Privacy Policy
Restaurants Pacini Inc. PUBLIC
Website Privacy Policy Version 1 (2024-02-21)
Privacy Policy and Protection of Personal Information
Effective date: 2024-10-29
Last updated: 2024-10-29
1. General information
a) Introduction
Purpose of this Policy. Protecting privacy is important to Restaurants Pacini Inc., its Franchisees and its related entities (hereinafter the “Company”, “We”, “Our”, “Us”). For this reason, We have implemented protective measures and sound management practices for Your Personal Information in accordance with the applicable laws in Québec and Canada.
Supplementary to the Terms and Conditions. This privacy policy (the “Policy”), which must be read together with Our Terms and Conditions, describes Our practices regarding the collection, use, processing, disclosure, communication, retention and destruction of Personal Information of individuals benefiting from Our Services, visitors to this Website and its users (hereinafter “You”, “Your”).
Consent. By using Our website https://pacini.com/ (hereinafter the “Website”) or any of Our Services, You agree that We may collect, use, disclosure, communicate, disclose and retain (hereinafter “Process” or “Processing”) Your Personal Information in accordance with the terms described herein. If You do not agree to comply with and be bound by this Policy, You are not authorized to visit, access or use Our Website or Our Services, nor to share Your Personal Information with Us.
Scope limits. This Policy does not apply to the Personal Information of the Company’s employees, representatives and consultants, or any other person affiliated with the Company, nor to any information that does not constitute Personal Information as defined by the applicable laws in Québec and Canada.
b) Person in charge of the protection of personal information
Contact information for the Person in charge of the protection of personal information. All comments, questions and complaints regarding the Policy and the Company’s privacy practices may be sent to Our Person in charge of the protection of personal information at the following contact details:
Phone : 450-444-4749 extension 257
Email : [email protected]
2. Definitions
Definitions of certain notions or expressions. The following notions and expressions, when they appear with an initial capital letter in the Policy, have the meaning assigned to them below, unless implicitly or explicitly stated otherwise in the text:
“Company”, “We”, “Our”, “Us”: Restaurants Pacini Inc., its Franchisees and its related entities such as Tok Tok;
“Service Provider”: any natural or legal person who Processes Personal Information on behalf of the Company. These are third-party companies or individuals employed by the Company to facilitate the Services, provide the Services on behalf of the Company, perform services related to the Services, or help the Company analyze the use of the Services.
“Cookie banner”: pop-up window requesting Your consent to certain collections of Your Personal Information on the Website.
“Franchisees and related entities”: such as the entities listed here: https://menus.pacini.com/en/
“Personal Information”: any information relating to a natural person that allows them to be identified, i.e., that reveals directly or indirectly something about the identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental capacities, character and behavior of the person concerned) or activities of that person, regardless of the medium or the form in which the information is accessible (written, graphic, audio, visual, computerized or otherwise).
“Person in charge of the protection of personal information”: the person responsible for applying this Policy and whose contact details are identified in section 1b) Person in charge of the protection of personal information of this Policy.
“Services”: Services refers to the Website applications, Our social media pages and all programs and services provided to You there, such as:
- Restaurant services;
- Enabling delivery services for Our Products.
“Website”: This website: https://pacini.com/;
“Cookie”: Cookies are text files installed on Your computer or mobile device. These cookies may contain information about Your search history, the web pages You visit and Your web browser.
“Process”, “Processing”: A concept encompassing any operation that may affect or concern Personal Information, including: collection, use, retention, destruction, communication or transmission.
“You”, “Your”: Individuals benefiting from Our Services, Website visitors and all users who use the Company’s Services.
3. Processing of Personal Information
3.1 Collection of Personal Information
3.1.1 Collection methods
Various methods. We collect Your Personal Information through Our Website or other technological means in various ways, namely:
- Automatically. When You connect to Our Website, the device You use to connect will communicate Personal Information to Us;
- Electronic forms. By completing and submitting one of Our electronic forms to Us;
- Emails provided. Through emails You send Us using one of the email addresses available on Our Website;
- Cookies. Through cookies, including those identified in Our Cookie Policy;
- Security cameras. Through security cameras installed on Our property; and
- Third parties. Through third parties who collect Your Personal Information for Us, identified in section 3.2 – Collection of Personal Information by a third party of this Policy.
Profiling, identification and location. Our Website has features that allow profiling of Your activities on Our Website, identification of You, and location of You. Profiling and identification are sometimes used by third parties identified in section 3.5 – Access, communication and transfer of Personal Information through cookies. The location feature is used to help You find the nearest restaurant. We disable these features by default. You can activate them via the Cookie banner or via the alert message that asks to access Your location.
3.1.2 Personal Information collected
Categories of information collected. In the course of Our activities, We may collect and Process different types of Personal Information, including the information listed below:
- Identification information and Your contact details, including Your first and last name, mailing address, email address, telephone number;
- Demographic information, such as Your age or place of residence.
- Technical or digital information, including connection data and other information about Your activities on the Website, such as Your IP address, the pages You viewed, the time and date of Your visits, Your number of connections, Your domain name, the referring site address (if You access the Website from another site), the type of
- hardware and software;
- Your consents to the use of certain cookies on Our Website and to the disclosure or use of Your Personal Information;
- Information necessary to provide Our Services, such as information about the Services We have provided or are providing to You;
- Information You choose to provide or transmit to Us, for example, when You complete an online form, respond to solicitations or surveys, or communicate with one of Our employees or representatives;
- Financial information, such as Your credit card number, if You wish to order online; and
- Location information, such as your location and the distance between You and our nearest restaurant. Collection of this information is only enabled if you accept it.
Limiting Processing to necessary and legitimate purposes. In each case, this Personal Information is Processed in accordance with the legitimate and necessary purposes listed in section 3.4 – Use of Personal Information below.
3.2 Collection of Personal Information by a third party
Third parties collecting Personal Information on Our behalf. We receive Your Personal Information from several third parties such as:
- Delivery platforms if You wish to order takeout or delivery from one of our restaurants;
- Payment platforms to allow You to pay electronically for Our Services;
- Event organization platforms such as Bell’s SHOPICO to offer Our Services to clients who request them through such a platform;
- Customer satisfaction platforms if you leave comments on our website or our social networks
These third parties may communicate to Us the following Personal Information:
- Your identification information and contact details;
- Information necessary to provide Our Services
- Your consents; and
- Your financial information.
Please also note that Restaurants Pacini Inc. share the Personal Information identified in section 3.12 – Personal Information collected with its Franchisees and related entities such as Tok Tok to fulfill the purposes identified in section 3.4 – Use of Personal Information. Similarly, the Franchisees and related entities of Restaurants Pacini Inc. communicate the same Personal Information to Restaurants Pacini Inc. for the accomplishment of the same purposes.
3.3 Refusing a collection
Refusing to consent. Unless the Law or Your contractual obligations provide otherwise, You may refuse or withdraw Your consent to certain specific uses or communications of Your Personal Information:
- by not entering Your Personal Information in Our electronic or paper forms when providing such information is indicated as optional;
- by selecting “refuse” in the Cookie banner; or
- by submitting a request to Our Person in charge of the protection of personal information at the contact details identified in section 1b) of this Policy.
Measures offered to refuse collection methods of Personal Information. You may also provide Your Personal Information to Us by means other than technological means such as Our Website. You may provide it to Us:
- By email;
- By phone; or
- In person.
3.4 Use of Personal Information
Purposes of Personal Information. We may use Your Personal Information for the purposes described below:
– operate, maintain, supervise, develop, improve and offer the features of Our Website;
– provide You with relevant information to become one of our franchisees;
– present and provide Our Services.
– assess a job application;
– perform Our contractual obligations toward You;
– manage billing and process payments;
– process and resolve complaints and dissatisfaction;
– develop, improve and offer new Services;
– send You messages or updates;
– for marketing and business development purposes;
– answer Your questions and provide assistance as needed;
– conduct research, analysis and statistics related to Our Company and Our Services;
– detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities; or
– for any other purpose required or permitted by applicable laws.
3.5 Access, communication and transfer of Personal Information
Possible access and communications. We may transfer, communicate or allow access to Your Personal Information to Our employees and Our Service Providers who need this information to help Us operate Our Website, deliver Our Services, conduct Our activities or serve You.
3.5.1 Access to Personal Information within the Company
Limiting access to Personal Information. Your Personal Information is accessible only to Our directors, employees or representatives for whom access to Your Personal Information is necessary to perform their duties. As such, Your information may be accessible to:
– Our Person in charge of the protection of personal information;
– Our IT (“Information Technology”) services;
– Our customer service;
– Our sales services;
– Our billing services;
– Our marketing services;
– Our human resources (in the case of a job application).
3.5.2 Disclosure of Personal Information
Protective measures when communicating to third parties. We disclose Your Personal Information to Our Service Providers only if they have previously committed in writing to ensure the confidentiality of Your Personal Information in accordance with applicable laws and Our Information Governance Program by implementing various protection and information governance measures. These measures are proportionate to the sensitivity of the Personal Information Processed or disclosed. Without limitation, Our Service Providers may use Your Personal Information only confidentially according to Our instructions and solely for the purposes for which it was provided. Furthermore, We provide Our Service Providers only with the Personal Information necessary to perform their mandate or contract and We require these Service Providers to destroy the Personal Information appropriately at the end of the contract or as soon as its use is no longer necessary.
Our service providers. While We try to avoid disclosing Your Personal Information to third parties, We may use Service Providers to perform various services on Our behalf, such as IT management and security, marketing, and analysis, hosting and data storage. We have outlined below certain cases where such sharing may occur:
– Restaurants Pacini Inc. mutually communicate the Personal Information identified in section 3.12 – Personal Information collected with its Franchisees and related entities to fulfill the purposes identified in section 3.4 – Use of Personal Information.
– We use the Google Analytics cookie to analyze Website audience, establish statistics and limit robot requests on Our Website. For more information, consult Google’s privacy policy as well as their advertising and measurement cookies table (English only);
This cookie communicates information to Google for the purposes identified in Our Cookie Policy;
– We use Google AdSense, which analyzes the audience of Our Services and the effectiveness of ads. For more information, consult Google’s privacy policy as well as their advertising and measurement cookies table (English only);
Please note that this cookie may identify You and profile Your web activities in order to provide advertising that matches Your interests (targeted advertising);
This cookie communicates information to Google for the purposes identified in Our Cookie Policy;
– We use DoubleClick to analyze the audience of Our Services, establish statistics and converse with clients and prospects. For more information, consult Google’s privacy policy as well as their advertising and measurement cookies table (English only);
Please note that this cookie may identify You and profile Your web activities in order to provide advertising that matches Your interests (targeted advertising);
This cookie communicates information to Google for the purposes identified in our Cookie Policy (“cookies”);
– We use Microsoft (Bing) Ads services to collect and store data to create usage profiles using pseudonyms. For more information, consult Microsoft’s privacy statement;
This cookie communicates information to Microsoft for the purposes identified in Our Cookie Policy;
– We use Meta (Facebook Pixel) services to help understand and deliver ads, establish statistics and converse with customers. It also enables real-time bidding by third-party advertisers. For more information, consult Meta’s privacy policy;
Please note that this cookie may identify You and profile Your web activities in order to provide advertising that matches Your interests (targeted advertising);
This cookie communicates information to Meta for the purposes identified in Our Cookie Policy;
– We use Microsoft services (Outlook and Microsoft Office suite) to store Our documents and emails. For more information, consult Microsoft’s privacy statement;
All categories of Personal Information identified in section 3.1 – Collection of Personal Information may be disclosed or stored through this service.
We use the services of [web host] to host Our Website;
All categories of Personal Information identified in section 3.1 – Collection of Personal Information may be disclosed or stored through this service.
– We use Metatracer on Our digital systems to facilitate the detection and management of Your Personal Information, in order to ensure Our compliance with privacy laws.
Metatracer collects, as Personal Information, only identification information.
3.5.3 Disclosure outside Québec
Disclosure of Personal Information outside Québec. We may disclose Your Personal Information outside Québec.
Protections when disclosing outside Québec. Before disclosing Your Personal Information to third parties outside Québec, We conduct a privacy impact assessment to evaluate risks that may affect the security of Your Personal Information. This assessment also helps identify appropriate security measures to reduce or eliminate these risks. The disclosure will then be subject to a written agreement binding such third parties to comply with these measures.
3.5.4 Compliance with legislation, response to legal requests, harm prevention and protection of Our rights
Specific disclosures of Your Personal Information. We may disclose Your Personal Information when We believe such disclosure is authorized, necessary or appropriate, including:
– to respond to requests from public and governmental authorities, including those outside Your country of residence;
– to protect Our operations;
– to comply with judicial proceedings;
– to protect Our rights, the privacy of Our employees, officers and directors, Our safety and property;
– to protect Your privacy and Your rights, or the privacy and rights of third parties;
– to enable Us to pursue available remedies or limit the damages We may sustain; and
– when this is consistent with or required under applicable laws, including laws outside Your country of residence.
3.5.5 Commercial transaction
Possibility of commercial transactions. We may share, transfer or communicate, in strict compliance with this Policy and the provisions of the Act respecting the protection of personal information in the private sector, CQLR c P-39.1 (the “Private Sector Act”) and the Act to modernize legislative provisions as regards the protection of personal information, SQ 2021, c 25 (the “Act 25”, assented to on September 22, 2021), Your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of the Organization or Our assets (for example, following a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or any other commercial transaction, including in the context of negotiating such transactions). In such a case, We will inform You before Your Personal Information is transferred and becomes subject to a different privacy policy.
3.6 Consent
Consents for the collection, use or disclosure of Personal Information. Unless otherwise provided by law, the Company obtains Your consent for Us to collect, use and disclose Your Personal Information. However, if You provide Us with Personal Information about other people, You must ensure that you have properly informed them that You are providing their information to Us and have obtained their consent to such disclosure.
Consent criteria. We will seek Your clear, free and informed consent for specific purposes before using or disclosing Your Personal Information for purposes other than those set out herein. We will also seek Your explicit consent each time sensitive Personal Information is involved in one of the Company’s Processing activities. We will request Your consent for each specific purpose in simple and clear terms, separately from any other information provided to You.
BY USING OUR WEBSITES, BY TRANSMITTING YOUR PERSONAL INFORMATION BY EMAIL OR USING AN ONLINE FORM, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
Refusal to use the Website. If You do not consent, please stop using the Websites. Except where otherwise provided by law, You may withdraw Your consent at any time by giving 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 provide You with certain Services.
3.7 Retention of Personal Information
Retention of Personal Information. Subject to applicable laws, We retain Your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, unless You consent to Your Personal Information being used or Processed for another purpose.
Additional information. To obtain more information about the periods during which Your Personal Information is retained, please contact Our Person in charge of the protection of personal information using the contact details provided in article 1b) – Person in charge of the protection of personal information of this Policy.
4. Your rights
List of rights. As a concerned person, You may exercise the rights set out below by contacting Our Person in charge of the protection of personal information in writing at the contact details provided in article 1b) – Person in charge of the protection of personal information of the Policy. Please note that We may ask You to verify Your identity before responding to any of these requests.
– You have the right to be informed of the Personal Information We hold about You, its use, disclosure, retention and destruction, subject to the exceptions provided by applicable law;
– You have the right to access Your Personal Information, request a copy of documents containing Your Personal Information, subject to the exceptions provided by applicable law, and obtain, where applicable, additional details on how We use, disclose, retain and destroy it by making a written request to Our Person in charge of privacy protection at the contact details identified in section 1b) – Person in charge of the protection of personal information of this Policy;
– You have the right to have the Personal Information We hold about You rectified, modified and updated if it is incomplete, ambiguous, outdated or inaccurate by making a written request to Our Person in charge of privacy protection at the contact details identified in section 1b) – Person in charge of the protection of personal information of this Policy;
– You have the right to withdraw or modify Your consent to the collection, use and disclosure of certain Personal Information collected (as identified in section 3.1 – Collection of Personal Information of this Policy) at any time, subject to applicable legal and contractual restrictions;
-You have the right to ask Us to stop disseminating Your Personal Information and to de-index any link attached to Your name that provides access to that information if such dissemination contravenes the law or a court order;
-You have the right to request that Your Personal Information be communicated to You or transferred to another organization in a structured, commonly used technological format;
– The right to be informed of a privacy incident involving Your Personal Information that could cause You serious harm. We keep a register listing all privacy incidents and assess the harm they may cause; and
– You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions provided by applicable law.
5. Questions and Complaints
Complaint process. You may address any complaints regarding Our practices and policies for protecting Your Personal Information by contacting Our Person in charge of the protection of personal information using the contact details identified in section 1b) – Person in charge of the protection of personal information.
Questions. You may also contact Our Person in charge of the protection of personal information for any questions relating to this privacy policy by using the contact details identified in section 1b) – Person in charge of the protection of personal information.
Need to identify You. To process Your request, You may be asked to provide appropriate identification documents or otherwise identify Yourself.
6. Cookies and other similar technologies
Use of cookies. Cookies are small text files that are stored on Your device or browser. They allow certain information to be collected during Your visit to the Website, including Your preferred language, the type and version of Your browser, the type of device You use and your device’s unique identifier. While some cookies are deleted after your browser session ends, other cookies are stored on your device or browser in order to recognize your browser on your next visit to the Website. We use cookies and other similar collection technologies such as Pixels (collectively “Cookies Files”) to help Us operate, protect and optimize the Website and the Services We offer.
Certain uses of cookies. While some Cookie Files We use are deleted after your browser session ends, other Cookie Files are stored on Your device or browser in order to allow Us to recognize your browser on your next visit to the Website. They help ensure the Website functions properly, improve users’ browsing experience, and provide data that helps Us better understand traffic and interactions that occur on Our Website, as well as detect certain types of fraud. Cookie Files do not cause any damage to Your device and cannot be used to extract Your Personal Information.
Browser configuration possible. You can configure Your browser to be informed of the placement of Cookie Files during Your visit to the Website, so that You can decide, in each case, whether to accept or refuse the use of some or all Cookie Files. Please note that disabling Cookie Files on Your browser may negatively affect Your browsing experience on the Website and prevent You from using some of its features.
Cookie policies. To learn more about how We use Cookie Files, You can consult Our “Cookie Policy”.
7. Security measures
Objectives of Our security measures. We have implemented physical, technological and organizational security measures intended to adequately protect the confidentiality and security of Your Personal Information against loss, theft or any access, breaches, disclosure, reproduction, communication, use or unauthorized modification. These measures include, in particular:
- Administrative measures. On an administrative level, adopting a series of measures, policies and procedures as part of implementing Our information governance program, which in particular:
– govern access, communication, retention, de-personalization, including destruction or anonymization of Personal Information;
– determine the roles and responsibilities of Our employees throughout the lifecycle of Personal Information and documents;
– establish intervention and response procedures in the event of a privacy incident;
– govern the process for requests and complaints related to the protection and Processing of Personal Information.
- Technical measures. On a technical level, using several means such as:
– using “Secure Socket Layer (SSL)” technology;
– limiting access privileges to Personal Information in accordance with section Error! Reference source not found. – Access to Personal Information within the Company;
– using backup systems;
– using network monitoring software;
– using a firewall system;
– using encryption and segregation of duties, access controls, and conducting internal audits.
Non-exhaustive list of measures. We have not listed all measures We implement, given the public nature of this Policy.
Impossible to guarantee a complete absence of risk. Despite the measures described above, We cannot guarantee the absolute security of Your Personal Information. If You have reason to believe that Your Personal Information is no longer protected, please contact Our Person in charge of the protection of personal information immediately using the contact details provided in article 1b) – b) Person in charge of the protection of personal information above.
8. Changes to this Privacy Policy
Right to modify this Policy. We reserve the right to modify this Policy at any time in accordance with applicable legislation. In the event of a change, We will publish the revised version of the Privacy Policy and update the “last updated” date in the footer. We will inform You reasonably before the effective date of the new version of Our Policy. If You do not approve the new Policy terms, We invite You to stop using Our Website and Our Services. If You continue to use Our Website or Our Services after the effective date of the new version of Our Policy, Your use of Our Website and Our Services will then be governed by that new version of the Policy.
9. Links to third-party websites
Third-party website responsibility. From time to time, We may include references or links on Our Website to websites, products or services provided by third parties (“Third-Party Services”). These Third-Party Services, which are not operated or controlled by the Company, are governed by privacy policies that are entirely separate and independent from ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services We offer.
10. Individuals under 14 years of age
Consent of minors under 14. We do not knowingly collect or use Personal Information from individuals under 14 years of age. If You are under 14, You must not provide Us with Your Personal Information without the consent of Your parents or guardian. If You are a parent or guardian and you learn that Your child has provided Us with Personal Information without consent, please contact Us using the contact details provided in section 1b) above to request that We delete the child’s Personal Information from Our systems.
11. Applicable laws
Laws of Québec and Canada. The laws of Canada and Québec, excluding its conflict of laws rules, will govern this agreement and Your use of the Website. Your use of the Website may also be subject to other local, provincial, national or international laws.