Privacy Policy and Data Governance

1. Accountability and Privacy Governance

This policy serves as my Privacy Governance Framework. It establishes my internal protocols for the lifecycle of personal information, including its secure collection, retention, and destruction, as well as my mandatory breach notification protocol.

As a professional committed to adhering to the highest standards of data privacy, I am responsible for the protection of all personal information in my custody (for example, any information I collect, use, or retain in the course of our professional interaction). In accordance with the requirements of Quebec’s Law 25, Canada’s PIPEDA, and the European Union’s GDPR, I have designated myself as the Privacy Officer (Person in Charge of the Protection of Personal Information) responsible for the protection of personal information. For any inquiries regarding this privacy policy, or to exercise your rights of access or erasure, please write to me directly at: info@dianebarbaric.ca.

2. Collection and Use of Personal Information

By voluntarily contacting me or by submitting an inquiry via this website, you provide your express and informed consent for the collection and use of your personal information. This website is intended for a professional audience; I do not knowingly collect personal information from individuals who have not reached the legal age for consent to data processing in their respective jurisdictions (for example, individuals under the age of 14 in Quebec or 16 in the European Union). If I become aware that such information has been collected without parental consent, I will take immediate steps to delete it. In accordance with the GDPR, this consent is the legal basis for the processing (the collection, use, and retention) of your personal information. You may withdraw this consent at any time. I adhere to the principles of data minimization and proportionality, collecting only the personal information required to respond to your inquiries and to facilitate our professional communication. I do not engage in individual behavioral tracking or profiling. I do not use automated decision-making or profiling systems. Website analytics are performed on an anonymous, aggregate basis (see Section 7).

3. Data Location and International Transfers

This website and all personal information collected on this site are hosted on secure servers in Canada. For ongoing professional correspondence, I utilize Swiss-domiciled, end-to-end encrypted infrastructure. Both jurisdictions benefit from a formal adequacy decision by the European Commission, in accordance with Article 45 of the GDPR. These decisions recognize that both Canada and Switzerland provide a level of protection essentially equivalent to that of the European Union, allowing personal information to be transferred from the EU without additional safeguards.

4. Data Subject Rights and Portability

In accordance with the GDPR and Canadian privacy laws, you have the right to access, rectify, request the restriction of processing, or request the erasure (the right to be forgotten) of your personal information. You also have the right to data portability, which entitles you to receive the personal information that you provided to me, and which was processed based on your express and informed consent, in a structured, commonly used, and machine-readable format.

To exercise these rights, please write to me directly. I will process your request without undue delay. Please note, however, that I may be legally or professionally obligated to retain certain records for prescribed periods to comply with regulatory, tax, or record-keeping obligations.

5. Data Retention and Destruction

In accordance with Canadian and international privacy laws, I retain personal information only for as long as necessary to fulfill the purposes of our professional interaction or to comply with legal and regulatory obligations.

Once these requirements have been met, personal information is either permanently and securely destroyed, or it is irreversibly anonymized so that you can no longer be identified, directly or indirectly.

6. Security Safeguards and Breach Protocol

I implement rigorous technical and organizational measures to protect your personal information against loss and theft, as well as against unauthorized access, disclosure, copying, use, or modification. These security safeguards include end-to-end encrypted infrastructure and zero-access architecture, ensuring that your personal information remains inaccessible to third parties, including service providers.

In the unlikely event of a confidentiality incident or data breach posing a risk of serious injury to your privacy, I will notify you and the relevant regulatory authorities without undue delay, in accordance with my legal obligations under Canadian and international law.

7. Technical Analytics

I monitor aggregate trends on this website, such as visitor volume and geographic origin by country or city. This monitoring does not allow you to be identified, located or profiled, as it does not use cookies, does not collect personal identifiers, and does not store IP addresses. Your data are anonymized and stored in aggregate format on secure servers located within the European Union.

8. Cookies and Tracking Technologies

This website does not use cookies or similar tracking technologies that require user consent under EU or Canadian law. The cookie consent pop-up or banner found on most websites is not required here because no tracking data are stored on your device during your visit.

9. Right to Lodge a Complaint

If you believe that your personal information has been mishandled, you may contact me directly to resolve the issue. You also have the right to lodge a complaint with the relevant regulatory authority, such as the Office of the Privacy Commissioner of Canada or your EU Data Protection Authority.

10. Effective Date and Governance Updates

This policy is reviewed annually to ensure ongoing compliance with international standards and technological advancements.

Effective Date: May 2, 2026
Last Reviewed: May 2, 2026

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