PRIVACY POLICY
Effective date: [Month DD, 2026] Last updated: [Month DD, 2026]
This Privacy Policy explains how DJL & Co ([legal name of the entity, e.g. "DJL & Co inc." / NEQ]) (“DJL & Co”, “we”, “us”) collects, uses, shares and protects your personal information when you visit our website at www.djlandco.com (the “Site”), contact us, book a consultation, or order custom jewelry from us.
We are a jewelry design studio located in Montréal, Québec. This policy is written to comply with Québec’s Act respecting the protection of personal information in the private sector (as amended by Law 25), the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada’s Anti-Spam Legislation (CASL).
Personal information means any information that relates to you and allows you to be identified, directly or indirectly.
1. Person in charge of the protection of personal information
In accordance with Law 25, we have designated a person in charge of the protection of personal information (our “Privacy Officer”). You may contact this person for any question, request or complaint regarding this policy or your personal information:
Privacy Officer: [Full name], [Title, e.g. Owner / Designer]
Email: info@djlandco.com Phone: (438) 228-7024
Mail: DJL & Co — Privacy Officer, 171 Av. Marien, Suite 665, Montréal (Québec) H1B 5V1
2. What personal information we collect and why
We only collect the personal information that is necessary for the purposes described below. We collect it directly from you, unless stated otherwise.
Sensitive information. We do not intentionally collect sensitive personal information (such as health, financial or biometric data). If you choose to share such information during a consultation, we will use it solely to create your piece and will treat it with a higher level of confidentiality.
Minors. Our Site and services are intended for adults. We do not knowingly collect personal information from anyone under 14 without the consent of a parent or guardian.
3. Consent
By providing your personal information for the purposes described above, you consent to its collection and use for those purposes. Where required by law, we will obtain your express consent (for example, before using photos of your piece for marketing, or before sending you commercial emails).
You may withdraw your consent at any time by contacting our Privacy Officer, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may mean we can no longer provide certain services (for example, we cannot deliver an order without a shipping address).
We will not use your personal information for a new purpose that is not described in this policy without first informing you and, where required, obtaining your consent.
4. Marketing communications (CASL)
We only send commercial electronic messages (newsletters, promotions, new collections) to people who have expressly opted in, or with whom we have an existing business relationship as permitted by CASL. Every message will identify DJL & Co and include an unsubscribe link. You may also unsubscribe at any time by emailing info@djlandco.com. We will process your request within 10 business days.
5. Cookies and similar technologies
Our Site is built and hosted on the Wix platform, which uses cookies and similar technologies. Law 25 requires that any technology allowing you to be identified, located or profiled be disabled by default, and that you be informed of how to enable it. Accordingly:
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Essential cookies (security, session, load balancing, remembering your cookie choices) are always active because the Site cannot function without them.
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Analytics cookies (e.g. Wix Analytics, Google Analytics) help us understand how visitors use the Site. They are off by default and are activated only if you accept them in the cookie banner.
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Marketing cookies (e.g. Meta/Facebook Pixel, TikTok Pixel) allow us to measure and personalize our advertising on social media. They are off by default and are activated only if you accept them in the cookie banner.
You can change your choices at any time through the cookie settings link at the bottom of the Site, or by adjusting your browser settings. Blocking essential cookies may prevent parts of the Site from working.
[Agency note — confirm in the Wix dashboard which cookies/pixels are actually installed (Wix Analytics, GA4, Meta Pixel, TikTok Pixel) and enable the Wix consent banner with non-essential categories set to OFF by default. Delete the bullets that do not apply.]
6. Who we share your information with
We do not sell, rent or trade your personal information. We share it only with service providers who need it to help us operate our business, and who are bound by contract to protect it and to use it only for the services they provide to us:
We may also disclose personal information when required by law, to respond to a lawful request from a public authority, to protect our rights or safety, or as part of a business transaction (sale or merger), in which case the recipient will be bound by this policy.
Transfers outside Québec
Some of the providers listed above store or process personal information outside Québec, notably in the United States. Before communicating personal information outside Québec, we conduct a privacy impact assessment as required by Law 25 to ensure the information receives adequate protection, taking into account the sensitivity of the information, the purposes of its use, the safeguards in place and the legal framework of the destination. Our transfers are governed by written agreements that require the recipient to protect your information to a standard comparable to Québec law.
7. How long we keep your information
We keep personal information only for as long as necessary to fulfil the purposes for which it was collected, and to meet our legal obligations. In general:
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Inquiries and consultations that do not lead to an order: up to 24 months after our last exchange, so that we can follow up if you come back to us.
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Orders, invoices and design records: 7 years after the transaction, as required by Canadian and Québec tax legislation, and to honour warranties, resizing and repairs.
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Marketing consents: until you unsubscribe, then a record of your unsubscribe request is kept to ensure we honour it.
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Analytics and cookie data: according to the retention periods set by the relevant provider, generally between 13 and 26 months.
Once the retention period has expired, we securely destroy the information or anonymize it in accordance with the law.
8. How we protect your information
We apply security measures that are reasonable given the sensitivity of the information, including: encryption of the Site (HTTPS/TLS), password-protected accounts with restricted access for our team, secure third-party platforms for hosting and payments, and physical safeguards for paper records at our studio. Only people who need access to your information to perform their duties have access to it.
Although we take these precautions, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Confidentiality incidents
If we become aware of a confidentiality incident involving your personal information (unauthorized access, use, disclosure or loss), we will take reasonable measures to reduce the risk of harm, record the incident in our incident register, and — where the incident presents a risk of serious injury — notify the Commission d’accès à l’information du Québec and the persons concerned, as required by law.
10. Automated decision-making and profiling
We do not make decisions based exclusively on automated processing of your personal information. We do not use technology to profile you unless you have accepted marketing cookies (section 5), in which case profiling is limited to advertising measurement and personalization by the social media platforms.
11. Your rights
Subject to the exceptions provided by law, you have the right to:
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Access the personal information we hold about you and obtain a copy.
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Rectify information that is inaccurate, incomplete or ambiguous.
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Withdraw your consent to the use or disclosure of your information.
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Request deletion (de-indexing) of your information in the circumstances provided by Law 25, notably where the purpose has been fulfilled or the information was collected unlawfully.
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Data portability: obtain the computerized personal information you provided to us in a structured, commonly used technological format, or ask us to transmit it to another organization.
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Be informed of how your information is used, who has access to it, and how long it is kept.
To exercise any of these rights, contact our Privacy Officer using the details in section 1. We may need to verify your identity before responding. We will respond in writing within 30 days of receiving your request. If we refuse a request in whole or in part, we will give you the reasons and inform you of your remedies.
Complaints. If you are not satisfied with how we handle your personal information or your request, you may file a complaint with our Privacy Officer, and you may also contact the Commission d’accès à l’information du Québec (www.cai.gouv.qc.ca, 1-888-528-7741) or the Office of the Privacy Commissioner of Canada (www.priv.gc.ca).
12. Links to other sites and social media
Our Site contains links to our pages on Instagram, Facebook and TikTok, and may contain links to other websites. These platforms have their own privacy practices, which we do not control. We encourage you to read their privacy policies. When you interact with us through social media, the platform may also collect your information according to its own policy.
13. Changes to this policy
We may update this policy from time to time to reflect changes in our practices or in the law. The most recent version, identified by its effective date, will always be posted on the Site. If a change significantly affects how we use your personal information, we will notify you by a notice on the Site or by email where appropriate.
14. Language
This policy is available in French and in English. In case of discrepancy between the two versions, the French version prevails, as required by the Charter of the French Language.
Contact — DJL & Co, 171 Av. Marien, Suite 665, Montréal (Québec) H1B 5V1 · info@djlandco.com · (438) 228-7024
Implementation checklist for the agency (remove before publishing)
Items that must be completed or confirmed with the client for this policy to be accurate and Law 25-compliant:
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Confirm the legal entity name and NEQ, and the name/title of the Privacy Officer. Law 25 requires the title and contact details of the person in charge to be published on the website (by default it is the highest-ranking person in the business).
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Publish the policy on the Site (footer link) in French — Bill 96 / Charter requires the French version; the English version is optional. This English draft should be translated and the French version made the prevailing one.
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Enable the Wix consent banner with analytics and marketing cookies OFF by default; verify which pixels are actually installed and align section 5 and the provider table.
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Confirm the payment processor, newsletter tool, shipping carrier and accounting provider, and fill in the provider table.
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Complete a short Privacy Impact Assessment (PIA) for transfers outside Québec (Wix, Meta, TikTok, payment processor) and keep it on file; a lightweight template is sufficient for a business of this size.
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Fix the placeholder email on the Contact page (currently points to info@mysite.com) and add a consent checkbox to the contact form if it will be used to subscribe people to marketing.
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Create an internal incident register (a simple spreadsheet is enough) and a written consent from clients before posting photos of their pieces.
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Set a retention/deletion routine (e.g. annual purge of stale inquiries in Wix Contacts).
