Privacy Policy

01.Scope and applicable laws

This policy explains how Novelletum collects, uses, discloses, retains, and destroys personal information obtained through its website, forms, email, and teaching services. Novelletum operates in Montréal, Québec.

Our practices are intended to comply with Québec'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) may also apply, including to interprovincial or international commercial activities. Commercial electronic messages are subject to Canada's Anti-Spam Legislation (CASL).

02.Person responsible for privacy

Yulia Parfenova, Person Responsible for the Protection of Personal Information
Novelletum
Montréal, Québec, Canada
info@novelletum.ca

The Privacy Officer oversees this policy, responds to access, correction, portability, consent-withdrawal, and deletion requests, handles complaints, and participates in assessing confidentiality incidents.

03.Information collected and how we collect it

We collect information directly from you when you submit a form or write to us:

• Learning Enquiry: parent's name, phone number, child's first name and age; optionally, email, preferred contact time, and information about the child's learning needs.
• Publication Updates: name, email, publication of interest, and proof of consent to receive those updates.
• Scholarship Application: parent's name and email, child's first name and age, family story, learning journey, and reasons for applying.

Our host and web server may also automatically process limited technical information, including IP address, request date and time, requested page, browser type, user agent, and referring address. The form temporarily converts the IP address into a hashed identifier to limit spam; that counter expires after approximately one minute.

We do not knowingly collect social insurance numbers, banking information, identity documents, complete medical records, or biometric data through this website. Please do not include information that is not necessary for your request.

04.Purposes

Depending on the selected form, we use the information to:

• answer your enquiry and communicate with you;
• assess learning needs, arrange an assessment lesson, and propose suitable services;
• assess a scholarship application fairly and communicate the decision;
• send the publication updates you expressly requested;
• maintain security, prevent abuse, and diagnose technical errors;
• comply with legal obligations, respond to a valid order, and establish, exercise, or defend a legal claim.

We do not use information for a new incompatible purpose without obtaining fresh consent, unless the law permits or requires it.

05.Required and optional information; consequences of refusal

Fields marked with an asterisk are necessary to process the selected type of request. Without them, the form cannot be submitted or we may be unable to respond. Other fields are optional. Refusing publication updates does not affect a learning or scholarship enquiry.

06.Consent and electronic communications

Before a form is submitted, we request separate, clear, and express consent to process the information entered. You may withdraw consent to future use or disclosure by writing to info@novelletum.ca. Withdrawal does not invalidate processing already lawfully completed and may prevent us from continuing the requested service.

Publication updates require additional consent. Every commercial electronic message must identify Novelletum and include a simple, free unsubscribe mechanism. We will give effect to an unsubscribe request without delay and no later than 10 business days. We retain proof of consent while relying on it and a minimal suppression record for only as long as needed to honour the opt-out and demonstrate compliance.

07.Children and sensitive information

The website is intended for parents and guardians, not for children completing forms themselves. Information about a child under 14 must be provided by a parent or guardian who consents on the child's behalf. If we learn that it was provided directly by a child without valid consent, we will delete it unless the collection is clearly for the child's benefit and permitted by law.

A description of learning needs, a disability, or family circumstances may be sensitive personal information. We request express consent before submission, restrict access, and apply safeguards appropriate to its sensitivity.

08.Disclosure and service providers

Access is limited to Yulia Parfenova and, where necessary, suppliers acting for Novelletum: website and database hosting, email delivery and hosting, IT maintenance and security, backup, and professional advisers. They may process information only to provide their services, on our instructions and subject to confidentiality and security obligations.

We may also disclose information where required by law, to respond to a valid order, protect a person from serious harm, or establish, exercise, or defend a legal claim. We do not sell or rent personal information or disclose it for third-party advertising.

09.Processing outside Québec

Some hosting, email, security, or backup providers may process information elsewhere in Canada or in another country. The information may then be subject to that jurisdiction's laws and may be accessible to its authorities as permitted by law.

Before entrusting information outside Québec, Novelletum assesses its sensitivity, the purposes, the contractual and technical safeguards, and the applicable legal regime. A transfer proceeds only if protection is considered adequate and is governed by an appropriate written agreement.

10.Cookies, audience measurement, and technologies

Public pages currently use no advertising cookies or audience-measurement tools. When the site's language module is enabled, a functional cookie may remember your language preference for up to one year. WordPress may use session and security cookies for administrators or authenticated users; these are not used to track ordinary visitors for advertising.

We do not use technology to locate or profile visitors, biometric data, or decisions based exclusively on automated processing. If these practices change, we will update this policy and the available consent choices before enabling them.

11.Retention and secure destruction

We retain information only for as long as necessary for the stated purposes and then securely destroy it, subject to a legal requirement, dispute, or a reasonable period needed to establish our rights:

• General or learning enquiries with no resulting relationship: up to 12 months after the last meaningful communication.
• Unsuccessful scholarship applications: deleted at the end of the selection process, normally no later than 30 days after the decision. Information about the selected family is retained afterward only if needed for the teaching relationship.
• Service records: for the relationship and up to 3 years afterward, unless a different legal period applies.
• Publication updates: until consent is withdrawn; proof of consent and the suppression record are kept only as long as needed to demonstrate compliance and honour the unsubscribe request.
• Technical logs: normally no more than 90 days, unless needed to investigate an incident. The form's anti-spam counter expires after approximately one minute.
• Backups: deleted through the regular rotation cycle, generally within a maximum of 90 days.

12.Safeguards and incidents

We use reasonable safeguards proportionate to the sensitivity of the information, including data minimization, access controls, authentication for administrative accounts, security updates, encryption in transit when the site is served over HTTPS, anti-spam controls, backups, and confidentiality obligations for suppliers.

From the outset, the Privacy Officer participates in a privacy impact assessment for any acquisition, development, or redesign of an information system or electronic service involving personal information. Privacy settings are set to the most protective level by default.

No system is completely secure. If an incident occurs, we promptly act to reduce risk, prevent recurrence, and document the event. Every incident is entered in a confidentiality-incident register kept for at least five years. Where an incident creates a risk of serious injury, we notify the Commission d'accès à l'information du Québec and affected individuals; where PIPEDA requires it, we also notify the Office of the Privacy Commissioner of Canada.

13.Your rights

Subject to legal exceptions, you may request:

• confirmation that we hold information about you, access to it, and a copy;
• correction of inaccurate, incomplete, or ambiguous information;
• withdrawal of consent to future use or disclosure;
• deletion of information no longer needed or not lawfully retained;
• computerized information collected from you in a structured, commonly used technological format where the portability right applies;
• cessation of dissemination or de-indexing where the statutory conditions are met.

14.Exercising a right or making a complaint

Write to the Privacy Officer at info@novelletum.ca with your name, the nature of your request, and enough information to locate the relevant record. We may request reasonable identity verification, used only for that purpose. We will respond in writing within 30 days after receiving a sufficiently specific request. If all or part of a request is refused, we will explain the reasons and available recourse.

An internal complaint is recorded, impartially reviewed by the Privacy Officer, and answered in writing. If you are not satisfied, you may contact the Commission d'accès à l'information du Québec. Where PIPEDA applies, you may also contact the Office of the Privacy Commissioner of Canada.

15.External links and changes

The site may link to external services. Their own policies govern their practices, and Novelletum is not responsible for their content or handling of information.

We may amend this policy to reflect changes to our practices or the law. We will clearly identify a material change on the website and, where required, notify affected individuals before it takes effect. The date at the top identifies the current version.