Les Produits de Marque Liberté inc. (“Liberté” or “us” or “we”) believes the right to privacy is one of paramount importance. This is why we have implemented this privacy policy, allowing the protection of your integrity and of your right to disclose or not your personal information.

This privacy policy discloses how Liberté collects, protects, uses and shares personal information gathered about you. Our privacy practices are consistent with:

  • Canada’s federal privacy legislation, the Personal Information Protection and Electronic Documents Act (hereinafter “PIPEDA”);

  • Quebec’s provincial privacy legislation the Act respecting the Protection of Personal Information in the Private Sector (hereinafter “PPIPS”);

Liberté may share informations, including Personal Information provided on a voluntary basis with its promotion and marketing agency and mass-mailing agency.

All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. Liberté values the privacy of its customers, employees, job applicants and other visitors to its website who may choose to provide Personal Information. We are well aware of the importance of appropriate protections and management of Personal Information you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used and with whom the information may be shared.

This Privacy Policy explains Liberté’s practices regarding the information collected online from users of the Liberté website located at www.liberte.ca (hereinafter the “Website”).

1. Liberté’s Commitment: Adhering to the ten Privacy Principles

1.1. In Canada, “Fair Information Practices” regarding your Personal Information are reflected in a series of 10 Privacy Principles developed by the Canadian Standards Association and incorporated into Canadian federal privacy legislation PIPEDA. Liberté adheres to the 10 Privacy Principles as follows:

Principle 1 – Accountability

Liberté is responsible for personal information under its control and have designated a Privacy Officer who is accountable for Liberté’s compliance with this Privacy Policy and the 10 Privacy Principles.

Principle 2 – Identifying the Purposes for collection of Personal Information

Liberté will identify the purpose for which personal information is collected at or before the time the information is collected. Some of the identified purposes for which Liberté collects, uses and discloses your personal information are described below in this Privacy Policy. If we intend to collect, use or disclose your personal information for additional purposes, we will seek your consent.

Principle 3 – Consent for Collection, Use, or Disclosure of Personal Information

Liberté will obtain your informed consent for the collection, use or disclosure of your personal information, except as permitted by law.

Principle 4 – Limiting Collection of Personal Information

Liberté will limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by Liberté. Liberté will collect your personal information by fair and lawful means, and not by misleading or deceiving you about the purpose for which information is being collected.

Principle 5 – Limiting Use, Disclosure and Retention of Personal Information

Liberté will not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. Liberté will retain your personal information only as long as necessary to fulfill the identified purposes.

Principle 6 – Accuracy of Personal Information

Liberté will attempt to make sure that your personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 – Security Safeguards

Liberté will protect your personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness Concerning Policies and Practices

Liberté will make readily available to you specific information about our policies and practices relating to the management of personal information.

Principle 9 – Individual Access to Personal Information

Upon written request, subject to certain exceptions, Liberté will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Challenging Compliance

You have the right to address a challenge concerning compliance with this Privacy Policy to Liberté’s Privacy Officer.

2. Consent

2.1. This Privacy Policy applies to all information gathered for and on behalf of Liberté, whether in writing, verbally or electronically, through any website operated by or on behalf of Liberté, including, but not limited to, www.liberte.ca. By using the Website, or participating in any program or service managed by Liberté, you consent to the data collection and use practices described in this Privacy Policy. If you have question about this Privacy Policy or the protection of your information, please refer to section 20 on how to contact our Privacy Officer.

2.2. BY SUBMITTING PERSONAL INFORMATION TO LIBERTÉ, AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE THAT LIBERTÉ MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW.

3. Consent to Share and Disclose Information

3.1. In addition to consenting to this Privacy Policy and the Terms and Conditions, including any relevant supplemental policies, you expressly consent to Liberté sharing the information that you have provided, as described herein. Liberté may share information with its promotion and marketing agency and mass-mailing agency.

4. Consent to Electronic Notice if there is a Security Breach

4.1. If Liberté is required to provide notice of unauthorized access of certain security systems, you agree that Liberté may do so when required or voluntarily by posting notice on the Website or sending notice to any email address has for you, in the good faith discretion of Liberté. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

5. Type of information we may collect

5.1. “Personal Information” is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

5.2. Personal Information shall include but is not limited to: name, home address, home postal code, home telephone number, mobile phone number, email address and employment related information such as may be found on resumes, applications, background verification information, or in employment references.

5.3. Non-personal Information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.

6. Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information

6.1 .Cookies - in addition to Personal Information, we use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.

6.2. Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.

6.3. Session cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security or to facilitate use of webmail. These session cookies expire after a browser session and would not be stored long term.

6.4. Persistent cookies – are stored on a users’ device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising

6.5. First and third party cookies – Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user - the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third party cookie.

6.6. For more information about cookies, including how to see what cookies have been set and how to manage, block and delete them, visit www.allaboutcookies.org. The website www.allaboutcookies.org gives you detailed step by step guidance on how to control and delete cookies depending on your browser type. You can adjust your browser settings to your preferred level of protection.

6.7.I nternet Protocol (IP) Address - an Internet Protocol (IP) Address is associated with your computer's connection to the internet. Liberté may use your IP address to help diagnose problems with Liberté’s server, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer's IP address also may be used to provide you with information based upon your navigation through the Website. Liberté does not link IP addresses to any Personal Information.

6.8. Aggregate Information – is used to measure the visitors’ interest in, and use of, various areas of the Website and the various programs that Liberté administers, Liberté will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, Liberté may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although Liberté may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

6.9. We also use the services of Google analytics to gather Aggregate Information on our website. To opt out of being tracked by Google Analytics across all websites visit: tools.google.com/dlpage/gaoptout.

7. Children and Data Collection

7.1. Children’s privacy is important to us. Therefore, we take additional measures to help children protect their privacy while online including not asking them to disclose more personally identifiable information than is necessary for them to participate in an activity and encouraging them to use non-personally identifiable screen names rather than their real names.

7.2. We will not knowingly allow anyone under 18 to provide us any personally identifying information. Children under 18 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately, please refer to section 20 on how to contact our Privacy Officer. We will use reasonable efforts to promptly delete the child's information from our servers.

7.3. Children can participate in many of our features without providing personally identifiable information. However, to enable their participation in certain of our interactive features, we may ask children to provide us with personally identifiable information. The types of information we may request include first name as well as the child’s and parent’s email addresses. We use a child’s email address to respond to a specific request to participate in an activity (e.g., participate in a contest or sweepstakes, respond to their question, enable them to subscribe to a newsletter). We use parents’ e-mail addresses to obtain their consent or notify them of their child's online activities and enable the parent to unsubscribe the child from a newsletter or other similar activity.

7.4. We do not share children's personally identifiable information with outside third parties not bound by this Privacy Policy. We may use agents or contractors to help us conduct a contest or sweepstakes, send prizes to winners, or provide customer service related to activities on the Website. In these cases, we require the agent or contractor to keep the information confidential and to use it only for the specific services they are performing.

7.5. At any time parents can refuse to permit us to collect further personal information from their child and can request that any personal information we have collected be deleted from our records.

7.6. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share their child’s personal information. Please note that, at all times, parents should update their personal information to provide us a current email address.

7.7. If you would like to review any personally identifiable information that we have collected online from your child, have this information deleted, and/or request that there be no further collection or use of your child's information, or if you have questions about these information practices, you may contact our Privacy Officer. Please refer to section 20 for information on how to reach our Privacy Officer.

8. Our Use of your Information

8.1. We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

8.2. Liberté may market to you directly by email, mail or by telephone for the purposes, among others, of offering you some of Liberté’s new or current product.

8.3. Liberté may use Personal Information which it is provided on a voluntary basis through a message or following a given participation to a survey, contest or promotion. Personal Information gathered for any of such purpose, will be namely used to communicate with you in the event you win. Contests and/or promotions offered by Liberté may be subject to additional specific regulations, which will be fully described in such conquest or promotion. You have no obligation to send us a message or participate in such survey, contest or promotion.

8.4. Liberté undertakes not to use any Personal Information it gathers in compliance with this policy or with any applicable legislation, to any other purposes unless we obtain your consent for that purpose or in certain exceptional circumstances, where Liberté believes in good faith that the law requires or allows it.

9. Collection and Use of Employee Personal Information

9.1. Liberté also collects Personal Information from its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to Liberté and its affiliates facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, and other employment related purposes.

9.2. It is the policy of Liberté to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:

9.2.1. To comply with municipal, regional, provincial or federal agency requests;

9.2.2. Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);

9.2.3. Third parties with which Liberté has contractual agreements to assist in administration of company sponsored benefits.

10. Verification of Employment

10.1. Prospective employers, government agencies, financial institutions, and residential property managers routinely contact Liberté requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department.

10.2. For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.

11. Collection and Use of Customer Information

11.1. Liberté will not collect Personal Information, unless you contact Liberté directly. In the future, it is possible that we may use this information to contact you regarding products or promotions, as well as other products and services, which may be of interest to you. If you do provide us with Personal Information we may use the information to contact you, via e-mail, regular mail, telephone or other means, to provide you with information that you requested about specific products or services, provide additional future information about products or services that may be of interest to you, and to learn about and develop products and services. If you do not want this information disclosed you may “opt out” of future contacts at any time by un-subscribing from our database or contacting the Privacy Officer, in writing, as described below in the section 20.

12. Mobile Information

12.1. This section applies to individuals who visit our Website through a mobile device such as cellphone or tablet computer :

12.2. Mobile Information We Collect

12.2.1 .Personally identifiable information (e.g. Name, email address) we collect consists only of what you share with us. For example, we may ask for this type of information so that we may contact you by phone or email at your request. You choose what, how, and when you want to share.

12.2.2. If you use any location-enabled products, you may be sending us location information. Liberté does not store or use this information other than to provide the service you requested. For example, a mobile product may use GPS data to find a nearby restaurant you requested. Location-enabled features are opt-in and you have control over your participation and can turn these services off at any time.

12.2.3. Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve our customers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to Liberté. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.

12.2.4. Use of 3rd party services such as social sharing sites (e.g., Facebook and Twitter) is governed by the privacy practices of those services. Liberté does not capture or store your login information or other personally identifiable information for these services, however session info or cookies may be stored.

12.3. How We Use Mobile Collected Information

12.3.1. We use the information to personalize your experience with the application and to improve your overall experience including the development of new products, services, and features. We also use the information to provide customer support, and when applicable, register and administer your account. Additionally, we may use the information you provide to contact you about updates to our service.

12.3.2. Information you provide may be used to fulfill the service(s) or carry out the transaction(s) you have requested or authorized.

12.4. Liberté does not share any collected Mobile Information with 3rd parties with the following exceptions:

12.4.1. Liberté may provide some personal data to third-party partners that are providing services essential to your mobile user experience.

12.4.2. All requests are sent through your mobile carrier's network and your carrier may have access to it. Consult your carrier's privacy policies for additional information.

13. Opt-Out of Email and Mobile Updates

13.1. You may have the opportunity to elect to receive email and mobile communications from Liberté. Liberté will only email you if you elect to receive emails from us. If you elect to receive emails, Liberté will send you occasional updates about new additions to the Website as well as special offers and promotions of which you can take advantage. If at any time you decide you would rather not receive these types of communications from Liberté, you can opt-out by clicking the unsubscribe link at the bottom of any Liberté email. You may opt-out by contacting the Privacy Officer, according to section 20 of the present Privacy Policy.

14. Sharing of Personal Information

14.1. Liberté does not sell Personal Information to third parties. We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, Liberté will not share Personal Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law.

14.2. We may share your Personal Information with agents, affiliates or service providers who act for or on behalf of Liberté in connection with the business of Liberté, or for further processing the data in accordance with the purpose(s) for which the data was originally collected, e.g., third party maintenance of secure listing databases or prize fulfillment in connection with a contest or sweepstakes. We require our agents, affiliates and service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on behalf of Liberté and not to use it for any purpose other than the purpose for which we retained them. We also require any third parties we retain to protect Personal Information disclosed by us in accordance with all applicable privacy requirements and the general privacy principles described in this Privacy Policy.

14.3. The Personal Information you provide Liberté is considered a company asset and may be disclosed and/or transferred to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of Liberté or of any of the business assets or shares of Liberté or a division thereof, in order for a customer to continue to receive the same products and services from the third party.

14.4. Although we make every effort to preserve user privacy, we reserve the right to disclose Personally Identifiable Information to a third party in certain limited circumstances, specifically: to comply with a law, regulation, search warrant, subpoena, judicial proceeding, a court order, or as otherwise may be required by law, to enforce our policies or contracts, to collect amounts owed to us, to protect users of our sites from fraudulent or abusive use, during emergencies when safety is at risk, as determined by Liberté, or otherwise where necessary for the establishment, exercise or defense of legal claims. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on the web site. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

15. Security

15.1. We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

15.2. We safeguard your Personal Information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.

16. Storage, Retention and Accuracy of Personal Information

16.1. Liberté takes all reasonable steps to insure that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

16.2. Liberté will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.

16.3. We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

16.4. Liberté may store your Personal Information in its databases located in the United States and/or other countries outside of Canada. Additionally, some of our service providers may reside in the United States or other countries outside of Canada and will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, the United States and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by Liberté.

17. Access, Control and Update Information About You

17.1. We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you should contact the Privacy Officer (see section 20) to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us also by contacting the Privacy Officer.

18. Links to Non- Liberté Web Sites and Third Parties

18.1. Please note that www.liberte.ca website may contain links to other websites for your convenience and information. Liberté does not control those sites or their privacy practices, which may differ from www.liberte.ca. Liberté’s privacy policy cannot and does not apply to external websites. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by the Liberté Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their personal data with Liberté; that sharing is governed by that third party’s privacy policy.

19. Social Media and Online Engagement

19.1. Liberté uses a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, the Liberté uses several third-party platforms including, but not limited to, Facebook and Twitter. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by Liberté. When interacting with the Liberté presence on those websites, you may reveal certain personal information to Liberté or to third parties. Except when used by Liberté’s employee’s for the purpose of responding to a specific message or request, Liberté will not use, share, or retain your personal information.

19.2. At this time, the Liberté has two Social Media Accounts, Facebook.com/LiberteCan, Twitter.com/LiberteCan.

19.3. Facebook: On the Facebook.com/LiberteCan Facebook page, the Liberté staff posts news and other items of interest to individuals. If you have a Facebook account or 'Like' Facebook.com/LiberteCan Facebook page, you can post comments or click on the 'like' option for individual entries. If you comment or click on the 'like' button, personally identifying information will be visible to the Liberté staff and other Facebook site visitors. The amount of visible personal information will depend on your own Facebook privacy settings. You can completely avoid displaying any personally identifiable information by not creating an account, not posting comments and not clicking on the 'like' options in Facebook. The Liberté staff does not collect, use or disclose any information about visitors who comment or 'like' the Liberté Facebook site. Facebook collects and reports on non-personally identifiable information about activities on Facebook pages. This information is password protected and only available to the Liberté employees, members of the Liberté Communications and Web Teams, and other designated staff who require this information to perform their duties. The Facebook privacy policy is available at: http://www.facebook.com/about/privacy/.

19.4. Twitter: Liberté uses Twitter to send short messages (up to 140 characters) or 'Tweets' to share information about Liberté with visitors and respond to comments and inquiries sent via Twitter to Liberté. While visitors may read the Liberté Twitter feeds without subscribing to them, visitors who want to subscribe to (or follow) the Liberté Twitter feeds must create a Twitter account at www.twitter.com. To create an account, you must provide some personal information, such as name, user name, password and email address. Visitors have the option to provide additional personal information including a short biography, location or a picture. Most information you provide for a Twitter account is available to the public, but you can modify how much of your information is visible by changing your privacy settings at the Twitter.com Web site. The Liberté staff members monitor the number of subscribers and respond to comments and queries via Twitter, but the staff never takes possession of the personal information belonging to Twitter followers. Liberté does not collect, maintain, disclose or share any information about people who follow Liberté on Twitter. The Twitter privacy policy is available at: http://twitter.com/privacy.

20. Our Privacy Officer

20.1. You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer shall contact the appropriate employee to fulfill your request.

20.2. Should you have any questions or complaints, do not hesitate to contact the Privacy Officer. The Privacy Officer may be reached:

 

  • By phone at

      (888) 340-9306

 

  • By mail at

  • Les Produits Liberté inc.
               a/s Responsable de la vie privée
               5000 J.A. Bombardier
               St-Hubert, QC
               J3Z 1H1

  • By facsimile at:

      (450) 926-8522

  • By email at:

      privacyofficer@liberte.ca

21. Changes to our Privacy Policy

21.1. This Privacy Policy is effective as of February 1st, 2013. Liberté may update this Privacy Policy occasionally. When Liberté posts changes to this Privacy Policy, we will also revise the "Last Updated" date above on Liberté’s Privacy Policy. Liberté encourages you to review this Privacy Policy periodically to be informed of how Liberté is protecting your information and to be aware of any changes to the Privacy Policy. Your continued use of the site after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. This Privacy Policy is incorporated into any Terms and Conditions governing the various websites and any programs or services operated or managed on or behalf of Liberté. Any changes to this Privacy Policy are effective immediately after being posted by Liberté.

22. Terms and Conditions of Website Use

The Terms and Conditions governing your use of this Website located at: http://www.liberte.ca/en/terms-of-use/index.sn contains important provisions disclaiming and excluding the liability of Liberté regarding your use of our Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding your use of this Website. Each of these provisions applies to any disputes that may arise in relation to this privacy policy and the collection, use and disclosure of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy.