Privacy Policy

Within reach

The ten (10) principles listed below that make up the Policy must be read in conjunction with the accompanying observations and the conditions of use of the Site.

This Policy applies to Fradameck SENC., as well as its divisions, subsidiaries and affiliates that offer various retail and supply services in the food sector.

This Policy applies to the activities of Fradameck SENC in Canada, including activities on the Transactional Site and the Fradameck SENC loyalty program. With regard to Fradameck SENC's activities in other countries, please refer to the Fradameck SENC Policy in the respective site, please refer to the privacy policy provided on this site.

This Policy applies to Personal Information that Fradameck SENC, or its suppliers on behalf of Fradameck SENC, collects, uses or discloses about its Clients.

This Policy applies to the management of Personal Information in verbal, written or electronic form.

This Policy does not cover the Collection, Use or Disclosure of Personal Information which is available to the public and which Fradameck SENC has obtained without the use of particular means, such as:

• all Personal Information available to the public, such as a Customer's name, address and telephone number, when this information is listed in a directory or available through any type of directory service including on the Internet; Or
• any other Personal Information available to the public.

The application of this Policy is governed by the requirements of the Quebec law entitled Act respecting the protection of personal information in the private sector and its related regulations. This Policy also respects the ten (10) principles of the Model Code on the Protection of Personal Information provided for in the Canadian law entitled Personal Information Protection and Electronic Documents Act .

B. Definitions

“Customer” means a natural person who (i) buys or orders products or services from a store carrying one of Metro's banners or on the Transaction Site, (ii) corresponds with Metro, (iii) participates in an advertising contest organized by Metro, (iv) is a member of the Fradameck SENC loyalty program or any other loyalty program.

“Collection” means the action of collecting, acquiring or obtaining Personal Information in any way and by any means, including from Third Parties.

“Consent” means free agreement to the Collection, Use and/or Disclosure of Personal Information for the purposes determined by Fradameck SENC. Consent may be explicit or implicit and may be given directly by the Client or by an authorized agent . Express Consent may be given orally, by electronic means or in writing. However, it must always be unequivocal. Implied Consent means Consent that can reasonably be inferred from an act or omission on the part of a person.

“Disclosure” means the action of revealing Personal Information to a Third Party.

“Personal information” or “Personal information” means any information which concerns a natural person and allows them to be identified, including in particular their names, addresses, email addresses, date of birth, credit data, membership number of programs or applications. Fradameck SENC

“Personal information protection manager” means one or more people from Fradameck SENC responsible for ensuring compliance and application of this Policy.

“Third party” means a person other than a Client, Fradameck SENC or an agent of the latter.

“Use” means the processing, handling and management of Personal Information by Fradameck SENC

C. Principles

Principle 1 – Responsibility

Fradameck SENC is responsible for the Personal Information it holds and must designate the Personal Information Protection Manager who must ensure compliance with the principles set out in this Policy .

1.1 It is the responsibility of the Personal Information Protection Officer to ensure compliance and application of this Policy. Other employees of Fradameck SENC may also be designated to support the Personal Information Protection Officer or to take care of the daily activities of Collection, Use or Disclosure and processing of Personal Information.

1.2 Fradameck SENC will transmit, upon request, the name of the Personal Information Protection Manager whose contact details are set out below.

1.3 Fradameck SENC is responsible for the Personal Information in its possession or in its custody, which includes Personal Information entrusted to a Third Party for processing purposes.

1.4 Fradameck SENC has developed various directives and practices allowing the concrete application of this Policy, among others:

• the implementation of procedures intended to protect Personal Information and ensure compliance with this Policy;
• the implementation of procedures relating to the receipt and processing of requests for information or complaints;
• provide information and training to employees regarding the protection of Personal Information.

Principle 2 – Determining the Purposes of Collecting Personal Information

Fradameck SENC must determine the purposes for which Personal Information is collected before or during any Collection .

2.1 Fradameck SENC collects Personal Information for the following purposes:

• allow the registration and participation of Customers in programs, applications, websites, services, activities, advertising contests, surveys, online purchases and newsletters offered by Fradameck SENC or any other program offered by Fradameck SENC or one of its partners and, as for the Fradaameck.com site, the Fradameck SENC loyalty program, allow the delivery of rewards, special offers and targeted advantages, the organization of promotional activities and communication with winners as part of advertising competitions, the design, improvement and marketing of products, improvement of the in-store offering (including marketing studies and surveys, if applicable), to personalize your navigation on the Site according to your preferences and to offer personalized services, products, promotions and advertising, as well as verifying the identity of members of the NOEMAGROUP loyalty program or epicesnoema.com;
• establish and maintain commercial relationships with Clients and ensure the execution of services;
• understand Customer needs and preferences;
• recommend specific products and services to Customers that meet Customer needs;
• design, improve, market or provide products and services that meet Customer needs;
• operate your commercial business;
• meet applicable legislative requirements;
• handle complaints;
• communicate with Customers; and or
• ensure the safety of Customers, its employees and Third Parties.

2.2 Fradameck SENC undertakes to use its best efforts, in the context of any Collection, to inform any Client, by electronic, verbal or written means, of the purposes surrounding said Collection of Personal Information. Upon request, persons who collect Personal Information must explain the purposes surrounding the Collection or indicate to any Customer which service they can contact in order to obtain the desired information.

2.3 Subject to any legislative provision to this effect, Fradameck SENC will not use or disclose Personal Information already collected for a new purpose before having first defined and recorded this new purpose and obtained the Consent of the Client concerned. .

2.4 Telephone calls handled by Fradameck SENC may be recorded and listened to for quality control purposes. Closed circuit security cameras are used in Fradameck SENC stores and offices to ensure the safety of Customers, Fradameck SENC employees and third parties.

Principle 3 – Consent to Collection, Use or Disclosure of Personal Information

The Customer must be informed of and consent to any Collection, Use or Disclosure of Personal Information concerning him or her, unless the law does not require it. In certain circumstances provided for by law, it is possible to collect, use or disclose Personal Information without the Client being formally notified and without the Client having to give Consent. Fradameck SENC may avail itself at any time of all the exceptions provided for in applicable laws which exempt it from notifying or obtaining the Consent of the persons concerned by the Collection, Use or Disclosure .

3.1 For example, Fradameck SENC may decide to collect, use or disclose Personal Information about a Client without notifying them or without their Consent:

• if it clearly serves the interest of the Customer and it is impossible to obtain their Consent within an appropriate period, for example, when a Customer has forgotten his credit card or loyalty card in store;
• if requesting Customer Consent risks defeating the purpose of the Collection, for example, in the case of an investigation into an infraction of a federal or provincial law or in the context of a breach of a contractual obligation;
• in an emergency, when a person's life, health or safety is threatened;
• in order to disclose them to an advisor who represents the interests of Fradameck SENC, in order to collect a debt; Or
• to comply with a subpoena, warrant or other court order or when required by law.

3.2 Fradameck SENC will take reasonable steps to ensure that the Client by Collection is duly informed of the purposes for which the Personal Information will be used or disclosed at the time the Client gives Consent to said Collection. These purposes will be clearly stated so that the Client can understand them.

3.3 As a general rule, Fradameck SENC will obtain the Client's Consent when collecting and disclosing Personal Information about them. However, Fradameck SENC may obtain this Consent after the Collection of Personal Information, but must always obtain the Client's Consent before using or disclosing it for a new purpose.

3.4 It is understood within the framework of this Policy that the purchase of products or use of services, including the transactional Site, the NOEMAGROUP loyalty program, by a Customer constitutes implicit Consent to the Collection, to the 'Use and Disclosure of Relevant Personal Information, for the purposes determined by NOEMAGROUP.

3.5 A Client may withdraw their Consent at any time, subject to the restrictions provided for by law or in any contract, following a reasonable period of time. The Client may contact Fradameck SENC to obtain further information on the consequences of such withdrawal.

Principle 4 – Limitation on Collection of Personal Information

Fradameck SENC may only collect Personal Information necessary for the specified purposes. Fradameck SENC must act honestly and lawfully in the execution of any Collection .

Fradameck SENC may also collect Personal Information from other sources, including credit reference agencies, if necessary in the context of processing the Client's request.

Principle 5 – Limitation on Use, Disclosure and Retention of Personal Information

Fradameck SENC must not use or disclose Personal Information for purposes other than those for which it was collected, unless the Client consents or the law permits it. Fradameck SENC must retain Personal Information only for the period necessary to achieve the purposes for which it was collected .

5.1 Fradameck SENC may also disclose Personal Information to:

• a person who, in the opinion of Fradameck SENC acting reasonably, requests Personal Information as a representative or agent of the Client;
• a Third Party who collaborates with Fradameck SENC as agent, subcontractor, supplier or partner of Fradameck SENC in the execution of various tasks;
• one or more Third Parties, when the Customer consents to the Disclosure or when the Disclosure is required by law.

5.2 As a general rule, Personal Information is stored by Fradameck SENC in Canada. In certain cases, Personal Information collected by Fradameck SENC may be stored and processed in countries other than Canada for the purposes of providing services and may therefore be subject to the jurisdiction of these countries.

5.3 Only persons authorized by Fradameck SENC and whose functions require it have access to Personal Information.

5.4 Fradameck SENC retains Personal Information only for the period necessary or useful for the specified purposes or as required by law. In the case of a request for access to information under this Policy, Fradameck SENC will retain either the Personal Information or an explanation of the reasons for the decision taken for a sufficient period so that the Client can have access to this Personal Information or for these reasons.

5.5 Fradameck SENC will establish control measures, timelines and practices relating to the retention and destruction or depersonalization of Personal Information and records when they are no longer necessary for the specified purposes or which are no longer required in under the law.

Principle 6 – Accuracy of Personal Information

Personal Information must be as accurate, complete and up-to-date as possible .

6.1 Personal Information used by Fradameck SENC must be as accurate, complete and up-to-date as possible in order to reduce the possibility of incorrect Personal Information being used.

6.2 Fradameck SENC will update Personal Information only when necessary to meet the specified purposes or following notice to this effect from the Client.

6.3 The Client is responsible for updating their Personal Information by contacting Fradameck SENC as soon as possible after any change.

Principle 7 – Security Measures

Fradameck SENC will take reasonable measures to protect Personal Information and use security measures that correspond to its level of sensitivity .

7.1 Fradameck SENC will take reasonable measures to protect Personal Information against loss or theft, unauthorized consultation, Disclosure, copying, Use, modification or destruction.

7.2 Fradameck SENC will take reasonable measures to protect Personal Information disclosed to Third Parties under the terms of contractual agreements which will state the confidential nature of this information and the purposes for which it is intended.

7.3 All persons authorized by Fradameck SENC who have access to Personal Information must respect its confidential nature.

7.4 Fradameck SENC understands the importance of protecting Personal Information and uses internet security protocols to protect said Personal Information collected via the Internet. However, Customers should keep in mind that the Internet is not a secure means of communication. Consequently, Fradameck SENC makes no representation or guarantee as to the absolute security of the Personal Information provided to it via the Internet. Customers acknowledge that they provide this Personal Information to Fradameck SENC at their own risk.

Also, Fradameck SENC is in no way responsible for the Personal Information protection practices for other websites which are not owned or controlled by Fradameck SENC but which are accessible by links or hyperlinks from Fradameck sites SENC. Your use of such third party websites is subject to the terms and conditions of such websites.

Principle 8 – Transparency of policies and practices

Fradameck SENC must ensure that any person has easy access to precise information on the management of Personal Information by Fradameck SENC.

Fradameck SENC must facilitate the understanding of this Policy, in particular by making available, upon request, the following information:

• the name of the Personal Information Protection Officer whose contact details are set out below;
• the procedure to follow in order to have access to Personal Information; And
• a description of the type of Personal Information that Fradameck SENC maintains, including a general explanation of the Use for which it is intended.

Principle 9 – Access to Personal Information

Fradameck SENC must inform the Customer who requests it of the existence of Personal Information concerning him, the use made of it and the fact that it has been disclosed to Third Parties. Fradameck SENC must also allow him to consult them .

This Client may contest the accuracy and completeness of the Personal Information and make any request to have the appropriate corrections made .

9.1 On request, Fradameck SENC will allow the Client to consult the Personal Information included in their file. Personal Information must be provided or made accessible in an understandable manner, within a reasonable time frame and at a reasonable cost to the Client.

9.2 In certain circumstances, Fradameck SENC may refuse in whole or in part access to the Personal Information requested by a Client through this information and in particular if:

• this risks revealing Personal Information about a Third Party or is likely to endanger the life or safety of another person;
• the Disclosure of this Personal Information would have the effect of revealing confidential or strategic commercial information for Fradameck SENC;
• Personal Information is protected by professional secrecy;
• the Personal Information was obtained following a dispute resolution process; Or
• the Personal Information was obtained following an examination relating to a contractual default, a current or potential dispute or a violation of a law.

Upon request, Fradameck SENC will indicate the reasons motivating its refusal to provide access to Personal Information.

9.3 Upon request, Fradameck SENC will inform the Client of the Use and Disclosure of Personal Information and, when available, indicate the source of the information. With regard to the provision of a Personal Information Disclosure statement, Fradameck SENC will provide a list of organizations to which it may have disclosed Personal Information about the Client, where it is unable to provide a precise list .