affecting access to the essential functions of the Harmonie Construction website. Here are the different cookie categories:

• Strictly Necessary – As a web application, we require certain necessary cookies to operate our service. These are purely technical and functional cookies that cannot be disabled.
• Emailing Tools – Our site hosts email service subscription forms to send marketing emails. These email services have pixels that track visitors to analyze the performance of sent emails and to see products viewed.
• Social Networks – Our site hosts social network cookies to share interesting and relevant content on social media platforms.
• Statistics and Audience – Our site hosts analytical cookies that allow tracking visitor activities and building advertising audiences.
• Experience and Relationship – Our site uses cookies to record user preferences in order to display relevant content on the site.
• Personalized Ads – Our site uses cookies to tailor ads to the profile and actions taken by users on our site after they have left it.
• Chat & Support – Our site uses cookies to facilitate smoother chat discussions by identifying customer profiles and products purchased or viewed, thereby streamlining request processing by our team.
• Customer Relationship – Our site uses cookies to more accurately and efficiently qualify leads received within our CRM tools.
• Marketing – Our site uses cookies to offer interesting and relevant content through marketing actions to users after they have left our site.
• Performance & Monitoring – Our site uses third-party cookies to monitor performance and errors that occur on our site to correct them more efficiently.
• A/B Testing – Our site tests different configurations to improve our performance. To do this, it uses cookies to ensure consistency across visits in order to draw better conclusions from these tests.

How to Control Your Cookies

Unless the cookie is strictly necessary, you can accept or refuse the use of cookies at any time. To change how we collect information about you, visit our Cookie Manager by clicking the icon in the bottom left corner of each page.

We will only retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected and to the extent required by applicable law. When we no longer need the Personal Data, we will delete it from our systems and/or take steps to anonymize it.

Here are some examples of typical retention periods before Personal Data is erased:

• Customer Account Data – 3 years after account closure, to allow for customer relationship follow-up or in case of complaints.
• Marketing Data – Until consent is withdrawn or 2 years after the last interaction with the user.
• HR Application Data – Immediately after the decision, or up to 1 year after the decision if retained for future opportunities.
• Browsing Data and Cookies – Between the end of the session (temporary cookies) and 6 months (persistent cookies) after the session.

5. Merger or Acquisition

If we are involved in a merger, acquisition, or asset sale, your personal information may be transferred. We will notify you before your personal information is transferred and becomes subject to a different privacy policy. In certain circumstances, we may be required to disclose your personal information if required by law or in response to valid requests by public authorities (e.g., a court or government agency).

6. How We Ensure the Security of Your Data

We have implemented appropriate organizational safeguards and security measures to protect your personal data against accidental loss, unauthorized use or access, alteration, or disclosure.

Communication between your browser and our website uses a secure encrypted connection when your personal data is involved.

We require any third party contracted to process your personal data on our behalf to implement security measures to protect your data and to process such data in accordance with the law.

In the unfortunate event of a data breach compromising your Personal Data, you will be informed within a maximum of 72 hours, in accordance with Law 25. We will also inform any applicable regulatory body when legally required to do so.

7. Your Rights Regarding Your Personal Data

All our users have the following rights regarding their Personal Data, regardless of their geographical location or citizenship. These rights are equal to or greater than those provided in the regulations listed in Article 1 of this Policy.

• Right of Access – You have the right to know whether we process your Personal Data and to request a copy of the Personal Data we process about you.
• Right to Rectification – You have the right to have incomplete or inaccurate Personal Data that we process about you rectified.
• Right to be Forgotten / Right to Erasure – You have the right to request that we erase the personal data we process about you, unless we must retain this data to comply with a legal obligation or to establish, exercise, or defend legal claims.
• Right to Data Portability – You have the right to obtain the Personal Data we hold about you, in a structured electronic format, and to transmit this Personal Data to another data controller, when it concerns (a) Personal Data that you have provided to us, and (b) if we process this data based on your consent or to execute a contract with you or the third party subscribing to the services. We may request identity verification before providing a copy of the Personal Data in our possession.
• Right to Opt-Out – You have the right to opt-out of the processing of your Personal Data for the purposes of: (1) targeted advertising; (2) sale of Personal Data; and/or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Under the CPRA, you have the right to opt-out of the sharing of your Personal Data with third parties and our use and disclosure of your sensitive Personal Data for uses necessary to provide the products and services you reasonably expect. To exercise this right, please use the Axeptio banner to manage your consent.
• Non-Discrimination and Non-Retaliation – You have the right not to be denied a service or to have an altered experience for having exercised your rights.

Withdrawal of Consent

If you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge, for example, if you wish to opt out of marketing messages you receive from us. If you wish to withdraw your consent, please contact us using the information at the bottom of this page.

How to Exercise Your Rights

You can make a request to exercise any of these rights in relation to your personal data by sending the request to our privacy team using the form below.

For your own privacy and security, at our discretion, we may ask you to prove your identity before providing the requested information.

8. Changes

We may amend this Policy at any time. If we make changes to this policy, we will publish an updated version of this policy on this website. When you use our services, you will be asked to review and accept our Privacy Policy. In this way, we can record your acceptance and inform you of any future changes to this Policy.

9. Contact Us

In accordance with the Act to modernize legislative provisions as regards the protection of personal information (Law 25), Harmonie Construction has appointed a Personal Information Protection Officer (PIPO). You can reach them for any questions regarding this Policy or to exercise your rights at the following address:

• Name: Maurice Dagenais
• Email: maurice@harmonieconstruction.com
• Mailing Address: 67 imp. Des Vents, Gatineau QC J8R 4A8, Canada
  

Last updated: January 3, 2025