Privacy policy

**Le Capitole de Québec Inc.**

**Framework for Privacy Practices**
**Last Updated: October 30, 2024**
This Privacy Policy (the “Privacy Policy”) outlines the statement that “Le Capitole de Québec Inc.” (“CDQ”) has established to protect the personal information of users and customers (collectively, the “Users”) of its websites, applications, hotels, restaurants, and all other channels through which CDQ collects and uses your personal information.
All references to “websites” in this Privacy Policy refer to the following sites: https://lecapitole.com/ and https://ilteatro.ca/, as well as any other websites or mobile applications developed and provided from time to time by CDQ (individually the “Website” or collectively the “Websites”).
This Privacy Policy is intended to inform all Users of the nature of the personal information that may be collected and used by CDQ or third parties, as well as that which may be communicated to authorized third parties in certain specific cases, if applicable.
Browsing the Website, simply activating any of the hyperlinks, purchasing a product at the hotel, and/or downloading an application constitutes acceptance of this Privacy Policy and implies your understanding of its scope. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, THE USER CONSENTS TO CDQ COLLECTING, USING, PROCESSING, AND DISCLOSING THEIR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
CDQ reserves the right to revise the terms of this Privacy Policy at any time without notice. The use of a Website, and/or the purchase at the hotel following the posting of a modified version of the Privacy Policy will constitute acceptance of the changes made. You are therefore encouraged to review this Privacy Policy on a periodic basis.
The Privacy Policy, as well as its interpretation, execution, validity, and effects are subject to the applicable provincial and federal laws in the province of Quebec (Canada), as applicable.

1. **We collect certain personal information for limited purposes.**
The term “personal information” generally refers to all information that identifies an individual. The personal information that CDQ may collect, use, and disclose via its Website, via Calls, via hotel purchases, and more generally in the course of our business may include name, age, gender, postal address, phone number, email address, and records of your communications with us. We never collect sensitive personal information. For the purposes hereof, “sensitive personal information” refers to any information that, due to its nature—particularly medical, biometric, or otherwise intimate—or the context of its use or communication, raises a high degree of reasonable expectation regarding privacy.
For the purposes hereof, “Call(s)” means all your exchanges with us, including during phone calls, which may be recorded and listened to for quality control purposes. If you do not wish to be recorded, please inform us at the beginning of your communication, and alternative solutions will be offered to you.

2. **Before collecting your personal information, CDQ will take all necessary measures to obtain your consent.**
Generally, CDQ explicitly requests the User’s consent before collecting personal information about them. The User may withdraw this consent subject to legal restrictions and exemptions by giving reasonable written notice to the Personal Information Protection Officer (as defined below) for CDQ using the contact details provided below.

3. **We only collect personal information that is necessary and for lawful purposes.**
In general, the Website is not intended as a tool for collecting personal information but rather aims to communicate information regarding CDQ’s business and the Websites, to disseminate certain advertisements and contests, to promote the products advertised and offered for sale, and to facilitate the completion of transactions or online purchases. However, when CDQ collects personal information for these purposes, it is done through honest and lawful means.

4. **We collect your personal information in specific circumstances.**
From time to time, CDQ may request the User or the User may voluntarily provide personal information to CDQ, notably through the Websites. Personal information about a User may be collected in the following contexts:
– To enable the completion of a purchase of product(s) at the hotel or an online transaction;
– To allow the opening of a customer account;
– To enable the voluntary subscription of a User to an email list, catalog, or promotions;
– To allow the voluntary entry of a User into a contest;
– To enable the voluntary participation of a User in a survey aimed at understanding their habits, needs, or preferences;
– To facilitate communications on CDQ’s social media pages (such as Facebook, Instagram, TikTok, LinkedIn, and Pinterest);
– To respond to general inquiries.
Please note that we also collect certain non-personal analytical data regarding the use of our Websites, which are used for customer experience optimization and analysis. This information may, from time to time, be communicated to third parties, including in connection with the services provided by Google Analytics. For more information on this topic, please refer to “How Google Uses Data from Sites or Apps That Use Its Services” and “Google Analytics and Privacy.”

5. **Your personal information is generally collected for internal purposes, except in the following cases.**
Generally, CDQ uses the personal information collected about Users for internal purposes only. However, CDQ may communicate the personal information collected from the User to the following parties:
– To external service providers with whom CDQ has entered into a contractual agreement that provides comparable levels of personal information protection and who use this personal information, including: (i) in connection with and for the services CDQ provides to Users, such as payment tools from First Data Canada, (ii) in connection with advertising, promotions, or advertising contests of CDQ, or (iii) to meet administrative requirements such as printing and faxing, archiving, or document and email management. For example, the service provider(s) hosting the Websites and performing maintenance on the Websites may potentially access Users’ personal information as part of the specific execution of their services under confidentiality obligations;
– To CDQ’s service providers (e.g., social networks, search engines, or analytical services such as Google Analytics) who provide audience analysis tools or reports on individuals viewing advertisements or performing online searches based on preferences, interests, demographic parameters, or geographic areas, allowing CDQ to target similar audiences for advertising purposes;
– To third parties, as required by law.
CDQ may communicate your personal information to third parties in the above categories who operate outside Quebec. To this end, CDQ conducts an evaluation of privacy factors for each of these third parties and ensures that when your information is communicated outside Quebec, it is adequately protected, particularly concerning generally recognized personal information protection principles.
Additionally, when making a payment through the secure transaction system of the secure payment platform provider, which is a distinct and external database from the Website, the User will need to enter on-screen the card number, expiration date (if applicable), the name of the cardholder, and any other information necessary to complete a product purchase order. The User acknowledges and agrees that any information and all personal information associated with the payment for a service that may thus be entered into the secure transaction system of the secure payment platform provider will then be held by the secure payment platform provider and not by CDQ.

6. **It is essential for CDQ to protect your personal information and take all available measures to safeguard it.**
CDQ takes appropriate measures to protect, to the best of its abilities, the personal information of Users against unauthorized access, use, or reproduction. These protective measures may include the use of a secure transaction program and physical protection aimed at restricting access to CDQ’s offices and files that may contain personal information collected, used, and communicated through its Websites.
Without limiting the generality of the foregoing, CDQ’s Websites have certain mechanisms or features that enhance the protection of Users’ personal information, including:
– Online order forms are protected and accessible only from a secure area;
– All communications between the various components of the Websites are encrypted;
– The Websites are subject to redundancy measures that are also secured;
– Orders transmitted by a User are hosted on a secure server;
– Payments made through a Website are verified by the external secure payment server transaction environment of the secure payment platform provider;
– CDQ’s IT service provider is required to comply with ongoing security obligations that include continuous validation of security practices and processes, as well as ongoing monitoring of the software components of the Websites and their updates.

7. **You may also take certain security measures before communicating your personal information.**
When a User must transmit confidential information via a Website, they can ensure that they are in a secure environment when the security seal (closed padlock) appears in the upper window of the Internet browser. The User can click on the padlock for information about the security seal.
Additionally, after completing a transaction through a Website, or when the User must temporarily leave their computer unattended during a session, it is important to log out. To log out securely, the User should click “Cancel,” clear the browser’s cache, and then close the Internet browser.

8. **You may contact CDQ at any time to review, correct, or update your file.**
Any User who has provided personal information to CDQ has the right to consult, correct, extract, and update the personal information concerning them, request that the dissemination of such information cease if that dissemination causes them serious harm, or obtain information on data processing by submitting a written request to the Personal Information Protection Officer identified in this Privacy Policy. In the event a request is submitted to CDQ, it will be addressed promptly. Furthermore, CDQ will indicate to the User which personal information has been collected about them and will provide access to this information by sending a copy in a structured