Privacy policy

1.Application and definitions

This policy applies to AQ, including its officers, employees and subcontractors, and to any person who otherwise provides services on AQ's behalf. It also applies to the website (https://angesquebec.com/).

It covers all types of personal information managed by AQ, whether it be information about potential or current contractors and angels, its employees, or any other person who has a relationship with AQ.

For the purposes of this Privacy Policy, personal information is information about an individual that directly or indirectly allows that individual to be identified. For example, it could be a person's name, address, e-mail address, telephone number, gender or banking information, information about his or her personal financial situation, ethnic origin, language, and so on.

Sensitive personal information is information towards which there is a high reasonable expectation of privacy, e.g. financial information, banking information and biometric information.

Generally speaking, an individual's professional or business contact information does not constitute personal information, such as an individual's name, title, address, e-mail address or business telephone number. More specifically, and for greater clarity, under Quebec's Act respecting the protection of personal information in the private sector, and as of September 22, 2023, sections 3 (collection, use, communication), 4 (retention and destruction) and 6 (data security) do not apply to an individual's information relating to the exercise of a function within an enterprise, such as name, title, function, as well as address, e-mail address and telephone number at work.

2.Collection, use and communication

As part of our services at AQ, we limit data collection to essential information for anyone interacting with us, including angels, contractors, or those wishing to join our team. This includes collecting names, professional titles, and contact information during interactions, and resumes or email content for job applications. Our goal is to respect confidentiality while ensuring appropriate and relevant communication with those who do business with AQ, as well as with our employees.

AQ will inform individuals, at the time of collection of personal information, of any other information collected, the purposes for which it is collected and the means of collection, in addition to any other information required by law.

AQ applies the following general principles to the collection, use and disclosure of personal information:

Consent :

AQ ,collects personal information directly from the individual concerned and with his or her consent, unless an exception is provided for by law. Consent may be implied in certain situations, for example, when the individual decides to provide his or her personal information after having been informed by this policy of the use and disclosure for the purposes indicated herein. Thus, this policy and the information it contains will be available to the person concerned at the time personal information is collected.

Normally, AQ must also obtain the consent of the person concerned before collecting his or her personal information from third parties, before communicating it to third parties or for any secondary use thereof. However, AQ may act without consent in certain cases provided for by law and under the conditions stipulated therein. The main situations in which AQ may act without consent are indicated in the relevant sections of this policy.

Collection :

• In all cases, AQ will only collect information if it has a valid reason to do so. In addition, the collection of information will be limited to that which is necessary to fulfill the purpose for which it is collected.
• Please note that QA services are never intended for minors (under 14).
• Collection from third parties. AQ may obtain your personal information from third parties, but only with your prior consent, except in certain exceptional cases provided for by law. If your data is not collected directly from you but through another entity, you have the right to request that AQ identify the source of such information.

In certain situations, AQ may also collect personal information from third parties, without the consent of the person concerned, if it has a serious and legitimate interest in doing so and a) if the collection is in the interest of the person and it is not possible to collect it from him or her in a timely manner, or b) if such collection is necessary to ensure that the information is accurate.

This collection through third parties may be necessary to use certain services, or to otherwise do business with AQ. When required, AQ will obtain consent at the appropriate time.

Holding and use :

AQ ensures that the information it holds is up-to-date and accurate at the time it is used to make a decision concerning the person concerned.

AQ may use an individual's personal information only for the purposes identified herein or for any other purposes identified at the time of collection. If AQ wishes to use the information for any other reason or purpose, a new consent must be obtained from the person concerned, which must be obtained expressly if the information is sensitive personal information. However, in certain cases provided for by law, AQ may use the information for secondary purposes without the individual's consent, e.g. :

• when such use is clearly for the benefit of that person.
• when necessary to prevent or detect fraud.
• when necessary to evaluate or improve protection and safety measures.

Limited access. AQ shall implement measures to limit access to personal information to those employees and individuals within its organization who have a right to know the information and for whom the information is necessary in the performance of their duties. AQ will seek the consent of the individual before granting access to any other person.

Communication to third parties in the course of business:

Generally, and unless an exception is indicated in this Policy or otherwise provided by law, AQ will obtain the consent of the individual concerned before disclosing his or her personal information to a third party. In addition, where consent is required and where sensitive personal information is involved, AQ will obtain the individual's express consent prior to disclosing the information.

However, disclosure of personal information to third parties is sometimes necessary. Thus, personal information may be communicated to third parties without the consent of the person concerned in certain cases, including, but not limited to, the following:

• AQ may communicate personal information, without the consent of the person concerned, to a public body (such as the government) which, through one of its representatives, collects it in the exercise of its powers or the implementation of a program it manages.
• Personal information may be transmitted to partners (e.g. QA and other co-investors) or service providers to whom it is necessary to communicate the information, without the consent of the individual. In such cases, the information must only be used to perform the service.
• If necessary for the purposes of concluding a transaction, AQ may also communicate personal information, without the consent of the person concerned, to the other party to the transaction and subject to the conditions provided by law.

Disclosure outside Quebec: Personal information held by AQ may be disclosed outside Quebec, for example, when AQ uses service providers whose offices are located outside Quebec or when AQ deals with subcontractors located outside the province.

Cookies and the website

Cookies are data files sent to a Web site visitor's computer by his or her Web browser when the site is visited and can serve several purposes.

The website controlled by AQ uses cookies, in particular:

• To memorize visitors' settings and preferences, e.g. for language selection, and to enable tracking of the current session.
• For statistical purposes, to track visitor behavior and content, and to improve the website.

The AQ-controlled website uses the following types of cookies:

• Session cookies: These are temporary cookies that are stored only for the duration of your visit to the Web site.
• Persistent cookies: These are kept on the computer until they expire, and are retrieved the next time the site is visited.

AQ collects personal information via a form with a technological service that has a cache in a Web form, and AQ must ensure that these settings offer the highest level of confidentiality by default (cookies are not covered).

3.Retention and destruction of personal information

Unless a minimum retention period is required by financial market regulations or applicable AMF regulations, AQ will retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected.

Depending on the nature of business activities, personal information used by AQ may be retained for periods ranging from a few months for resumes received, to more than 10 years for inactive contractor files or cases of employees who have left the company.

At the end of the retention period or when the personal information is no longer required, AQ will ensure:

• Destroy them; or
• anonymize them (i.e., they no longer irreversibly identify the individual and it is no longer possible to establish a link between the individual and the personal information) and use them for serious and legitimate purposes.

The destruction of information by QA must be carried out in a secure manner, to ensure the protection of this information. The internal security policy defines the mechanisms for secure destruction.

This section may be supplemented by any policies or procedures adopted by AQ regarding the retention and destruction of personal information, if any. Please contact AQ's Privacy Officer (identified in this policy) for further information.

4.Anges Quebec responsibilities

In general, AQ is responsible for protecting the personal information it holds, regardless of whether the computer media are under its direct responsibility or via a cloud provider.

AQ's Privacy Officer is a person in authority. He or she is generally responsible for ensuring compliance with applicable privacy legislation. The person in charge must approve the policies and practices governing the governance of personal information. More specifically, this person is responsible for implementing this policy and ensuring that it is known, understood and applied. In the event of the absence or inability to act of the Privacy Officer, the General Manager of AQ will assume the duties of the Privacy Officer.

AQ employees who have access to personal information or are otherwise involved in its management must ensure its protection and comply with this policy.

The roles and responsibilities of AQ employees with respect to personal information may be specified by any other AQ policy in this regard, if applicable.

5.Data Security

AQ is committed to defining, implementing, and enforcing an internal security policy and reasonable security measures to ensure the protection of personal information under its control. The security measures in place correspond, among other things, to the purpose, quantity, distribution, medium and sensitivity of the information. This means that information that may be considered sensitive (see definition in section 2) will require more stringent security measures and greater protection.

In particular, and in accordance with what was mentioned above concerning limited access to personal information, AQ must put in place the necessary measures to impose constraints on the rights of use of its information systems so that only employees who need to have access to them are authorized to access them.

6.Rights of access, rectification and withdrawal of consent

To exercise his or her right of access, rectification or withdrawal of consent, the person concerned must submit a written request to that effect to AQ's Privacy Officer, at the e-mail address indicated in the following section.

Subject to certain legal restrictions, individuals may request access to and correction of their personal information held by AQ if it is inaccurate, incomplete or equivocal. They may also request that the dissemination of personal information concerning them cease, or that any hyperlink attached to their name allowing access to this information by a technological means be de-indexed, when the dissemination of this information contravenes the law or a court order. They may do the same or require that the hyperlink providing access to this information be reindexed, when certain conditions provided for by law are met.

The AQ Privacy Officer must respond in writing to such requests within 30 days of receipt of the request. Reasons must be given for any refusal, together with the legal provision justifying the refusal. In such cases, the response must indicate the remedies available under the law and the time limit for exercising them. If necessary, the person in charge must help the applicant understand the refusal.

Subject to applicable legal and contractual restrictions, data subjects may withdraw their consent to the communication or use of the information collected.

They may also ask AQ what personal information has been collected from them, what categories of people at AQ have access to it, and how long it is kept.

7.Complaints handling process

Reception

Any person who wishes to make a complaint regarding the application of this policy or, more generally, regarding the protection of his or her personal information by AQ, must do so in writing to AQ's Privacy Officer at the e-mail address indicated in the following section.

The individual will be asked to provide his or her name, contact information, including telephone number, as well as the subject and reasons for the complaint, in sufficient detail to allow the complaint to be evaluated by QA. If the complaint is not specific enough, the Privacy Officer may request any additional information he or she deems necessary to assess the complaint.

Treatment

AQ undertakes to treat all complaints received confidentially.

Within 30 days of receipt of the complaint, or of receipt of any additional information deemed necessary and required by AQ's Privacy Officer to process the complaint, the Privacy Officer shall assess the complaint and provide a reasoned written response by e-mail to the complainant. The purpose of this assessment will be to determine whether AQ's handling of personal information complies with this policy, any other policies and practices in place within the organization, and applicable legislation or regulations.

If the complaint cannot be processed within this timeframe, the complainant must be informed of the reasons for extending the deadline, the progress made in processing the complaint and the reasonable time required to provide a definitive response.

AQ must set up a separate file for each complaint it receives. Each file contains the complaint, the analysis and documentation supporting its assessment, as well as the response sent to the person who initiated the complaint.

8.Approval

This policy is approved by AQ's Privacy Officer, whose business contact information is as follows:

AQ Privacy Officer

Mrs. Nidal Fadel
3 Place Ville-Marie
Espace CDPQ
Suite 1-100, Suite 12350 
Montreal, Quebec
H3b 0E7

We invite you to send your questions and comments about security and privacy to our Privacy Officer using the contact form available at the following address :Protection of personal information