Privacy Policy

1. Introduction

Code Sprit Libre ("we", "us", "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your data in compliance with Loi 25 (An Act to modernize legislative provisions as regards the protection of personal information, Québec) and PIPEDA (Personal Information Protection and Electronic Documents Act, Canada).

By using our website or services, you consent to the practices described in this policy.

2. Data Controller

The data controller responsible for your personal information is:

3. Personal Information We Collect

We collect only the information necessary to provide our services. Depending on how you interact with us, we may collect:

• Contact form: your name, email address, phone number (optional), preferred language, session format preference, and the message you send us.
• Mental Clarity Test: your name and email address (to send you your test results).

We do not collect sensitive personal information such as health data, financial data, or government-issued identifiers unless you voluntarily provide them in your messages.

4. Purposes of Collection

We use your personal information solely for the following purposes:

• Respond to your session booking requests and communicate with you about our services.
• Send you the results of the Mental Clarity Test.
• Follow-up communication related to your sessions (with your consent).
• Improve our services and website experience.

5. Legal Basis for Processing

6. Retention Period

We retain your personal information for a maximum of 3 years after our last contact with you, unless a longer retention period is required or permitted by law. After this period, your data is securely deleted or anonymized.

7. Cookies

Our website uses only essential cookies (PHP session cookies) required for the basic functioning of the site. We do not use:

• Tracking or analytics cookies
• Advertising or marketing cookies
• Third-party cookies

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the website.

8. Your Rights

Under Loi 25 and PIPEDA, you have the following rights regarding your personal information:

• Right of access: You may request a copy of the personal information we hold about you.
• Right of rectification: You may request correction of inaccurate or incomplete information.
• Right to deletion: You may request that we delete your personal information, subject to legal obligations.
• Right to portability: You may request your data in a structured, commonly used format.
• Right to withdraw consent: You may withdraw your consent to the processing of your data at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at codespritlibre@gmail.com. We will respond within 30 days.

9. Security Measures

We implement reasonable technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• HTTPS/SSL/TLS encryption for all site communications.
• Passwords stored with bcrypt encryption (irreversible).
• Restricted access to personal data limited to authorized personnel.
• Encrypted backups.
• Communication platforms with end-to-end encryption (WhatsApp, Signal) for online sessions.
• Periodic review of data protection practices.

10. Personal Data Breach

In the event of a personal data breach (unauthorized access, loss, theft, or accidental disclosure), we follow this procedure in accordance with Loi 25 and PIPEDA:

1. Risk Assessment: We determine whether the breach presents a real risk of serious harm to affected individuals.
2. Notification to the CAI: If there is a risk of serious harm, we notify the Commission d'accès à l'information du Québec within 72 hours of discovery.
3. Notification to Affected Individuals: We inform individuals whose data has been compromised as soon as possible, indicating:
   • Nature of the compromised data
   • Probable date of the breach
   • Measures we have taken to limit harm
   • Measures the individual can take to protect themselves
   • Contact information for further details
4. Record Keeping: We document all data breaches, even if notification is not required.
5. Review: We analyze the causes and strengthen security measures to prevent future breaches.

Contact for data emergencies: codespritlibre@gmail.com

11. Third-Party Transfers

We do not sell, rent, or share your personal information with third parties for commercial purposes. Your data may be transferred outside of Canada only in the following circumstances:

• Hosting: Our website is hosted by DreamHost, located in the United States. This involves a transfer of data outside Canada. DreamHost is contractually bound to protect your data in accordance with applicable privacy laws.
• Legal obligation: If required by law, court order, or governmental regulation.

12. Informed Consent Form

Before beginning a session, we ask that you review and sign our Informed Consent Form, which provides detailed information about our services, methodology, and your rights as a client.

13. Right to File a Complaint

If you believe that your privacy rights have been violated, you have the right to file a complaint with the following supervisory authorities:

• Commission d'accès à l'information du Québec (CAI)
  www.cai.gouv.qc.ca
• Office of the Privacy Commissioner of Canada (OPC)
  www.priv.gc.ca

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: