Data Retention Policy
Entreprises Netcap Inc. (DBA Newind / Newind Marketing)
Last updated:  2026/ 01/ 03

1. Purpose

This Data Retention Policy (“Policy”) outlines the practices of Entreprises Netcap Inc., doing business as Newind / Newind Marketing, regarding the retention, storage, and destruction of personal information, in accordance with Québec’s Law 25.

This Policy aims to ensure that personal information is retained only for as long as necessary for the purposes for which it was collected and is securely destroyed when no longer required.

2. Scope

This Policy applies to all personal information collected in connection with:

  • The website thenewind.com
  • The products and technology platforms Newind Engine
  • Contact forms
  • Analytics tools (e.g., Google Analytics, cookies)
  • Internal business operations

It also applies to personal information processed on behalf of clients, subject to applicable contractual agreements.

3. General Principles

We apply the following principles:

  • Limiting retention to defined purposes
  • Data minimization
  • Securing data throughout its lifecycle
  • Secure destruction once purposes are fulfilled

4. Retention Periods

a) Website contact form data (thenewind.com)

  • Type: name, email, phone number
  • Purpose: responding to inquiries
  • Retention: up to 24 months after last contact, unless an ongoing business relationship exists

b) Analytics data (cookies, Google Analytics)

  • Type: IP address, browsing behavior
  • Purpose: website and product performance analysis and improvement
  • Retention: based on tool configuration, generally from 2 to 14 months, including the minimum configurable duration (2 months) and the default recommended period from Google Analytics

c) Communications

  • Type: email exchanges or form submissions
  • Purpose: follow-up and customer service
  • Retention: up to 36 months, unless otherwise required by law

5. Data Processed on Behalf of Clients

When we process personal information on behalf of our clients:

  • We act as a service provider within the meaning of Law 25
  • Retention periods are determined by the client
  • Contractual agreements take precedence over this Policy

We commit to:

  • Retaining data only for the duration necessary to fulfill the mandate
  • Destroying data at the end of the mandate in accordance with client instructions

6. Data Storage and Location

Personal information is hosted and stored on secure infrastructure provided by OVHcloud, including at the Beauharnois data center in Québec, Canada.

We prioritize hosting data in Québec to ensure stronger legal control and compliance with Law 25 requirements.

7. Financial Data

We do not collect or retain sensitive financial information as part of our regular operations, including:

  • Credit card numbers
  • Banking information

Where applicable, payments are processed through secure third-party providers. No payment data is stored on our internal systems.

8. Use of Data in Client Mandates

Personal information provided by our clients, as well as data relating to their own customers, is:

  • Used strictly within the scope of the specific mandate assigned
  • Limited to purposes defined by the client
  • Processed in accordance with client instructions and applicable legal requirements

We commit not to use such data for any other purpose or for our own benefit.

9. Security Measures

Personal information is:

  • Stored in secure environments
  • Protected against unauthorized access
  • Accessible only to authorized personnel

10. Destruction and Anonymization

At the end of the retention period:

  • Data is securely deleted
  • Or irreversibly anonymized when used for statistical purposes

11. Data Outside Québec

In some cases, certain service providers may process data outside Québec. Where applicable:

  • A privacy impact assessment (PIA) is conducted
  • Appropriate contractual safeguards are implemented

12. Review and Updates

This Policy is reviewed periodically to reflect legal, technological, or operational changes.

13. Privacy Officer

The Privacy Officer is responsible for enforcing this Policy.

Entreprises Netcap Inc.
461 Chem. de la Grande-Côte, Suite 204
Rosemère, Québec, J7A 1L3
Email: philippe.baron@thenewind.com

Acknowledgment

By using the website thenewind.com or the products Newind Engine, you acknowledge that your personal information is retained in accordance with this Policy.