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Privacy Policy

Last updated on: December 14, 2018

General 

The protection of your personal information being paramount to us, we have designed a Policy aimed at defining the data we may collect about you and how it may be used, as well as describing the safety measures implemented in order to keep it privileged and confidential.

This Policy applies to the services readily available on our website (www.lespac.com), on our mobile applications, and on all portals optimized for mobile devices (hereinafter referred to as the “Sites”).

By accessing our Sites, you expressly consent to the collection, use, disclosure, and retention of the information you provide, subject to the terms and conditions set out in this Policy.

Purpose and objectives 

The main purpose of any collection of personal information is to provide users of our Sites with the most secure, profitable, and personalized browsing experience possible. The data we collect enables us, first, to tailor our services and features to your immediate needs, and, second, to personalize our web environment in order to make every visit as secure and user-friendly as can be. In that context, the information we keep on record is limited to what is considered absolutely necessary and indispensable.

From the outset, you may browse our Sites without having to disclose any personal information. However, the moment you sign up as a member of LesPAC, anonymity can no longer apply. So, in the end, the only way to prevent the recording of personal data is to refrain from accessing the services and features offered on our Sites.

Information you provide 

The user who signs up as a member of LesPAC must provide basic personal information such as their first name, family name, e-mail address, and postal code – all in order to complete a membership profile. Other information found on the application remain optional. Since only LesPAC can access your membership file, nobody else can disclose the information in contains, in accordance with this Policy. When you post an ad online, our systems require you to enter contact information which will be made available to other LesPAC members, as well as to the general public. If you make use of your actual name and first name in relation to an ad, such information will allow other users to properly identify you. If you wish to, you can post an ad under a pseudonym. In any event, you shall always remain accountable for any information you disclose while posting an ad or engaging into a discussion with another LesPAC member. Furthermore, always keep in mind that if the contact information you provided in relation to an ad is incorrect, or if an ad you posted is no longer active on the Site while other members are trying to contact you, we shall disclose, in terms of data, no more than what is expressly permitted under this Policy.

Should you wish to purchase any paid service by means of a credit card, you will be required to provide financial information. All credit payments are managed by Moneris, an independent firm recognized for its outstanding Internet services. As soon as you choose a credit payment method, you will find yourself redirected to Moneris’ website. The information you will then be asked to provide includes your first name, family name, civil and e-mail addresses, and credit card number. No purchase can be validated before such information has been disclosed. But not to worry: highly sensitive financial data such as credit card information are encrypted to begin with.

Again, the collection and processing of credit information are managed by Moneris, which means that LesPAC does not record or keep any credit card numbers on record or on its servers. Consequently, LesPAC cannot in any way or any quality be held accountable or liable for the interception of financial information. Please refer to Moneris’ own data protection policy, available for download on its website.

Other types of data may be kept on record, namely information you shared with us in discussion forums or chat rooms, that was exchanged in order to settle a dispute, or that was part of everyday correspondence sent through any one of our Sites.

Information we collect systematically 

Whenever you browse our Sites or use a service or feature, some technical information is automatically collected, regardless of the device you are using at the time (computer, tablet, smartphone, etc.) Such information may include your IP address, your geographic location, the make of your operating system, the search engine you are using, and additional anonymous data picked up by cookies, web trackers, and other similar engines. For the purpose of this Policy, the words “tracking tools” refer to any kind of technology designed to collect information systematically, as described above.

Information gathered by means of tracking tools may be used to (i) make services and features (including advertisement) as targeted as possible, (ii) remember who you are and what information you have already provided, whenever you return to a Site, (iii) identify you by recognizing the devices you use to log in, (iv) quantify the effectiveness of the services we offer and the potential reach of advertisement campaigns, (v) analyze Site usage statistics, including the amount of visitors, overall traffic, and demographic trends, (vi) diagnose and solve technological issues, and (vii) in general, update and improve the services we offer.

If your browser allows you to, you can disable tracking tools such as cookies. Peruse the configuration options of your browser to find out is such an option is available. However, understand that once cookies or other tracking devices are disabled, it may become more difficult to browse our Sites or to access specific features.

Whenever you download or use one of our mobile applications, or log on one of our mobile-optimized portals, information relating to your geographic location or to the mobile device you are using (including the device’s exclusive identifier) may be disclosed. Once again, such data may be used to tailor services and features (advertisement, search results, and other personalized content) to your immediate needs and surroundings. Most mobile devices come with a “Settings” menu where you can activate and deactivate location trackers.

Information third-party Vendors collect systematically  

LesPAC works in collaboration with third-party service providers, including Google, who also use tracking tools in order to systematically collect anonymous data about the parameters of your visits to our Sites or other websites. Once again, such information is used to target advertisements and content that may be of interest to you, and also to provide statistical insight through features such as Google Analytics.

In some instances, tracking tools used by third-party service providers may be disabled. For example, Google allows you to deactivate cookies designed to target ads by accessing the Opt-Out page of its main website. Google Analytics may also be deactivated, once you download the browser add-on available for that purpose. You may also decline the use of cookies by other third-party vendors by logging on to the Network Advertising Initiative consumer deactivation page.

Information found on social media 

LesPAC offers a feature which allows its members to log on to third-party social media websites, such as Facebook and Google Plus (hereinafter referred to as the “Social Media Sites”), using their LesPAC user name and password. Features allowing for the direct exchange of information with such Social Media Sites are also available.

In the course of your LesPAC membership, you may allow us to access specific personal information found on Social Media Sites. The content of such information may vary according to the Social Media Site at hand, and shall be restricted by the privacy settings you activate and the nature of the consent you release. It may include your full name, address and profile picture, the name and profile pictures of “friends”, and other identification parameters. By linking a third-party account such as Facebook or Google Plus to your LesPAC membership, and then authorizing LesPAC to access the personal information available on that account, you implicitly allow LesPAC to collect, use, and keep on record the information in question, in compliance with the provisions of this Policy.

If personal information about your “friends” or people you associate with through Social Media Sites is part of the data you allow us to access, such access may be restricted by the privacy settings and parameters your “friends” have activated on the Social Media Sites. If some “friends” or people you associate with through Social Media Sites do not wish to share their personal information, they must make sure to change their privacy settings and parameters accordingly, or to contact our customer service department directly.

Use of your personal information  

As mentioned before, we collect personal information from our members for the purpose of granting them access to the LesPAC Site and offering them the most secure, effective, and personalized navigation experience possible. In such a context, you must agree and accept that personal information will be used in order to:

  • secure your access to our Sites and features;
  • update, improve, personalize, and target content, services, and advertisement;
  • contact you whenever a problem is likely to affect the integrity of a Site or of your account, or for any other valid reason recognized by law;
  • keep you informed about our services and the services provided by our affiliates (members of the Mediagrif Interactive Technologies Inc. group, hereinafter referred to as the “Mediagrif Group”), offer you niche marketing products, and allow you to benefit from up-to-date features and promotional offers;
  • detect, prevent, and, if required, investigate attempts of fraud, security breaches, and other illegal activities, while enforcing compliance with our Terms and Conditions of Use;

Disclosure of your personal information  

For the purpose of this Policy, the words “personal information” refer to descriptive data associated to a single, specific individual, and that might be used to properly identify them. Common knowledge, information that has been “depersonalized” or aggregated, or which, by itself or combined with other information, does not allow for the identification of a single, specific user, would not, in our opinion, fall under this definition. However, any information you include to an ad you post on any of our Sites is, indeed, personal information that is subject to this Policy.

Please understand that we may have to disclose your personal information in order to meet certain legal requirements, to enforce compliance with our Terms and Conditions of Use, to respond to claims based on an ad or some other content being in breach of the law or the rights of a third party (including intellectual property rights), or to otherwise ensure our staff’s or members’ safety and security. In such a case, disclosure would be made in accordance with applicable laws and regulations.

For instance, we are entitled (without the legal requirement of a subpoena) to disclose your personal information (including first name, family name, postal code, e-mail address, telephone number (if on record), browsing history of our Sites, IP address, as well as any other information deemed relevant) in response to the formal request of a legal or judicial authority, issued in connection with alleged illegal activities, an ongoing criminal investigation, or any other procedure likely to expose LesPAC to civil or criminal liability.

Your personal information may also be shared with affiliates of the Mediagrif Group or contractual service providers, in view of proposing targeted content, pooling services, or reaching common decisions about products or features. The affiliated members of our group shall only use such data in order to inform you of ongoing marketing campaigns, and only as long as you have already benefited from the services in question. In any event, all personal information shall be used in strict compliance with the terms and conditions of this Policy.

In no case or circumstances, whatsoever, shall your personal information ever be sold, leased, or licensed to third parties, whether it be for marketing purposes or otherwise, without your express and explicit consent.

How to consult and modify your personal information  

Your password is the most useful and efficient tool at your disposal for protecting the privacy of your LesPAC account. As such, a password should be composed of a unique string of numbers, letters, and symbols. It goes without saying that it should never be disclosed to anyone. Should you ever share personal information (including your password) with another individual, you shall be held fully accountable and liable for any misconduct or adverse effect caused by the use of your account’s identification data. In fact, losing control of your password could mean losing control of your account as a whole (and of the other personal information it contains), since legally binding actions or measures could potentially be taken in your name or on your behalf. Should the integrity of your password ever be compromised in any way, you are invited to notify LesPAC of the situation immediately, and to create a new password.

You can consult, modify, and delete most of your personal information by logging on to the LesPAC website. As a general rule, we will not adjust any personal data manually, since confirming the identity of a member remotely proves extremely difficult. If your personal information ever changes or appears incorrect, you must update it yourself, as soon as possible. Please keep in mind that personal data that has already been made public might not be modifiable any longer.

Information that has been deleted at your request will be kept on our servers until it is no longer required in order to provide services, to prevent fraud, to facilitate troubleshooting, to collaborate to any ongoing investigation, or to comply with legal requirements. Therefore, you should not expect outdated personal information to be permanently removed from our databases the moment you request its deletion.

If you are unsure about the content of the personal information we keep on record, wish to obtain a confirmation on the matter, or intend to have outdated personal information deleted permanently, visit the LesPAC website and click on the “Contact Us” menu. It is crucial that you provide us with all the e-mail addresses you have used in connection to your account.

In any event, please remember that we may be required by law to keep certain types of personal information on our servers.

Safeguard and protection of your personal information  

From the outset, most computers located and operating within Canada retain and process personal information. Therefore, LesPAC implements technical and procedural features aimed at protecting your identification data against loss, theft, and unauthorized access or disclosure, namely information filtering, encoding and encryption. Several security devices remain hard at work to protect collected data from any unauthorized access on the part of internal and external users.

Despite all best efforts to preserve the privacy and integrity of personal information, third parties may, from time to time, intercept strings of data kept on our servers, or otherwise breach the security of our systems. Hence, LesPAC cannot be held accountable or liable for the loss, corruption, or unauthorized disclosure of information occurring in circumstances over which it cannot exercise any reasonable amount of control. That being said, we vow to notify you of such a situation in the shortest possible delays.

Amendment of the Policy 

The contents of this Policy may be updated or otherwise modified at any time, without prior notice. The amended version of the text would then be published on our Sites. Any amendment shall come into full force and effect the moment you indicate your acceptance of its terms on the Policy itself. Should you ever disagree with an amendment but continue to use our services and features after the amended Policy has been published on our Sites, your acceptance of the amended provisions shall be deemed presumed and implicit.


Consult the Political Ads Registry issued under section 319 of the Canada Elections Act for the 2019 Federal Election.

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