BBA is committed to respecting the privacy of individuals with whom we interact and to protecting their information. It is important to us to be transparent and to inform you of the types of Personal Information we collect, the manner in which we use this information, the people with whom we share it, as well as the purposes and reasons for why we collect, use and communicate it.

1. Scope and application

This Privacy Policy (“Policy”) applies whenever you interact with us, including when you contact us for a proposal, when you visit our website at www.bba.ca or when you apply for a job at BBA. This policy does not apply to the collection, use and sharing by BBA of Personal Information about its employees.

2. What is Personal Information?

In this policy, the term Personal Information refers to all information about an individual that allows them to be identified alone or in combination with other information, for example, their name, contact information, birth date, credit card number, etc. Personal Information can also refer to more technical information, such as an IP address, web browser settings and a device’s unique ID, but only when this information identifies you as an individual. Information that is rendered anonymous and cannot be associated with an individual is not considered Personal Information.

3. What categories of Personal Information do we collect and how do we collect it?

BBA only collects Personal Information that is strictly necessary to provide you with our services, to respond to any of your other requests and for other purposes laid out in the section "How do we use your Personal Information?" Some of the main categories of Personal Information we collect are:

• Your name and your contact information, which can include your email address, your residential address and your phone number. We may collect this information in various situations, for example if you contact us for a proposal, apply for a job at BBA or interact in any way with us as part of your role and duties as a client representative. We generally collect this information directly from you, but in certain cases, we may receive it from third parties.
• Information about employment, such as your work experience and education. We collect this information if you apply for a job at BBA, including by means of recruitment platforms. We will collect Personal Information contained in your application, or generated in connection with your request, to evaluate your application and determine whether we will consider you for a job posting. We may also collect Personal Information from third parties as part of a pre-employment background or reference check.
• Information about online activity, including IP addresses, sections of our website that were visited or language preferences. We generally collect this information when you visit our website using cookies or similar technology such as those described in the "Cookies and similar technology" section. We treat this information as Personal Information when it can be used to identify you.

4. How do we use your Personal Information?

We may use your Personal Information for the purposes indicated in this section. We may also use your Personal Information for other purposes, in which case, we will ask for your prior consent.

• Ensuring the delivery of our services. For example, we may use Personal Information to prepare a proposal requested by your organization.
• Managing our business operations. For example, we may use your Personal Information to improve our business strategies or detect fraud or other illegal activities.
• Communicating with you. For example, we may communicate with you to respond to a question about our services.
• Handling job applications. If you apply for a job at BBA, we use your Personal Information to process and assess your application.
• Analyzing client data. We analyze the behaviour of visitors to our website to improve the client experience. This information is not provided to us in a format that identifies you personally and is collected using settings on visitors’ devices or browsers.
• To fulfill other purposes permitted or required by law. For example, we may use the information we collect to protect the security of this information and our website or to comply with a legal requirement, if necessary.

5. When do we share your Personal Information with other organizations?

We may share your Personal Information with the following categories of people or with others when permitted or required by law. We may also share your Personal Information with other third parties, in which case, we will ask for your prior consent.

• Our employees, when access to the information is necessary to carry out their duties.
• Our service providers, when it is required to carry out a mandate or contract that has been entrusted to them. We hire service providers to plan our business operations, for credit enquiries, criminal background checks for job applications and to host data. We make sure to obtain a written agreement from our service providers that they will not use your Personal Information for anything other than fulfilling their mandate and that they will take reasonable security measures to protect your Personal Information.
• Other people, when the law requires or authorizes the disclosure of Personal Information.

6. What are your choices regarding privacy?

When you provide us with Personal Information, we assume that you consent to it being collected, used and shared for the purposes indicated at the moment it was collected, including those described in this Policy. In some circumstances, we may ask for your consent after collecting your Personal Information, particularly if BBA wants to use it or disclose it for purposes that were not determined beforehand.

You may withdraw your consent at any time, except under limited circumstances, such as when certain legal or regulatory requirements apply or due to your contractual obligations with us. If you withdraw your consent, BBA may no longer be able to provide you with certain services. In this case, you will be advised how withdrawing your consent may affect you. To withdraw your consent, please contact our Privacy Officer using the contact details indicated in the "Contact us" section herein.

7. How do we protect your Personal Information?

We take appropriate measures and controls to protect your Personal Information. These measures include restricting physical access to our offices and records, restricting access to your Personal Information to only employees or personnel who need it to carry out their duties, restricting unauthorized access, disclosure, use and mishandling of your Personal Information in our custody and control, storing archived documents with trusted third parties off site and in secure premises, and using a firewall, passwords and file encryption for all online activities.

Our goal is to prevent all unauthorized access, loss, misuse, distribution or modification of the Personal Information in our possession.

8. How long do we store your Personal Information?

We store your Personal Information only for as long as is reasonably necessary to fulfill the purposes for which it was collected or as permitted or required by law.

9. Where is your Personal Information stored?

We strive to ensure that your Personal Information is stored in Québec or, when that is not possible, in Canada. However, it is possible that information stored on one of our service providers’ servers may be located outside of Canada (such as in Europe or the United States) and may be subject to the laws of those countries, including any law permitting governmental authorities to access it. Subject to these foreign laws, we will use, to the best of our ability, contractual measures to ensure the protections in place for your Personal Information are at least equivalent to those employed in Québec.

10. Cookies and similar technologies

We use cookies to collect certain technical information when you visit our website. This information does not directly identify you and is used to improve the content of our website and to facilitate access to it. This information may be stored on the servers of service providers located outside of Canada and may therefore be subject to the laws of other countries, including any law allowing government authorities to access it. We use Google Analytics, which allows us to see information about a user’s activity, including pages they have consulted, the source and the time they spent on our website. This information is depersonalized and shown in the form of figures, which means that it cannot be used to identify the user. You can deactivate the use of Google Analytics by visiting the Google Analytics deactivation page.

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11. Access, correction and other requests related to Personal Information

For any request about your Personal Information, please write to us using the relevant contact details indicated in the "Contact us" section below.

12. Changes to this Policy

We may modify this Privacy Policy periodically. The modifications we make will take effect when we publish an amended version of this policy on our website. If we make important changes to this Policy, we will publish a notice on our website or inform you using a more formal method, if required by law. The reference to the “Effective date” at the beginning of this Policy indicates the date at which it was last updated.

13. Contact us

If you have any questions or complaints concerning the way we handle your Personal Information, please email BBA’s Privacy Officer at legal@bba.ca.