LEGAL NOTICES

PRIVACY POLICY
Last updated February 2024

1 — General information
The purpose of this Privacy Policy (the “Policy”) is to formalize the commitment of Sports Rousseau®, Hockey Experts®, L’Entrepôt du Hockey® doing business under the name FGL Sports Ltd (hereinafter “FGL” or “we” or “us”), to the protection of Personal Information (as defined hereinafter) and to inform you of the types of Personal Information that FGL collects, uses and discloses, in particular in connection with the operation of the recruitment site https://carrieres.triohockey.ca/en/annonces (the “website”).

The Policy applies to all Internet users of the website (“the User” or “you”) accessible from the URL  https://carrieres.triohockey.ca/en/annonces (the “website”) and operated by FGL, in particular candidates who submit their applications as well as our current employees insofar as they have previously used the website. To facilitate external recruitment, FGL uses DigitalRecruiters software, published by BANKESS, to post job offers, collect applications and manage them.

The Policy does not apply to Personal Information about our sub-contractors.

The following articles provide information on:  
  • The scope of your consent; 
  • The nature of the Personal Information we collect and the means by which we do so;  
  • The security and governance measures we take to protect your information;   
  • The purpose of its use; 
  • How we communicate and store it;  
  • Your rights and how to exercise them.  

2 — Scope of the Privacy Policy

The Policy applies to all Personal Information about you that we collect or receive from any source.

“Personal Information” is any information relating to a natural person that identifies that person directly (e.g. surname, first name, email address) or indirectly (information that, when combined with other information, makes it possible to identify the person).

We only collect Personal Information about you that is necessary to establish, manage and maintain our relationship with you. 

3 — Collection of Personal Information
  • Nature of Personal Information collected

We only collect Personal Information that is necessary for the purposes of recruitment activities and to which you have consented. This may include: 
  • Your identifying information, such as your last name, first name, email address, mailing address and telephone number;
  • Information required to optimize your experience on the website, such as your IP address, location or navigation data;
  • Personal Information contained in your resume and/or cover letter.   

FGL informs you that it may also supplement your profile with information about you, namely information collected during its exchanges with you, whether in writing, by telephone or from physical interviews, and from professional social networks or any public information source, when this information is useful for the management of your application. 

  • Means of collection
In most cases, we collect Personal Information directly from you when you:
  • Create a profile on the website;
  • Apply for a job;
  • Add your resume to your profile;
  • Add a cover letter to your profile;
  • Log in to our website from your LinkedIn account;
  • Contact our teams by email; and
  • In general, when you use our website.

Answers to fields marked with an asterisk on the website are mandatory and failure to answer may jeopardize the processing of your application. In other cases, they are optional and have no impact on the examination of your application.

Your data may also be integrated into a CV database which will enable FGL to offer you other job offers, where applicable, for the period set out in Article 7 hereof.

4 — Disclosure of your Personal Information
  • To whom?  
In view of its purpose, which consists of processing the Personal Information of candidates responding to job offers and integrating candidate data into the CV database, the processing of your Personal Information is necessary to pursue the legitimate interests of FGL, namely the management of its recruitment process, as well as the execution of pre-contractual measures that may exist between FGL and candidates responding to its job offers.

FGL ensures that the Personal Information it holds is accessible only to those persons who require access to it in the course of their duties in order to enable them to consider your application. 

In its capacity as a sub-contractor of FGL, BANKESS is authorized to access your Personal Information when necessary, in particular as part of its duties to administer and maintain the website and the job application management tool. However, BANKESS may not communicate this data, except to sub-contractors for the purposes of hosting and processing such data in a manner consistent with the purposes for which it was collected.

FGL ensures that the confidentiality of your Personal Information is preserved when it is communicated to third parties. Furthermore, FGL undertakes not to sell, transfer or rent your Personal Information to a third party.

  • Where?
We may communicate Personal Information outside Quebec, in particular to France where Personal Information is hosted and processed. 

Before disclosing Personal Information outside of Quebec, we will conduct a privacy impact assessment that will take into account: 
  • The sensitivity of the Personal Information; 
  • The purpose of its use; 
  • The protective measures it will benefit from; and 
  • The legal regime applicable in the State where the Personal Information will be communicated. 

We will only proceed with disclosing the information if this assessment demonstrates that the Personal Information will be adequately protected in accordance with generally accepted privacy principles. In addition, this disclosure must be the subject of a written contract that takes into account all of the conclusions of the assessment.   

5 — Your consent 

Your consent to the collection, use or disclosure of your Personal Information must be clear, free and informed. It must be given for the specific purposes and objectives identified in this Policy. 

Depending on the nature and sensitivity of your Personal Information, such consent may be express if it is expressed though specific words or gestures, or implied if it can be inferred from the conduct of the person whose Personal Information is collected, used or shared.

By completing the form on the website, you consent to the collection, use, disclosure and retention of your Personal Information in accordance with this Policy.

If you do not consent, please discontinue use of the website. Except where otherwise provided by law, you may withdraw your consent at any time upon reasonable notice. Please note that if you choose to withdraw your consent to the collection, use or disclosure of your Personal Information, certain features of our website may no longer be available to you or we may no longer be able to analyze or manage your application.

6 — Use of Personal Information 

Except in accordance with the Policy, and unless permitted or required by law, FGL does not collect, use or share Personal Information without prior consent.

We use your Personal Information for the following purposes:
  • To confirm your identity and to verify the accuracy of your Personal Information;
  • To evaluate your job application; 
  • To respond to your requests and questions;
  • To analyze your responses and profile for recruitment purposes;
  • To propose job offers that match your profile or career aspirations;
  • To obtain statistics on the use of the website, including allowing BANKESS to obtain such statistics on an anonymous basis. 

All of our employees who use Personal Information are bound by confidentiality obligations. In addition, they may only have access to Personal Information that is necessary for the performance of their respective duties. Our governance policies and practises provide for sanctions in the event of non-compliance. 

7 — Retention 

Except where legal requirements or contractual interests recognized by law oblige us to retain it for a longer period, Personal Information of external candidates will be retained only for as long as necessary to fulfill the purposes for which it was collected, but at the latest until the expiry of a period of 24 months after your last contact with our recruitment department, the notion of “last contact” being understood as the date on which you consented to the collection of your Personal Information. 

We reserve the right to establish Personal Information destruction policies from time to time. If you request the destruction of your Personal Information, we will use reasonable efforts to comply with your request as soon as possible. Your Personal Information will be deleted within 30 days of your request. 

8 — Security and governance

FGL applies security measures proportional to the sensitivity of the Personal Information it holds, the purpose for which it is used, its quantity, its distribution and its medium. These security measures are designed to protect your Personal Information against loss or theft, as well as unauthorized access, use or disclosure. 

The security measures applied by FGL include: 
  • Administrative measures such as ongoing information security awareness training, including key privacy concepts, a code of ethics, policies and guidelines dictating the framework to be followed in terms of security, laws and professional ethics, as well as the application of the best principles of identity and access management such as least privilege and segregation of duties. 
  • Technical measures such as software for identifying, pre-protecting and detecting technological threats, strong passwords with a complexity based on the best market recommendations, multi-factor authentication and prompt identification and correction of vulnerabilities affecting our information assets. 

9 — Your rights 

By providing your Personal Information, you confirm that it is accurate and that you are not impersonating any third party. 

The User also has the following rights with respect to their Personal Information:
  • The right to be informed of its use, disclosure, retention and destruction, which is specifically covered by this Policy;
  • The right to access your Personal Information and to obtain, where appropriate, additional details about how we use, disclose, retain and destroy it;
  • In some cases, the right to object, restrict or withdraw your consent to such operations upon reasonable notice sent to the email address provided at the end of this Policy; 
  • The right to have your Personal Information corrected if it is inaccurate or misleading and to have it completed if it is incomplete; 
  • The right to have your Personal Information deleted subject to our legal obligations; 
  • The right to be informed of a privacy incident involving your Personal Information that may cause you serious harm. To this end, we maintain a register of all privacy incidents and assess the harm they may cause.  

You may exercise these rights at any time by contacting us. You must make this request in writing and send it to us by email at the email address provided at the end of this Policy, enclosing proof of your identity. In such a case, any information provided to identify you will be used solely for this purpose. We undertake to reply within thirty (30) calendar days of receipt of your request, except where the law permits an extension of this period.

Subject to legal restrictions, if we refuse to provide you with or correct your information, we will provide you with the reasons for said refusal, information about your recourse and the applicable sections of the law. 

If we refuse to rectify your Personal Information, we will allow you to add written comments to your file with respect to the Personal Information for which rectification has been refused. We will also retain Personal Information that has been the subject of an access request for as long as necessary to allow you to exhaust any recourse provided by law.

10 — Communications

You may decide to stop receiving electronic communications from FGL by unsubscribing using the mechanism indicated in such communications or by sending us a written request by email.

11 — Cookies

Your use of the website allows us to automatically compile certain information, known as cookies, which may include: 
  • The Internet Protocol (IP) address of your computer; 
  • Your geolocation zone; 
  • The operating system you are using; 
  • Your preferred language; 
  • The identity of your Internet Service Provider; 
  • The date and time you accessed the website; 
  • The previous website that you visited that provided you with a link to our website; and
  • The content viewed and downloaded on our website or the number of visits. 

Generally, the cookies we use are grouped into three categories: 
  • Technical cookies: Technical cookies are used throughout navigation to enable our website to be used. For example, a technical cookie may be used to remember your username to enable you to log in, to remember your preferences or the options you have selected;
  • Analytical cookies: These cookies are anonymous and are used to collect statistics on the use of our website;
  • Advertising cookies: These cookies may be added by the website or by other sites displaying advertising or announcements. These cookies collect information anonymously and establish your visitor profile.  

If you prefer, you can set your browser to notify you when you receive cookies, or to refuse them altogether. You can erase cookies from your computer’s hard drive, block the creation of cookies or receive a warning before a cookie is stored. 

However, in doing so, your use of our website may be affected and you may no longer have access to all its functions. We invite you to visit the Ads Setting and Network Advertising Initiative sites as well as your browser’s instructions or help section for more information on cookies.

12 — Contact us

All requests, comments, questions, concerns or complaints regarding your Personal Information, this Policy or our privacy practises should be sent to us by email at: hrstores@fglsports.com

13 — Modification

FGL reserves the right to modify the content of this Policy at any time and without prior notice. You can consult the applicable Policy at any time on this website. The date on which this Policy was last updated is indicated at the top of the Policy.

14 - Jurisdiction and applicable law

Without prejudice to your right to take legal action against FGL in any court of competent jurisdiction, this Policy is governed by the laws of the Province of Quebec and the laws of Canada applicable therein.