1. Person in Charge of Processing

This privacy policy applies to the website and online services operated by La Distinction (referred to in this policy as “we,” “us,” or “our”). By visiting our website or using our services, you acknowledge that we collect and use your personal information as described below.

La Distinction is subject to Quebec Law 25 — formally known as An Act to modernize legislative provisions as regards the protection of personal information (S.Q. 2021, c. 25) — which governs how businesses operating in Quebec collect, use, communicate, and retain personal information about individuals.

Our website is hosted by Horizon-Cumulus (9322-8310 Québec inc.), located in Joliette, Quebec. Our hosting infrastructure is operated in Quebec (OVH, Beauharnois, Quebec), meaning your data stored on our servers remains on Quebec soil.

Our DNS is managed through Cloudflare. Our business email is operated through Horizon-Cumulus (Quebec) and Microsoft 365 (United States). Please see Section 5 for details on cross-border transfers.

2. Personal Information Collected

We collect personal information only to the extent necessary for the purposes described in Section 3. The categories below reflect what we actually collect based on how our website and services operate.

2.1 Identification and Contact Information

• Name, email address, phone number (collected when you subscribe to our newsletter, place an order, or contact us)
• Billing and shipping address (collected during online purchases)

2.2 Transaction and Order Information

• Order details, items purchased, order history, and payment confirmation data (collected through our WooCommerce online store)
• Note: payment card details are processed directly by our payment processor and are not stored on our servers

2.3 Navigation and Device Information

• IP address, approximate geographic location, device identifiers, browser type and version
• Pages visited, session duration, navigation behavior, and referral source
• This information is collected automatically when you visit our website via cookies and similar technologies

2.4 Advertising Identifiers and Social Identifiers

• Advertising identifiers and social network identifiers (collected by Meta Pixel and LinkedIn Insight Tag when you interact with our website and have consented to marketing cookies)

2.5 Communication Preferences

• Newsletter subscription status, email engagement data (opens, clicks), and communication preferences (managed through Mailchimp)

2.6 Consent Preferences

• Your cookie consent choices, recorded by Moelleux (operated by Horizon-Cumulus, Joliette, Quebec). A cookie named moelleux_{site_key} is stored in your browser for up to 13 months to remember your preferences.

3. Purposes of Processing

We use your personal information only for the purposes listed below. For each purpose, we identify the legal basis under Quebec Law 25.

3.1 Operating Our Online Store

Purpose: Processing your orders, managing your account, sending order confirmations and receipts, and handling returns or inquiries.
Data used: Identification and contact information, transaction and order information.
Legal basis: Performance of a contract (your purchase agreement with us).
Service involved: WooCommerce Analytics (store performance analysis).

3.2 Newsletter and Marketing Communications

Purpose: Sending you promotional emails, special offers, and news about our restaurant, when you have subscribed.
Data used: Email address, name, communication preferences.
Legal basis: Your consent, which you may withdraw at any time (see Section 7).
Service involved: Mailchimp (United States) — see Section 5 for transfer details.

3.3 Website Analytics and Performance

Purpose: Understanding how visitors use our website so we can improve content, navigation, and performance.
Data used: Navigation and device information, IP address, session data.
Legal basis: Your consent (analytics cookies are only activated after you accept them).
Services involved: Google Analytics 4 (United States), WooCommerce Analytics (United States).

3.4 Targeted Advertising and Retargeting

Purpose: Delivering relevant advertisements on social media platforms and measuring the effectiveness of our advertising campaigns.
Data used: Advertising identifiers, social identifiers, navigation behavior, transaction data, IP address.
Legal basis: Your consent (marketing cookies are only activated after you accept them).
Services involved: Meta Pixel / Facebook (United States), LinkedIn Insight Tag (United States).

3.5 Website Display and Functionality

Purpose: Rendering our website correctly in your browser, including displaying text in the intended typefaces.
Data used: IP address, device identifiers.
Legal basis: Your consent (functional cookies are activated after you accept them).
Service involved: Google Fonts (United States).

3.6 Consent Management

Purpose: Recording and storing your cookie consent choices so we can demonstrate compliance with Quebec Law 25 and honor your preferences on future visits.
Data used: Consent preferences, IP address.
Legal basis: Legal obligation under Quebec Law 25.
Service involved: Moelleux by Horizon-Cumulus (Quebec) — data stays in Quebec.

4. Third Parties and Processors

The table below lists every third-party service active on our website. We share your personal information with these parties only to the extent necessary for the stated purpose, and only when you have given the applicable consent where required.

We do not sell your personal information to any third party. We do not share your personal information with third parties for their own independent marketing purposes without your explicit consent.

5. Transfers Outside Quebec

Several of the services we use involve transferring your personal information to servers or processors located outside Quebec — specifically in the United States. Under section 17 of Quebec Law 25, we are required to disclose these transfers and ensure that your personal information receives a level of protection equivalent to what Quebec law provides.

5.1 Services That Transfer Data to the United States

• Google Analytics 4 (Google LLC, United States) — navigation and device data are processed on Google’s infrastructure in the United States.
• WooCommerce Analytics (Automattic Inc., United States) — store performance and transaction data may be processed in the United States.
• Meta Pixel / Facebook (Meta Platforms Inc., United States) — advertising identifiers, social identifiers, and behavioral data are transferred to Meta’s servers in the United States.
• LinkedIn Insight Tag (LinkedIn Corporation, United States) — advertising and behavioral data are transferred to LinkedIn’s servers in the United States.
• Mailchimp (The Rocket Science Group LLC / Intuit Inc., United States) — your name and email address, along with email engagement data, are stored and processed in the United States. We use Mailchimp to manage our newsletter. Your contact information may therefore be processed in the United States.
• Google Fonts (Google LLC, United States) — your IP address and device identifiers are transmitted to Google servers in the United States each time a page on our site loads a font.
• Microsoft 365 (Microsoft Corporation, United States) — our business email is partially operated through Microsoft 365, which stores and processes email data in the United States.

5.2 Services That Keep Data in Quebec

• Moelleux by Horizon-Cumulus — consent records and this privacy policy are hosted in Quebec (OVH, Beauharnois). No data leaves Quebec through this service.
• Horizon-Cumulus Email — our primary business email infrastructure is operated by Horizon-Cumulus in Joliette, Quebec. Data processed through this service remains in Quebec.
• Website hosting — our website is hosted by Horizon-Cumulus in Quebec. Your data stored on our web servers remains on Quebec soil.

5.3 Contractual Safeguards and Privacy Impact Assessments

Before transferring personal information outside Quebec, we conduct or rely on a Privacy Impact Assessment (PIA) — known in French as an évaluation des facteurs relatifs à la vie privée (EFVP) — as required by section 17 of Quebec Law 25. We enter into data processing agreements with each of our U.S.-based processors that include contractual clauses requiring them to protect your personal information to a standard comparable to Quebec law. You may request a summary of these assessments by contacting our Person responsible for the protection of personal information (see Section 8).

6. Retention Period

We keep your personal information only for as long as necessary to fulfill the purpose for which it was collected, or as required by law. The table below summarizes our retention practices.

When the applicable retention period expires, we securely delete or anonymize your personal information so that it can no longer be linked back to you.

7. Your Rights

Quebec Law 25 gives you meaningful rights over your personal information. Here is what you can ask us to do, and how.

7.1 Right of Access

You have the right to ask us whether we hold personal information about you, and if so, to receive a copy of it. We will tell you what information we have, where it came from, how we use it, and with whom we have shared it.

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 that information with a third party, we will notify them of the correction where feasible.

7.3 Right of Erasure (Right to be Forgotten)

You may ask us to delete personal information that we collected for a specific purpose once that purpose has been fulfilled, or if you believe we no longer have a lawful reason to keep it. We will honor your request unless we are required by law to retain the information (for example, for tax or accounting purposes).

7.4 Right to Data Portability

You have the right to receive the personal information you provided to us in a structured, commonly used, and machine-readable format, and to have it transmitted to another organization where technically feasible. This right applies to information you actively provided to us (such as your account details or order history).

7.5 Right to Withdraw Consent

Where we rely on your consent to process your personal information — for example, for analytics cookies, marketing cookies, or our newsletter — you may withdraw that consent at any time without penalty. To withdraw consent for cookies, use the cookie preference tool on our website (the Moelleux consent banner). To unsubscribe from our newsletter, click the unsubscribe link in any email we send you, or contact us directly. Withdrawing consent does not affect the lawfulness of processing that took place before your withdrawal.

7.6 How to Exercise Your Rights

To exercise any of the rights above, 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, as required by Quebec Law 25.

7.7 Right to File a Complaint

If you believe 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). You can reach the 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, La Distinction has designated a Person responsible for the protection of personal information who oversees compliance with our privacy obligations and handles requests and complaints from individuals.

• Name: Josée Lauzon
• Title / Role: —
• Email: marketing@distinction.qc.ca
• Phone: 450 759-6900

You may contact our Person responsible for the protection of personal information for any of the following reasons:

• To exercise one of the rights described in Section 7
• To ask a question about how we handle your personal information
• To report a concern or potential privacy incident
• To request a summary of our Privacy Impact Assessments for cross-border transfers

We will acknowledge your request promptly and provide a substantive response within 30 days, as required by Quebec Law 25. If your request is complex or involves a large volume of information, we may extend this period by an additional 30 days and will notify you accordingly.

Note on email security: Our business email is operated through a combination of Horizon-Cumulus (Quebec) and Microsoft 365 (United States). Our DMARC email authentication policy is currently configured in monitoring mode. To further protect the integrity of communications from our domain and reduce the risk of email spoofing, we are in the process of strengthening this configuration. In the meantime, if you receive a suspicious email claiming to be from us, please contact us by phone to verify its authenticity.

9. Effective Date and Versioning

This privacy policy takes effect on 10 juin 2026 and replaces any prior version.

Version: 2

We review this policy at least once a year and whenever a material change occurs in how we collect or use personal information — for example, when we add a new third-party service or change a retention period. When we make a significant change, we will update the effective date above and, where appropriate, notify you by email or through a notice on our website.

The current version of this policy is always available on our website. If you have questions about any changes, please contact our Person responsible for the protection of personal information using the details in Section 8.