Effective date: 28 September 2026. Hebrew Free Loan Association Montreal (“HFLA”, “we”, “us”) is committed to protecting your personal information. This policy explains what personal information we collect, why, how we use and protect it, who we share it with, and the rights you have. It is provided in accordance with Quebec’s Act respecting the protection of personal information in the private sector (Law 25).

Person responsible for the protection of personal information

We have designated a person responsible for the protection of personal information within our organization:
Valerie Abitbol — Privacy Officer, Hebrew Free Loan Association
Email: info@hflamtl.org
You may contact our Privacy Officer with any question about this policy or to exercise your rights (described below).

What personal information we collect

Depending on your relationship with us, we may collect:
• Identity & contact information — name, address, email, telephone, date of birth;
• Loan-application information — financial details, employment and income, and information about guarantors/endorsers;
• Sensitive identifiers — where required to assess or administer a loan, government identifiers (such as health-insurance or driver’s-licence numbers) and banking details;
• Donation information — donations and the details needed to issue tax receipts;
• Website information — what you submit through our forms, and limited technical data (see “Cookies and analytics”).
We collect only the personal information necessary for the purposes described below.

Why we collect it

We use personal information to:
1. assess, grant, and administer interest-free loans, including verifying identity and eligibility and managing repayment;
2. process donations and issue tax receipts;
3. communicate with you and respond to your requests;
4. operate, secure, and improve our website and services;
5. meet our legal, accounting, and regulatory obligations.
We will not use your personal information for a new purpose without your consent, unless the law permits it.

Consent

We collect, use, and disclose personal information with your consent. Where the information is sensitive (for example, financial or government-identifier information), we obtain your express consent. You may withdraw your consent at any time by contacting our Privacy Officer, subject to legal or contractual limits; withdrawing consent may prevent us from providing certain services. We do not sell your personal information.

Who we share it with, and transfers outside Québec

We share personal information only as needed with service providers who process it on our behalf under contract — for example our website and database host, our payment processor (Stripe), our email provider (Microsoft 365), our newsletter tool (Constant Contact), and website analytics (Google, only with your consent). Some of these providers are located outside Québec, including in the United States. Before communicating personal information outside Québec, we assess whether it will receive adequate protection and put appropriate contractual safeguards in place. We may also disclose personal information where required by law.

How long we keep it

We keep personal information only as long as necessary for the purposes for which it was collected, and to meet our legal and financial-record obligations. When it is no longer needed, we securely destroy or anonymize it. Retention periods vary by record type (for example, loan and donation records are kept for the periods required by applicable financial and tax rules).

How we protect it

We use reasonable physical, technical, and organizational measures to protect personal information, including access controls and encryption of sensitive fields — such as government-identifier and banking information — at rest. Access is limited to those who need it to carry out their work.

Cookies and analytics

Our website uses essential cookies needed for the site to function. With your consent, we also use analytics cookies (Google Analytics) to understand how our site is used; these stay off unless you accept them through our cookie banner, and you can change your choice at any time. You may also set your browser to refuse cookies, though some features may not work.

Your rights

Subject to applicable law, you have the right to:
• access the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request portability of the computerized personal information you provided to us, in a structured, commonly used technological format;
• withdraw your consent;
• request that we stop disseminating your information, or de-index a link, where the law allows.
To exercise any of these rights, contact our Privacy Officer at info@hflamtl.org. We will respond within the time required by law (generally 30 days). If you are not satisfied with our response, you may file a complaint with the Commission d’accès à l’information du Québec (CAI).

Changes to this policy

We may update this policy from time to time. The effective date above shows when it was last revised, and we will not reduce your rights without your consent.

How to contact us

For any question about this policy or our handling of your personal information, contact our Privacy Officer, Valerie Abitbol, at info@hflamtl.org.