Privacy Policy
Lower Canada College (“LCC”, “we”, “our” or “us”) is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable laws. This Privacy Policy is a statement of principles and guidelines concerning the protection of the personal information of our students, their parents, our donors, and other individuals that interact with LCC ("you”). This Privacy Policy applies to any personal information that we collect, use, and disclose (collectively “process”) about you, including through LCC.ca, LCCstore.ca, lcc.schooladmin.ca/portal, lccschool.crowdchange.ca, axiom.veracross.com/lcc, lowercanadaconnect.ca (our “websites”), and through telephone, written, and in-person interactions with you.
1. Consent
By submitting personal information to LCC or its service providers and agents, you agree that we may collect, use and disclose such personal information in accordance with this Privacy Policy and as permitted or required by law. Where consent for the use and disclosure of personal information is provided for purposes other than those stated at the time of collection, LCC will seek consent from the appropriate person.
In the case of a student’s personal information, the school will seek the consent from the student and/ or parent depending on the circumstances and the student’s mental ability and maturity to understand the consequences of the proposed collection, use or disclosure. If you provide LCC or our service providers and agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.
If you consented to the publication of photos, schoolwork or personally identifiable information, any document you may submit through e-mail, or on-line form or application will be subject to such consent.
2. What Personal Information do We Process?
Personal information means any information which relates to a natural person and allows that person to be identified directly, or indirectly in combination with other information (hereinafter, “Personal Information”). It does not include information from which all references to the identity of the relevant individual have been removed (i.e., anonymous information).
Without limitation, any of the following categories of information may be collected by us:
- Academic information: includes information about a student’s application and student file, course of study, evaluations, academic and related extracurricular or co-curricular achievements;
- Contact information: includes email, address, postal code and telephone numbers;
- Donor information: includes the history of past donations made to LCC (e.g., amount and date of last donation);
- Financial information: includes credit/debit card or bank account information and information about creditworthiness, as well as financial aid information as applicable;
- Health information: includes medical history, immunization records, allergies, disabilities, and any necessary accommodations;
- Identity information: includes name, date of birth, gender, copies of IDs and other legal documents, Social Insurance Number, username and password;
- Internet activity information: includes session information, such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
- Purchase information: includes information about products/services you have purchased on the LCC Store, including the date of your purchase and the price paid and information about products/services that you prefer or that interest you; and
- Technical information: includes internet protocol (IP) address and geolocation information, web browser type and version, operating system and/or device, cookies and other technology on the devices you use to access our websites.
3. How do We Collect Your Personal Information?
We use different methods to collect Personal Information from and about you including through:
- Direct interactions. You may give us Personal Information by corresponding with us or by using our services, including without limitation our websites’ features and services. This includes Personal Information you provide when you:
- Sign-up for a user account on our websites and update such user account;
- Contact us through mail, email, social media, or our websites;
- Input or upload any Personal Information through one of our websites; and
- Subscribe to our newsletter, respond to a survey, fill out a form, participate in a sweepstakes, or otherwise input or upload information or files through our websites, by telephone, or in person.
- Automated technologies or interactions. As you interact with our websites, we will automatically collect technical information and internet activity information about your equipment and browsing actions and patterns. We collect this information by using cookies, pixels, server logs and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies.
4. Why do We Process Your Personal Information?
In general, LCC processes Personal Information in order to provide you with services related to your purchase of products, and about applicants for positions with LCC for the purpose of evaluating the application and deciding whether to establish (and subsequently to manage or terminate) an employment, contractual relationship or partnership. More specifically, we process your Personal Information for the following purposes:
| Purpose | Category of Personal Information |
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To process applications, open and maintain a student file, process the payment of tuition and other fees, maintain a record of a student’s attendance, evaluations, academic and curricular or extracurricular achievements, to process or facilitate scholarships, grants and awards. |
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To provide information to other academic institutions, for example colleges and universities. |
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To communicate with students and parents about matters related to the student’s attendance, evaluation, course of study and LCC activities and events. |
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To maintain contact with and notify all stakeholders of activities, events, services and other matters relating to LCC. |
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To conduct fundraising initiatives, for billing, and the processing of fees and donations. |
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To communicate with designated contacts and to manage emergencies. |
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To protect students, staff and the public and to detect and deter criminal activity and vandalism (video surveillance). |
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To distribute School promotional material. |
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To manage the LCC Store (e.g., process payments, provide the requested goods and services, send purchase and billing confirmations, provide customer support, and to plan and develop the activities of LCC and the LCC Store by performing analytics and other forms of research on the information collected in relation to the LCC Store). |
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In connection with a sale or other transaction or reorganization of LCC’s operations. |
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As permitted by, and to comply with, any legal or regulatory requirements or provisions, and for any other purpose to which you consent. |
Any other Personal Information, as permitted or required by applicable laws. |
5. To Whom do We Disclose Your Personal Information?
From time to time, LCC may disclose your Personal Information to:
- service providers, including an organization or individual retained by LCC to perform functions on its behalf, such as marketing, data processing, accounting, document management and other administrative services;
- a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;
- a person who, in the reasonable judgment of LCC, is providing or seeking the information as your agent;
- to our insurers and to regulatory agencies such as insurers or others in connection with regulatory or other activities relating to the obligations of LCC;
- to personnel within LCC, government authorities, insurers, consultants or agents as reasonably required to establish, manage or terminate employment, contractual relationships and partnerships;
- to an acquiring entity in connection with the consummation or proposal of a business transaction (including liquidation, realization, seizure or repossession), concession, merger, business combination or any other type of acquisition, liquidation, transfer, translative contract or financing of LCC, in whole or in part, or of any property, or asset of LCC; and
- any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.
By providing us with Personal Information, you acknowledge and agree that such Personal Information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada and in the United States, where laws regarding the protection of Personal Information may be less stringent than the laws in your jurisdiction. Further, such Personal Information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the Personal Information.
6. Your Rights
Subject to certain exemptions, to the extent permitted by applicable law, you have the following rights in relation to the Personal Information we hold about you:
- Your right of access. At your written request we will inform you whether we hold Personal Information relating to you and if we do, you have the right to receive a general account of our processing of such Personal Information. If your request is made in writing, subject to applicable laws and the provisions of this Privacy Policy, we will also provide you with access to your Personal Information that is in our possession. A reasonable fee may be levied if you request the transcription, reproduction or transmission of such information and you will have to provide information or documentation to verify your identity. We will inform you of the approximate cost before proceeding to respond to your request. Your rights to access your Personal Information are not absolute. Access can be denied for several different reasons under applicable legislation. If we deny your request for access to your Personal Information, we shall explain why.
- Your right to rectification. If we hold Personal Information about you and you believe that it is not accurate, complete and up-to-date, you can request to have it rectified (or rectify it yourself via your account information page). If we discover that information is not accurate, complete and up-to-date, we will take reasonable steps to rectify it. We will also send any information that has been amended, where appropriate, to any third parties that have access to the information. If we refuse a request to rectify information, we shall explain why and we will make a note of this in your file (and forward such note to anyone else who received the earlier information).
- Your right to withdraw consent. If we rely on your implicit or explicit consent as our legal basis for processing your Personal Information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you wish to withdraw your consent to certain of the purposes identified in this Privacy Policy or a dedicated consent form at any time by contacting LCC’s Privacy Officer at communications@lcc.ca. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
7. How do We Protect Your Personal Information?
We will use reasonable security measures to protect personal information against unauthorized access that are compliant with applicable data protections laws. LCC has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard personal information.
8. How Long Will We Retain Your Personal Information?
The Personal Information that we collect, access or process will be retained only as long as necessary for the fulfillment of the purposes for which it was collected and/or for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous. LCC will ensure destruction of personal information in a method that prevents improper access.
9. Our Websites
- Cookies - Like other websites, our websites use a standard technology better known as cookies (i.e., a small text file that allows our site to remember your preferences). We also use web server logs to collect information on the use of our site. When a visitor visits one of our websites, our server collects certain information, including the IP address, browser and operating system used by the device of the visitor. This anonymized information can be consolidated and shared with research firms. Cookies and the shared data will not disclose your identity or your personal information, and do not allow recipients to contact you. It is possible to enable or disable the cookies by changing your browser settings.
Like most standard website servers we use statistic service packages such as Google Analytics to analyze trends in how our websites are accessed and utilized. Information monitored includes internet protocol (IP) addresses, geographic location of visitors (country, city), browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, time spent on pages, and keywords used to find our site via search engines. This information is anonymous and cannot be directly linked to individual users.
- Analytics - Our websites use Google Analytics and Clicky Web Analytics to help us understand how visitors engage with our websites. Your web browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. Google may also set cookies on your browser, or read cookies that are already there. If you would like further information on how Google uses data when you use our websites you may visit, www.google.com/policies/privacy/partners.
- Links - Our websites may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than LCC, and LCC has no responsibility for such third party websites.
- Non-secured communications - Posts to discussion forums, discussion boards, comments to blogs, and Alumni Classifieds are viewable by other users. Those areas may be viewable by the general public. Please be aware of this when posting personal information in these areas.
10. E-mail Communications
Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about upcoming and past LCC events and activities. In this process, we may collect certain information such as the date/time you first opened our e-mail communications, the number of times you open our e-mail communications, the number of click-throughs per article, total click-through activity on the contents of our e-mail communications and compile generally the related statistics. We may combine and store any such information to manage and improve our e-mail communications to you. We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from LCC.
11. Changes to the Privacy Policy
LCC will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our Policy may therefore change from time to time. We will post any changes on our websites and, if the changes are material, we will provide a more prominent notice.
12. Contact Us
For any questions or concerns about this Privacy Policy, or to exercise any of the rights that you have in relation to your Personal Information, please contact our Privacy Officer:
Attn: Privacy Officer
communications@lcc.ca
514-482-9797, ext. 294
4090 Royal Avenue
Montreal, Quebec, Canada
H4A 2M5