Privacy Policy

1. Person responsible for the protection of personal information

Romano, a business based in Laval, is responsible for the personal information it holds. The person responsible for its protection is Abdel Zaggaz. You can contact this person by email at [email protected], by phone at (450) 805-1994 or by mail: Romano, 484 Jean-Dallaire, Laval, Quebec H7L 6C6.

2. Information we collect

We only collect the information needed to respond to your request. When you fill in the form on this website, we collect:

• your name, email and phone number;
• the service you are interested in (Web presence or Scout);
• your availability and any message you enter in the field provided;
• if you tick the box “I agree to be called back at the number provided”: proof of that consent, namely the date and time, the phone number provided and the wording of the box you accepted.

If you speak with the voice assistant, the information you give it (need, type of business, urgency, availability) is noted in a file so that we can follow up on your request.

If you write to us by email or social media message, or call us, we also receive the information you choose to share. Do not send any sensitive personal information through the website form.

Minimal technical data (device type and pages viewed, in aggregated and anonymous form) is collected only if you accept audience measurement.

3. Why we use it

• Respond to your request and reach you at the times you indicate.
• Call you back by phone, only if you ticked the callback box. We make no automatic outbound calls.
• Keep proof of your callback consent.
• Meet our legal obligations.
• Improve our website, using anonymous statistics, if you accepted audience measurement.

We do not use your information for any other purpose without obtaining new consent.

4. Your consent

We ask for your consent clearly, for each purpose, before collecting your information. It is given freely. The callback box is unticked by default: without your agreement, we do not call you back. You may withdraw your consent at any time by contacting the person responsible. Withdrawal may limit our ability to respond to your request.

Voice calls: if you choose to speak with the voice assistant, you are told so at the start of the call by a greeting message: "This call is handled by an automated assistant. Your conversation is transcribed so that we can call you back. If you do not wish to continue, please hang up." If you prefer, the call follows its normal course to voicemail, and you can ask to speak with a person at any time.

5. Cookies and audience measurement

This website uses only the cookies strictly necessary for it to function, for example to remember your consent choice. No advertising cookies or social media trackers are installed.

If you accept audience measurement, we use a cookie-free tool that does not follow you from one site to another. You can change your choice at any time with the “Manage cookies” link at the bottom of the pages. You can also delete the site’s data in your browser settings.

6. Disclosure to third parties

We do not sell or rent your information. It may be disclosed only to service providers who help us operate our services (website hosting, receiving and processing requests, email, telephony), who are bound by confidentiality agreements, or where required by law. If information is hosted outside Quebec, we ensure that it receives adequate protection, in accordance with Law 25.

7. Retention and security

We keep your information for the periods stated in section 11 for the voice assistant and, for other requests, for as long as necessary to handle them, then we securely destroy or anonymize it, unless the law requires longer retention. We apply reasonable safeguards: access restricted to people who need it, and encrypted communications.

8. Your rights

Under the Act respecting the protection of personal information in the private sector (Law 25), you may at any time:

• request access to the information we hold about you;
• request its correction if it is inaccurate, incomplete or equivocal;
• withdraw your consent;
• request that we cease disseminating your information or de-index any link providing access to it, in the cases provided for by law;
• request that your information be provided to you in a structured, commonly used technological format.

Send your request to the person responsible, Abdel Zaggaz, by email at [email protected], by phone at (450) 805-1994 or by mail: Romano, 484 Jean-Dallaire, Laval, Quebec H7L 6C6. We respond within 30 days.

9. Privacy incidents

We keep a register of privacy incidents. If an incident presents a risk of serious injury, we notify the Commission d’accès à l’information and the persons concerned promptly.

10. Complaints

If you believe your rights are not being respected, first contact our person responsible for the protection of personal information. You may also file a complaint with the Commission d’accès à l’information du Québec: www.cai.gouv.qc.ca.

11. Voice assistant (website and telephone)

What it is. The "Talk to the assistant" button on our website and our phone number give access to an automated voice assistant, not a person. It answers your questions, notes your request and can offer an appointment.

What we collect.

• Your voice, sent live during the conversation. We make no audio recording, and our telephone provider does not record calls either. Your voice is not used to identify you.
• By phone, a written transcript of the call and a summary, so that we can call you back.
• On the website, the transcript is displayed in your browser during the conversation; we do not keep it on our servers.
• The contact details you give for an appointment (first name, email, phone, service requested).
• For phone calls, the calling number, the date, the duration and the status of the call.
• For the website, proof of your consent: date, version of the text accepted and a code derived from your IP address (never the address itself), without the content of your conversation.
• Technical logs (shortened identifier, duration, session cost).

Why. To answer your request, book an appointment, call you back, prevent abuse and demonstrate your consent. We do not use your conversations to train a model.

Your consent. On the website, you must accept the notice before the conversation begins. By phone, the call opens with this message: "This call is handled by an automated assistant. Your conversation is transcribed so that we can call you back. If you do not wish to continue, please hang up." You may hang up or decline at any time; the contact form and email remain available.

Who processes your information, and where. To provide the service, we use providers whose servers are located outside Quebec:

• Google Cloud: live voice processing, in the United States, and transcript summaries (region "global", so possibly outside Canada). Google may, if it detects abusive activity, temporarily keep exchanges for up to 90 days.
• Twilio: transmission of phone calls; keeps call logs (numbers, date, duration, status) in the United States for up to 13 months.
• Neon: hosting of the database holding our files and transcripts, in the United States.
• Cloudflare: website hosting, bot protection and storage of the proof of consent.

Before any transfer outside Quebec, we assess the privacy factors and bind these providers by written contract, in accordance with the Act respecting the protection of personal information in the private sector (sections 17 and 18.3). This information may be subject to the laws of the places where it is processed.

How long we keep it.

• Transcript of a call that does not lead to a follow-up request: 30 days.
• Transcript and summary tied to a request (lead file): 12 months after the last contact.
• Code derived from the IP address: 30 days.
• Technical logs: 30 days.
• Proof of consent (date, text version, salted IP code): 3 years.
• Contact details of an appointment request: 12 months after the last contact.
• Call logs at Twilio: up to 13 months.

At the end of the period, the information is destroyed or anonymized.

Your rights. You may ask for access to your information, its correction or its deletion, withdraw your consent, or ask for details about how it is processed. Write to the person responsible for the protection of personal information: Abdel Zaggaz, [email protected], or by mail: Romano, 484 Jean-Dallaire, Laval, Quebec H7L 6C6. We respond within 30 days. If you are not satisfied with the response, you may file a complaint with the Commission d’accès à l’information du Québec (www.cai.gouv.qc.ca).

Incident. In the event of a confidentiality incident presenting a risk of serious harm, we notify the Commission and the people concerned.

12. Changes to this policy

We may update this policy. The date of the last update appears at the top of the page. In the event of a significant change, we will inform you on the website.