MOM cares about your privacy
1. Context
MOM Entretien de Bureau Montréal Inc (hereinafter “MOM”) is a federally incorporated company that processes personal information in the course of its activities.
The purpose of this policy is to ensure the protection of personal information and to govern the manner in which MOM collects, uses, communicates, retains and destroys or otherwise manages personal information. In addition, it is intended to inform all interested parties of the manner in which MOM handles their personal information. It also covers the processing of personal information collected by MOM through technological means.
2. Application and definitions
This policy applies to MOM, including its officers, employees and consultants. It also applies to the MOM website, as well as to all websites controlled and maintained by MOM.
It applies to all types of personal information managed by MOM, whether it be information about its customers, potential or actual, its consultants, its employees, or any other person (such as visitors to its websites or otherwise).
For the purposes of this policy, personal information is information about an individual that directly or indirectly identifies that individual. For example, it could be a person’s name, address, e-mail address, telephone number, language, etc.
Generally speaking, a person’s professional or business contact information, such as name, title, business address, business e-mail address or business telephone number, does not constitute personal information.
3. Collection, use and communication
In the course of its business, MOM may collect different types of information for different purposes. The types of information that MOM may collect, its use (or purpose) and the means by which the information is collected are set out in Appendix A of this Policy.
MOM will also inform individuals, at the time of collection of personal information, of any other information collected, the purposes for which it is being collected and the means of collection, in addition to other information required by law.
MOM applies the following general principles to the collection, use and disclosure of personal information:
Consent:
- Generally, MOM collects personal information directly from the individual and with his or her consent, unless an exception is provided by law. Consent may be obtained implicitly in certain situations, for example, when the individual decides to provide his or her personal information after being informed by this policy about the use and disclosure for the purposes indicated herein (see Appendix A for more details). Thus, this policy and the information it contains will be available to the person concerned at the time personal information is collected.
Collection:
- In all cases, MOM will only collect personal information if it has a valid reason to do so. In addition, the collection of personal information will be limited to that which is necessary to fulfill the purpose for which it is collected.
MOM may collect personal information, indirectly, through such means as:
- Calendly or an equivalent service. Calendly has its own terms and conditions and privacy policy, which can be consulted for further information.
- Meta instant form. Meta has its own terms and conditions and privacy policy, which can be consulted for more information.
- ActiveCampaign web form. ActiveCampaign has its own terms and conditions and its own privacy and data protection policy, which can be consulted for further information (https://www.activecampaign.com/legal/privacy-policy)
This collection through third parties may be necessary to use certain services or programs, or to otherwise do business with MOM. When required, MOM will obtain consent at the appropriate time.
Storage and use:
- MOM ensures that the information it holds is up to date and accurate at the time it is used to make a decision about the person concerned.
MOM may use an individual’s personal information only for the purposes identified herein or for any other purposes identified at the time of collection. As soon as MOM wants to use this information for another reason or another purpose, a new consent will have to be obtained from the person concerned, which will have to be obtained expressly if it is sensitive personal information. However, in certain cases provided for by law, MOM may use information for secondary purposes without the consent of the individual, for example:
- when such use is clearly for the benefit of that person;
- when necessary to prevent or detect fraud;
- when necessary to evaluate or improve protection and security measures.
- Limited access. MOM implements measures to limit access to personal information only to those employees and individuals within its organization for whom the information is necessary in the performance of their duties. MOM will seek the consent of the individual before granting access to any other person.
Communication:
- Generally, and unless an exception is indicated in this Policy or otherwise provided by law, MOM will obtain the consent of the individual concerned before disclosing his or her personal information to a third party. In addition, where consent is required and where sensitive personal information is involved, MOM will obtain the individual’s express consent prior to disclosing the information.
- However, disclosure of personal information to third parties is sometimes necessary. Thus, personal information may be disclosed to third parties without the consent of the person concerned in certain cases, including, but not limited to, the following:
- MOM may disclose personal information, without the consent of the individual concerned, to a public body (such as the government) which, through one of its representatives, collects it in the exercise of its powers or the implementation of a program under its management.
- Personal information may be transmitted to its service providers to whom it is necessary to communicate the information (for example, MOM’s franchisees or subcontractors), without the individual’s consent.
- If it is necessary for the purposes of concluding a commercial transaction, MOM may also communicate personal information, without the consent of the person concerned, to the other party to the transaction and subject to the conditions stipulated by law.
- Disclosure outside Quebec: it is possible that personal information held by MOM may be disclosed outside Quebec, for example, when MOM uses cloud service providers whose server(s) are located outside Quebec or when MOM deals with franchisees or subcontractors located outside the province.
Further information on the technologies used:
- Use of cookies
Cookies are data files sent to a website visitor’s computer by their web browser when they visit a website and can serve several purposes.
Websites controlled by MOM use cookies in particular:
- To memorize visitors’ settings and preferences, for example for language selection and to enable tracking of the current session.
- For statistical purposes, to track visitor behavior and content, and to help improve the website.
The websites controlled by MOM use the following types of cookies:
- Session cookies: these are temporary cookies that are stored only for the duration of your visit to the website.
- Persistent cookies: these are kept on the computer until they expire, and are retrieved the next time the site is visited.
Some cookies may be disabled by default and visitors may choose whether or not to enable these functions when visiting MOM websites.
It is also possible to activate and deactivate the use of cookies by changing the preferences in the browser settings.
- Use of Google Analytics
The MOM website uses Google Analytics in order to allow its continuous improvement. In particular, Google Analytics makes it possible to analyze how a visitor interacts with the MOM website. Google Analytics uses cookies to generate statistical reports on the behavior of visitors to this website and the content viewed.
Information from Google Analytics will never be shared by MOM with third parties. By default, we do not collect personal data from Google Analytics. Visitors must give their consent for us to collect this type of information.
- Other technological resources used
MOM also collects personal information through technological means such as web forms integrated into a website controlled by MOM (for example, its contact form and newsletter sign-up form), surveys accessible online on its platforms and applications, as well as other platforms or forms tools (for example, Microsoft Forms).
4. Retention and Destruction of Personal Information
Unless a minimum retention period is required by applicable law or regulation, MOM will retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected.
Personal information used by MOM to make a decision about an individual must be retained for a period of at least one year following the decision in question or even seven years after the end of the fiscal year in which the decision was made if it has tax implications, for example, the circumstances of a termination of employment.
At the end of the retention period or when the personal information is no longer required, MOM will ensure:
- destroy them; or
- anonymize them (i.e., they no longer irreversibly identify the individual and it is no longer possible to establish a link between the individual and the personal information) and use them for serious and legitimate purposes.
The destruction of information by MOM shall be done in a secure manner to ensure the protection of such information.
This section may be supplemented by any policies or procedures adopted by MOM regarding the retention and destruction of personal information, as applicable. Please contact MOM’s Privacy Officer (identified in this policy) for further information.
5. MOM's responsibilities
In general, MOM is responsible for the protection of the personal information it holds.
The person responsible for the protection of personal information is the President of MOM. The Privacy Officer is generally responsible for ensuring compliance with applicable privacy legislation. The Privacy Officer must approve the policies and practices governing the governance of personal information. More specifically, this person is responsible for implementing this policy and ensuring that it is known, understood and applied. In the event of the absence or inability to act of the Privacy Officer, MOM’s Director of Operations will assume the duties of the Privacy Officer.
MOM employees who have access to personal information or are otherwise involved in the management of such information must ensure its protection and comply with this policy.
6. Data security
MOM is committed to implementing reasonable security measures to ensure the protection of personal information under its control. The security measures in place correspond, among other things, to the purpose, quantity, distribution, medium and sensitivity of the information. This means that information that may be considered sensitive (see definition in section 2) will require more stringent security measures and greater protection. In particular, and in line with what was mentioned above concerning limited access to personal information, MOM must put in place the necessary measures to impose constraints on the rights of use of its information systems so that only employees who need to have access to them are authorized to do so.
7. Rights of access, rectification and withdrawal of consent
To exercise his or her right of access, rectification or withdrawal of consent, the person concerned must submit a written request to this effect to MOM’s Privacy Officer, at the e-mail address indicated in the following section.
Subject to certain legal restrictions, individuals may request access to and correction of their personal information held by MOM if it is inaccurate, incomplete or equivocal. They may also request that MOM cease disseminating their personal information.
MOM’s Privacy Officer must respond in writing to such requests within 30 days of receipt. Reasons must be given for any refusal, together with the legal provision justifying the refusal. In such cases, the response must indicate the remedies available under the law and the time limit for exercising them. The person in charge must help the applicant understand the refusal if necessary.
Subject to applicable legal and contractual restrictions, individuals may withdraw their consent to the disclosure or use of the information collected.
They may also ask MOM what personal information has been collected from them, which categories of MOM personnel have access to it, and how long it will be kept.
8. Complaints handling process
Reception
Any individual who wishes to make a complaint concerning the application of this policy or, more generally, concerning the protection of his or her personal information by MOM, must do so in writing to MOM’s Privacy Officer at the e-mail address indicated in the following section.
The individual will be asked to provide his or her name, contact information, including a telephone number, as well as the subject of the complaint and the reasons for the complaint, in sufficient detail to allow MOM to evaluate the complaint. If the complaint is not specific enough, the Privacy Officer may request any additional information he or she deems necessary to assess the complaint.
Treatment
MOM undertakes to treat all complaints received confidentially.
Within 30 days of receipt of the complaint, or of receipt of any additional information deemed necessary and required by MOM’s Privacy Officer to process the complaint, the Privacy Officer shall evaluate the complaint and provide a written response, including reasons, to the complainant by e-mail. The purpose of this assessment will be to determine whether MOM’s handling of personal information complies with this Policy, any other policies and practices in place within the organization, and applicable legislation or regulations.
In the event that the complaint cannot be processed within this timeframe, the complainant shall be informed of the reasons for the extension, the status of the complaint and the reasonable time required to provide a final response.
MOM shall keep a separate file for each complaint received. Each file contains the complaint, the analysis and documentation supporting its assessment, as well as the response sent to the person who lodged the complaint.
It is also possible to file a complaint with the Commission d’accès à l’information du Québec (gouv.qc.ca) or any other privacy oversight body responsible for the application of the law concerned by the subject of the complaint.
However, MOM invites all interested parties to contact MOM’s Privacy Officer first, and to wait until MOM has completed its processing.
9. Approval
This policy is approved by MOM’s Privacy Officer, whose business contact information is as follows:
Privacy Officer:
Laurent Saumon
5723 rue Ferrier – Mont-Royal, Québec, H4P 1N3
For any request, question or comment regarding this policy, please contact the person in charge by email.
10. Publication and modifications
This policy is published on the MOM website, to which this policy applies, with respect to the personal information collected there. This policy is also disseminated by any means likely to reach the persons concerned.
MOM shall do the same for all modifications to this policy, which shall also be the subject of a notice on its website informing the persons concerned.
*Notes: please note that the use of the masculine gender is intended to simplify and facilitate the reading of this policy.
Table of versions and changes:
| Version | Effective on | Changes since the last version |
| 1.0 | October, 10 2023 | Initial version |
Appendix A
The following is a non-exhaustive list of the types of information MOM may collect, its use or purpose, and the means by which the information is collected. This includes, but is not limited to, the following.
Please note that most of the personal information managed by MOM is the personal information of residential customers, employees, job applicants and consultants. For the other categories of individuals listed in the table below, the information provided is, in the majority of cases, of a professional or business nature (see section 2 on business contact information). Please note that in most cases, MOM also collects the individual’s professional title/function, organization name and/or address, as well as e-mail address and business telephone number (see section 2 on business contact information).
| Relationship with MOM, services, program, etc. | Type of personal information collected | Purpose of collection and use | How we collect information |
| Customers | Name Phone number Source of web contact (e.g. Google Ads, Meta, etc.) Banking information (when required) Customer type (residential or commercial) Language Postal code Type of service required Free field in the quote request form for the customer to specify his needs | Establish and manage customer relations (and obtain a means of communication) Provide a service (e.g. window cleaning service) Respond to inquiries about our cleaning services or other requests for information Know the preferred language of communication Ensure payment of fees related to our services Subscribe to MOM newsletter Conduct satisfaction surveys Inspect the quality of service provided by our subcontractors or franchisees | By means of social media forms such as Meta’s, web forms integrated into a website controlled by MOM, questionnaires accessible online on its platforms and applications, as well as other technological platforms or form tools. By e-mail (directly or via a document or other form attachment) Through third parties |
| Job applicants and employees | Name Phone number Banking information Social Insurance Number (SIN) Date of birth Address RESUME Background check Results of pre-employment tests | Managing communications with the candidate or employee | By e-mail (directly or via attachment: Word, PDF, etc.) By telephone By connection to a website (tests for example) |
| Consultants | Name Phone number Banking information Address | Management of communications with the consultant Invoicing and payment of invoices | By e-mail (directly or via an attachment: Word, PDF, etc.) |