Privacy Policy

1. Introduction

Andes Paper Trading Inc. ("we," "us," or "our") operates the website andespapertrading.com (the "Site"). This privacy policy explains how we collect, use, disclose, and protect your personal information.

We are committed to complying with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Act respecting the protection of personal information in the private sector (commonly known as "Law 25").

2. Privacy Officer

In accordance with Quebec's Law 25, we have designated a privacy officer responsible for the protection of personal information. You may contact them for any question, access or rectification request, or complaint regarding the processing of your personal information:

• Name: Privacy Officer
• Email: info@andespapertrading.com
• Mailing address: Montreal, Quebec, Canada H2S 2S5

3. Information We Collect

3.1 Information you provide (contact form)

When you use our contact form, we collect:

• Your name
• Your email address
• The content of the message you send us

3.2 Browsing data (analytics)

We use Umami, a privacy-friendly, self-hosted web analytics tool. Umami does not set any cookies and does not track individual visitors. The data collected is anonymous and aggregated, and includes:

• Pages visited
• Referring site
• Device type, browser, and operating system (in aggregated form)
• Country of origin (inferred from IP address, which is not stored)

This data does not allow us to identify you personally.

4. Purposes of Collection

We use the information collected for the following purposes:

• Contact form: to respond to your inquiries and follow up on communications
• Analytics: to understand how the Site is used and improve its content

We do not collect information beyond what is necessary for these purposes.

5. Consent

By submitting the contact form, you expressly consent to the collection and processing of your information for the purposes described above. You may withdraw your consent at any time by contacting us (see Section 2), subject to legal or contractual restrictions.

6. Disclosure to Third Parties

We do not sell, rent, or trade your personal information.

We may disclose your information to third parties only in the following cases:

• Service providers who assist us in operating the Site (IONOS for hosting, SMTP for receiving messages)
• Legal obligations: when required by law or in response to a legitimate request from a public authority

7. Transfer of Information Outside Quebec and Canada

Important: Our Site and Umami instance are hosted in the United States by IONOS. This means your personal information may be stored or processed outside Quebec and Canada, and will then be subject to the laws of that jurisdiction, which may differ from those of Quebec.

In accordance with Law 25, we have assessed the risks associated with this transfer and implemented reasonable contractual and technical measures to protect your information. By submitting your information through our Site, you acknowledge and accept this transfer.

8. Retention of Information

We retain your personal information only for the time necessary for the purposes for which it was collected:

• Contact form messages: kept for the time necessary to handle your inquiry and any resulting business relationship; messages that do not lead to a business relationship are deleted when they are no longer needed
• Umami analytics data: anonymous data retained for statistical purposes

After these periods, information is securely destroyed or anonymized.

9. Security Measures

We implement reasonable technical and organizational measures to protect your information against loss, theft, unauthorized access, disclosure, copying, use, or modification. These measures include:

• Secure connection (HTTPS/TLS)
• Restricted access to personal information
• Regular system monitoring and updates
• Self-hosted Umami analytics to limit sharing with third parties

However, no method of electronic transmission or storage is 100% secure.

10. Your Rights

Under PIPEDA and Law 25, you have the following rights:

• Right of access to your personal information
• Right to rectification of inaccurate or incomplete information
• Right to deletion of your information, in cases provided by law
• Right to withdraw consent to processing
• Right to data portability of your information (effective September 22, 2024 in Quebec)
• Right to file a complaint with our privacy officer, or with the Commission d'accès à l'information du Québec (CAI) or the Office of the Privacy Commissioner of Canada

To exercise any of these rights, contact our privacy officer (see Section 2). We will respond to your request within 30 days.

11. Cookies

Our Site does not use any tracking or advertising cookies. The Umami analytics tool we use is designed to function without cookies.

Only strictly necessary technical cookies may be used for the proper functioning of the Site (for example, to remember your language preference). These cookies do not require your prior consent.

12. Third-Party Sites

Our Site may contain links to third-party websites. We are not responsible for the privacy practices of these sites. We encourage you to review their own privacy policies.

13. Changes to This Policy

We may modify this privacy policy at any time. Any significant changes will be posted on this page with a revised update date. We encourage you to review this policy periodically.

14. Contact

For any questions regarding this policy or the processing of your personal information:

Andes Paper Trading Inc.
Montreal, Quebec, Canada H2S 2S5
General email: info@andespapertrading.com
Privacy officer: info@andespapertrading.com

Supervisory authorities:

• Commission d'accès à l'information du Québec (CAI) — cai.gouv.qc.ca
• Office of the Privacy Commissioner of Canada — priv.gc.ca