The GCL Group acknowledges the importance of strengthening governance in the protection of personal
information we hold. The Privacy Policy aims to provide you with clear information regarding the types
of personal information we collect, how we use them, to whom we disclose them, as well as the
purposes and reasons for this collection, use, and disclosure. We want to inform you of your rights
concerning your privacy and its protection.
1. DEFINITIONS
Personal information refers to information about an individual that allows for their identification. It is
confidential and, except for exceptions, cannot be disclosed without the consent of the individual
concerned. Within the Governance Framework, unless the context indicates otherwise, the following
terms are defined as follows:
• Anonymize or generalize personal information: The process by which information about an
individual becomes such that it is no longer possible to identify them directly or indirectly.
• Consent: The authorization given by the individual who owns the personal information to collect
and use their personal data. Consent must be explicit, freely given, informed, specific, and the
duration of its use must be clearly defined. Examples of personal information are provided in
the annex.
• Sensitive personal information: Personal information is considered sensitive when, by its nature
or the context of its use or disclosure, it creates high expectations of privacy. This includes
medical, biometric, genetic, or financial information, as well as data regarding sexual
orientation, religious beliefs, or ethnic origin.
• Third party: Any natural or legal person external to the GCL Group who is not part of our
community of clients or staff. Third parties may include research centers, suppliers,
subcontractors, partners, consultants, external organizations, etc.
2. SCOPE
This Privacy Policy (hereinafter referred to as the "Privacy Policy"), in addition to the governance
framework on personal information, applies to all your interactions with us. This includes, among
others, your visit to our website at www.gclgroup.ca, your various subscriptions to our newsletters, your
job application within our organization, or your registrations for our various events, including our
various projects. Within the GCL Group, we only collect personal information that is strictly necessary
for the fulfillment of our missions and the implementation of our management programs. We take
measures to ensure that the personal information we collect is appropriate, relevant, not excessive, and
used only for specific purposes. Upon request, we also provide the individual concerned with additional
information, including the personal information collected from them, the categories of persons who
have access to this data within GCL Group Canada Inc, the duration of retention of this information, and
the contact information of the person responsible for the protection of personal information.
3. COLLECTION AND USE OF PERSONAL INFORMATION
GCL Group Canada Inc is committed to collecting only the personal information that is strictly necessary
for its activities and to respect your privacy. The types of personal information we collect include:
• Contact Information: This may include your name, personal and/or professional email address, and
phone number. We typically obtain this information directly from you, such as when you register for one
4
of our events, fill out our contact form to schedule a consultation with one of our consultants, or apply
for a position within our organization.
• Information Related to Your Participation in Our Events: This includes the names of
participants, their professional contact details, as well as their dietary preferences and allergies
when necessary. We may also collect qualitative information about your experience at our
events through satisfaction surveys.
• Information from Surveys: When you register as a user on our platform or participate in our
surveys, we may collect information such as your organization's name, industry sector, company
size, region, your job position, and other relevant information.
• Financial Information: The banking information we collect is primarily related to settling various
invoices. For event payments, we use external platforms.
• Employment-Related Information: When you apply for a position within our organization, we
may collect information about your work experience and education. This information is used in
the recruitment process. We may also obtain personal information from third parties during
reference checks or pre-employment background checks.
• Online Activity-Related Information: We may collect information such as IP addresses (and
their associated locations) and pages visited on our website. This collection is typically done
using cookies or similar technologies, as explained in our cookie policy. We treat this
information as personal data when applicable.
For the use of your personal information, we commit to using your personal information only for the
purposes for which it was collected, as described in this section. However, there may be instances where
we use your personal information for other purposes for which we will seek your prior consent.
How we use your personal information:
• Ensure the Delivery of Our Services: Your personal information is used to provide you with
exclusive benefits reserved for registered participants in our events, such as webinars,
conferences, and other events, thereby ensuring the delivery of our services.
• Manage Our Business Activities: We use your personal information to improve our business
strategies, detect fraud and other illegal activities, and oversee the overall management of our
operations.
• Communicate with You: We use your contact information to send you event invitations,
newsletters (subject to your right to withdraw your consent), or for any other necessary
communication.
• Evaluate Job Applications: If you apply for a position within our organization, your personal
information is used for the processing and evaluation of your application.
• Conduct Statistical Analysis: We analyze the behaviors of visitors to our website to improve the
user experience. This information does not allow for your personal identification and is collected
anonymously. Data provided in surveys is used for market research and statistical reports
without personal information.
• Achieve Other Purposes Permitted or Required by Law: Your personal information may be used
to protect data security and our website or to comply with legal obligations, as applicable.
Furthermore, we will always seek your prior consent when we use your personal information for
purposes other than those stated above.
4. PROTECTION OF PERSONAL INFORMATION
At GCL Group Canada Inc, we implement appropriate and reasonable security measures to protect
personal information against loss, theft, unauthorized access, disclosure, copying, illegal use, or
modification. Only members of our staff who have a legitimate need to access personal information as
part of their job responsibilities are authorized to do so. Managers are responsible for supervising and
implementing personal information protection policies within their respective teams.
Our staff members and individuals working on our behalf must, among other things:
• Make reasonable efforts to minimize the risk of unintentional disclosure of personal
information.
• Take special precautions to ensure that personal information is not monitored, overheard,
accessed, or lost when working outside our premises.
• Take reasonable measures to protect personal information when it is being transported from
one location to another.
All third parties who have access to the personal information held by GCL Group Canada Inc are
informed of our Policy, Management Framework, Governance Framework, as well as other applicable
policies and processes to ensure the security and protection of personal information. All third parties
are required to commit in writing to adhere to these policies, frameworks, processes, and applicable
laws.
5. DISCLOSURE OF PERSONAL INFORMATION
GCL Group Canada Inc may share personal information without the consent of the individual concerned
when required by Law 25 or as part of legal investigations. Additionally, this information may be shared
with internal staff who need it for their duties. When shared with third parties or service providers,
contracts or written agreements are used to ensure the confidentiality and appropriate use of this data
in accordance with our Governance Framework and applicable laws. Personal information may also be
disclosed for research, studies, or statistical purposes, subject to conditions prescribed by Law 25, with
appropriate record-keeping by the person responsible for the protection of personal information (PRP).
GCL Group Canada Inc may also share personal information with the valid consent of the individual
concerned.
6. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
Within GCL Group Canada Inc, we retain the personal information we hold for the period necessary to
achieve the purposes for which it was collected, in accordance with our retention schedule, unless
otherwise authorized or required by legal or regulatory requirements.
Generally, once the purposes for which personal information was collected or used have been achieved,
we proceed with its irreversible destruction or anonymization for use for public interest purposes.
7. REQUEST FOR ACCESS OR CORRECTION OF PERSONAL INFORMATION
• Request for Access to Personal Information: Any individual has the right to access their
personal information held by GCL Group Canada Inc, except for exceptions provided by the
Access to Information Act. For the request to be valid, it must be submitted in writing by the individual
concerned or their authorized representative, along with proof of identity. The request must contain
sufficiently specific details to be processed.
• Request for Correction: If an individual discovers that their personal information in a file is
inaccurate, incomplete, ambiguous, or collected, disclosed, or retained in an unauthorized
manner under the Access to Information Act, they can request its correction. This request must
be submitted in writing by the individual concerned or their authorized representative, with
specific details for processing. If the request for correction is accepted, GCL Group Canada Inc
provides a copy of the modifications made to the personal information or a statement of its
deletion, as applicable, free of charge.
8. COOKIES AND OTHER TECHNOLOGIES
We use cookies to collect certain technical information when you visit our website. This information
does not allow for your direct identification and is used to improve website content and facilitate access.
This information may be stored on servers of our service providers located outside Quebec and may
thus be subject to the laws of those countries, including any laws allowing government authorities to
access it. We use Google Analytics, which allows us to see information about user activities, including
the pages they have viewed, the source, and the time spent on our website. This information is
depersonalized and presented in aggregate form, meaning it cannot be used to identify the user. You
can disable the use of Google Analytics by visiting Google Analytics.
9. IMPORTANT NOTES
All staff members, service providers, and third parties are required to comply with this policy starting
from September 2023. However, we reserve the right to update and periodically revise this policy to
reflect legislative, regulatory, or organizational developments in personal information protection.
If you have any questions or comments regarding how we handle your personal information, please
feel free to contact our Privacy Officer at the following address: info@gclgroup.com.
Privacy policy - All rights reserved
