Policy effective as of September 21, 2023.

Protecting our clients’ personal information is a priority for Arenco Inc. (“Arenco”). You are invited to review this policy, where you will find answers to your questions, including the types of information we collect, why we request personal information, how we use such information, and the security measures in place to protect it.

Your consent is essential for collecting, using and disclosing your personal information. Providing us with your personal information is entirely your choice. However, please be aware that if you refuse to supply certain essential information or withdraw your consent to its use, we may be unable to assist you fully and may not be able to deliver all or part of our services.

Collecting information

Arenco does not collect your personal information unless you provide it voluntarily and for investigative purposes. By providing personal information, you consent to the manner in which Arenco collects, uses, discloses and manages that information as described in this policy. The term “personal information” means any information that can identify you, directly or indirectly.

We may, for example, need to collect your personal information when you make an online purchase, communicate with us by phone, by email or otherwise, or participate in a survey, contest or promotion.

The information essential to establishing your file with us may include, among other things, the following: basic information (name, residential address and length of residence at that address, telephone number where we can reach you, email address, date of birth, social insurance number and driver’s license); financial and credit information (your employment status, whether you own or rent property, your banking details for withdrawals and your credit history); and any other relevant information we need to provide you with the best possible service for your situation. We may contact your references, your current and former employers, and your landlord to verify the accuracy of your personal information. If we are unable to reach you using your personal information, we will contact these references. Should we need your personal information for any purpose other than those set out in this privacy policy, you will be notified and given the opportunity to consent before any action is taken.

Use of information

We collect the information noted above to properly complete your file, determine your eligibility, process and manage your account, and provide you with the best possible service. To address your request, the information will be used to analyse your application and, if applicable, for debt recovery. Your personal information will not be used or disclosed for any purposes other than those for which it was collected and in accordance with this policy, unless you consent or unless required or permitted by law.

Personal information identified as most sensitive will be restricted to ensure that only staff members who absolutely need it can access it. For more information on data limitation, please contact us using the details provided in the “How to Contact Us” section.

Disclosure of personal information

Subject to the following, Arenco undertakes not to disclose, sell or otherwise transfer your personal information to third parties, nor exchange it with third parties, without first obtaining your consent. We may share personal information with certain third parties, including the following:

– third-party service providers and/or partners who supply us with website services, application development, hosting, maintenance and other services. These third parties may access or process personal information as part of the services they provide to us. We limit the information we share with these service providers to what is reasonably necessary for them to perform their duties;

– government authorities and law enforcement agencies when required by applicable law.

– the purchaser, successor or assignee in the context of any merger, acquisition, debt financing, sale of assets or similar transaction, as well as in the event of insolvency, bankruptcy or receivership involving the transfer of personal information as a business asset to one or more third parties;

We will use personal information solely to achieve the primary and legitimate purposes for which it was collected, or for purposes compatible with that primary purpose.

Use of the website

On Arenco’s website, we do not collect any identifying information about you unless you choose to provide it voluntarily. You are free to browse our site anonymously at any time without disclosing any personal or financial details. We manage our servers and maintain a robust firewall infrastructure to ensure your browsing remains secure. We continuously review our practices and policies, audit our data network, test our site’s security measures, and apply every update to guarantee that the confidentiality of your information is never compromised.

When you access our website or any internet link sent by Arenco, your computer and the portal server automatically exchange information. This automatic communication is necessary for the server to deliver a file compatible with your computing equipment. The exchanged information includes, in particular, the following:

• the domain name of your Internet service provider;
• your IP address (e.g., 123.45.67.255), the unique number assigned to your computer when it is connected to the Internet;
• the type of browser (e.g., Firefox, Explorer) and operating system (e.g., Windows, Mac OS) you are using;
• the pages you visit;
• the date and time you access those pages;
• any information and data you have agreed to share.

To continuously improve your experience on our website and better understand your preferences, Arenco may use cookies, web beacons, spy pixels, tools such as Facebook pixels, Google Analytics, and other similar technologies. This enables us, among other things, to evaluate and enhance your site experience, personalize your online interactions, understand your preferences, and deliver tailored content. Additionally, some cookies may be required for our website to function correctly. By accessing our site with cookies enabled in your browser, you consent to our use of those cookies. You can modify your browser settings to delete or block cookies or install a plug-in to manage them. Please note that if you choose to limit cookies, Arenco’s website or certain features may not work properly.

Changes to our policy

This policy is subject to change to reflect evolving rules on the protection of personal information and privacy. Any new version will take effect automatically upon publication by Arenco. We therefore encourage you to review Arenco’s website regularly for any updates. The date of the most recent amendment is displayed at the bottom of the page for your convenience.

How to reach us

You may direct your questions, concerns, complaints and requests regarding this policy to us in writing or by telephone using the contact information below, and our Privacy Officer and their team will be pleased to assist you. If you wish to exercise your rights of access or correction of your personal information, you may contact us using the details below. Arenco undertakes to respond to you within 30 days of receiving your request.

Privacy Officer

Michel Aubin
5445 Cousineau Street,
Saint-Hubert, Quebec
Phone: (450) 676-6820
Email: [email protected]

How long do we retain personal information?

We will destroy physical personal information and anonymize digital personal information to comply with our legal and regulatory obligations. For details on retention periods, please contact us using the information provided in the “Contact Us” section.

Where do we store personal information and international transfers?

All personal information obtained by Arenco is stored in North America, both as a secure physical copy and as a digital copy maintained on an external server.

How do we protect personal information?

We adhere to industry-accepted standards to protect the information you submit, both during transmission and once received. We maintain appropriate physical, technical and administrative safeguards to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, misuse or any other form of illegal processing. We have implemented measures to ensure that only personnel subject to a duty of confidentiality who need to know your personal information in order to perform their duties have access to it.

However, no method of transmission over the Internet or electronic or physical storage is completely secure. Therefore, we cannot guarantee the security of the information you transmit or provide to us, and you do so at your own risk. We also cannot guarantee that such information will not be accessed, obtained, disclosed, altered or destroyed as a result of a breach of our physical, technical or administrative safeguards. If you have reason to believe that personal information has been compromised, please contact us using the details provided in the “Contact Us” section.

What information do we retain following the destruction of personal information?

Personal information is retained only for as long as necessary for the purposes set out in this Policy and to ensure compliance with our legal and regulatory obligations.

Furthermore, as noted in the previous section, your personal information may be stored in Canada or abroad. Rest assured, we implement the necessary security measures and pertinent contractual agreements to protect your personal information.

If you would like to learn more about how long your personal information is retained, we invite you to contact our…

Privacy Officer

Michel Aubin
5445 Cousineau Street,
Saint-Hubert, Quebec
Phone: (450) 676-6820
Email: [email protected]

What rights does an individual have regarding their personal information?

Under certain circumstances and in accordance with applicable data protection laws, an individual has the following rights:

• Access: the right to request whether we are processing personal information and, if so, to obtain access to that personal information. Subject to applicable law and, where required, payment of a fee, an individual may receive a copy of the personal information we hold about them and certain other related information;
• Accuracy: we are required to take reasonable steps to ensure that the personal information in our possession is accurate, complete, not misleading and up-to-date;
• Rectification : the right to request the correction of any personal information we hold that is incomplete or inaccurate.
• Deletion: the right to request that we erase, destroy or remove personal information in certain circumstances. The requester must demonstrate that the disclosure of the information is unlawful or causes harm;
• Right to be Forgotten : the right to prevent the dissemination of personal information or to request its de-indexing. Exceptions may apply, for example when the information is required to comply with the law, honour a contractual obligation between the parties, or for the purposes of claims.
• Restriction : the right to request that we suspend the processing of certain personal information, in order to verify its accuracy or the lawfulness of its processing;
• Portability : the right to receive the personal information we have collected in a structured, commonly used and machine-readable format, and to request that it be transferred directly to any person or organization authorized by law to collect such information. An exemption applies where providing the information in this format would present serious practical difficulties for us.
• Transfer: the right to request the transfer of certain personal information to another party;
• Objection: the right to object to the processing of personal information based on a legitimate interest (ours or that of a third party) or for certain direct marketing purposes. However, we may still be entitled to continue processing the information.
• Automated Decision-Making: the right to challenge any automated decision that has a significant legal or similar effect, and the right to request that it be reconsidered;
• Consent: where we have obtained your consent to the processing of personal information, the right to withdraw that consent in circumstances provided by law.
• Processing: the right to request information about how their data is processed, including which personal information has been collected from them and how we handle it.

Finally, it is also possible to file a complaint with a data protection supervisory authority, in particular in the country, province or state where you normally reside, where we are located, or where an alleged violation of data protection laws has occurred.