Privacy policy

Privacy Policy and Protection of Privacy (hereinafter the “Policy”)

Last updated: June 11, 2021

Auray Capital Canada Inc, Auray Capital International Inc, Auray Sourcing International Inc and Auray Sourcing Immigration Inc. (collectively “Auray” or “we”) are committed to ensuring the protection of the personal information you provide or that we collect when you visit our site.

This Policy discloses how Auray collects, uses, discloses and protects your personal information. Our practices with respect to your Personal Information comply with applicable legislation in Quebec, including the Quebec Act Respecting the Protection of Personal Information in the Private Sector (the “Act”);

All personal information is collected in a fair, reasonable, equitable and non-intrusive manner and with your consent. All personal information is collected by fair, reasonable, equitable and non-intrusive means and with your consent. The personal information collected is accessible only to those persons necessary to fulfill the purposes for which it is collected.

The personal information we collect is used for the purposes identified at the time the visitor discloses the information requested.



This Policy applies to your use of the website and the Auray Services. This Policy governs the personal information collected on the Website and any Auray application and explains how we use and disclose, if at all, the personal information we collect. It also explains how we use cookies and similar technologies.

This Policy also applies to any Personal Information collected or generated by Auray, or any authorized representative. At any time you deal with Auray or its authorized representatives, you are protected by the rights and warranties contained in this Policy.

If you have any questions about the Policy, please feel free to contact Auray’s Privacy Officer by email at


“Personal Information” means any information relating to the personal or material circumstances of an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, by reference to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

This may include, for example, your name, contact information, e-mail address and the services you use. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered personal information.


Auray is responsible for Personal Information under its control and has designated a Privacy Officer who is accountable for Auray’s compliance with this Policy and the Privacy Principles. The Privacy Officer is the person identified herein.

Auray is also responsible for Personal Information that it has transferred to a third party for any of the purposes described herein. In this regard, Auray will take reasonable steps to ensure that third parties treat Personal Information in a confidential manner, all in accordance with the Policy.

Auray shall identify the purposes for which Personal Information is collected at or before the time of collection. Some of the purposes for which Personal Information is collected, used or disclosed are described in the Policy.

In this regard, in the course of its business, Auray collects Personal Information for the following purposes only (the “Permitted Purposes”):

to establish, develop and maintain business relationships with our customers, employees and other individuals with whom we deal
to sell, improve, design or otherwise market its services
to detect and assess the interests, needs and expectations of its customers with a view to improving the services it offers or proposing new products and services
to administer and manage its business;
for internal training and quality assurance purposes;
to meet legal obligations (including the Act)

In the event that we wish to collect, use and/or disclose Personal Information for purposes other than the Authorized Purposes, Auray is committed to obtaining your consent, except as otherwise required by law.

Auray is committed to obtaining your informed consent, whether oral, written or implied, for the collection, use or disclosure of your Personal Information, except as required by law or as set out in this Policy. By completing any form on the Website or by using our services, you consent to the collection, use and disclosure of your personal information. In addition, by visiting, interacting with and/or using our Website, you agree to be bound by the terms and conditions of this Policy.

In this regard, Auray may collect, use or disclose your personal information without your consent in any of the following circumstances:

where such collection, use or disclosure is clearly in your best interests and obtaining your consent is not reasonably practicable in the circumstances, including in the case of an emergency, where the life, health or security of an individual is threatened
where such collection, use or disclosure of Confidential Information would defeat the purpose for which it was collected, used or disclosed, including preventing or hindering unlawful activity
where such collection, use or disclosure of Confidential Information is necessary to permit Auray to comply with any applicable law, subpoena, warrant or other order made by a court of competent jurisdiction.

You may withdraw your consent at any time, subject to legal restrictions and reasonable notice. However, as a result of such withdrawal, Auray may no longer be able to provide you with all of our services. You may contact Auray for information on the consequences of such withdrawal

Auray will limit the collection of Personal Information, both with respect to the type and amount of information, to that which is necessary to fulfill the Authorized Purposes, or any other purpose for which Auray has obtained your consent.

Finally, in addition to collecting Personal Information from you, Auray may also collect such information from other sources, including credit reporting agencies or from third parties claiming to be authorized to disclose such Personal Information.

Auray will not use or disclose your Personal Information for purposes other than those identified and for which it was collected, except with your prior consent or as permitted or required by law. Auray will retain your Personal Information only for as long as necessary to fulfill the purposes for which your Personal Information was collected.

For your information, you understand that Auray may disclose your Personal Information to

any third party engaged by Auray to perform services for Auray, including business improvement services operated by Auray, etc.
any third party to whom Auray may wish to sell a portion of its business or assets or any entity involved in the operational financing of Auray;
any other third party, where you consent, or where such disclosure is required by law, including disclosure at the request of law enforcement.

Only Auray employees who require access for business reasons, or whose duties reasonably so require, have access to your Personal Information.

In some cases, Personal Information may be stored or processed abroad, in which case it will be subject to the applicable laws of those countries.

Auray undertakes to retain Personal Information only for as long as it is necessary or relevant for the Authorized Purposes, or as required by law. Where Personal Information has been used to make a decision about you, Auray has an obligation to retain it for a period of time that is reasonably sufficient to allow you to exercise your right of access to the information or the reason for such decision.

Finally, Personal Information that is no longer required by Auray and for which the statutory retention periods have expired is destroyed, erased, anonymized or de-identified.

Auray will make reasonable efforts to ensure that your Personal Information is accurate, complete, current and necessary for the purposes for which we collected such Personal Information, all in order to minimize the risk that incorrect Personal Information will be used to make a decision against you.

Auray will protect your personal information by security safeguards appropriate to the sensitivity of the information.

Also, in the event that Personal Information is transferred to third parties, Auray will obtain contractual undertakings from such third parties that they will protect the Personal Information.


Subject to certain exceptions, Auray will, upon written request, disclose the existence, use and disclosure of your Personal Information and provide you with access to that Personal Information, all provided in an understandable manner, within a reasonable time and at minimal or no cost, except as required by law.

However, notwithstanding the above, in certain exceptional cases, such as where Personal Information cannot be disclosed for legal, security or commercial reasons, Auray may refuse to provide you with access to all of your Personal Information.

You have the right to challenge the accuracy and completeness of the Personal Information held by us and have the opportunity to have that Personal Information corrected as appropriate. In this regard, in the event of an error in such Personal Information, Auray will act promptly and expeditiously to correct such errors.

Finally, in order to gain access to your Personal Information, we invite you to contact the Privacy Officer at this Policy.

You have the right to address a challenge concerning our compliance with this Policy to our Privacy Officer.

In this regard, Auray shall establish mechanisms to receive and respond to all such complaints and inquiries about its personal information handling policies and practices. If Auray determines that a complaint is justified, it will take appropriate measures, including amending its policies and practices, if necessary.



We collect and use personal information that you have agreed to share directly with us or with third parties. We collect technical information through our website and social networks, using cookies and other similar technologies. You can block these cookies, but if you do so, we may not be able to provide you with all the features of our website.

The “Help” feature of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies. If you choose to withhold your consent or block cookies later, you may not be able to access some or all of the content on our website. In addition, you can disable or delete similar data used by browser add-ons by changing the add-on’s settings or by visiting its manufacturer’s website.

The terms and conditions governing your use of the Website can be found at the bottom of the Website’s home page and contain important provisions that state and exclude Auray’s liability for your use of our Website. These terms also contain provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute regarding your use of this Website. All of these provisions apply to any dispute or controversy that may arise in connection with the Policy and the collection, use and disclosure of your personal information. These terms have the same effect as if they had been reproduced in full in this Privacy Policy.



Auray may, at any time and in its sole discretion, amend this Policy. In such event, Auray will post notice of the change on its Web Site and the change will be effective as of the date of posting of the amended Policy. Auray assumes no liability to you or any other Internet user for failure to comply with the Policy.

The Policy is governed by the laws applicable in Quebec. The parties consent to the exclusive jurisdiction and venue of the courts of the Province of Quebec with respect to any matter addressed herein.

If any provision of this Agreement is found by a court of competent jurisdiction to be invalid, illegal or unenforceable in any respect, the remaining provisions shall not be affected thereby and shall remain in full force and effect.

Auray’s failure to insist upon full compliance with any term of the Policy shall not constitute a waiver of any breach thereof and shall not prevent Auray from subsequently insisting upon full compliance with such term, nor shall it constitute a waiver of the right to seek sanctions for any subsequent breach, whether or not of the same nature.