Privacy Policy

Last updated: May 19, 2026
Effective date: May 19, 2026

This Privacy Policy (the “Policy“) describes, in plain language, how Elefen Communications Inc. (hereinafter “Elefen“, “we“, “our“) collects, uses, discloses, retains and protects personal information when you visit our website www.elefen.com (the “Site“), use our services or communicate with us.

This Policy is drafted in accordance with:

Quebec’s Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1), as modernized by Law 25;
Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA);
the European Union’s General Data Protection Regulation (GDPR), where applicable to European visitors;
the California Consumer Privacy Act (CCPA) as amended by the CPRA, where applicable to California residents.

1. Who are we?

Elefen Communications Inc., a registered Canadian company, acts as the data controller (or “person carrying on an enterprise” within the meaning of Law 25) with respect to the personal information covered by this Policy.

Company contact information:
Elefen Communications Inc.
1525, rue de la Pierre-de-Lune
Drummondville, Quebec J2C 8N7 Canada
Email: info@elefen.com
Phone: 819-469-7247

2. Person in charge of the protection of personal information

In accordance with section 3.1 of the Act respecting the protection of personal information in the private sector, we have designated a Person in charge of the protection of personal information (Privacy Officer):

Mr. William Larochelle
Person in charge of the protection of personal information
Elefen Communications Inc.
1525, rue de la Pierre-de-Lune, Drummondville, Quebec J2C 8N7
Email: info@elefen.com
Phone: 819-469-7247

You may contact the Privacy Officer with any question regarding this Policy, to exercise your rights, to file a complaint or to report a confidentiality incident.

3. Personal information we collect

3.1 Information you provide to us

When you fill out a form, request a quote, subscribe to our newsletter, apply for a job posting, interact with our AI-assisted chat or communicate with us, we may collect:

Identity: first name, last name;
Contact details: email address, phone number, company name, job title;
Content of your communications with us (emails, form messages, chat conversations);
Information relating to the project or mandate entrusted to us (e.g.: budget, objectives, content you send us);
Billing and payment information (for clients);
For job applications: resume, cover letter and any information you choose to include in them.

3.2 Information collected automatically

When you browse the Site, we automatically collect, by means of cookies and similar technologies:

IP address (generally anonymized by our analytics tools);
Browser type and version, operating system, language;
Pages viewed, duration of visits, referral source;
Technical data useful for Site security and abuse detection.

3.3 Information from third parties

We may receive information about you from a client who engages us (e.g.: your contact details as the contact person for a project), or from public platforms you use (e.g.: LinkedIn).

4. Purposes: why we use your information

We use your personal information solely for the purposes set out below, to the extent necessary for each of them:

Purpose	Legal basis
Responding to your requests (quotes, questions, mandates)	Pre-contractual measures / consent
Providing, managing and billing our services to clients	Performance of a contract / legal obligation (accounting)
Sending you our newsletter and marketing communications	Consent (revocable at any time)
Improving our Site, measuring its audience and usability	Legitimate interest (anonymized analysis) / consent (cookies)
Managing job applications and recruitment	Pre-contractual measures / consent
Ensuring Site security and preventing fraud (including reCAPTCHA)	Legitimate interest / legal obligation
Complying with our legal, regulatory and tax obligations	Legal obligation

We will not use your personal information for incompatible purposes without first obtaining your consent.

5. Automated decisions and use of artificial intelligence

In accordance with section 12.1 of Law 25, we inform you that we use certain generative artificial intelligence (AI) tools, including an automated chat on our Site, in order to answer your questions more quickly and direct your requests.

Important clarifications:

These tools do not use your information to render a decision based exclusively on automated processing that has a legal or similar effect on you (e.g.: denial of a service, automatic pricing).
Any business proposal, service offer or contractual decision is reviewed and validated by a member of the Elefen team.
You may at any time ask to speak with a human being by writing to us at info@elefen.com or by phone.
Conversations with our chat may be retained for service improvement and security purposes (see section 9).

6. Cookies

The Site uses different categories of cookies:

Strictly necessary cookies: essential to the operation of the Site and your security. They are placed without prior consent.
Audience measurement cookies: Google Analytics / Google Tag Manager, to understand how the Site is used. They are placed only with your consent.
Functional cookies: remembering your preferences (e.g.: language).

In accordance with section 8.1 of Law 25, the settings providing the highest level of confidentiality by default are enabled. You may change your choice at any time via the “Cookie Settings” module accessible at the bottom left of the Site (CookieYes).

7. Sharing and disclosure of information

We do not sell, rent or trade your personal information. We may, however, disclose it in the following cases:

7.1 With our service providers

We use service providers who act strictly according to our instructions and are bound by confidentiality and security commitments:

Web hosting and infrastructure (primarily in Canada);
Google Analytics and Google Tag Manager (Google LLC – United States) for anonymized audience measurement;
Newsletter tool (Mailchimp or equivalent) for sending our communications;
Customer relationship management (CRM) solution for tracking prospects and clients;
Intranet and internal tools hosted in Canada for mandate management;
Google reCAPTCHA for protection against spam and abuse.

7.2 For legal obligations

Where required by law, a regulation, a court order or a competent public authority.

7.3 In the context of a business transaction

In the event of a merger, acquisition or transfer of assets, your information could be disclosed to the acquiring party, subject to equivalent confidentiality commitments.

8. Disclosure of information outside Quebec

Some of our service providers (notably Google and our newsletter tool) may process your information outside Quebec, primarily in the United States. In accordance with section 17 of Law 25, Elefen conducted a privacy impact assessment (PIA) before disclosing information outside Quebec, in order to ensure that it receives adequate protection, in particular through:

contractual clauses imposing confidentiality, security and purpose-limitation obligations on service providers;
technical measures (encryption in transit and at rest, anonymization where possible);
minimization of the information transferred to what is strictly necessary.

You may request more information about these assessments by contacting the Privacy Officer.

9. Retention of information

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, after which we destroy or anonymize it, in accordance with section 23 (now 63.1) of the Act.

Usual retention periods:

Type of information	Retention period
Requests via form or chat (no follow-up)	24 months following the last exchange
Active prospects (CRM)	36 months without interaction, then deletion or anonymization
Newsletter subscribers	Until unsubscription, then deletion within 30 days
Clients (files, contracts, billing)	Duration of the mandate + 7 years (tax and accounting obligations)
Unsuccessful job applications	12 months (then deletion, unless consent to longer retention)
Technical and security logs	12 months maximum
AI chat conversations	12 months, then anonymization

Different periods may apply where required by law or for the establishment, exercise or defence of a legal claim.

10. Your rights

Subject to the conditions and exceptions provided by applicable law, you have the following rights with respect to your personal information:

Right of access to your information;
Right of rectification of inaccurate, incomplete or ambiguous information;
Right to withdraw your consent at any time, where processing is based on it;
Right to cessation of dissemination, de-indexing or re-indexing (section 28.1 of Law 25);
Right to portability: obtaining your computerized information in a structured, commonly used technological format;
Right to object to certain processing or to request its limitation;
Right to be informed when a decision about you is rendered exclusively on the basis of automated processing;
Additional rights for EU/EEA residents (GDPR): the right to lodge a complaint with a supervisory authority;
Additional rights for California residents (CCPA/CPRA): the right to know, the right to delete, the right to correct, the right to opt out of the “sale” or “sharing” of personal information (Elefen does not sell or share for cross-context behavioural advertising purposes).

How to exercise your rights? Send your request, in writing, to the Person in charge of the protection of personal information at the contact details indicated in section 2. We will respond within a maximum of 30 days of receipt. We may ask you for reasonable proof of identity in order to prevent any unauthorized disclosure.

If you are not satisfied with our response, you may file a complaint with the Commission d’accès à l’information du Québec (Quebec’s privacy regulator) (www.cai.gouv.qc.ca) or the Office of the Privacy Commissioner of Canada (www.priv.gc.ca).

11. Information security

We implement reasonable organizational, physical and technological security measures, proportionate to the sensitivity of the information, including:

access control based on the principle of least privilege;
strengthened authentication (strong passwords and, where possible, multi-factor authentication);
encryption of data in transit (TLS) and at rest where applicable;
access logging and monitoring;
regular backups and a continuity plan;
employee training and awareness regarding the protection of personal information.

Since no measure can guarantee absolute security, in the event of a confidentiality incident presenting a risk of serious injury, Elefen will notify, in accordance with the law, the Commission d’accès à l’information as well as the persons concerned as soon as possible.

12. Minors

The Site and our services are not directed at persons under 14 years of age and we do not knowingly collect their personal information. For persons under 18 years of age, we recommend the guidance of a parent or legal guardian before submitting any information.

13. Advertising, tracking and profiling

Elefen does not display advertising on its Site and does not use remarketing techniques or advertising profiling. No third-party advertising pixel (e.g.: Meta, LinkedIn) is deployed on the Site for advertising purposes.

14. Links to third-party sites

Our Site may contain links to third-party websites (LinkedIn, Facebook, X, etc.). Elefen is not responsible for the privacy practices of these sites. We invite you to consult their own policies.

15. Changes to this Policy

We may amend this Policy to reflect changes in our practices, technologies or legislation. The applicable version is always the one published on this page, with the update date indicated at the top. If substantial changes are made, we will inform you by appropriate means (notice on the Site, email).

16. Contact us

For any question, request or complaint relating to the protection of your personal information: