Synex Business Performance Inc. and its partner firms Synex Insurance and Synex Group Solutions (hereinafter "Synex") recognizes the importance of privacy and is committed to protecting the personal information it collects and processes in the course of its activities.
The purpose of the Personal Information Protection Policy (hereinafter the "Policy") is to set out the principles applied by Synex with respect to the personal information protection practices (hereinafter the "PRI") of Data Subjects.
The Policy describes the PRI standards and practices applied by Synex in order to:
This Policy applies to any identified or identifiable individual about whom Synex collects Personal Information in the course of its business.
The Policy reflects Synex's ongoing commitment to comply with the PRI requirements of the following persons:
(Collectively, the "Data Subjects")
Guiding principles: Synex's PRI practices are defined and applied in accordance with the following PRI guiding principles, consistent with applicable law:
Accountability: Synex is responsible for the handling of PRP in its possession, including information that is entrusted to third parties. A Privacy Officer, whose contact details can be found in paragraph 7, has been appointed and ensures that the Policy is applied and that Synex complies with applicable laws and regulations relating to PRP.
Purposes of Collection: Synex identifies the purposes for which it collects, uses, discloses and retains PRP before collecting it. Synex ensures that it only collects PR that is necessary to fulfill the predetermined purposes. The purposes for which PR will be used will be specifically identified at the time of collection. As of the date of adoption of the Policy, the purposes for which PR is used include, but are not limited to:
Collection: Synex limits the collection of PI to that which is necessary for the identified purposes. Synex collects PR directly from the Data Subject, unless it has obtained the Data Subject's consent to collect PR from third parties or is otherwise permitted by law. Synex may also receive PR from its partners.
Limiting use, disclosure and storage
Limitation: Synex restricts the use of PR to the purposes for which it was collected and to which the Data Subject has consented, subject to exceptions provided by law or to obtaining new consent.
Synex limits access to the PR it holds to only those persons for whom access is required for the performance of their duties and provides PRP training to its staff. Synex employees are also bound by a confidentiality undertaking, which covers in particular the confidentiality of PR processed in the course of their duties.
Communication: Synex may communicate the PR of Data Subjects to various business partners, suppliers or other third parties in the course of its activities. It may also disclose to courts, regulators, government officials or prosecutors, or any other investigative or law enforcement party. Synex ensures that PR is only disclosed for the purposes identified and consented to by the Data Subject, unless the Data Subject gives consent to the new purposes or unless exceptions are provided by law.
Retention: Synex uses systems and technology service providers that ensure the retention of Data Subjects' PR in a manner that maintains its confidentiality. Synex retains data and documents containing PR for the length of time necessary to fulfill the purpose for which it was collected and for the retention periods required by law.
PR is generally kept in the province of Quebec. It is possible, however, that the disclosure of PR to certain service providers may result in the transfer of PR outside of Quebec, in which case Synex will consult the applicable PRP laws and practices in the relevant jurisdiction and ensure that PR is adequately protected through a privacy impact assessment and that the contractual framework stipulates appropriate PRP commitments.
Security measures: Synex applies security measures that are proportionate to the sensitivity of the PR it holds in order to prevent breaches of confidentiality and integrity, in accordance with its information security frameworks.
Transparency: Synex documents its PR management practices simply and clearly, and makes them available on its websites. Synex provides the prescribed information to the Data Subject when the collection is made through the use of technology that includes functionalities that allow the Data Subject to be identified, located or profiled through the use of technology.
Rights of Data Subjects: Synex has procedures in place to deal with requests for the exercise of rights by Data Subjects, including requests for access, rectification and withdrawal of consent. Requests for the exercise of rights must be forwarded to the office of the PRP Manager, whose contact details appear in paragraph 7, for processing in accordance with the law.
Synex respects the rights granted to Data Subjects in respect of their PRP and has procedures in place to deal with the following requests:
Synex will respond to all requests within 30 days of receipt of such a request. Where Synex is unable to meet this deadline, or if additional time is required to satisfy a request, it will inform the Person concerned in writing.
Synex has appointed a Privacy Officer who is responsible for Synex's compliance with applicable privacy legislation.
If you have any questions regarding the collection, use, disclosure or retention of PR by Synex, you may contact the PRP Officer as indicated below:
Privacy Officer
Civic address: 2828, boul. Laurier, Suite 1300,
Quebec City, Quebec G1V 0B9
Phone: 1-866-321-2233
E-mail: confidentialite@synexcorp.ca
This Policy has been adopted by the Synex Executive Board and takes effect on the date of adoption. It replaces all previous versions. Historical versions of the Policy may be obtained from the PRP Manager upon request. The collection, use, disclosure and other processing of a Data Subject's PRP by Synex will be governed by the version of the Policy in effect at the time of processing.
The PRP Manager is responsible for the Policy and its revision. The Policy may be amended at Synex's discretion to reflect changes in applicable requirements or Synex's practices and will be reviewed at least every three years.
1. OBJECTIVES
The Complaint Handling and Dispute Resolution Policy (hereinafter referred to as the “Policy”) aims to establish a fair and free procedure for our clients to ensure that complaints received by SYNEX COLLECTIVE SOLUTIONS or one of its partner firms (hereinafter referred to as “the firm”) are properly addressed.
It also seeks to improve our services by identifying common causes of complaints and implementing solutions to correct problematic situations.
2. DEFINITION
A complaint expresses dissatisfaction or criticism regarding one of our services or products. It is submitted by a client who expects the firm to take action to resolve it.
The following communications are NOT considered complaints:
- A request for information or documents about a product or service offered
- A claim for compensation or insurance
- A request to correct an administrative error, such as a transcription mistake or miscalculation
- A request to access or modify personal information
- A comment or remark about our organization
For example, when you request a refund or expect us to take action to resolve the issue that led to the complaint.
3. COMPLAINT HANDLING PROCESS
HOW TO SUBMIT A COMPLAINT
You may submit your complaint using the method most convenient for you.
Contact Information:
- Phone: 1-866-321-2233
- Email: plainte@synexcorp.ca
- Address: 2828 Laurier Blvd, Suite 1300, Québec (Québec) G1V 0B9
Office hours: Monday to Friday, 8:30 AM to 4:30 PM
Questions? Contact us to learn more about how we handle complaints.
You may also complete the Financial Markets Authority (AMF) complaint form, and we remain available to assist you.
COMPLAINT HANDLING STEPS
SYNEX COLLECTIVE SOLUTIONS and its partner firms may resolve certain complaints through a simplified process, described later in this policy. If your complaint cannot be resolved this way due to its nature or complexity, it will follow these steps:
- Receipt of Complaint
You will receive an acknowledgment within 10 days of submitting your complaint.
If the complaint is incomplete, you will receive a request for additional information, which must be provided within 10 business days. Otherwise, the complaint will be considered abandoned.
- Complaint Analysis
We will analyze your complaint to understand your expectations. To avoid delays, we may contact you for additional information.
- Final Written Response
Within 60 days* of receiving your complaint, you will receive a final written response explaining:
- How the complaint was analyzed
- The elements considered in our response
- If applicable, the proposed solution
*If your complaint is complex or requires more time, SYNEX COLLECTIVE SOLUTIONS will notify you in writing, explaining the reasons for an extension of up to 30 additional days.
- Evaluation and Resolution
We encourage you to review our final response carefully.
You must respond within 30 days unless you request a reasonable extension in writing. You may:
- Accept the offer
- Refuse the offer
- Submit a counter-offer
Once an agreement is reached, SYNEX COLLECTIVE SOLUTIONS will implement the resolution within 30 days unless a different timeline is agreed upon for your benefit.
If no response is received within the prescribed timeframes, SYNEX COLLECTIVE SOLUTIONS may be forced to close your complaint file.
COMPLAINT FILE MANAGEMENT
Each complaint must have a separate file containing all relevant information and documents.
TRANSMISSION TO THE AUTHORITY
If you are dissatisfied with the final position or complaint handling, you may request that the file be transferred to the Financial Markets Authority at any time.
The file includes all relevant information and must be sent within 15 days of your request.
SIMPLIFIED COMPLAINT PROCESS
Some complaints may be resolved through a simplified process if we can offer:
- A satisfactory solution or explanation
- A resolution within 20 days
- Handling by a customer service representative (e.g., during a phone call)
If we cannot resolve your complaint through this process, we will inform you in writing.
The simplified process does not affect our commitment to provide a final written response within the prescribed timeframe.
4. COMPLAINTS OFFICER
The firm has appointed a Complaints Officer to ensure SYNEX COLLECTIVE SOLUTIONS and its partner firms comply with applicable laws regarding complaint handling and dispute resolution.
The officer acts as the liaison with the Financial Markets Authority and ensures staff are informed and the policy is properly applied.
5. POLICY ADOPTION AND MODIFICATION
This Policy was adopted by the Synex Executive Council and takes effect on July 1, 2025. It replaces all previous versions.
The version history is available upon request from the Complaints and Dispute Resolution Officer.
The Officer is responsible for the Policy and its review. The Policy may be amended at Synex’s discretion to reflect changes in applicable requirements or practices and will be reviewed at least every three years.
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