1. Controller identity
This policy is issued by 9153-3133 Quebec Inc., doing business as Horizon Nord, hereinafter "Horizon Nord" or "we".
Address: Quebec, Canada.
General email: [email protected].
Phone: (438) 230-NORD / (438) 230-6673.
2. Person responsible for personal information protection
Pursuant to Quebec Law 25 (An Act to modernize legislative provisions as regards the protection of personal information), Horizon Nord has designated a person responsible for the protection of personal information:
Eric McGee, President
Dedicated email: [email protected]
Response time for requests: 30 days.
3. Personal information we collect
We limit collection to information necessary for the purposes described in section 4.
When you complete our contact form
- Full name
- Email address
- Company or organization
- Phone number (optional)
- Subject of inquiry
- Message content
When you browse the site
- IP address, browser type, operating system, pages visited (navigation information collected by our host Cloudflare for technical and security purposes)
- No third-party tracking cookies are currently deployed on the site
When you subscribe to our newsletter
- Email address
- Subscription status (opened, unsubscribed)
4. Purposes of processing
We use your personal information to:
- Respond to your contact request and conduct the associated commercial follow-up
- Send you email communications about our services, only with your express consent
- Deliver our newsletter, if you are subscribed
- Measure site performance (anonymized statistics) and improve content
- Maintain site security and prevent fraud
- Comply with our legal obligations
5. Legal basis for processing
Depending on the type of information, processing relies on:
- Consent: for collection via the contact form and newsletter subscription
- Legitimate interest: for anonymized navigation statistics, site security, and service improvement
- Legal obligation: for the retention of certain tax and accounting data
6. Retention period
Personal information is retained only for the time necessary for the stated purposes:
- Contact form: 3 years after the last exchange with you, then anonymized
- Newsletter: as long as you remain subscribed, then 12 months after unsubscription, then deleted
- Tax and accounting data: 7 years, in accordance with Canadian tax requirements
- Navigation data: 90 days, then deleted
7. Subprocessors and information sharing
We never sell your personal information. We share it only with technical subprocessors necessary to deliver our services. Each subprocessor is bound by a contract requiring them to respect the confidentiality and security of your data.
- Cloudflare (hosting, CDN, security): operates from the United States and a global network
- monday.com (internal CRM, request tracking): operates from Israel and the European Union
- Beehiiv (newsletter): operates from the United States
- Microsoft 365 (email): operates from Canada and the United States
We disclose your information to no other third party, except: (a) with your written consent, (b) if required by law, or (c) in the context of a commercial transaction (merger, acquisition, asset sale), in which case the acquirer assumes the obligations of this policy.
8. Transfers outside Quebec
Some of our subprocessors operate outside Quebec, notably in the United States and Europe. In accordance with section 17 of the Act respecting the protection of personal information in the private sector (as amended by Law 25), we have conducted a privacy impact assessment and concluded that the protection afforded by these subprocessors is adequate. Adequacy is ensured by standard contractual clauses and by the public privacy policies of the relevant providers.
9. Your rights
Under Quebec Law 25, you have the following rights:
- Right of access: obtain a copy of the personal information we hold about you
- Right of rectification: have inaccurate or incomplete information corrected
- Right to withdraw consent: withdraw at any time a consent you have given
- Right to deletion (right to be forgotten): request deletion of your information, subject to our legal retention obligations
- Right to portability: receive your information in a structured, commonly used, machine-readable format
- Right to de-indexation: request that your information no longer be accessible through a search engine in certain circumstances
- Right to complain: file a complaint with the Quebec Commission d'accès à l'information (CAI) if you believe your rights have been violated
10. How to exercise your rights
To exercise any of these rights, write to [email protected] specifying the nature of your request. We will respond within 30 days.
If you are not satisfied with the handling of your request, you may contact the Commission d'accès à l'information du Québec:
Commission d'accès à l'information du Québec
525 René-Lévesque Boulevard East, Suite 2.36
Quebec (Quebec) G1R 5S9
Phone: 418 528-7741
Toll-free: 1 888 528-7741
Website: www.cai.gouv.qc.ca
11. Cookies and similar technologies
The horizonnord.com site currently uses a minimal number of cookies:
- Essential cookies: strictly necessary for the site to function. No consent is required for these cookies.
- Consent preference cookies: store your choice expressed in our consent banner, for a maximum duration of 12 months.
- No third-party analytics or advertising cookies are currently deployed. If we deploy tools such as Google Analytics or an advertising pixel in the future, their activation will be subject to your prior explicit consent, collected via our consent banner.
You can modify your preferences at any time by clicking "Cookie preferences" in the site footer.
12. Automated decisions
Horizon Nord makes no decision based solely on automated processing that produces legal effects concerning you or that significantly affects you.
13. Security of personal information
We protect your information through reasonable technical and organizational measures:
- TLS 1.2 or higher encryption for all transmissions
- Data access restricted to authorized Horizon Nord personnel
- Multi-factor authentication for administrative accounts
- Periodic security reviews with our subprocessors
14. Confidentiality incident procedure
In the event of a confidentiality incident (breach, loss, unauthorized access) presenting a serious risk of harm, Horizon Nord will take the following measures as soon as possible:
- Assess the nature, scope, and consequences of the incident
- Implement corrective measures to limit harm
- Notify the Commission d'accès à l'information du Québec (CAI)
- Notify affected individuals if the risk is serious
- Maintain an incident register in accordance with Law 25 requirements
15. Changes to this policy
We may update this policy as our practices or legal requirements evolve. Material changes will be signaled by a visible notification on the site and, if applicable, by email to affected individuals. The last-updated date appears at the top of this document.
16. Contact us
For any question relating to this policy or to your personal information:
Horizon Nord (9153-3133 Quebec Inc.)
General email: [email protected]
Privacy email: [email protected]
Phone: (438) 230-NORD
Address: Quebec, Canada