This Privacy Policy serves as the foundation for AQ’s commitment to protecting personal information. It transparently explains how data is collected, used, shared, and stored, affirming the importance the organization places on the confidentiality and security of information in an increasingly digital world. This framework not only reassures partners and participants that their privacy is respected but also ensures that AQ’s practices align with applicable legal and ethical standards.
1. Scope and Definitions
This policy applies to AQ, including, but not limited to, its officers, employees, and subcontractors, as well as any person who otherwise provides services on behalf of AQ. It also applies to the website (https://angesquebec.com/).
It covers all types of personal information managed by AQ, whether it pertains to potential or current entrepreneurs and angel investors, its employees, or any other individuals who have a relationship with AQ.
For the purposes of this Policy, “personal information” means information that relates to an individual and that allows that individual to be identified, either directly or indirectly. For example, this could include a person’s name, address, email address, phone number, gender, or banking information, as well as information about their personal financial situation, ethnic origin, language, etc.
Sensitive personal information is information for which there is a high degree of reasonable expectation of privacy, e.g., financial information, banking information, and biometric information.
Generally speaking, a person’s professional or business contact information does not constitute personal information; examples include a person’s name, title, address, email address, or work phone number. More specifically, and for the sake of clarity, under Quebec’s Act respecting the protection of personal information in the private sector, and effective September 22, 2023, Sections 3 (collection, use, disclosure), 4 (retention and destruction), and 6 (data security) do not apply to information about a person relating to the performance of a function within a business, such as their name, title, position, as well as their workplace address, email address, and phone number.
2. Collection, Use, and Disclosure
As part of our services at AQ, we limit data collection to essential information, whether for anyone interacting with us—including angel investors, entrepreneurs, or those wishing to join our team. This approach includes collecting names, job titles, and contact information during interactions, as well as resumes or email content for job applications. Our goal is to respect privacy while ensuring appropriate and relevant communication with those who do business with AQ, as well as with our employees.
AQ will inform the individuals concerned, at the time of collecting personal information, of any other information being collected, the purposes for which it is collected, and the methods of collection, in addition to any other information required by law.
AQ applies the following general principles regarding the collection, use, and disclosure of personal information:
Consent:
Generally, AQ collects personal information directly from the individual concerned and with their consent, unless an exception is provided for by law. Consent may be implied in certain situations, for example, when the individual decides to provide their personal information after being informed by this policy of its use and disclosure for the purposes set forth herein. Thus, this policy and the information it contains will be made available to the individual concerned at the time of collection of personal information.
Normally, AQ must also obtain the data subject’s consent before collecting their personal information from third parties, before disclosing it to third parties, or for any secondary use of such information. However, AQ may act without consent in certain cases provided for by law and under the conditions set forth therein. The main situations in which AQ may act without consent are outlined in the relevant sections of this policy.
Collection:
In all cases, AQ collects information only if it has a valid reason to do so. Furthermore, collection will be limited to only the information necessary for AQ to fulfill the intended purpose.
Please note that AQ’s services are never intended for minors (under 14 years of age).
Collection from Third Parties: AQ may obtain your personal information through third parties, but this is done 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 ask AQ to identify the source of this information.
In certain situations, AQ may also collect personal information from third parties without the consent of the individual concerned if it has a serious and legitimate interest in doing so and a) if the collection is in the individual’s best interest and it is not possible to obtain the information from the individual 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 the individual’s consent at the appropriate time.
Retention 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 regarding the individual concerned.
AQ may use an individual’s personal information only for the reasons set forth herein or for any other reasons provided at the time of collection. As soon as AQ wishes to use this information for another reason or purpose, new consent must be obtained from the individual concerned, and such consent 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 in the individual’s best interest;
- when it is necessary to prevent or detect fraud;
- when it is necessary to assess or improve protection and security measures.
Limited Access. AQ must implement measures to restrict access to personal information solely to employees and individuals within its organization who are authorized to access it and for whom such information is necessary in the performance of their duties. AQ will seek the individual’s consent before granting access to any other person.
Disclosure to Third Parties in the Course of Business:
Generally, and unless an exception is specified in this policy or otherwise provided for by law, AQ will obtain the consent of the individual concerned before disclosing their personal information to a third party. Furthermore, when consent is required and the information in question is sensitive personal information, AQ must obtain the individual’s explicit consent before disclosing the information.
However, the disclosure of personal information to third parties is sometimes necessary. Thus, personal information may be disclosed to third parties without the consent of the individual concerned in certain cases, including, but not limited to, the following:
- AQ may disclose personal information, without the consent of the individual concerned, to a public body (such as the government) that, through one of its representatives, collects such information in the exercise of its duties or the implementation of a program under its management.
- Personal information may be disclosed to its partners (e.g., AQ and other co-investors) or service providers to whom it is necessary to disclose the information, without the individual’s consent. In such cases, this information may be used only for the purpose of performing the service.
- If necessary for the purpose of concluding a transaction, AQ may also disclose personal information, without the consent of the individual concerned, to the other party to the transaction, subject to the conditions set forth 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 does business with subcontractors located outside the province.
Cookies and the Website
Cookies are data files transmitted to a website visitor’s computer by their web browser when they visit the site and can serve various purposes.
The website operated by AQ uses cookies, in particular:
- To remember visitors’ settings and preferences, such as language selection, and to track the current session.
- For statistical purposes to understand visitor behavior and the content viewed, and to enable improvements to the website.
The website operated by AQ uses the following types of cookies:
- Session cookies: These are temporary cookies that are stored in memory only for the duration of the visit to the website.
- Persistent cookies: These are stored on the computer until they expire and will be retrieved during the next visit to the site.
AQ collects personal information via a form using a technology service that employs a cache in a web form, and AQ must ensure that these settings provide the highest level of privacy by default (session cookies are not affected).
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 for as long as necessary to fulfill 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 received resumes to more than 10 years for inactive contractor files or cases involving employees who have left the company.
At the end of the retention period or when personal information is no longer needed, AQ will ensure that:
- to destroy it; or
- anonymize it (i.e., make it irreversibly impossible to identify the individual and establish a link between the individual and the personal information) for use for serious and legitimate purposes.
The destruction of information by AQ must be carried out securely to ensure the protection of such information. The internal security policy defines the mechanisms for secure destruction.
This section may be supplemented by any policy or procedure adopted by AQ regarding the retention and destruction of personal information, as applicable. Please contact AQ’s Privacy Officer (listed in this policy) for more information.
4. AQ’s Responsibilities
In general, AQ is responsible for protecting the personal information it holds, regardless of whether the data storage media are under its direct control or managed by a cloud service provider.
AQ’s Privacy Officer is a person in a position of authority. In general, this individual is responsible for ensuring compliance with applicable privacy laws. The Privacy Officer must approve the policies and practices governing the management of personal information. More specifically, this individual is responsible for implementing this policy and ensuring that it is known, understood, and followed. In the event that the Data Protection Officer is absent or unable to perform their duties, AQ’s Chief Executive Officer will assume the responsibilities of the Data Protection Officer.
AQ staff members 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 further specified by any other AQ policy on this matter, as 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 the personal information it manages. The security measures in place are commensurate with, among other factors, the purpose, volume, distribution, medium, and sensitivity of the information. Thus, this means that information that may be classified as sensitive (see the definition provided in Section 2) must be subject to more stringent security measures and must be better protected.
In particular, and in accordance with what was mentioned earlier regardingrestricted access to personal information, AQ must implement the necessary measures to restrict access rights to its information systems so that only employees who need access are authorized to access them.
6. Rights of Access, Correction, and Withdrawal of Consent
To exercise their rights of access, correction, or withdrawal of consent, the data subject must submit a written request to that effect to AQ’s Privacy Officer at the email address provided in the following section.
Subject to certain legal restrictions, data subjects may request access to their personal information held by AQ and request that it be corrected if it is inaccurate, incomplete, or ambiguous. They may also demand that the dissemination of personal information concerning them be ceased or that any hyperlink associated with their name that provides access to such information via technological means be de-indexed, when the dissemination of such information violates the law or a court order. They may do the same, or may request that the hyperlink providing access to such information be reindexed, when certain conditions set forth by law are met.
AQ’s Privacy Officer must respond in writing to these requests within 30 days of the date the request is received. Any refusal must be supported by a statement of reasons and accompanied by the legal provision justifying the refusal. In such cases, the response must indicate the legal remedies available and the time limit for exercising them. The Privacy Officer must assist the requester in understanding the refusal, if necessary.
Subject to applicable legal and contractual restrictions, data subjects may withdraw their consent to the disclosure or use of the information collected.
They may also ask AQ what personal information has been collected about them, which categories of AQ personnel have access to it, and how long it will be retained.
7. Complaint Handling Process
Receipt
Any person wishing to file a complaint regarding the application of this policy or, more generally, regarding the protection of their personal information by AQ, must do so in writing by contacting AQ’s Privacy Officer at the email address provided in the following section.
The individual must provide their name, contact information (including a phone number), as well as the subject and grounds for their complaint, providing sufficient details to allow AQ to evaluate it. If the complaint is not sufficiently specific, the Privacy Officer may request any additional information deemed necessary to evaluate the complaint.
Handling
AQ is committed to handling all complaints received confidentially.
Within 30 days of receiving the complaint or of receiving all additional information deemed necessary and requested by AQ’s Privacy Officer to process it, the Privacy Officer must evaluate the complaint and provide a reasoned written response via email to the complainant. This assessment will aim to determine whether AQ’s processing of personal information complies with this policy, any other policies and practices in place within the organization, and applicable laws or regulations.
If the complaint cannot be processed within this timeframe, the complainant must be informed of the reasons justifying the extension, the status of the complaint’s processing, and the reasonable timeframe required to provide a final response.
AQ must create a separate file for each complaint submitted to it. Each file contains the complaint, the analysis, and the documentation supporting its assessment, as well as the response sent to the person who filed the complaint.
8. Approval
This policy is approved by AQ’s Privacy Officer, whose business contact information is as follows:
Privacy Officer for AQ
Ms. Nidal Fadel
3 Place Ville-Marie
Espace CDPQ
Suite 1-100, Office 12350
Montreal, Quebec
We invite you to send your questions and comments regarding security and privacy to our Privacy Officer using the contact form available at the following address: Privacy Policy