Privacy Policy

Last updated: 2023-11-28

Governance Policy on the Protection of Personal Information

SNACS Entrepreneurs (hereinafter “SNACS“) is committed to collecting, using, disclosing, retaining and destroying your Personal Information, regardless of the format in which it is held or accessed, in accordance with this policy (the “Policy”).

This Policy also discloses the roles and responsibilities of the SNACS’ staff from the collection to the destruction of your Personal Information.

If you have any questions about your Personal Information and have read the Policy and still have questions, you may contact our Privacy Officer, Nectaria Skokos, at the following email address:

SNACS may, at its discretion, change the Policy from time to time. If there is a change to the Policy, you will be notified, as appropriate. Once notified, your continued use of the services provided by SNACS, after the amended Policy becomes effective, will represent your consent to the Policy as amended.

  1. Definitions
    The attributed meanings of words and expressions found within this policy have been listed below:
    1. Governmental Authority(ies)” means the following: a) any multinational, federal, provincial, state, regional, municipal or local government, department, court, tribunal, arbitral body, commission, agency, board or office; b) any subdivision, agent, commission or authority of any of the foregoing; c) any quasi- governmental or private body exercising a power of regulation, administration, expropriation or any taxing authority under the direction of or on behalf of any of the foregoing, including any private body mandated to render public services; and, d) any judicial or quasi-judicial body, court or tribunal;
    2. “Act” means the Act respecting the protection of personal information in the private sector, chapter P-39.1, and any subsequent amendments or modifications thereto;
    3. “Personal Information” means any information relating to a natural person which enables that person to be identified, directly or indirectly;
    4. “Privacy Officer” means the Privacy Officer appointed by SNACS to ensure compliance with and implementation of the Act, who as of the date hereof is Ms. Nectaria Skokos, who can be reached by email at
  1. Consent
    By submitting your Personal Information to SNACS, you consent to the collection, use, disclosure, and retention of your Personal Information by SNACS in accordance with this Policy.
  1. Purposes for which personal information is collected.
    SNACS collects your Personal Information for the following purposes:
    1. Respond to your requests or questions;
    2. To improve the Website and its services. SNACS may combine information obtained from you with information it receives about you from third parties;
    3. To send you, according to the choice you have made, information about our various activities and our annual fundraising campaign;
    4. To prevent and detect fraud or to evaluate and improve protection and security measures;
    5. Contact you about this Policy;
    6. Manage the administration of volunteers and communicate with them in preparation for various community activities;
    7. Send you transactional communications, such as a receipt for a charitable donation; 
    8. Carry out publicity to promote the activities and interests of SNACS;
    9. To facilitate your participation in SNACS’ activities.

SNACS uses your Personal Information solely for the purposes set out in this Policy and undertakes to obtain your consent for any other use that is not provided for herein, except in the case of exceptions provided for in the Act.

  1. Means of collecting your personal information
    SNACS collects your Personal Information when you:
    1. Register to attend one of our events and/or activities;
    2. Click on an advertisement that SNACS has placed on a third-party website (e.g. Google, Facebook, etc.);
    3. Complete a survey, enter a contest or any other promotion;
    4. Fill in a paper or online form (e.g. Microsoft Form, Zoom);
    5. Contact us by email, telephone or any other means of communication; and
    6. You send us your Personal Information by email.
  1. Right of access and rectification provided by law
    At your request, SNACS will confirm the existence of your Personal Information, provide you with access to it and allow you to obtain a copy of it in a structured and commonly used technological format.

You have the right to demand that Personal Information that is inaccurate, incomplete or ambiguous be rectified, or that Personal Information be deleted if its collection, communication or retention is not authorized by law.

You have the right to require SNACS to cease disseminating your Personal Information where such dissemination is contrary to law, a court order or where the following conditions are met: (i) serious harm is caused to your reputation or privacy, (ii) such harm clearly outweighs the public interest in knowing the information or any individual’s interest in free expression, and (iii) the requested cessation of dissemination does not exceed what is necessary to prevent further harm.

In all cases, your request for access or rectification must be made in writing, providing proof of your identity as the person that the Personal Information pertains to. The Privacy Officer at SNACS undertakes to respond to your written request within 30 days of receipt of your request.

Access to your Personal Information is free of charge, except where reasonable charges may be applied for the transcription, reproduction, or transmission thereof.

In the event of a refusal to grant your request, the Privacy Officer undertakes to provide the reasons for the decision and to inform you of the provisions of the Act on which the refusal is based; the recourse available to you; and, the time limit within which they may be exercised. The Privacy Officer undertakes to provide you with the necessary assistance to help you understand the refusal.

The Privacy Officer undertakes to issue, free of charge, a copy of your Personal Information that has either been modified, or added, or depending on the request, an attestation of the deletion of your Personal Information. The Privacy Officer also undertakes to notify, without delay, any person who has received the information in the six months preceding the request from the person concerned and, where applicable, the person from whom the information was received.

The Privacy Officer undertakes to keep the Personal Information, that is the subject of your request, for access or rectification for the time required to enable you to exhaust your recourse under the Act.

  1. Right to withdraw your consent
    You have the right, at any time, to withdraw your consent to the disclosure or use of your Personal Information by SNACS. To do so, please contact the Privacy Officer using the contact information provided in this Policy.

However, where applicable, withdrawal of your consent may result in SNACS being unable or unwilling to provide its service.

  1. Personal information collected automatically through our website – cookies.
    SNACS collects Personal Information provided by cookies. Cookies are data files that are commonly stored on your device when you use websites and online services. They are used for the efficient operation of websites and may provide information and help personalize services.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies. If you prefer, however, you can usually change your browser settings to refuse cookies. If you wish to disable the use of cookies, you can do so from your browser’s preferences menu. It is possible to disable cookies or use the private browsing mode when using the website services. By refusing to accept cookies, however, use of the website may be considerably affected.

  1. Disclosure of your personal information
    8.1 Communication to entities and/or persons in Québec
    SNACS wants you to understand with whom it shares the Personal Information it collects about you. Accordingly, SNACS shares your Personal Information with the following persons/entities:
    1. Authorized service providers – SNACS may share your Personal Information with service providers who perform services on our behalf. The services provided by these service providers include processing credit card payments, processing donations, providing customer service, analyzing, and promoting activities, supporting website functionality, conducting contests, sweepstakes and surveys, and supporting other website functions. These service providers may have access to your Personal Information for the sole purpose of performing their functions. In such cases, measures will be put in place to ensure the confidentiality of your Personal Information.
    2. Business partners – SNACS may share your Personal Information with its business partners to be able to provide services to you. In such cases, measures will be put in place to ensure the confidentiality of your Personal Information.
    3. Community partners – SNACS may share your Personal Information with its community partners with the goal of improving the health and well-being of the English-speaking community in the Capitale-Nationale region (the Greater Québec City region), including Portneuf and Charlevoix. In this case, measures will be put in place to ensure the confidentiality of your Personal Information.
    4. Public health and social services – SNACS may share your Personal Information with the staff in the public health and social services sector in the Greater Québec City region. In this case, measures will be put in place to ensure the confidentiality of your Personal Information.
    5. Government authorities – SNACS may share your Personal Information with government authorities when required. In such cases, measures will be put in place to ensure the confidentiality of your Personal Information.

SNACS must obtain your consent to communicate or transmit your Personal Information to a third party that is not covered by this Policy, except when justified to do so by virtue of an exception provided for in the Act.

8.2 Communication to entities and/or persons outside Québec

Your Personal Information may be disclosed or stored outside Québec. In such cases, SNACS undertakes to carry out a privacy impact assessment and to transfer your information only if the assessment demonstrates that the Personal Information disclosed is adequately protected.

SNACS may share your Personal Information with the following companies, which demonstrate or have demonstrated that your Personal Information is adequately protected:

  1. BetterImpact – Software for engaging and managing volunteers and donors.
  2. FileMaker – A platform that stores data on a secure server.
  3. MS SharePoint – A tool for creating websites, publishing content and storing files.
  4. Zoom – A communications platform that allows users to connect with video, audio and phone.
  1. Third-party websites

There may be several places on our website where you can click on links that take you to other websites that are not subject to the terms of this Policy. Third-party websites may request and collect information about you, including Personal Information, and in some cases may inform us of your activities on those websites. SNACS recommends that you review the privacy policy of each third-party website you visit by clicking on the “Privacy Policy” link usually located at the bottom of the web page you are visiting.

  1. Retention of your personal information

SNACS stores your Personal Information on secure computer servers and, where necessary, in paper format in locked offices. The following is a list of physical locations where your Personal Information may be stored:

  1. Québec High School;
  2. The Gatehouse at the entrance to St. Patrick’s Cemetery;
  3. The Wellness Centre at Jeffery Hale;
  4. The Mary Gillespie House
  5. Desjardins Group
  1. Safety measures

SNACS takes appropriate security measures, including physical, electronic and procedural measures to protect your Personal Information from unauthorized access and disclosure.

SNACS has taken the following security measures to protect your personal information adequately:

  1. Each employee has a unique password to access their computer.
  2. A multifactor authentication system is in place.
  3. Each SNACS staff member signs a confidentiality agreement, as do our suppliers, customers and volunteers, including Board and Committee members.
  4. SNACS staff and volunteers receive training on the application of this Policy and on good practices for storing and protecting Personal Information.
  5. Locked filing cabinets are in place, along with a secure method of storing the keys for each of them. Personal Information collected in paper format / physical form can also be stored in locked offices.
  1. How long we keep personal information.

SNACS retains Personal Information for as long as it is required for the purposes set out in this Policy and subject to any retention period provided for by law.

Once the purposes for which your Personal Information was collected have been fulfilled, it will be destroyed or anonymized by SNACS, subject to any retention period provided for by law.

We may retain some of your account information for analytical and accounting purposes, as well as for record-keeping integrity and fraud prevention purposes, to collect fees charged, to enforce the Terms of Use, to take any action SNACS deems necessary to protect the integrity of the Website or its users, or as otherwise permitted by law. In addition, if any of your information has been provided to third parties with your consent, the use and retention of your information will be subject to the policies of those third parties and SNACS cannot be held responsible in any way.

When SNACS makes decisions based on your Personal Information, it is retained for a period of one year in accordance with the Act.

  1. Handling complaints

If you have a complaint regarding the protection of your Personal Information or the use of your Personal Information by SNACS, please contact our Privacy Officer, at the email address indicated on the first page of this Policy. A response to your complaint will follow as soon as possible.

  1. Staff roles and responsibilities

Only authorized employees of SNACS have access to your Personal Information, that is, employees who need to know or have access to your Personal Information to enable SNACS to provide its services. Employees authorized by SNACS to access your Personal Information are given specific access codes and each authorized employee has access only to the Personal Information in the program area that is required to perform their duties.

The Privacy Officer is responsible for ensuring compliance with and implementation of this Policy. He or she shall also ensure that all authorized SNACS employees are familiar with the Policy and that they use Personal Information in accordance with its provisions.

  1. Access to and means of accessing your Personal Information

If you have any questions about access to or use of your Personal Information by SNACS, please contact our Privacy Officer at the email address listed on the first page of this Policy. The contact information for the Privacy Officer will also be available on our website.

  1. Collection of Personal Information of minors or someone of 18 years of age or older requiring legal guardianship

SNACS over 18 years of age requiring legal guardianship. In such cases, SNACS will obtain the consent of the parent or legal guardian for the collection of the Personal Information and will only use the Personal Information for the purposes specified at the time of collection.

  1. Protocol in the event of a breach of confidentiality

In the event of a breach of confidentiality that can affect someone’s reputation, finances, credit rating, identity theft, and loss of employment, SNACS will promptly notify the Commission d’accès à l’information as well as notify the person (s) affected by the breach. 

SNACS will also implement an internal register of confidentiality incidents so as to put into place procedures that prevent new incidents of the same nature.

  1. Precedence

In the event of any inconsistency between this Policy and the Act, the provisions of the Act shall prevail.