Aéroports de Montréal’s Privacy Policy
1. PURPOSE AND SCOPE
At Aéroports de Montréal (“ADM”), we ensure that we respect the privacy of individuals and protect the information that concerns them. It is important for us to be transparent and provide you with information regarding the types of personal information we collect, how we use that information, with whom we share it, and the purposes and reasons for such collection, use and communication. We also want you to be informed of your rights regarding your privacy and its protection.
This Policy applies to individuals using our services or facilities, visiting our website, or using our mobile application, as well as to our operations throughout Canada. However, this Policy does not apply to personal information related to ADM employees or job applicants, who are subject to a separate policy.
2. DEFINITIONS
“Personal Information” refers to any information that can, directly or indirectly, identify an individual or can reasonably be associated with an individual in particular. This includes information such as your name, or your parents’ names, if you are a minor, your contact information, your date of birth, your banking information, your personal health information (i.e. relevant allergies, medical records in case of an accident or incident, or other relevant health information) and your identification documents.
This may also encompass more technical information such as your IP address, web browser settings, and unique device identifier. Information that remains anonymous and cannot be linked to an identifiable individual is not considered personal information if it is, at all times, reasonable under the circumstances to anticipate that this information can no longer be used to directly or indirectly identify an individual, in an irreversible way.
If you have any questions or complaints about how we handle your personal information, please contact us using the contact information provided below.
3. PRIVACY OFFICER
The Vice President, Legal Affairs and Corporate Secretary of ADM, acting as the Privacy Officer, is responsible for ensuring compliance with this Policy and upholding the rights and obligations provided by applicable laws. You can contact the Privacy Officer using the information provided below:
Address: 800 Place Leigh-Capreol
Suite 1000
Dorval, Quebec H4Y 0A5
E-mail: privacy@admtl.com
If you have any questions or complaints about how we handle your personal information, please contact us using the contact information provided above.
4. COLLECTING PERSONAL INFORMATION
What type of personal information do we collect?
We only collect personal information that is reasonably necessary for the purposes for which it was collected.
Depending on your interaction with us, we may collect personal identifiers necessary to conduct our business activities, provide you with the products and services you request, administer and implement security programs, verify your identity, conduct security screening under the Transportation Security Clearance Program – Aviation Security, and investigate legal violations of the laws of Canada or Quebec in collaboration with the appropriate authorities. Additionally, we may gather information from fraud prevention purposes.
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Personal identifiers such as your name, postal address, phone number, email address, date and place of birth, national identification numbers, account number, username, or Internet Protocol (IP) addresses, signatures and photos.
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Payment information such as credit or debit card numbers used to make purchases.
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Vehicle information such as license plate number or vehicle make and model.
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Professional or employment-related information if you hold a restricted area pass.
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Travel-related information, such as your departure and destination flights, luggage weight and number, and any requests for additional searches.
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Biometric data you submit when applying for a restricted area pass.
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Information relating to activity on the Internet or other electronic networks (i.e. technical information when you visit our websites), including when you use our online products and services. This information is collected by automated means, such as cookies, authorized tokens, Web beacons and similar technologies, and may include your IP address, your device's unique identifier, browser type, data on the Web pages you have consulted on our Web sites, the time and duration of a visit, information on your location, your language preferences, and so on. For further details on how we use this type of information, please refer to the “Use of Your Personal Information” section below.
How do we collect your personal information?
We collect your personal information through various methods, both directly from you and indirectly through third parties, our websites and more generally from the following sources:
a. Directly from you
We may collect personal information directly from you in the following ways:
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When you use our products or services, visit our facilities, browse our websites, or contact us;
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When you apply for a permit or a pass and submit the necessary forms and supporting documents;
If you are a minor under the age of 14, please do not provide any personal information without the explicit consent of a parent or guardian.
b. Through our websites and applications
We or our service providers, who help us maintain and operate our websites, may also automatically collect the following information relating to your access and use of our websites through cookies, authorization tokens, web beacons and other technologies.
We may use a variety of technological methods to track the patterns of users who access and use our Web sites, including the following:
Cookies: Cookies are small data files stored on your browser to enhance your website experience. You have the right to configure your browser to accept or reject cookies. However, refusing cookies might limit your ability to fully utilize our websites.
Authorization tokens: We may allow the use of certain third-party accounts (e.g., LinkedIn, Google) for authentication and login to parts of our websites. In such cases, we may receive either your login information or an anonymous token.
Third-party web analytics: We may use automated tools and applications, such as Google Analytics and AdWords to analyze how our services and websites are used. These tools help us improve our offerings and user experience. They may use cookies and other tracking technologies to perform their services.
Location data: We may determine your device’s approximate location based on your IP address. We use this data to gauge the geographic distribution of our website visitors.
c. Through third parties
We may also obtain personal information about you from our service providers and partners, including airlines, carriers, or the Canada Border Services Agency, when you use our products or services or visit our facilities.
Additionally, when you apply for a permit or pass, we may collect information regarding your criminal record or personal and employment history from investigative agencies, relevant government authorities, or references you have provided to us.
If you are under the age of 14, we may collect your personal information directly from your parent or guardian.
5. USE OF YOUR PERSONAL INFORMATION
We may use your personal information for the following purposes, with your consent, or as permitted or required by law:
a. Safety and security purposes
We use your personal information to ensure the safety and security of our facilities and the individuals within them. For instance, we employ surveillance cameras to monitor access, exits, and activities within both public areas and areas limited to authorized individuals.
b. Common business purposes
We use your personal information for routine business purposes, such as managing our ongoing business operations and websites, delivering products or services, mitigating business risks, and securing our information, systems, infrastructures, and computer networks.
c. Research and development purposes
We use your personal information to better understand and cater to your interests and needs. This assists us in enhancing our existing products and services and developing new ones. It also aids in evaluating potential enhancements or other modifications to our website functionalities. For example, we may employ third-party web analytics services, like Google Analytics, to analyze how visitors interact with our websites. When required by law, we use anonymized information for these purposes.
d. Marketing purposes
We may use your personal information to provide you with personalized content and services, for example to tailor our products and services, our digital experience for individuals and our offers to your preferences.
We may also use your personal information to communicate with you in a variety of ways (for example, by e-mail, telephone, text message, mail or through our online individual support services) about our programs, products, services, special offers, promotions, contests, or events that may be of interest to you. If you no longer wish to receive our commercial e-mail messages, please follow the unsubscribe procedure included in each such message. For more details on this subject, see What are your privacy choices?
6. COMMUNICATION OF YOUR PERSONAL INFORMATION
We may share your personal information with service providers, but only if it is necessary to deliver the services you use, and after obtaining your consent or as required by law. We may also share your personal information with:
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Our agents, mandataries, suppliers, or other organizations that provide services to ADM or its passengers, as outlined in this Privacy Policy. This includes airlines, baggage service providers, software providers, data hosting and payment processing services, parking management, and organizations involved in managing complaints and feedback.
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Insurance companies, specifically for handling claims.
In certain situations, we may share your personal information without your consent where the law allows, including:
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Medical emergencies or situations posing a threat to individual safety.
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Compliance with legal processes such as warrants or orders from courts or regulatory authorities.
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Actions taken to recover debts.
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Investigations into breaches of agreements or laws, such as potential theft investigations.
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Requests from auditors, or for verifying applications for accreditation or granted accreditations.
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Efforts to detect, prevent, or suppress crime.
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Transactions such as business sales, asset or share transfers, mergers, or other business deals, in line with legal requirements. For example, we may provide your personal information to advisors or potential buyers of our business, if necessary for the completion of the transaction and the continuation of operations.
7. YOUR CONSENT AND CHOICES IN TERMS OF PRIVACY
By using our services, visiting our facilities, or providing us with information related to our products and services, you agree to the collection, use, and disclosure of your personal information as described in this Policy.
You have control over how ADM manages your personal information in the following ways:
a. Change of your communication preferences
If you prefer not to receive marketing or promotional messages from ADM via email, simply click “unsubscribe” in any email you receive from us.
Please be aware that even if you opt out of receiving commercial messages, we may still need to communicate with you regarding service-related issues, as permitted by applicable law.
b. Adjust your browser settings on your device
We use technologies such as cookies to enhance your individual experience and present you with tailored offers, including personalized advertising. These technologies allow our websites to recognize you when you visit or return, providing a smoother user experience. You can manage, delete, or deactivate these technologies at any time through your browser settings. However, please note that disabling these technologies might affect your ability to use certain functionalities on our websites.
For detailed instructions on how to block, delete, or manage cookies, please refer to your browser’s help section or follow the instructions provided on your browser’s official website. Quick links for managing settings in browsers like Internet Explorer, Google Chrome, Microsoft Edge, Firefox, and Safari are available.
To deactivate Google Analytics, you can download and install the Google Analytics Deactivation Browser Add-on for your browser.
c. Limiting the collection, use, and disclosure of your personal information
You have the option to withdraw your consent for the collection, use, and disclosure of your personal information in accordance with this Privacy Policy at any time. To do so, please contact us using the details provided in the Privacy Officer section above, keeping in mind that legal or contractual obligations may apply.
Be aware that withdrawing your consent may impact our ability to continue providing you with the products and services you currently enjoy or wish to receive, as ongoing use and disclosure of your information are necessary for us to deliver our services. In some cases, legal requirements may also limit your ability to withdraw your consent.
8. PERSONAL INFORMATION OUTSIDE QUEBEC OR CANADA
Your personal information may be transferred to, stored, accessed, or used in a jurisdiction different from your place of residence (i.e. outside your province, Quebec, or Canada) as part of our engagement with service providers. These providers assist us in delivering our services, such as processing payments, fulfilling orders, providing e-commerce solutions, or managing our communications.
We are committed to ensuring that all our service providers implement reasonable security measures to protect your personal information and use it solely for authorized purposes.
When your personal information is transferred outside your province or Canada, it becomes subject to the laws of the foreign jurisdiction, which may vary from those in your own jurisdiction. Under such circumstances, we strive to use contractual measures to maintain protections for your personal information that are at least equivalent to those applicable in Canada.
9. SECURITY OF YOUR PERSONAL INFORMATION
We implement robust measures and controls to safeguard your personal information. These measures include limiting physical access to our offices and files, ensuring only authorized employees or agents who require your personal information for their duties have access, and protecting against unauthorized access, disclosure, mishandling, and misuse of your information under our control. We store archival documents in secure, off-site facilities with reliable third parties and employ digital security tools such as firewalls, passwords, and file encryption for online activities.
Our objective is to prevent unauthorized access, loss, misuse, sharing, or alteration of your personal information. These safeguards are also in place when we delete or destroy your information.
To ensure the protection of your personal information, we have instituted a range of measures based on the volume and sensitivity of the data, its usage purposes, and its storage format, such as:
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Internal policies and procedures that define employee roles and responsibilities regarding personal information throughout its lifecycle and restricting access on a need-to-know basis.
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For electronically stored or collected information, we use technical security measures such as encryption, firewalls, software protection and other similar measures.
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We designate a privacy officer responsible for ensuring ADM's compliance with applicable privacy laws.
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We provide employee training focused on privacy and computer security.
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We maintain procedures for receiving, investigating, and responding to complaints or inquiries about our personal information handling practices, including any incidents involving privacy breaches.
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We adhere to specific rules regarding the retention and destruction of personal information, detailed further in the Retention of your personal information section.
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We use contractual protections and other measures to ensure that our service providers who have access to personal information adhere to adequate security standards. For example, we typically require service providers to restrict their use and retention of personal information to the necessities of their services and to report any real or suspected privacy incidents to us.
10. RETENTION OF YOUR PERSONAL INFORMATION
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by law. Once it is no longer needed, your personal information is securely destroyed or anonymized in line with applicable laws.
ADM ensures that all retained personal information is kept up-to-date, accurate, and complete for its intended purposes.
Furthermore, ADM has established a specific schedule for the retention and destruction of personal information. However, if an individual has filed an access request or a complaint, ADM will retain their personal information for as long as necessary to allow the individual to fully exercise their legal rights and recourses.
11. ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION
You have the right to inquire if we hold personal information about you and to access that information. You may also request corrections to any personal information that is inaccurate, incomplete, or outdated, although there are some exceptions under applicable law. Before addressing your request, ADM will take reasonable steps to verify your identity.
ADM will respond to your request within thirty (30) days of its receipt.
There are circumstances where ADM may refuse to provide access to personal information, such as when doing so would reveal personal information about another person, or if the disclosure is sought under conditions where an individual’s life, health, or security could be threatened.
To access or correct your personal information, or for any other inquiries regarding your individual rights, please contact us in writing at the contact details provided in the Privacy Officer section above.
Should you wish to obtain a copy of your information, a reasonable fee may be charged to cover the costs of transcription, reproduction, or transmission of the data.
12. PRIVACY INCIDENT NOTIFICATION
ADM implements necessary measures to maintain the confidentiality of your personal information.
However, despite these efforts, there may be exceptional circumstances—such as third-party negligence, natural disasters, or illegal activities—that could lead to unauthorized access, use, disclosure, or destruction of your personal information. In such cases, ADM will promptly notify and collaborate with the relevant government authorities to safeguard your data.
Should your personal information be compromised, ADM will inform you once it is determined that doing so will not hinder any internal or government investigations.
Additionally, ADM may alert any individuals or organizations that could help reduce or prevent the risks associated with the breach, sharing only the necessary personal information required for these purposes.
ADM also commits to documenting any incidents involving personal information in a confidential register, aiming for continual improvement and adherence to applicable legal standards.
13. REVIEW
ADM continuously updates its policies and procedures for protecting personal information to ensure they remain effective. In line with our governance principles, these policies are reviewed every two years.
Furthermore, we may periodically amend this Privacy Policy. Any changes will become effective once we publish the revised policy on our websites and applications. By continuing to use our services or products after these changes are posted, you are accepting the new terms.
We encourage you to regularly check the most recent version of our Privacy Policy on our website at www.admtl.com. If you wish to receive a copy of the policy by mail, you can request one using the contact details found in the Privacy Officer section.
If you disagree with any changes to our Privacy Policy, you have the responsibility to discontinue using our services or products.
14. QUESTIONS AND CONCERNS
You are welcome to contact ADM with any questions, concerns, or complaints regarding the Policy and its implementation. All such inquiries should be directed in writing to the contact details provided in the Privacy Officer section. The Privacy Officer is committed to investigating each written complaint thoroughly.
If a complaint is validated, the Privacy Officer will take the necessary actions to resolve the issue. This may include amending the Policy or its procedures to better protect personal information. The complainant will be informed in writing about the results of the investigation.
Additionally, the Privacy Officer annually reports to ADM's Board of Directors regarding the number and nature of complaints received in the previous year, as well as the actions taken in response.
15. EFFECTIVE DATE
This updated Policy becomes effective immediately upon its adoption by the Board of Directors.
