1. Person in Charge of Processing
This privacy policy applies to the website and online store operated by Nettoyeur Élégance (referred to in this policy as "we," "us," or "our"). By visiting our website or placing an order with us, you acknowledge that we collect and use your personal information as described below.
Nettoyeur Élégance is 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 in Quebec and Canada. This law governs how we collect, use, disclose, retain, and protect your personal information.
Our website is hosted in Quebec, Canada, through Horizon-Cumulus (Joliette, Quebec), and our consent records are stored at OVH Beauharnois, Quebec. However, certain third-party services we use may transfer personal information outside Quebec or Canada, as detailed in Sections 4 and 5 below.
2. Personal Information Collected
We collect personal information about you in the course of operating our website and online store. The categories below reflect what is actually collected based on our services and technology stack.
- Identity and contact information: Your name, email address, phone number, and billing or shipping address when you place an order or contact us.
- Transaction and order data: Details of purchases you make through our WooCommerce store, including products ordered, order amounts, and payment confirmation data. Note: full payment card details are processed directly by our payment processor and are not stored by us.
- Device and technical identifiers: IP address, browser type, operating system, device identifiers, and approximate geographic location, collected automatically when you visit our site.
- Browsing behavior: Pages visited, session duration, navigation patterns, and interactions with our site content, collected via analytics and marketing tools.
- Advertising identifiers: Identifiers used for ad targeting and conversion tracking, collected by Meta Pixel (Facebook) and Google Ads when you interact with our site or advertisements.
- Consent preferences: Your cookie consent choices, recorded and stored by Moelleux (operated by Horizon-Cumulus, Joliette, Quebec) for a period of 13 months via a cookie named
moelleux_{site_key}.
We do not knowingly collect personal information from individuals under the age of 14 without verifiable parental consent.
3. Purposes of Processing
We collect and use your personal information only for the purposes described below. Where we rely on your consent, you may withdraw it at any time (see Section 7).
- Processing your orders (legal basis: contractual necessity): We use your identity, contact, and transaction data to fulfill orders placed through our WooCommerce store, process payments, arrange delivery, and provide customer support. WooCommerce Analytics also helps us monitor store performance and understand purchasing behavior.
- Website analytics and improvement (legal basis: consent): We use Google Analytics 4 and WooCommerce Analytics to measure site traffic, understand how visitors navigate our site, and improve our content and user experience. These tools collect device identifiers, IP addresses, pages visited, session duration, and approximate location. Data is transferred to the United States (see Section 5).
- Advertising and remarketing (legal basis: consent): We use Meta Pixel (Facebook) and Google Ads / Conversion tracking to measure the effectiveness of our advertising campaigns, retarget visitors who have shown interest in our services, and optimize our ad spend. These tools collect device identifiers, IP addresses, browsing behavior, transaction data, and advertising identifiers. Data is transferred to the United States (see Section 5).
- Site functionality and security (legal basis: legitimate interest / contractual necessity): We use Google Fonts to display our site's typography, YouTube to embed video content, and Google reCAPTCHA to protect our forms from automated abuse. These tools may collect your IP address and device identifiers. Google reCAPTCHA also analyzes your browsing behavior to distinguish human visitors from bots. Data is transferred to the United States (see Section 5).
- Consent management (legal basis: legal obligation under Quebec Law 25): Moelleux, operated by Horizon-Cumulus (Joliette, Quebec), records and stores your cookie consent choices to ensure we comply with our obligations under Quebec Law 25. Consent records are hosted in Quebec (OVH Beauharnois).
- Business email communications (legal basis: legitimate interest / contractual necessity): We use Horizon-Cumulus Email (Quebec) for our primary business email. Microsoft 365 (United States) is also used for certain email operations. When you contact us by email, your message and contact details may be processed through these services.
4. Third Parties and Processors
The table below lists all third-party services active on our website, their purpose, their category, and whether they involve a transfer of personal information outside Quebec.
| Service | Purpose | Category | Transfer Outside Quebec |
|---|---|---|---|
| Moelleux (by Horizon-Cumulus) | Cookie consent management and privacy policy hosting; consent records stored in Quebec (OVH Beauharnois) | Essential | No — data stays in Quebec |
| WooCommerce Analytics | E-commerce store performance analysis and customer behavior tracking | Analytics | Yes — United States |
| Google Analytics 4 | Website audience measurement and visitor behavior analysis | Analytics | Yes — United States |
| Meta Pixel (Facebook) | Conversion tracking and remarketing for Meta advertising campaigns | Marketing | Yes — United States |
| Google Ads / Conversion | Conversion tracking and optimization for Google advertising campaigns | Marketing | Yes — United States |
| Google Fonts | Delivery of web fonts for site display | Functional | Yes — United States |
| YouTube (embedded videos) | Embedding and displaying video content on the site | Functional | Yes — United States |
| Google reCAPTCHA | Bot detection and form abuse prevention | Functional | Yes — United States |
| Horizon-Cumulus Email | Primary business email communications; hosted in Quebec | Functional | No — data stays in Quebec |
| Microsoft 365 | Business email operations | Functional | Yes — United States |
We require all third-party processors to handle your personal information in a manner consistent with applicable privacy laws and to implement appropriate security measures.
5. Transfers Outside Quebec
Several of the third-party services we use involve transferring your personal information to the United States. Under section 17 of Quebec Law 25, we are required to inform you of such transfers and to conduct a Privacy Impact Assessment (PIA — also called an EFVP in French) before any such transfer takes place, to ensure your personal information receives adequate protection.
The following services transfer personal information to the United States:
- Google Analytics 4 (United States) — device identifiers, IP address, browsing behavior, approximate location
- Meta Pixel (Facebook) (United States) — device identifiers, IP address, browsing behavior, transaction data, advertising and social identifiers
- Google Ads / Conversion (United States) — device identifiers, IP address, pages visited, transaction data, advertising identifiers
- Google Fonts (United States) — IP address
- YouTube (embedded videos) (United States) — device identifiers, IP address, browsing behavior, session duration
- Google reCAPTCHA (United States) — device identifiers, IP address, browsing behavior
- WooCommerce Analytics (United States) — device identifiers, IP address, browsing behavior, transaction data
- Microsoft 365 (United States) — email content and contact details processed through business email
For email specifically: our primary business email is operated by Horizon-Cumulus (Quebec), and your correspondence sent to that address is processed in Quebec. However, certain email operations also involve Microsoft 365, which processes data in the United States. Your email communications may therefore be processed in that jurisdiction.
Before transferring personal information outside Quebec, we conduct or rely on a Privacy Impact Assessment (PIA) to evaluate whether the destination jurisdiction offers an adequate level of protection. We also put in place contractual safeguards — such as data processing agreements and, where applicable, standard contractual clauses — with each third-party processor. If you would like more information about the safeguards in place for a specific transfer, please contact our Person responsible for the protection of personal information (see Section 8).
6. Retention Period
We retain your 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 by data type.
| Data Type | Retention Period | Justification |
|---|---|---|
| Order and transaction data (name, address, order history) | 7 years | Legal obligation under Quebec tax and accounting laws (Act respecting the Ministère du Revenu) |
| Customer account information | Duration of account + 2 years after last activity | Legitimate interest in providing ongoing service and handling post-purchase inquiries |
| Analytics data (Google Analytics 4, WooCommerce Analytics) | Up to 14 months (Google default); aggregated data may be retained longer | Audience measurement and site improvement; configured per Google Analytics data retention settings |
| Advertising and conversion data (Meta Pixel, Google Ads) | Up to 180 days for conversion windows; varies by platform | Campaign performance measurement; governed by Meta and Google data retention policies |
| Cookie consent records (Moelleux) | 13 months | Legal obligation to demonstrate consent under Quebec Law 25; cookie expires after 13 months |
| Email correspondence | 3 years | Legitimate interest in maintaining a record of customer communications and resolving disputes |
| Security and server logs (IP addresses, access logs) | 90 days | Legitimate interest in detecting and investigating security incidents |
When personal information is no longer required, we destroy, delete, or anonymize it in a secure manner.
7. Your Rights
Under Quebec Law 25, you have 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 (see Section 8). We will respond within 30 days of receiving your request.
- Right of access: You have the right to ask us whether we hold personal information about you, and to receive a copy of that information in a clear and understandable format.
- Right of rectification: If the personal information we hold about you is inaccurate, incomplete, or ambiguous, you have the right to ask us to correct it.
- Right of erasure (right to be forgotten): You may ask us to delete your personal information when it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. You may also ask us to de-index any information about you that is published online and that is associated with your name, where that information causes you harm.
- Right to data portability: You have the right to receive the personal information you have provided to us in a structured, commonly used, and machine-readable format, and to have it transmitted to another organization where technically feasible.
- Right to withdraw consent: Where we process your personal information based on your consent (for example, analytics cookies or marketing cookies), you may withdraw that consent at any time by updating your preferences through our cookie consent banner or by contacting us directly. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
If you believe your rights have not been respected, you have the right to file a complaint with the Quebec Information Access Commission (CAI) at https://www.cai.gouv.qc.ca.
8. Person Responsible for the Protection of Personal Information
In accordance with section 3.1 of Quebec Law 25, Nettoyeur Élégance has designated a Person responsible for the protection of personal information who oversees compliance with this policy and with Quebec Law 25.
If you have any questions about this privacy policy, wish to exercise your rights, or have a concern about how we handle your personal information, please contact our Person responsible for the protection of personal information:
- Name: Thomas Emard-Munger
- Title / Role: --
- Email: info@nettoyeurelegance.com
- Phone: 450 755-1414
We are committed to responding to all privacy-related requests within 30 days of receipt, as required by Quebec Law 25. If your request is complex or if we receive a high volume of requests, we may extend this period by an additional 30 days, in which case we will notify you promptly.
9. Effective Date and Versioning
This privacy policy takes effect on 10 juin 2026 and replaces any prior version of our privacy policy.
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 material changes, 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, a consent management and privacy policy platform operated by Horizon-Cumulus (9322-8310 Québec inc.), Joliette, Quebec.
