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Privacy Policy
1ÈRE AVENUE PRIVACY POLICY - last update: March 3rd, 2025
1. Introduction
www.1ereavenue.com (hereinafter the "Website") is owned and operated by 9191542 Canada inc. (hereinafter "1ère Avenue", "us", "we", "our"). This privacy policy (hereinafter the "Policy") sets out how we collect, hold, use or communicate to third parties Personal Information (as defined hereinafter) of our customers or other individuals (hereinafter individually referred to as “you”), other than our employees or contracted staff, which is dealt with separately.
We are committed to treating any Personal Information we collect, hold, use or communicate with care, within the limits of this Policy and applicable law.
2. Types of Personal Information
This Policy applies to Personal Information regardless of the type of medium or the form in which it is accessible: written, graphic, sound, visual, taped, filmed, computerized, or others.
We define “Personal Information” as any information about an identifiable individual, or that taken alone or combined with other data, allows an individual to be identified. By way of illustration, Personal Information could consist of, but is not limited to:
• first and last name;
• date of birth;
• phone, home address and email address;
• preferred language;
• time zone;
• financial, credit, billing, and account information;
• details about the use of our Website obtained by means of cookies or similar tools;
• Internet protocol (IP) address, browser type, locale preferences, mobile carrier; and
• any other Personal Information provided.
3. The Purposes for which we Collect Personal Information
We collect Personal Information for the following purposes :
• to provide and maintain our products, services and Website?
• to develop and manage our business, activities and operations;
• for marketing and advertising purposes;
• for statistical purposes relating to the use of our Website;
• to attend or manage requests to us;
• to evaluate a job candidate’s application and to determine whether to offer such job candidate a position at 1ère Avenue;
• to comply with our legal, regulatory and risk management;
• any purpose permitted or required by applicable laws; and
• any other purpose to which you have consented.
4. Means by which we Collect Personal Information
We generally collect Personal Information i) directly from the person concerned; or ii) from a number of independent sources, such as social networks, our service providers or other business partners.
We additionally collect, passively using cookies, a limited amount of Personal Information from our Website users. Cookies are small text files or strings that a website can send to your device to identify your web browser and the activities of your computer. This mainly consists of IP address, type of operating system, pages visited, requests made, dates and times of connections. Cookies help us improve our products, services and Website.
The use of cookies does not allow us or our analysis service providers to identify you specifically. Furthermore, it does not give us access to your device or any other information about you, other than the data you choose to share with us. The use of cookies can be accepted through the cookie banner displayed when entering our Website for the first time. Please note that if you choose not to accept cookies, you may not be able to access or fully experience the interactive features of our Website.
5. Outsourcing, Storage and Transfers of Personal Information
We may disclose the Personal Information we have collected to third parties in the following circumstances :
• to third-party in connection with our products, services, Website and business;
• to comply with an applicable statute, regulation, rule of law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other legal process;
• to allow us to enforce available recourses or limit the damages we may suffer;
• to protect the safety and/or security of the Website or the general public;
• in the event of a commercial transaction, namely the sale, transfer or assignment, in whole or in part, of shares or assets of 1re Avenue; and
• any other circumstances to which you have consented.
If you are a Quebec resident, note that your Personal Information may be transferred to places outside Quebec. Indeed, we call upon service providers located outside of Quebec to carry out specific mandates in the normal course of business. Furthermore, your Personal Information may be stored in data centers located outside Quebec.
To protect your information in all such cases, we use contractual and other means to provide a comparable level of protection to that used by 1ère Avenue (as outlined in Section 8).
6. Your Consent under this Policy
We will not collect, hold, use or disclose your Personal Information without your consent unless it is authorized or required to do so by applicable law.
By submitting your Personal Information, using our Website or services and/or purchasing our products, you consent to the collection, use and disclosure of your Personal Information to the extent described in this Policy and as required or permitted by applicable law.
If you provide Personal Information concerning another individual to us, you represent that, prior to submitting such information, you have obtained the necessary consent or authority to permit us to collect, use and disclose such Personal Information for the purposes set out in this Policy, or the collection, use and disclosure is permitted by applicable law.
You may vary or withdraw your consent to the use and disclosure of your Personal Information, or opt-out of certain uses and disclosures, subject to legal and contractual restrictions as well as applicable law. Please note that the withdrawal of your consent may prevent us from providing or continuing to provide our products and services or access to our Website.
If you require any assistance in understanding the scope of the consent being sought or to vary or withdraw your consent, please contact our Privacy Officer using the contact information in Section 13.
Email marketing communications. We may send to our customers marketing and promotional emails. If a customer no longer wants to receive such emails, he may click on the “unsubscribe” link in such emails to opt out of future marketing communications.
If you require any assistance in understanding the scope of the consent being sought or to vary or withdraw your consent, please contact our Privacy Officer using the contact information in Section 13.
7. Your Rights
You have the following rights regarding your Personal Information:
• to access and request an exported or physical copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;
• to have the Personal Information we have about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
• to request the deletion of your Personal Information when : i) the retention of the information is no longer justified for the purpose for which it was collected; or iii) the information was not collected in a lawful manner; and
• to withdraw or change your consent to our processing of your Personal Information, subject to applicable legal and contractual restrictions. In some instances, withdrawing your consent may result in 1ère Avenue no longer being able to provide our services, products and/or Website.
We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise his or her rights.
If the Europe or United Kingdom privacy laws apply to you, please review Section 12.2 of this Policy. If the California, Virginia, Colorado, Connecticut or Utah privacy laws apply to you, please review Section 12.3 of this Policy.
8. How we Safeguard Personal Information
In order to protect the Personal Information that is in our possession, we employ administrative, physical, and technological safeguards which are appropriate to the sensitivity of the Personal Information provided. These safeguards also prevent the accidental or unlawful destruction, loss, unauthorized alteration or disclosure, access, or misuse of the Personal Information in our possession. We follow generally accepted industry standards to protect the information that is provided during its submission and once it has been received. These include measures to deal with any suspected data breach.
Once communicated, the Personal Information is kept in an electronic file within our document management system or third-party technologies used by us, or both. Only those personnel who reasonably require the Personal Information to perform their duties are granted access to the information and they are bound by a duty of confidentiality.
It is important to note that, despite our best efforts to protect your Personal Information, there is a risk associated with the communication, exchange and storage of information, as no form of electronic transmission or storage is perfectly secure. 1ÈRE AVENUE ASSUMES NO RESPONSIBILITY FOR THE DESTRUCTION, LOSS, UNAUTHORIZED ACCESS OR DISCLOSURE, OR ALTERATION OF PERSONAL INFORMATION, NOR FOR ANY DAMAGES SUFFERES AS A RESULT.
9. Links to Third-party Websites and Services
Our Website may contain links to third-party websites or services that are not owned or controlled by 1ère Avenue. This Policy only applies to information collected by us for the purposes mentioned in Section 3 above. We have no control over these third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Website.
10. Personal Information of Children under 14
Our products and services are not directed at or intended for use by children, nor do we knowingly collect Personal Information from children under the age of 14. If you are a parent or guardian and become aware that your child has provided us with Personal Information without your consent, please contact our Privacy Officer using the contact information in Section 13.
11. Retention and Destruction of Personal Information
The Personal Information we collect is retained for varying periods of time depending on the type of information in question and the purposes for which it is collected and used. Subject to a retention period provided for by applicable law, the Personal Information we hold is destroyed or anonymized to use for serious and legitimate purposes once the purpose(s) for which it was collected or used (or any subsequent and compatible purpose(s)) has been fulfilled.
12. Notice to Certain Residents
12.1 Notice to Quebec Residents
This Policy is compliant with an Act respecting the protection of Personal Information in the private sector, as recently amended by an Act to modernize legislative provisions as regards the protection of Personal Information (commonly referred to as “Law 25”).
12.2 Notice to Europe and United Kingdom Residents
If the processing of your Personal Information is subject to the General Data Protection Regulation 2016/679 ("EU GDPR") or the United Kingdom General Data Protection Regulation ("UK GDPR"), this supplemental Section of our Policy apply to you.
Our lawful basis for processing Personal Information may include when:
• you have given consent;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• processing is necessary to protect our legitimate interests or that of a third party, except where such interests are overridden by your interests or fundamental rights;
• processing is necessary for compliance with a legal obligation to which we are subject; and
• processing is necessary to protect the vital interests of the data subject or of another natural person.
You have many rights with respect to our processing of your Personal Information. Depending upon the lawful basis of processing, you may have the right to withdraw consent or object to our processing of your Personal Information.
You have the right to be informed about your Personal Information and how it is being processed, to access, correct and erase Personal Information, to restrict further processing, to obtain and reuse your data for your own purposes across different services and to object to processing. You also have the right to lodge a complaint with the relevant EU or United Kingdom supervisory authority.
We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise his or her rights.
12.3 Notice to California, Virginia, Colorado, Connecticut and Utah Residents
To the extent any California, Virginia, Colorado, Connecticut or Utah privacy law applies to you, this supplemental Section of our Privacy Policy outlines the rights that residents of such jurisdictions may have, and how they can exercise those rights. We provide this supplemental Section to comply with the California Consumer Privacy Act [as amended by the California Privacy Rights Act (referred to collectively as “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”) and the Utah Consumer Privacy (“UCPA”).
We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise his or her rights below.
Subject to certain exceptions under applicable law, you may be entitled to the following rights:
• to access and request an exported or physical copy of the documents containing your Personal Information;
• to have the Personal Information we hold about you corrected or updated;
• to request deletion, in certain circumstances, of the Personal Information that we hold about you;
• to opt out of the sharing of your personal information for cross-context behavioral advertising or targeted advertising purposes;
• to opt out of the “sale” of your Personal Information (as the term is defined under applicable law);
• if you are a California resident, you have a right to know the categories and names/addresses of third parties that have received your Personal Information for their direct marketing purposes;
• if you are a Virginia, Colorado and Connecticut resident, you have the right to appeal our denial of any request you made under this Section, and if we deny your appeal, to lodge a complaint to the relevant Office of the Attorney General; and
• to not be discriminated for exercising any of your rights under this Section.
13. How to Contact Us
In order to obtain more information on the Policy or the use of your Personal Information, to exercise your rights or to file a complaint, please contact our Privacy Officer at the following coordinates:
9191542 Canada inc.
ATTN : Privacy Officer
6890 Saint Hubert, Montreal, Quebec, H2S2M6
14. Changes to this Policy
We may change this Policy from time to time to reflect changes to our privacy practices or for other operational, legal or regulatory reasons. Changes will be effective immediately upon notifying to you or posting on our Website. After these changes are notified or posted, as applicable, by submitting your Personal Information or by continuing to use our Website and services or purchase our products you agree to any such revised policy.