Privacy policy

Updated on November 14, 2023

9299-7139 QUÉBEC INC. (hereinafter “M2D”, “Us”, “We”, “Our”) operates the website in addition to certain services (collectively the “Services”).

This Privacy Policy (hereinafter the “Policy”) explains our policies for collecting, using and communicating Personal Information when you retain our services and the options that are available to you with regard to such Personal Information.

In order to provide high-quality services, we must have access to some of your Personal Information. We ensure that our employees treat this information with the utmost rigour and discretion, in accordance with the legal and regulatory requirements in effect. In choosing to retain our Services, you agree that your Personal Information will be collected and used in accordance with this Policy.

1. Definitions

1.1. Service

Service refers to the website operated by M2D in addition to the services available on this website or performed by Us.

1.2. Personal Information

For the purposes of this Policy, “Personal Information” refers to information relating to a natural person that allows the person to be identified or information which, when taken separately or combined with other Personal Information, allows for a person to be identified. As a general rule, Personal Information does not include your professional contact information, such as your name, title, address or work telephone number.

1.3. Usage data

Usage data is collected automatically and generated either by using the Services or from the Service infrastructure itself (e.g., the duration of a page visit).

1.4. Cookies

Cookies are small files with Personal Information that are stored on your device (computer or mobile device) when a website or online service is used. Cookies are used to ensure that the website is operating effectively and can provide information and help to personalize services.

1.5. Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Information is, or is to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Information.

1.6. Data subject or User

Data Subject is any living individual who is using our Services.

2. Types of Personal Information collected

2.1. Personal Information

When you use our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personal Information may include, but is not limited to:

  1. Email address;
  2. First name and last name;
  3. Phone number;
  4. Address, city, province, state and postal code;
  5. Cookies and personal usage data;
  6. Information on your skills.

2.2. Personal usage data

We may also collect information on how the Services are accessed and used (“Personal Usage Data”). This Personal Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

2.3. Refusal of collection and withdrawal of consent

It is your right, if you so desire, to refuse the collection, use and disclosure of your Personal Information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of Personal Information already collected by contacting our Privacy Officer. Please note, however, that if you choose not to provide us with your Personal Information, it may prevent you from accessing some of our Services since we need your Personal Information to be able to provide our Services to you. Note, however, that anonymized information, meaning information that does not allow you to be identified, will be kept.

2.4. Minors

We do not knowingly collect information from children or other persons under the age of 16. If you are a minor under the age of 16, please do not provide any Personal Information without the express consent of your parent or guardian. If we learn that we have collected Personal Information from minor children without verification of parental consent, we will take steps to delete this information.

3. Use of you Personal Information

3.1. M2D uses the Personal Information collected for various purposes :

  1. To provide and maintain our Service;
  2. To notify you about changes to our Service;
  3. To allow you to participate in interactive features of our Service when you choose to do so;
  4. To provide customer support;
  5. To perform analyses so that we can improve our Service;
  6. To monitor the usage of our Service;
  7. To detect, prevent and address technical issues;
  8. To provide you with news, special offers and general information about other services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

3.2. Using information for profiling or secondary purposes

M2D may also ask for your consent for the use of your Personal Information for secondary or profiling purposes, for example to carry out market research or to supply its databases. Your consent for secondary purposes or profiling can be withdrawn at any time without affecting the provision of our services to you.

3.3. If you reside in Canada,

the legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

3.4. M2D may process your Personal Information because :

  1. We need to perform a contract with you;
  2. You have given us permission to do so;
  3. The processing is in our legitimate interests and it is not overridden by your rights;
  4. To comply with the law.

4. Cookies and similar tracking technologies

4.1. Tracking cookies data

We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information.

Cookies are files with a small amount of personal data which may include an anonymous unique identifier. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

Examples of cookies we use :

  1. Session Cookies. We use Session Cookies to operate our Services;
  2. Preference Cookies. We use Preference Cookies to remember your preferences and various settings;
  3. Security Cookies. We use Security Cookies for security purposes.

4.2. Deactivation of Cookies

You can prevent the personalization features of our Services by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device. However, if you choose to decline cookies, some pages or sections of our Services may not display correctly, or some features may not be available.

5. Disclosure of your Personal Information

5.1. Legal requirements

M2D may disclose your Personal Information in the good faith belief that such action is necessary :

  1. To comply with a legal obligation;
  2. To protect and defend the rights or property of M2D;
  3. To prevent or investigate possible wrongdoing in connection with the Services;
  4. To protect the personal safety of Users of the Services or the public;
  5. In the event of a business transfer;
  6. To protect against legal liability.

5.2. Access to services and test features

You must use a tokenized link sent by M2D to access the services and/or certain M2D test features. In using this tokenized link, you agree for your Personal Information to be collected when you are using certain M2D test features.

5.3. Responsibility for confidentiality

It is your responsibility to ensure that this tokenized link remains confidential and to notify M2D immediately of any unauthorized use.

5.4. Right to refuse service

M2D reserves the right to refuse to provide service if you do not meet the terms of this Privacy Policy or any other condition that may apply at M2D’s reasonable discretion.

6. Retention of Personal Information

6.1. M2D will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy

We will retain and use your Personal Information to the extent necessary to comply with our legal or ethical obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

6.2. Internal analysis.

M2D will also keep personal usage data for internal analysis purposes. Personal usage data is generally kept for a shorter period of time, except when used to enhance security or improve the features of our Service, or if we are legally required to keep this Personal Information for a longer period of time.

7. Transfer of Personal Information

7.1. Communication of Personal Information with agents or service providers :

We sometimes may be required to provide your Personal Information to agents or service providers to assist us in making all of the features of our Services available (maintenance, analysis, legal requirements, fraud detection, marketing and development). Please note that these agents and service providers may be located in Canada or in other countries or jurisdictions, notably the United States. They will only have access to the Personal Information that is necessary to carry out these tasks on our behalf and will be required not to disclose or use your Personal Information for any other purpose. Please note that we have contractual agreements with these providers to ensure that your Personal Information remains secure. In accepting this Privacy Policy and providing this information, you agree for your Personal Information to be transferred.

7.2. Personal Information transmitted outside Québec :

In the event that M2D is required to communicate Personal Information outside Québec or to assign the task of collecting, using, communicating or keeping Personal Information on its behalf to a third party outside Québec, we will do so in compliance with our privacy impact assessment policy, which in particular will take the following factors into account :

  1. The sensitivity of the information;
  2. The purpose for which it is to be used;
  3. The protection measures, including those that are contractual, that would apply;
  4. The legal framework applicable in the State in which the information would be communicated, including the personal information protection principles applicable in that State.

In addition, M2D will anonymize this Personal Information as much as possible to ensure that you cannot be directly or indirectly identified.

8. Protection of your Personal Information

8.1. Transmission of Personal Information

The security of your Personal Information is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

8.2. Protection of Personal Information

Physical, technical and/or administrative protection and security measures have been put in place and are kept up to date in order to avoid :

  1. Any accidental destruction or destruction not in accordance with the laws;
  2. Any accidental loss;
  3. Any unauthorized disclosure;
  4. Any unauthorized modification;
  5. Any unauthorized access; and
  6. Any illegal processing.

8.3. To do this :

We make sure, among other things, to restrict access to our offices and computer equipment, to train our staff and to require our agents and suppliers of goods and services with access to Personal Information to sign confidentiality agreements and to put in place security measures deemed equivalent.

8.4. Incident involving your Personal Information

When an incident involving Personal Information is reported, it is included in our register of confidentiality incidents and we will quickly take action to reduce the risk of harm to you.

8.5. Commission d’accès à l’information

Additionally, in accordance with Section 3.5 of the Act respecting the protection of personal information in the private sector (the “Act”), we will notify the Commission d’accès à l’information if the incident presents a risk of serious injury. We will also notify any person whose Personal Information is concerned by the incident.

8.6. Contact

If you believe that your Personal Information has been compromised, we invite you to contact us using the contact details listed in the “Contact Us” section of this Policy.

9. Social media features

9.1. Our social media features :

Our services include social media features such as the share button on LinkedIn, Instagram, Facebook, Twitter or YouTube or interactive mini-programs that work on our Services. If you use these features, they collect your IP address as well as the page you are visiting on our Services and then create a cookie to allow these features to work properly. These functions may be hosted by a third party or directly on our Services. Your interaction with these features is governed by the privacy policy of M2D which proves the functionality and not by this policy.

9.2. Data collected for web analytics purposes :

Data that is collected for web analytics purposes (e.g., Google Analytics) may be sent and stored outside Canada, such as in the United States or other countries where the servers are located and may be subject to the governing legislation of those countries (e.g., USA Patriot Act).

10. Your rights regarding your Personal Information

10.1. You have a certain number of rights with regard to your Personal Information

Individuals have the following rights in certain circumstances and in accordance with legislation governing data protection:

  1. Access. You have the right to know if we hold Personal Information and, if so, to have access to this information. You can receive a copy of the Personal Information in our possession, as well as certain other information concerning you, subject to the governing legislation and, if applicable, payment of a monetary amount;
  2. Accuracy. We are required to take reasonable steps to ensure that the Personal Information in our possession is complete, accurate, up to date and not misleading;
  3. Rectification. You have the right to ask that any incomplete or inaccurate Personal Information in our possession be rectified.

10.2. You can withdraw your consent for us to communicate or use the Personal Information collected at any time.

10.3. Resource person

If you would like to know which Personal Information we are holding regarding you and would like this information to be deleted from our systems, please contact us :

Isabelle Théroux
Director, Finance and Administration
514 861-9344 (ext. 119)

11. Changes to this privacy policy

11.1. Right to modify this Policy

We reserve the right to update our Policy from time to time. We will notify you of any changes by issuing the new Policy on this page.

11.2. Notice of change

Before the changes to the Policy take effect, we will inform you by email and/or by posting a prominent notice on our Services indicating the “effective date” at the top of the Policy.

11.3. Referring to this Policy

We suggest that you refer to this Policy periodically to take note of any changes. Any changes made to this Policy take effect when published on this page.

12. How to contact us

12.1. If you have any questions or comments regarding this Privacy Protection Policy or regarding your Personal Information to exercise your rights, file a complaint or obtain information on our policies and practices, please contact our privacy officer by email at or by mail at :

9299-7139 QUÉBEC INC. - M2D Leadership
Attention: Isabelle Théroux
666 Sherbrooke Street West, Suite 1708
Montréal, Québec, Canada H3A 1E7