About this translation
This is an English translation provided for convenience. The French version is the official text and prevails in the event of any discrepancy.
Cap d'Acier (capdacier.ca) is committed to protecting its users' personal information in accordance with the Act to modernize legislative provisions as regards the protection of personal information (hereafter « Law 25 »), in force in Quebec since September 22, 2023.
This policy explains what information we collect, why, how we use it and what rights you hold over it.
1. Privacy officer
In accordance with section 3.1 of the Act respecting the protection of personal information in the private sector (the « Private Sector Act »), the following person is designated as the person in charge of the protection of personal information at Cap d'Acier:
Name: Vincent Bernier
Title: Privacy officer
Organization: Cap d'Acier
Email: vbernier@capdacier.ca
Website: www.capdacier.ca
2. Personal information collected
We collect only the information necessary for the purposes described in section 3. It falls into three categories:
a) Newsletter sign-up
- Email address
Provided voluntarily through the newsletter subscription form.
b) Contact form
- Name (first and/or last)
- Email address
- Message content
Provided voluntarily when you send us a request or a question.
c) Browsing data (with consent)
- Anonymized IP address
- Browser type and operating system
- Pages viewed and time spent
- Traffic source (referrer)
Collected through Google Analytics only if you have accepted analytics cookies. This data is aggregated and does not identify you directly.
3. Purposes of processing
Your information is used solely for the following purposes:
| Information | Purpose |
|---|---|
| Email address (newsletter) | Sending the Cap d'Acier newsletter (news, podcast episodes, announcements). |
| Name + email (contact) | Handling and answering your contact or partnership request. |
| Browsing data | Statistical audience analysis to improve the site's content and experience (aggregated data only). |
| Google OAuth account | Secure authentication to the administration area reserved for authorized members. |
No personal information is used for commercial or advertising purposes beyond those described above, nor sold to third parties.
4. Legal basis for processing
Under Law 25, any processing of personal information must rest on a valid legal basis. For Cap d'Acier, that basis is the explicit consent of the person concerned:
- Newsletter: you actively check a box or submit the subscription form.
- Contact form: you fill in and submit the form voluntarily.
- Analytics cookies: you explicitly click « Accept all » or enable the « Analytics » category in our consent banner.
- Google sign-in:you start the connection through the « Sign in with Google » button.
You may withdraw your consent at any time (see section 8).
5. Disclosure to third parties
Cap d'Acier does not sell, rent or transfer your personal information for commercial purposes. Some information is however passed to technical processors strictly necessary to operate the site:
Supabase
Database hosting
Database holding newsletter subscribers' email addresses and contact form submissions.
Supabase Inc. — United States. Supabase privacy policy
Google LLC
Analytics + Auth
Google Analytics: anonymized audience measurement (only with your consent). Google OAuth: secure authentication for site administration.
Google LLC — United States. Google privacy policy
Anthropic
Artificial intelligence
Anthropic provides the artificial intelligence infrastructure that may be used for internal analysis or content generation. No information directly identifying you is sent to Anthropic without justified cause.
Anthropic PBC — United States. Anthropic privacy policy
Each processor is contractually bound to handle your information only on our instructions and to protect it adequately.
6. Transfers of information outside Quebec
In accordance with section 17 of the Act respecting the protection of personal information in the private sector, we inform you that some information is transferred outside Quebec, to servers located in the United States:
| Provider | Country | Safeguards |
|---|---|---|
| Supabase Inc. | United States | Standard contractual clauses (SCC); encryption in transit (TLS) and at rest. |
| Google LLC | United States | Standard contractual clauses (SCC); EU-US Data Privacy Framework certification. |
| Anthropic PBC | United States | Standard contractual clauses (SCC); documented security policies. |
Before any transfer, a privacy impact assessment is carried out in accordance with section 17 of the Private Sector Act, to confirm that the information receives adequate protection in the destination country.
7. Retention periods
We keep personal information only as long as necessary for the purposes for which it was collected, in line with the minimization principle of Law 25:
| Type of information | Retention period |
|---|---|
| Email address — newsletter subscribers | Until you unsubscribe or request deletion. |
| Contact forms (name + email + message) | 2 years from the date of submission, then automatic deletion. |
| Server logs and browsing data | 90 days, then automatic deletion. |
| Session data (authentication cookies) | Duration of the session; deleted at sign-out. |
| Consent preferences (cookie_consent cookie) | 1 year. |
8. Your rights
Under Law 25 and the Private Sector Act, you hold the following rights over your personal information:
Right of access
You may request a copy of the personal information we hold about you.
Right to rectification
You may request the correction of inaccurate or incomplete information.
Right to erasure (right to be forgotten)
You may request the destruction of personal information concerning you when it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
Right to portability
You may ask to receive your information in a structured, commonly used, machine-readable format, or ask for it to be transferred to another controller.
Withdrawal of consent
You may withdraw your consent at any time, free of charge and without justification. Withdrawal does not affect the lawfulness of processing carried out before it. For cookies, see our cookie policy.
To exercise any of these rights: send your request by email to vbernier@capdacier.ca, stating your name, your email and the nature of your request.
We undertake to respond within 30 days of receiving your request, as required by Law 25. If your request is complex or if there are many of them, that period may be extended by a further 30 days, with prior notice.
9. Confidentiality incidents
A confidentiality incident means any unauthorized access to, use or communication of personal information, or its loss.
Where an incident presents a risk of serious injury to the people concerned, Cap d'Acier will:
- Notify the Commission d'accès à l'information du Québec (CAI) with diligence.
- Inform the people concerned, with the information they need to take steps to protect themselves.
- Record the incident in the register of confidentiality incidents, in accordance with section 3.6 of the Private Sector Act.
To report an incident or ask a question about one, contact vbernier@capdacier.ca.
10. Automated decisions
Cap d'Acier makes no automated decision producing legal effects or significantly affecting individuals on the basis of their personal information. No behavioural profiling or fully automated decision within the meaning of Law 25 is carried out on this site.
11. Updates to this policy
Cap d'Acier reserves the right to amend this policy at any time to reflect legislative developments, new site practices or changes of provider.
The date of the last update appears at the top of this page. Where a substantial change affects your rights, a notice will be shown to you on your next visit to the site.
12. Contact us
For any question, complaint or request concerning the protection of your personal information:
You may also file a complaint with the Commission d'accès à l'information du Québec (CAI) if you believe your rights have not been respected: www.cai.gouv.qc.ca.