PRIVACY POLICY
EFFECTIVE DATE: Monday, November 27, 2023
We hope you will enjoy and appreciate using our “Services”, which may be: visiting our website at the URL https://yesmontreal.ca/ (the “Website”); signing up and using the job board platform for employers and candidates on the Website (the “Platform”); signing up and using the YES Business Directory at https://directory.yesmontreal.ca/ (the “Directory”); or accessing any other Youth Employment Services websites or services which may be specified in this Privacy Policy (the “Policy”) from time to time.
Youth Employment Services Foundation (the non-profit organization that owns and operates the Services) takes your privacy and security of personal information very seriously. We have provided and will continue to provide a secure environment and this strict Policy that describes the limited ways your information is used and the limited access to such information. We ask that you read it carefully.
Key Elements of this Policy
Here are the key elements of this Policy needed to make an immediate, informed decision about your consent for our collection, use and disclosure of your personal information. By submitting any personal information to us or our service providers via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy.
Personal Information we collect from you directly but only with your consent | What we do with it | Third parties we share it with |
Contact Information (your name, email address and phone number) | Respond to your inquiry | Companies that provide the infrastructure for the Services, specifically WP Engine |
Volunteer information (your name, email address, mailing address, phone number and current employment information) | Respond to your inquiry about volunteering and consider your suitability to be a volunteer | Companies that provide the infrastructure for the Services, specifically WP Engine |
Newsletter Information (your name and email address) | Send you our newsletter | Companies that provide our email communications for the newsletter, specifically Brevo |
Platform Employer Account Information (your email address) | To create a Platform account for you, to communicate with you about your account, and to control your access to the Platform | Companies that provide the infrastructure for the Services, specifically WP Engine |
Platform Candidate Account Information (your name, email address, and any additional optional personal information) | To create a Platform account for you, to communicate with you about your account, to control your access to the Platform, and to share with potential employers | Companies that provide the infrastructure for the Services, specifically WP Engine |
Directory Account Information (your name and email address) | To create a Directory account for you, to communicate with you about your account, and to control your access to the Directory | Companies that provide the infrastructure for the Services, specifically WP Engine |
Community Portal Information (your email address and optionally your name) | To create a Community Portal account for you, to communicate with you about your account, and to control your access to the Community Portal | Companies that provide the infrastructure for the Services, specifically WP Engine |
Find a Mentor Information (your name, address, email address and phone number) | To help match you with a mentor and to communicate with you about the mentorship program | Companies that provide the infrastructure for the Services, specifically WP Engine |
Personal Information collected by third-party service providers on our behalf | What we do with it | Third parties who share it with us |
Donation Information (your name, email address, and credit card information) | Communicate with you (including sending you a tax receipt), and process your payments for your donations made to Youth Employment Services | Third parties who manage donations and process payments, specifically Canada Helps |
Event Registration Information (name, email address and additional information) | Register you for events | Third parties who manage our events registration, specifically Eventbrite |
Event Payment Information (your credit card information) | Process your payments for paid events | Third parties who manage our events registration specifically Eventbrite, and payment processors used by Eventbrite |
Auction Contact Information (name, email address, mailing address and cell phone number) | Communicate with you about your fundraiser auction bids, and send you tax receipts | Third parties who manage our events registration, specifically Goowi |
Auction Payment Information (your credit card information) | Process your payments for fundraiser auctions you win and your tickets to the fundraiser | Third parties who manage our events registration, specifically Goowi, and payment processors used by Goowi |
Some Terms and Definitions
Before we really get started on the details, here are a few terms and phrases we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal information and privacy in the place where you live. These include (1) “PIPEDA” (the Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada outside Quebec; (2) the Act Respecting the Protection of Personal Information in the Private Sector (the “Quebec Privacy Act”) as amended by Law 25, which applies to our activities in Quebec; (3) any other applicable data protection law. Youth Employment Services is committed to adhering to all the Data Protection laws.
Under PIPEDA, Youth Employment Services “collects, uses, and discloses” your personal information. Under the Quebec Privacy Act, Youth Employment Services “collects, holds, uses or communicates to third persons” your personal information. Those phrases (or their variations) may be used interchangeably in this Policy.
“Personal information” – this is information we collect from you or about you and which is defined in PIPEDA as “information about an identifiable individual.” Under the Quebec Privacy Act, it is defined as “any information which relates to a natural person and allows that person to be identified either directly or indirectly.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you.
About Us, and Contacting Us and Our Privacy Officer
Youth Employment Services Foundation is a registered non-profit organization located in the Province of Quebec, Canada, with an office at the address listed below. Where this Policy refers to “Youth Employment Services”, it may refer to Youth Employment Services Foundation and / or its affiliates, and their respective officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to Youth Employment Services. In this Policy a Website visitor or any Services user may be referred to as “you”.
Under PIPEDA, Youth Employment Services is an “organization”; under the Quebec Privacy Act, Youth Employment Services is an “enterprise”.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data-related, or exercise any of your available privacy rights, you can contact our Privacy Officer Fernanda Amaro at:
Privacy Officer Fernanda Amaro
[email protected]
or:
Privacy Officer Fernanda Amaro
666 Sherbrooke Street West, Suite 700
Montréal, Québec
Canada
H3A 1E7
Your Rights
You have the following rights regarding your personal information held by Youth Employment Services, and other rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting the price you pay for any of the Services, if any.
- The right to withdraw at any time your consent for Youth Employment Services to use your personal information;
- The right to have your personal information erased from Youth Employment Services’ records;
- The right to have any hyperlink from Youth Employment Services or the Website that is attached to your name removed;
- The right to access your personal information and any relevant information around its collection, use, and disclosure;
- The right to have a copy of your personal information given to you in an easy-to-read format so that you can transfer it to another organization;
- The right to have your personal information corrected or updated if you believe it is inaccurate or out of date;
- The right to opt out of marketing communications we send you, at any time;
- The right to know whether Youth Employment Services sells or shares your personal information (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications;
- The right to restrict the use of your personal information if it is inaccurate or if our collection, use or disclosure of it is against the law; and
- The right to refuse any marketing or advertising targeted at you by Youth Employment Services. Please note that Youth Employment Services does not currently perform any targeted marketing or retargeting advertising via the use of cookies on the web to its Website visitors.
If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above or refer to the relevant sections further in this Policy.
Please note that if you request the erasure of your personal information, we shall do it to the extent feasible; however, Youth Employment Services reserves the right to retain some of your personal information for a reasonable time in order to satisfy certain legal obligations or under a legal procedure of any sort. Furthermore, deletion of your personal information may prevent you from using all or a portion of the Services.
Limited Personal Information Collected from You and What We Use It For
Youth Employment Services limits the amount of personal information we collect to only what is necessary and appropriate for the identified purposes. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.
In the table below, please find all the personal information we may collect from you directly, and what we use it for. Under PIPEDA and the Quebec Privacy Act, the legal basis for our collection and use of this personal information is your informed consent, and by submitting this personal information you acknowledge having granted this consent to Youth Employment Services. In the event you withdraw your consent to use such personal information, you may no longer be able to access certain of the Services.
Personal Information category | Personal Information collected | What we use it for |
Contact Information | Your name, email address and phone number | Respond to your inquiry |
Volunteer Information | Your name, email address, mailing address, phone number and current employment information) | Respond to your inquiry about volunteering and consider your suitability to be a volunteer |
Newsletter Information | Your name and email address | To send you the newsletter |
Platform Employer Account Information | Your email address | To create a Platform account for you, to communicate with you about your account, and to control your access to the Platform |
Platform Candidate Account Information | Your name, email address, and any additional optional personal information you submit, such as details included in your C.V. |
· To create an account on the Platform for you, to communicate with you about your account, and control your access to the Platform · In the event you set your Candidate profile to public, your personal information is displayed to the public and employers · Sharing it with potential employers of position(s) you have applied for |
Directory Account Information | Your name and email address | To create a Directory account for you, to communicate with you about your account, and to control your access to the Directory |
Community Portal Information | Your email address and optionally your name | To create a Community Portal account for you, to communicate with you about your account, and to control your access to the Community Portal |
Find a Mentor Information | Your name, address, email address and phone number | To help match you with a mentor and to communicate with you about the mentorship program |
Personal Information Collected About You from or by Third Parties and What We or the Third Party Use It For
Sometimes we get personal information about you from third parties, or the third party collects it on our behalf and uses it. This table explains the details about this personal information – what it is, where it came from and what we or the third party does with it. Under PIPEDA and the Quebec Privacy Act, the legal basis for our collection, use, and disclosure of this personal information is your informed consent, and by submitting such personal information to third parties, you agree that you have granted such consent. None of this data comes from publicly available sources.
Personal information category | Personal information collected by the third party | Who collects the personal information | What we and/or the third party use it for |
Donation Information* |
1. Name and email address 2. Credit card holder name, credit card number, expiration date, CVV/CVC number and billing address (as required by your credit card agreement) |
Third parties who manage donations and process payments for us, specifically Canada Helps |
1. To communicate with you about your donation and send you a tax receipt 2. To process the payment for your donation |
Basic Event Registration Information | Name, email address | Third parties who manage our events registration, specifically Eventbrite | To register you for events and communicate with you about events you have registered including to send you your tickets |
Detailed Event Registration Information | Gender, date of birth, home address, home phone, mobile phone, identification with certain minority groups | Third parties who manage our events registration, specifically Eventbrite | For statistical purposes, this personal information is used in the aggregate only in Youth Employment Services’ efforts in applying for funding from grants, donations, and other financial sources |
Event Payment Information | Credit card holder name, credit card number, expiration date, CVV/CVC number and billing address (as required by your credit card agreement) | Third parties who manage our events registration, specifically Eventbrite and payment processors used by Eventbrite | To process your payments for paid events |
Auction Contact Information | Name, email address, mailing address and cell phone number | Third parties who manage our events registration, specifically Goowi | To communicate with you about your fundraiser auction bids, and send you tax receipts |
Auction Payment Information | Credit card holder name, credit card number, expiration date, CVV/CVC number and billing address (as required by your credit card agreement) | Third parties who manage our events registration, specifically Goowi, and payment processors used by Goowi | To process your payments for fundraiser auctions you win and your tickets to the fundraiser |
*Please note that when you make a donation on the Website, the information entered is collected by Canada Helps directly, despite you being on the Youth Employment Services Website. For more information about how Canada Helps treats your personal information, you can read their Privacy Policy.
To the extent that analytics identifiers and IP addresses are generated by or collected from third parties, these may be considered personal information collected from third parties, and you can find details about that further below in this Policy.
Sensitive Personal information
Generally, we do not collect any of what the Data Protection Laws consider sensitive personal information from you, unless you voluntarily submit it to us, which we encourage you not to do.
Exceptionally, under the Quebec Privacy Act, certain personal information of the Detailed Event Registration Information may be considered sensitive personal information, for example, if you identify as certain minorities including LGBTQIA+. We only use this sensitive information in the aggregate, for the purposes described in the table above.
Who We Transfer Your Personal Information To
We routinely share some of your personal information with certain types of third parties who are identified in the table below along with what they do with it. Please note that some of those third-party recipients may be based outside your home jurisdiction. If you are in Quebec, please see the “Transfer of Your Personal Information Outside of Quebec” section further down in this Policy for information on how we safeguard your personal information when this occurs.
We will share personal information with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the Youth Employment Services Terms and Conditions; or (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Services infrastructure or the Services generally).
We may also share personal information: (1) to joint ventures or other organizations under common control with Youth Employment Services (in which case we will require such entities to honour this Policy); (2) if Youth Employment Services merges with another entity, or is subject to a reorganization (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).
We will never share your personal information with other third parties except under these circumstances. We do not sell or rent your personal information to any third party for direct marketing purposes or any other purpose.
Personal information category | Who we transfer it to | What they do with it |
Contact Information | Companies that provide the infrastructure for the Services, specifically WP Engine | Store it so that we may retrieve it to respond to your inquiry |
Volunteer Information | Companies that provide the infrastructure for the Services, specifically WP Engine | Store it so that we may retrieve it to respond to your inquiry about volunteering and consider your suitability to be a volunteer |
Newsletter Information | Companies that provide our email communications for the newsletter, specifically Brevo | Send you the newsletter, as described more fully in the Email Communications section below |
Platform Account Information, Directory Account Information, Community Portal Information, and Find a Mentor Information | Companies that provide the infrastructure for the Services, specifically WP Engine | Store it so that we may retrieve it to perform the functions described above |
Platform Candidate Account Information | Potential employers | Evaluate your candidacy for a position you applied for |
Analytics identifiers and IP addresses | Companies that provide data analytics such as Google Analytics | Provide us with analytics as to how the Services are used and to trace fraudulent activities, as further detailed in the Limited Gathering of Information section below |
Limited Gathering of Information for Statistical, Analytical and Security Purposes
Youth Employment Services automatically collects certain information using the “Third-Party Analytics Programs” Google Analytics, Microsoft Clarity, and Hootsuite to help us understand how our users use the Services, but none of this information identifies you personally, except via an alphanumeric string. For example, each time you visit the Website or log in to the Platform or other Services, we automatically collect (as applicable): your IP address, browser and computer or device type, access times, the web page from which you came, the web page(s) or content you access, the social media sharing links you use while on the Website, other engagement information, and other general related information. We use information collected in this manner only to better understand your needs and the needs of Website visitors and Services users in the aggregate. Youth Employment Services also makes use of information gathered for statistical purposes to keep track of the number of visits to the Website and Services, the specific pages on the Website and Services, and users with a view to introducing improvements to the Website and Services.
Your IP address and other relevant information we collect using the Third-Party Analytics Programs may be used in order to trace any fraudulent or criminal activity, or any activity in violation of the Youth Employment Services Terms and Conditions.
Email Communications and Compliance with Anti-Spam Laws
Youth Employment Services uses Brevo to manage our mailing list, send out our newsletter and communicate with you about the Services, as well as using WordPress plugins and Outlook to send various emails (Brevo, WordPress, and Outlook collectively the “Email Service Providers”). Personal information (your email address) is transferred to the Email Service Providers in order to manage the mailing list and for the emails to be sent out properly. Your personal information is only used to send out emails; the Email Service Providers do not use this personal information for any other purpose, and will not transfer or sell your personal information to any other third party. For more information, please refer to Brevo’s Privacy Policy.
You may unsubscribe from Youth Employment Services’ mailing list at any time by following the link at the bottom of all Youth Employment Services emails. Other types of emails, such as transactional, relational, and other emails related to certain Platform or other Services functions will not have an opt-out option as they are necessary for the use of the Platform or other Services.
Youth Employment Services’ practices in regards to its email are designed to be compliant with anti-spam laws, including the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23) and the American CAN-SPAM Act. If you believe you have received email in violation of these laws or any other anti-spam law, please contact us using the contact information further up in this Policy.
Tracking Technology (“Cookies” and Related Technologies)
Youth Employment Services uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) in the Services and in our newsletter, and by interacting with the Services or signing up for the newsletter you agree to their use. Cookies are small text files placed on your computer or device when you visit a website or use an online service, in order to track use of the site or service and to improve the user experience by storing certain data on your computer or device.
By default, all non-necessary cookies are turned off when you first visit the website; you can use our cookie management tool in the cookie banner presented to you to accept or decline categories of cookies.
Specifically, we use cookies and related technologies for the following functions:
- to enable your logging-in to the Platform, Community Portal or other Services;
- to track the number of views and user preferences for embedded videos from YouTube;
- to track performance of our email campaigns using Brevo;
- to facilitate your donations through Canada Helps;
- to provide general internal and user analytics in the Services and to conduct research to improve the content of the Services using the analytics programs as described above in this Policy; and
- to assist in identifying possible fraudulent activities.
Your browser or device can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s or device’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:
- Google Chrome
- Mozilla Firefox
- Microsoft Edge
- Microsoft Internet Explorer
- Opera
- Apple Safari
- iOS
- Android
Please note that deleting or blocking certain cookies may reduce your user experience by requiring you to re-enter certain information, including information required to use certain of the Services. Furthermore, deleting certain cookies may prevent certain functions, or the entirety of the Platform, from working at all.
How We Protect Your Personal Information
We have implemented very strict technical and organizational procedures to ensure that, by default, only personal information that is necessary for each specific purpose is collected, used, and disclosed by us. These procedures prevent your personal information from being lost, used or accessed in any unauthorized way. Examples of such procedures include restricted access to offices, training of personnel, use of passwords, and well-defined internal policies and information technology practices.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Law requires us to do so and within the time frame required by the applicable Data Protection Law.
Youth Employment Services uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal information) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Youth Employment Services uses vendors such as WP Engine, a recognized leader in secure data, for hosting of the Services and related data, and storage of data including personal information.
All information, including personal information, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check Youth Employment Services’ valid SSL security certificates on the Website.
Internal Procedures and Policies
In addition to the measures to protect your personal information described in the previous section, we have drafted and implemented certain internal procedures and policies regarding personal information, including the following:
- A framework for the keeping and destruction of personal information, including where we may keep anonymized data;
- Defining and describing the roles and responsibilities of the members of Youth Employment Services personnel throughout the life cycle of the personal information;
- A process for dealing with individual complaints and requests for personal information and exercising of the individual’s rights under Data Protection Laws; and
- A management and IT policy and procedure for addressing potential data breach incidents involving personal information in the custody of Youth Employment Services.
Transfer of Your Personal Information Outside of Quebec
For our Quebec users and visitors, we endeavor to keep your personal information in Quebec. However, certain of our third-party service providers are in other provinces or countries where your personal information may be transferred. When this happens, we do the following to safeguard your personal information:
- We will perform what the Quebec Privacy Act calls an “Assessment of the privacy-related factors” (what is generally called a “Privacy Impact Assessment,” or “PIA”) prior to the personal information leaving Quebec. If the PIA does not meet our standards and the standards required by the Quebec Privacy Act, we will not transfer your personal information to such a service provider; and
- If the PIA allows us to transfer the personal information to such a service provider outside Quebec, we will sign what is generally called a “Data Processing Agreement,” or DPA, or conclude other contractual provisions with the service provider, which protects the person data transferred to them and limits their use of it to what we have contracted with them to do. The DPA or other contractual provisions will adhere to the requirements of the Quebec Privacy Act.
Furthermore, any time we are considering sending your personal information outside Quebec to a third party who is not a service provider, we will perform a PIA. If the PIA does not meet our standards and the standards required by the Quebec Privacy Act, we will not transfer your personal information to such third party.
Supervisory Authorities and Complaints
If you are in Canada outside Quebec and you are not satisfied with the response received or the actions taken by our Privacy Officer, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website. In Quebec you can make a complaint to the Commission d’accès à l’information du Québec with information found on their website.
Data Retention
Your personal information will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will retain your Platform Account Information only for as long as you have an account with us to use the Platform.
We may have to keep your personal information for a longer period of time to satisfy our requirements under any applicable law.
Automated Decision-Making
Youth Employment Services does not use any automated decision-making processes in providing the Services.
Children’s Privacy Statement
The Services are not intended for children under the age of 16. We do not knowingly collect any personal information from a child under 16. If we become aware that we have inadvertently received personal information from a person under the age of 16 through the Services, we will delete such information from our records.
Changes to This Privacy Policy
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy. You can always find the most updated version at this URL, and we will always post a notice on our Website if we make big changes. If you have a Youth Employment Services account to use the Platform or any other Youth Employment Services service, we will also email you to tell you the Policy has been updated, and what the important changes are.
Thanks for reading! Please keep your personal information safe; we promise to do the same.
© Youth Employment Services Foundation 2023