Privacy policy

Alto Consultants Inc. Privacy Policy

Latest version: [add publication date to your website here]

This Privacy Policy (the “Policy“) sets out the practices of Alto Consultants Inc. with respect to the collection, use and disclosure of your personal information and applies to the situations set out in Section 2. For ease of reference, we refer to ourselves as “Alto” or simply “we“.

For the purposes of this Policy, personal information is any information that allows a natural person to be identified, directly or indirectly.

By accepting our Policy or by providing us with personal information after having had the opportunity to consult it, you agree to your personal information being processed in accordance with our Policy.

1. How do I contact our Privacy Officer?

If you have any questions about this Policy or our handling of your personal information, you can contact our Privacy Officer:

2. How do we use your personal information? 

How we process your personal information will depend on the nature of your interaction with us on our website, by telephone or by e-mail. Below is a description of how Alto collects and uses your personal information with the understanding that we may also process your personal information as required by applicable law or otherwise with your consent.

In the course of our activities, we process your personal information by technological means in the manner set out in sections 2.1 to 2.2:

2.1 – When you communicate with our team via our contact form on our website or by e-mail;

2.2 – When you send us your application.

• When you communicate with our team via our contact form on our website or by e-mail

• When you send us your application

3. Minors under 14 years of age

We do not voluntarily collect personal information from persons under the age of 14. If you are a minor under the age of 14 and are browsing our website, you may not provide us with any personal information without the express consent of a parent or guardian. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we discover that we have collected personal information from someone under the age of 14 without the consent of the parent or guardian, we will take steps to delete that information from our systems.

4. What identification, profiling or location technologies do we use?

We use technologies to identify, locate or profile you through the use of cookies. You can activate these technologies by accepting cookies on our website’s cookie banner. For more information, please refer to our Web site’s cookie banner and our policy on the use of cookies in Appendix A.

5. Where do we store personal information and is it transferred outside Quebec?

Your personal information is mainly held virtually on Alto servers on the servers of our service providers with whom we do business and who are located in Canada and the United States.

Your personal information is disclosed outside Quebec only if we believe it is adequately protected. Disclosure will also be governed by an appropriate contractual agreement.

6. Security measures and protection of your personal information

We deploy appropriate security measures to protect your personal information. In particular, we have put in place appropriate physical, technical and administrative safeguards to ensure the protection of your information.

In addition, we have implemented access control measures to limit access to your personal information to only those of our employees who require access in the course of their duties.

If you have reason to believe that personal information has been compromised, please contact our Privacy Officer at the coordinates listed in section 1 of this Policy.

7. What are your rights regarding your personal information?

By law, you have various rights with respect to your personal information. In particular, you have the following rights:

7.1 Access to your personal information

You may ask us whether we hold any personal information about you and, if so, you may request access to that personal information.

7.2 Rectification

You may ask us to rectify any incomplete or inaccurate personal information we hold about you.

7.3 Withdrawal of consent

In some cases, you may withdraw your consent to the disclosure or use of the personal information we hold about you. You understand, however, that in such a case, we will no longer be able to process your personal information in the ways set out in sections 2.1 and 2.2.

7.4 Portability

You may request that your personal information be disclosed to you or transferred to another organization in a structured, commonly used technological format.

8. How can you exercise your rights?

To exercise any of your rights above, please contact our Privacy Officer at the contact information provided in Section 1 of this Policy.

9. Comment formuler une plainte concernant notre traitement de vos renseignements personnels?

Alto takes inquiries, complaints and comments about our handling of your personal information very seriously. We invite you to contact our Privacy Officer if you have any complaints or comments about our confidentiality practices.

Your complaint will be reviewed by the Privacy Officer, who will determine whether the processing of your personal information complies with our confidentiality program and any applicable laws.

You may also file a complaint with the Commission d’accès à l’information du Québec using the form available on the Commission’s Web site. However, we invite you to first contact our Privacy Officer.

10. External sites or services

This Policy does not apply to third-party websites, pages or applications that may be accessed through our website. If you follow such links, these third-party sites or services may have their own privacy policies that you should review before submitting your personal information.

11. How do we update this Policy?

To ensure the clarity and transparency of our Privacy Policy, it may be amended from time to time. Changes will be posted on the Alto website, along with the date of the last update. Changes will be effective as of the date of the last update.
Summary of our internal policy on the governance of personal information

Alto is committed to protecting your personal information throughout its life cycle, in accordance with its confidentiality practices and the requirements of applicable laws.

In addition to our confidentiality policy, Alto has adopted an internal policy on the governance of personal information, the purpose of which is to set out the principles governing the protection of personal information in the context of its operations.

The objectives of our internal governance policy are:

1. To ensure proper, secure, compliant and transparent handling of your personal information;

1. Establish guidelines for Alto’s handling of personal information throughout its life cycle; and

• Define the roles and responsibilities of the Privacy Officer and our staff.

1.              Roles and responsibilities

Since respecting your personal information is everyone’s business at Alto, our Privacy Officer is supported by a team that is committed well-informed about confidentiality protection and the rights of the individuals concerned.

Every member of our staff has a role to play in ensuring that we act in accordance with our confidentiality program. In fact, every member of our staff is called upon to:

1. Direct any questions or comments about how we handle or should handle your personal information to the Privacy Officer;
2. Participate in training and awareness-raising activities on the importance of protecting personal information.

2.              Corporate governance guidelines

Alto recognizes the importance of the protection, confidentiality and security of the personal information it handles in the course of its activities, and the importance of making its employees and partners aware of this.

Alto has prepared guidelines of good and prohibited practices regarding how we may handle your personal information, for example:

1. We identify the purposes for which your personal information is collected. Thereafter, your personal information is used only in accordance with those purposes;
2. We seek to collect only the bare minimum in order to achieve the identified purposes;

• We strive to obtain your consent when we collect your personal information, and where sensitive personal information is involved, we seek your express consent;

1. We post our confidentiality policy clearly and prominently when we collect your personal information through technology;
2. We ensure that our technology products or services with confidentiality settings offer the highest level of confidentiality by default, without any intervention on your part;
3. We do not use technologies that allow identification, localization or profiling without disclosing this practice and informing you how to activate such features;

• We conduct confidentiality impact assessments when required by law, and when we consider that processing your personal information involves risks to your confidentiality;
• Wherever possible, we restrict access to your personal information to those members of our staff and our service providers who require access in order to carry out our operations;

1. We do not share your personal information with third parties without your consent, except when permitted by law.

3.              Confidentiality incident

Alto has set up a process for responding to and handling confidentiality incidents.

Under this process, Alto must take reasonable steps to reduce the risk of serious harm and review its practices to prevent confidentiality incidents.

Alto documents all confidentiality incidents in its confidentiality incident log and will adjust its confidentiality program as necessary following a confidentiality incident

Appendix A

Policy on the use of cookies and analytical tools

This Policy covers the use of cookies and analytics tools (“Cookie Policy”) and describes how Alto uses cookies, web beacons and other identification, profiling and tracking technologies (“Cookies”) on its website.

Our Cookie Policy supplements our Privacy Policy and should be read in conjunction with it.

1. What do you need to know about cookies and Web beacons?
   • What are cookies and Web beacons?

Cookies are small text files that are downloaded to your device when you visit a website, use a mobile application or download an e-mail. Cookies enable a website to recognize a device and store information (e.g. about your preferences, your use of the website) and to read this information each time you access the website.

There are two types of cookies: (i) primary; and (ii) third-party. Essentially, both types are technically identical and perform the same functions; the main difference lies in the way they are created and then used.

Primary cookies. Primary cookies are created by the website you are visiting. A website can only access cookies it has placed on your device, so, for example, cookies placed when you visit a search engine cannot be accessed by our websites.

Third-party cookies. Third-party cookies are created by a site other than the one you are visiting and are mainly used for profiling purposes and behavioral advertising. They also enable Web site owners to provide certain services. This type of cookie may be placed by what is known as a Web beacon (more on this below). Since a Web site can only access cookies it has placed itself, we cannot access third-party cookies placed on any of our Web sites.

A Web beacon, often referred to as a “web beacon”, is a transparent image, usually 1 pixel x 1 pixel, that is placed on a website or in an e-mail to evaluate how a user interacts with specific content. Web beacons work by sending information along with the request to the third-party web server when the request to display the web beacon is made.

• What can you do to control the cookies placed on your computer?

Most browsers allow you to configure how cookies are accepted by your browser. Please bear in mind that changing your cookie settings may prevent certain websites from functioning properly. Please consult your browser’s documentation to find out how to configure your cookie settings.

You can also use your browser’s private or incognito mode, which will automatically delete any cookies placed when you use private mode, once all private mode tabs have been closed. See your browser’s help section for more information on how private mode works.

Some recent browsers have built-in functionality to block or control profiling content. We invite you to consult your browser’s help section to see if such functionality is available.

Some browsers may have third-party extensions that can be used to manage and delete cookies. If you decide to use extensions, please pay particular attention to the extensions you install and the permissions they require.

You can also disable our use of cookies and similar technologies that enable us to profile and display advertising on third-party sites via our cookie banner.

2. How do we use cookies on our website?
   • Why do we use cookies on our website?

Alto may use cookies to enhance your user experience, to enable certain features and to provide visitors with personalized advertising. For more information on the cookies we use, please see our website’s cookie banner.

3. Analytical tools to measure interaction with our website
   • What you need to know about analytics

Analytics tools are used to collect, analyze and measure web traffic and user visits to our website in order to understand and optimize the use of our website. Analytics work by collecting information about a visitor’s interactions with one or more web pages. This information includes, for example, the average number of pages visited by a user.

• What analytics tools do we use on our website?

Alto may use analytics tools to understand how visitors interact with our website. For more information on the cookies used, please see our website’s cookie banner.

• What can you do to prevent our website from collecting analytical information?

You can take various steps to prevent a website from collecting details about your browsing. You can:

• Control the cookies accepted by your browser (see section 1.2);
• Install browser extensions to disable the use of analytics tools;
• Set your preferences via our cookie banner.