Privacy Policy
Last Updated: 2024
1. Introduction and Scope
Linen Ledger ("we", "us", or "our") is committed to protecting the privacy and security of your personal information. As an entity operating in Quebec City, Quebec, Canada, we adhere to the strictest standards of data protection. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services related to Registered Education Savings Plans (RESP).
Our practices are governed by the Act respecting the protection of personal information in the private sector (Quebec), as amended by Law 25 (formerly Bill 64), and where applicable, the federal Personal Information Protection and Electronic Documents Act (PIPEDA).
2. Data Controller and Privacy Officer
Linen Ledger acts as the controller and operator of your data. In compliance with Law 25, we have appointed a Privacy Officer responsible for overseeing our privacy strategy and compliance.
- Company: Linen Ledger
- Address: 1015 Boulevard René-Lévesque Ouest, Quebec City
- Email:
- Phone: +1 (514) 146-8850
3. Information We Collect
We collect information that identifies, relates to, or could reasonably be linked to you. This includes:
- Identity Data: Name, surname, and relationship to the beneficiary (child).
- Contact Data: Email address, telephone number, and residential address.
- Financial Context: Information regarding your interest in RESP contributions and government grants (CESG, QESI).
- Technical Data: IP address, browser type, time zone settings, and operating system.
- Usage Data: Information about how you use our website, products, and services.
- Cookies: Tracking data via essential and analytical cookies.
4. Purposes and Legal Basis for Processing
Under Quebec law, we must have a valid purpose for collecting data. We process your information to:
- Consent: To provide you with information about RESP accounts and government education grants based on your explicit request.
- Performance of a Contract: To facilitate the opening of education savings accounts and manage your portfolio.
- Legal Obligation: To comply with tax reporting requirements to Revenu Québec and the Canada Revenue Agency (CRA).
- Legitimate Interest: To improve our website functionality, ensure network security, and conduct internal analytics.
5. Data Retention
We retain personal information only as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally, RESP-related data is kept for the duration of the account plus 7 years to satisfy Canadian tax audit requirements. When data is no longer required, it is securely destroyed or anonymized in accordance with Law 25 standards.
6. Disclosure to Third Parties
Linen Ledger does not sell your personal data. We may share your information with:
- Financial Institutions: Partners who hold the RESP funds.
- Government Bodies: Employment and Social Development Canada (ESDC) and Revenu Québec for grant processing.
- Service Providers: IT hosting, analytics (Google Analytics), and CRM providers who are contractually bound to protect your data.
7. International and Inter-provincial Transfers
Your data is primarily stored on servers located in Canada. However, some of our service providers may process data in other jurisdictions (e.g., the United States). In such cases, we conduct Privacy Impact Assessments (PIA) as required by Law 25 to ensure that the information receives an adequate level of protection.
8. Your Rights as a Data Subject
As a resident of Quebec, you have specific rights regarding your personal information:
Access & Rectification
The right to request a copy of your data and correct any inaccuracies.
Right to be Forgotten
The right to request the deletion of your data when it is no longer necessary.
Data Portability
The right to receive your data in a structured, commonly used format.
Withdrawal of Consent
The right to withdraw consent for data processing at any time.
To exercise these rights, please contact our Privacy Officer at . We will respond to your request within 30 days.
9. Security Measures
Linen Ledger implements robust technical and organizational measures, including encryption (SSL/TLS), firewalls, and strict access controls, to prevent unauthorized access, disclosure, or loss of your personal information.
10. Complaints
If you believe Linen Ledger has not complied with its legal obligations, you have the right to lodge a complaint with the Commission d'accès à l'information du Québec (CAI).