PRIVACY POLICY

This privacy policy (the “Policy”) describes how Me Fayçal Boutenbat, a lawyer admitted to the Barreau du Québec (the “Firm”), collects, uses, discloses, and protects the personal information of individuals who visit this website or contact the Firm through the online form.

This Policy does not apply to strictly professional information (name, title, company, professional contact details shared in a business context), unless otherwise indicated.

 

1. Scope

 

This Policy applies to any individual who:

•    visits the Firm's website;
•    contacts the Firm through the online form, by email, or by telephone;
•    retains the Firm to provide legal services; or
•    participates in any activity organized by the Firm.

2. Collection of Your Personal Information
2.1 Information You Provide

Depending on the context, you may be asked to provide the Firm with the following personal information: first and last name; mailing address; telephone number; email address; and any other information you choose to share through a contact form, an email exchange, or a professional engagement.

This information is collected when:

•    you complete the online contact form;
•    you contact the Firm by email or telephone;
•    you provide documents or information in connection with an engagement; or
•    you transmit files through a file-sharing platform (OneDrive, Google Drive, or otherwise).

2.2 Information Collected Automatically

When you visit the website, the Firm may automatically collect certain browsing data, including: pages viewed, the date and time of your visit, the type of browser used, and the device's IP address. This information is collected using cookies, as described in Section 5 below.

3. Purposes of Collection

The Firm collects only the personal information necessary for the following purposes:

•    responding to inquiries and communications submitted through the contact form or by email;
•    establishing and maintaining the professional relationship between the Firm and its clients;
•    providing the legal services retained and following up on files;
•    complying with the Firm's ethical obligations under the rules of the Barreau du Québec;
•    improving the website and measuring its performance using anonymized data; and
•    complying with any applicable legal or regulatory obligation.

4. Disclosure of Your Personal Information

The Firm discloses your personal information to third parties only in the following circumstances:

•    with your express consent;
•    with third-party service providers (hosting, digital platforms) bound by strict contractual confidentiality obligations, who process your information only for the purposes and in accordance with the instructions of the Firm;
•    with other parties involved in your file when necessary for the provision of services (for example: experts, opposing counsel in formal exchanges, administrative authorities);
•    with government authorities, in connection with applicable legal or regulatory obligations;
•    when required in response to a court order, a subpoena to produce documents, or an investigation by the authorities; or
•    when necessary in connection with a business continuity transaction involving the Firm (merger, transfer of clientele, or otherwise).

4.1 Transfers Outside Quebec

The Firm may use digital tools or platforms whose servers are located outside Quebec (including cloud computing services). In such cases, the Firm ensures that your personal information receives adequate protection abroad, including by conducting a privacy impact assessment (PIA) where required, in accordance with the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1).

5. Cookies

The Firm's website may use cookies or similar technologies to improve your browsing experience, gather anonymous usage statistics, and ensure the website functions properly.

 

Cookies may be set by the Firm or originate from third parties (for example, analytics tools). They may record information such as screen size, pages visited, the date and time of your visit, and your browsing behaviour.

You may configure your browser to refuse cookies or to notify you when cookies are received. In such cases, some features of the website may not be available. Cookies stored on your device may be viewed and deleted at any time.

The Firm does not use advertising cookies or behavioural profiling for commercial purposes.

6. Protection of Your Personal Information

The security of your personal information is a priority for the Firm. Reasonable technical, organizational, and contractual measures are implemented to protect your information against loss, theft, unauthorized access, disclosure, alteration, or destruction.

Anyone with access to your information in connection with the Firm's activities is subject to strict confidentiality obligations, including under the Code of ethics of lawyers.

 

7. Retention and Destruction of Information

 

The Firm retains your personal information for the period necessary to fulfill the purposes for which it was collected, or for any longer period required or authorized by applicable law, including under the professional rules governing the retention of a lawyer's files.

Upon expiry of the applicable retention period, your information is destroyed or anonymized using secure methods.

8. Your Rights Regarding the Protection of Personal Information
8.1 Nature of Your Rights

In accordance with applicable law, you have the following rights with respect to your personal information:

•    the right to confirm the existence of, and to access, information about you held by the Firm;
•    the right to obtain a copy of your information in a written and intelligible format, or in a structured, commonly used technological format (portability);
•    the right to have any inaccurate, incomplete, or outdated information corrected or updated;
•    the right to request the deletion of information whose collection, disclosure, or retention is no longer justified by law or by the original purposes;
•    the right to request that the dissemination of information about you cease, or that a hyperlink concerning you be de-indexed, where such dissemination is unlawful or seriously harms your reputation or privacy; and
•    the right to file a complaint with the Commission d'accès à l'information (CAI) if you believe your rights have not been respected.

8.2 Processing of Requests

Any request relating to the exercise of your rights must be addressed to the Firm's person in charge of the protection of personal information:

Me Fayçal Boutenbat
Person in charge of the protection of personal information
131 rue Barnett, DDO,
Québec, H9G 1W7
confidentialite@anfaconseil.com

The Firm undertakes to process your request within the timeframes prescribed by law. Reasonable fees may be charged for the transcription, reproduction, or transmission of the requested information; where applicable, you will be informed of this before any processing takes place.

8.3 Grounds for Refusal

The Firm may refuse, in whole or in part, to act on a request in the following cases:

•    a serious and legitimate interest justifies the refusal;
•    the law authorizes or requires the retention of the information;
•    the information sought is likely to seriously harm a third party;
•    disclosure in a structured technological format would raise serious practical difficulties;
•    the identity of the requester or their capacity to act as a representative cannot be verified; or
•    disclosure could affect judicial proceedings in which you or the Firm have an interest.

In the event of refusal, the Firm will communicate the reasons in writing, along with the remedies available to challenge the decision.

9. Handling of Privacy Incidents

In the event of a privacy incident likely to compromise the security of your personal information, the Firm will implement the following response plan:

 

1.    Assessment of the nature and scope of the incident;
2.    If the incident is confirmed:
•    mobilization of the personnel responsible for managing the incident;
•    immediate implementation of measures to limit the breach of privacy and prevent recurrence;
•    assessment of the risk of harm to the individuals concerned;
3.    If the risk of harm is serious:
•    notice to the Commission d'accès à l'information (CAI);
•    notice to the individual concerned; and
•    notice to any other person or organization that may help reduce the risk.
4.    Recording of the incident in the Firm's privacy incident register;
5.    Review of internal procedures and policies as needed.

For any complaint concerning the protection of your personal information, you may contact the designated person in charge at the contact information indicated in Section 8.2 above.

10. Minors

The Firm's website is not intended for minors. The Firm does not knowingly collect personal information from individuals under eighteen (18) years of age. If you are the parent or guardian of a minor and believe that information about them has been provided to the Firm, please notify the designated person in charge referred to in Section 8.2.

 

11. Links to Third-Party Websites

This site may contain hyperlinks to websites operated by third parties. The Firm disclaims all responsibility for the privacy practices of such sites and invites you to review their own privacy policies before providing them with any personal information.

12. Changes to This Policy

The Firm reserves the right to amend this Policy at any time to reflect changes in the law, technology, or its internal practices. The version in effect is the one published on this site, identifiable by the update date shown at the top.

By continuing to use this site after a modification, you acknowledge that you have reviewed the revised version of the Policy.

13. Supervisory Authority

If you believe that the Firm's processing of your personal information does not comply with applicable legislation, you have the right to file a complaint with the Commission d'accès à l'information (CAI):

Commission d'accès à l'information du Québec
www.cai.gouv.qc.ca
Telephone: 1 888 528-7741

For any question relating to this Policy, please contact the Firm at the address indicated in Section 8.2.