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Privacy Policy

1. Our commitment

Groupe Momentum - Stratégie Conseil ("Momentum", "we") takes the protection of personal information seriously. This policy explains what information we collect, why, how we protect it, and what rights you can exercise.

It applies to our website momentumstratgr.com, in both its French and English versions, and to information you provide to us in the course of our services.

We comply with Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, and with Canada's Personal Information Protection and Electronic Documents Act.

2. Privacy Officer

As required by law, one person is designated as responsible for the protection of personal information at Momentum:

Jean-François LeBlanc, Strategic Partner and Privacy Officer. Email: jfleblanc@momentumstratgr.com

All questions, access or correction requests, and complaints concerning your personal information should be directed to this person.

3. Information we collect

Information you provide. When you complete a form, book a consultation or write to us: your name, email address, phone number, company name, job title, and any information you choose to include in your message.

Information collected automatically. When you visit the site: IP address, browser and operating system type, display language, pages viewed, time spent, and referring site.

Information related to an engagement. In the course of a consulting engagement, we may receive business, financial or operational information about your organization. Such information is treated as confidential and governed by our service agreement.

We do not knowingly collect information from individuals under 14 years of age.

4. Purposes

We use your information only to respond to your inquiries and provide the services you request; schedule and conduct consultations; send you information about our services where you have consented; produce aggregated site usage statistics; maintain site security and prevent fraud; and meet our legal, regulatory and contractual obligations.

We do not sell, rent or trade your personal information.

5. Consent

Your consent is requested freely, on an informed basis, and separately for each purpose. When you submit a form, you consent to our using the information provided to respond to you. Separate consent is requested for promotional communications, and you may withdraw it at any time.

Withdrawing consent is not retroactive and may, depending on the circumstances, prevent us from continuing to provide a service.

6. Cookies and third-party services

Our site places no analytics or advertising cookies. We do not use Google Analytics, advertising pixels, or behavioural tracking tools. No cookie is set by our site itself during an ordinary visit.

Some site functions do rely on external services, which receive your IP address and may set their own cookies: Google reCAPTCHA, used on our forms to prevent automated submissions and governed by Google's privacy policy; hosted typefaces from Adobe Fonts and Google Fonts; and animation libraries delivered by content delivery network.

You may configure your browser to refuse or delete cookies. Refusing cookies associated with reCAPTCHA may prevent our forms from being submitted.

7. Disclosure to third parties

We disclose your personal information only to those who need access to perform their duties, and to the suppliers who assist us in operating the site and delivering our services: our website host and platform, our appointment scheduling tool, and our email platform. Each is bound by contractual confidentiality commitments.

We may also disclose information where required by law, including at the request of a competent authority or in response to a court order.

8. Information held or processed outside Quebec

Some of our suppliers host or process information outside Quebec, including in the United States.

Before entrusting personal information to a supplier located outside Quebec, we conduct a privacy impact assessment, as the law requires. That assessment considers the sensitivity of the information, the purpose of its use, the protective measures in place, and the legal regime of the jurisdiction concerned.

9. Retention

We retain your personal information for as long as necessary for the purposes for which it was collected, and thereafter for the period required by law. By way of indication: inquiries not followed by an engagement are kept for twenty-four months; client files are kept for seven years after the end of the engagement, in line with accounting and tax obligations.

At the end of these periods, information is securely destroyed or anonymized.

10. Security measures

We apply security measures proportionate to the sensitivity of the information we hold: encryption of communications with the site, multi-factor authentication on our cloud tools, access restricted on a least-privilege basis, logging of access, regular and tested backups, periodic security awareness training for our team, and a documented incident response procedure.

No measure provides absolute security. In the event of a confidentiality incident presenting a risk of serious injury, we will notify the individuals concerned and the Commission d'accès à l'information du Québec, and will maintain the incident register required by law.

11. Automated decisions and profiling

We do not use systems that make decisions about you based exclusively on automated processing of your personal information. Should this change, we would inform you at the time of the decision, and you could submit observations and request review of the decision by a person.

We do not use any identification, location or profiling technology without informing you beforehand and providing the means to deactivate it.

12. Your rights

At any time, and in most cases free of charge, you may: be informed of the information we hold about you; access it and obtain a copy; have corrected information that is inaccurate, incomplete or ambiguous; withdraw your consent; request that dissemination cease, or that a hyperlink giving access to information be de-indexed, where dissemination causes serious injury to your reputation or privacy; and obtain portability of the computerized information you provided to us.

Address your request to the officer designated in section 2. We will respond within thirty days of receipt. Proof of identity may be required before we act on a request.

13. Complaints and recourse

If our response does not satisfy you, you may file a complaint with the Commission d'accès à l'information du Québec, at www.cai.gouv.qc.ca.

14. Links to third-party sites

Our site contains links to sites we do not operate, including social networks. This policy does not apply to them. We encourage you to review their own policies before providing them with information.

15. Changes

We may amend this policy to reflect changes in our practices or in the legal framework. Where a significant change affects the use of information already collected, we will inform you and, where the law requires, seek your consent again.

16. Contact us

Groupe Momentum - Stratégie Conseil. Email: jfleblanc@momentumstratgr.com. Website: www.momentumstratgr.com

Effective September 18, 2026.