Privacy and Personal Information Protection Policy

Éléphant Chocolat Placement de Gardiennes et Professionnels Inc. ("Éléphant Chocolat," "we," "us," or "our") places great importance on protecting the personal information entrusted to us.

We collect and use personal information in connection with our placement and recruitment services, support provided to families, management of applications, and relationships with our employees and partners.

We are committed to protecting this information and handling it in accordance with applicable privacy laws, including Quebec's Act respecting the protection of personal information in the private sector and, where applicable, the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Responsibility for the protection of personal information is assumed by:

The Privacy Officer oversees compliance with the requirements applicable to the collection, use, disclosure, retention and destruction of personal information held by Éléphant Chocolat.

Personal information is information about an individual that allows that individual to be identified, directly or indirectly.

Depending on the nature of our services and your relationship with Éléphant Chocolat, we may collect:

• your first and last name and contact information;
• your address and other contact details;
• information about your family and children;
• children's ages and dates of birth;
• information necessary for their health, safety, routines or specific needs;
• information relating to a request for services;
• professional, educational or work experience information;
• résumés, references and documents related to an application;
• information required for hiring and managing an employment relationship;
• information and documents required for administrative or immigration procedures when such services are involved;
• financial or banking information when required to provide our services or manage an employment relationship;
• information you provide through our forms, emails, telephone communications or other means of communication.

We limit the collection of personal information to what is necessary for the purposes identified before or at the time of collection.

We may collect, use and, where necessary, disclose personal information for purposes including:

• responding to a request for information or services;
• assessing a family's needs;
• determining eligibility for our services;
• presenting profiles suited to the needs of a family or childcare setting;
• assessing, selecting and supporting candidates;
• conducting reference checks or other checks required as part of the selection process;
• arranging meetings and interviews;
• managing employee records;
• assisting certain individuals with administrative and immigration procedures;
• protecting the health, safety and well-being of children entrusted to our professionals;
• monitoring and maintaining the quality of the services provided;
• communicating with clients, candidates, employees and partners;
• preparing and managing contracts, invoices, payments and administrative records;
• complying with our legal, regulatory, tax, contractual and administrative obligations;
• processing access, correction and other requests relating to personal information;
• preventing privacy incidents, fraud and unauthorized use;
• improving our services and the operation of our digital platforms.

We do not use personal information for a new purpose that is incompatible with the purpose communicated at the time of collection without obtaining the required consent, unless otherwise permitted by law.

Where required by law, Éléphant Chocolat obtains your consent before collecting, using or disclosing your personal information.

Requests for consent are presented clearly and for specific purposes.

Where sensitive personal information is involved, we apply the specific requirements established by applicable legislation.

You may withdraw your consent to certain uses or disclosures of your personal information, subject to applicable legal and contractual restrictions.

However, withdrawing consent may prevent Éléphant Chocolat from providing certain services where the information concerned is necessary to provide those services.

As part of our services to families, we may need to collect certain information about children, including their age, routines, needs, health or information required to ensure their safety and provide the requested services.

Such information is collected only when necessary to provide the relevant services and is subject to safeguards appropriate to its sensitive nature.

Where the consent of a parent or person having parental authority is required by law, we obtain that consent.

Éléphant Chocolat does not sell or rent the personal information entrusted to us.

We may, however, disclose certain information when necessary to provide our services, including to:

• technology or administrative service providers acting on our behalf;
• professionals or partners involved in providing a service;
• families, candidates or childcare settings when disclosure is necessary for a matching, recruitment or placement process;
• government, administrative or regulatory authorities when necessary or required by law;
• any other person or organization where you have consented to the disclosure or where disclosure is authorized or required by law.

In all cases, we seek to limit disclosure to the information necessary for the relevant purpose.

Éléphant Chocolat may use technology and administrative service providers for hosting and for managing our communications, forms, records and digital services.

Certain service providers may process or store personal information outside Quebec or Canada.

Where required by applicable law, Éléphant Chocolat assesses privacy-related factors before communicating personal information outside Quebec and implements appropriate contractual and protective measures.

When you use our website, certain technical information may be collected automatically, including your IP address, the type of device or browser you use, the pages you visit and certain information relating to your interactions with our website.

Our website may use cookies or similar technologies that are necessary for its operation, to measure its use or, where you consent, for analytics or advertising purposes.

Where the law requires your consent for the use of certain technologies, those technologies are used only after such consent has been obtained.

Éléphant Chocolat implements reasonable administrative, technical and physical safeguards to protect personal information against:

• unauthorized access;
• loss or theft;
• unauthorized use or disclosure;
• unauthorized alteration;
• unauthorized destruction.

Access to personal information is limited to individuals who require it in the performance of their duties or in connection with the services concerned.

Our employees and relevant collaborators are required to maintain the confidentiality of the information to which they have access.

Éléphant Chocolat maintains a process for managing privacy incidents.

If an incident involving personal information occurs, we take reasonable measures to reduce the risk of harm and to prevent similar incidents from occurring again.

Where required by law, we notify affected individuals and the appropriate authorities, including Quebec's Commission d'accès à l'information.

Éléphant Chocolat also maintains a register of privacy incidents in accordance with applicable requirements.

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal, tax, administrative or contractual obligations.

When retention is no longer necessary, the information is securely destroyed or, where permitted by law and where applicable requirements are met, anonymized.

Éléphant Chocolat maintains internal rules governing the retention and destruction of personal information.

We take reasonable measures to ensure that personal information used in connection with our services is accurate, complete and up to date where necessary.

We ask that you inform us of any relevant changes, particularly those concerning emergency contact information, a child's health or safety, or any information required to provide our services.

Depending on the applicable laws and subject to the exceptions provided by those laws, you may request:

• access to the personal information we hold about you;
• correction of inaccurate or incomplete personal information;
• information concerning the use and disclosure of your personal information;
• withdrawal of your consent where consent is required;
• in circumstances provided by law, the cessation of dissemination or de-indexing of certain information.

Requests may be submitted to our Privacy Officer using the contact information provided in this Policy.

We may request information to verify your identity before responding to a request.

We will process requests within the time limits prescribed by applicable legislation.

If Éléphant Chocolat uses personal information to make a decision based exclusively on automated processing, the individuals concerned will be informed in accordance with applicable legal requirements.

Éléphant Chocolat has implemented policies and practices governing the personal information it holds.

These address, among other matters:

• the roles and responsibilities of individuals who have access to personal information;
• the life cycle of personal information, from collection through destruction;
• security measures;
• retention and destruction of personal information;
• the handling of access and correction requests;
• the management of privacy incidents;
• the process for handling complaints relating to the protection of personal information.

Éléphant Chocolat may amend this Policy to reflect changes to our practices, services, technologies or legal requirements.

The date of the most recent update appears at the beginning of the Policy.

Where a material change is made, we will take appropriate steps to inform affected individuals in accordance with applicable requirements.

If you have questions about this Policy or our personal information protection practices, wish to exercise a right relating to your personal information, or wish to submit a complaint concerning the handling of your personal information, please contact: