1. Identity of the Business and Applicable Law
This privacy policy is published by DR conseils (hereinafter "we," "us," or "our"). It governs the collection, use, disclosure, and retention of personal information through our website and related services.
We are subject to Quebec Law 25 — formally titled An Act to modernize legislative provisions as regards the protection of personal information (S.Q. 2021, c. 25) — as well as any other applicable privacy legislation. Quebec Law 25 grants you specific rights regarding your personal information and imposes obligations on us to handle that information responsibly and transparently.
This policy applies to all visitors and users of our website, regardless of where they are located.
2. Personal Information We Collect
We collect personal information only to the extent necessary for the purposes described in this policy. The categories below reflect what is actually collected through our website and its integrated services.
2.1 Identification and Contact Information
- Name and email address (when you subscribe to our newsletter or submit a contact form)
- Phone number (when voluntarily provided through a form)
2.2 Technical and Navigation Information
- IP address
- Device identifiers and browser type
- Pages visited, session duration, and navigation behavior
- Approximate geographic location (derived from IP address)
2.3 Advertising and Conversion Information
- Advertising identifiers
- Conversion events (e.g., form submissions, clicks on ads)
- Pages visited and navigation behavior in the context of ad campaigns
2.4 Consent Preferences
- Your cookie consent choices, recorded and stored by our consent management platform (Moelleux by Horizon-Cumulus)
- IP address associated with the consent record
2.5 Bot-Detection Information
- IP address and device identifiers collected by Google reCAPTCHA to verify that form submissions originate from a human user
3. Purposes of Processing
We process your personal information only for specific, explicit purposes. The legal basis for each purpose is identified below.
3.1 Website Analytics and Performance Measurement
We use Google Analytics 4 to measure audience size, understand how visitors navigate our site, and improve our content and user experience. This involves collecting device identifiers, IP addresses, pages visited, session duration, navigation behavior, and approximate location.
Legal basis: Your consent, obtained through our cookie consent banner before any analytics cookies are activated.
3.2 Advertising, Remarketing, and Conversion Tracking
We use Google Ads / Conversion to track the effectiveness of our advertising campaigns and to show relevant ads to users who have previously visited our site (remarketing). This involves collecting device identifiers, IP addresses, advertising identifiers, conversion data, and navigation behavior.
Legal basis: Your consent, obtained through our cookie consent banner before any marketing cookies are activated.
3.3 Newsletter Communications
If you subscribe to our newsletter, we use your name and email address to send you updates, news, and information relevant to our services. We use Microsoft 365 and Mandrill (Mailchimp transactional) to manage and deliver these communications. Both services operate from the United States — please see Section 5 for details on cross-border transfers.
Legal basis: Your consent, given at the time of subscription. You may withdraw this consent at any time by clicking the unsubscribe link in any email we send you.
3.4 Form Security and Bot Prevention
We use Google reCAPTCHA on our web forms to prevent automated abuse and unauthorized access. This service collects your IP address, device identifiers, and navigation behavior to assess whether a submission is made by a human.
Legal basis: Our legitimate interest in protecting the security and integrity of our website and your data.
3.5 Consent Management and Policy Hosting
We use Moelleux (by Horizon-Cumulus) to manage your cookie consent choices and to host this privacy policy. A cookie named moelleux_{site_key} is stored in your browser for up to 13 months to remember your preferences. Consent records and this policy are hosted in Quebec (OVH, Beauharnois). No data processed by Moelleux is transferred outside Canada.
Legal basis: Our legal obligation under Quebec Law 25 to document and honor your consent choices.
4. Third Parties and Service Providers
We share personal information only with the service providers listed below, strictly for the purposes described. Each provider acts as a processor on our behalf and is bound by contractual obligations to protect your personal information.
| Service Provider | Purpose | Category | Transfer Outside Quebec |
|---|---|---|---|
| Moelleux (by Horizon-Cumulus) | Consent management and privacy policy hosting | Essential | No — hosted in Quebec (OVH Beauharnois) |
| Google Analytics 4 | Audience measurement and site performance analysis | Analytics | Yes — United States |
| Google Ads / Conversion | Advertising conversion tracking and remarketing | Marketing | Yes — United States |
| Google reCAPTCHA | Bot detection and form security | Functional | Yes — United States |
| Microsoft 365 | Email communications infrastructure | Functional | Yes — United States |
| Mandrill (Mailchimp transactional) | Transactional and newsletter email delivery | Functional | Yes — United States |
We do not sell your personal information to any third party, and we do not share it for purposes other than those described in this policy.
5. Transfers Outside Quebec
Several of our service providers are located in or operate from the United States. Under section 17 of Quebec Law 25, we are required to inform you of any transfer of personal information outside Quebec and to take steps to ensure that your information receives adequate protection in the destination jurisdiction.
5.1 Services Transferring Data to the United States
- Google Analytics 4 — Your navigation data, device identifiers, and approximate location are processed by Google LLC in the United States.
- Google Ads / Conversion — Your advertising identifiers, conversion data, and navigation behavior are processed by Google LLC in the United States.
- Google reCAPTCHA — Your IP address and device identifiers are processed by Google LLC in the United States.
- Microsoft 365 — Email communications infrastructure is operated by Microsoft Corporation in the United States.
- Mandrill (Mailchimp transactional) — Transactional and newsletter email delivery is operated by The Rocket Science Group LLC (Intuit) in the United States.
5.2 Contractual Safeguards
Before transferring personal information outside Quebec, we conduct or rely upon a Privacy Impact Assessment (PIA) as required by Quebec Law 25, and we ensure that appropriate contractual safeguards are in place — including data processing agreements and, where applicable, standard contractual clauses — to provide a level of protection equivalent to that afforded under Quebec law.
5.3 Data Hosted in Quebec
Your cookie consent records and this privacy policy are hosted exclusively in Quebec through Moelleux (Horizon-Cumulus), using OVH infrastructure located in Beauharnois, Quebec. No consent data processed by Moelleux is transferred outside Canada.
6. Retention Periods
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. The table below summarizes our retention practices.
| Data Type | Retention Period | Justification |
|---|---|---|
| Newsletter subscription data (name, email) | Until you unsubscribe, then deleted within 30 days | Necessary to deliver the service you requested; deleted promptly upon withdrawal of consent |
| Contact form submissions | Up to 2 years from the date of submission | Reasonable period to follow up on inquiries and maintain a record of communications |
| Analytics data (Google Analytics 4) | Up to 14 months (Google's default retention setting) | Sufficient to identify seasonal trends and measure site performance over time |
| Advertising and conversion data (Google Ads) | Up to 90 days for conversion windows; longer aggregated data per Google's terms | Required to attribute conversions to advertising campaigns and optimize spend |
| Cookie consent records (Moelleux) | 13 months from the date of consent | Required by Quebec Law 25 to demonstrate that valid consent was obtained; aligns with the cookie's own lifespan |
| reCAPTCHA bot-detection data | Per Google's data retention policies (typically a few weeks for risk scoring) | Necessary only for the duration of the security assessment |
| Email delivery logs (Microsoft 365 / Mandrill) | Up to 30 days for delivery logs; longer for bounce and suppression lists | Required for troubleshooting delivery issues and honoring unsubscribe requests |
Once the applicable retention period expires, personal information is securely deleted or anonymized so that it can no longer be linked to an identifiable individual.
7. Your Rights
Quebec Law 25 grants you the following rights with respect to your personal information. To exercise any of these rights, please contact our Person responsible for the protection of personal information using the details in Section 8. We will respond within 30 days of receiving your request.
7.1 Right of Access
You have the right to ask us whether we hold personal information about you, to obtain a copy of that information, and to receive details about how it has been used and with whom it has been shared.
7.2 Right of Rectification
If any personal information we hold about you is inaccurate, incomplete, or ambiguous, you have the right to ask us to correct it. If we have already shared the incorrect information with a third party, we will notify that party of the correction where feasible.
7.3 Right to Erasure (Right to be Forgotten)
You have the right to ask us to delete personal information that was collected without a valid legal basis, that is no longer necessary for the purposes for which it was collected, or where you have withdrawn your consent and no other legal basis applies. Certain information may need to be retained to comply with a legal obligation.
7.4 Right to Data Portability
Where technically feasible, you have the right to receive personal information that you provided to us in a structured, commonly used, and machine-readable format, and to have it transmitted to another organization of your choosing.
7.5 Right to Withdraw Consent
Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time — for example, by updating your cookie preferences through our consent banner, or by clicking the unsubscribe link in any newsletter we send you. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
7.6 Right to File a Complaint
If you believe that we have not handled your personal information in accordance with Quebec Law 25, you have the right to file a complaint with the Quebec Information Access Commission (CAI) at www.cai.gouv.qc.ca. We encourage you to contact us first so we can try to resolve your concern directly.
8. Person Responsible for the Protection of Personal Information
In accordance with section 3.1 of Quebec Law 25, DR conseils has designated a Person responsible for the protection of personal information who oversees compliance with this policy and applicable privacy legislation.
You may contact this person for any question, concern, or request related to your personal information. We are committed to responding within 30 days of receiving your request, as required by Quebec Law 25.
- Name: --
- Title: Responsable de la protection des renseignements personnels
- Email: [email protected]
- Phone: 1 833 853-8683
All requests will be handled confidentially and in accordance with the procedures established under Quebec Law 25.
9. Effective Date and Version History
This privacy policy takes effect on 10 juin 2026 and supersedes any previous version.
Version: 1
We may update this policy from time to time to reflect changes in our practices, the services we use, or applicable law. When we make a material change, we will update the effective date above and, where appropriate, notify you through our website or by email. We encourage you to review this policy periodically.
This policy was generated and is hosted by Moelleux (by Horizon-Cumulus), a Quebec-based consent management platform. Consent records associated with this policy are stored in Quebec (OVH, Beauharnois).
