1. Person in Charge of Processing
Turkey Hill Sugarbush LTD. (referred to in this policy as "we," "us," or "our") operates the website you are currently visiting. We are subject to Quebec Law 25 (An Act to modernize legislative provisions as regards the protection of personal information, S.Q. 2021, c. 25), which governs how we collect, use, disclose, and protect your personal information.
This Privacy Policy explains what personal information we collect about you, why we collect it, who we share it with, and what rights you have under Quebec Law 25. By using our website, you acknowledge that you have read and understood this policy.
2. Personal Information Collected
We collect the following categories of personal information when you visit or interact with our website:
- Device and network identifiers — your IP address and device identifiers, collected automatically when you load any page on our site.
- Browsing behavior — pages you visit, how long you spend on each page, navigation paths, and interactions with site content.
- Approximate location — a general geographic location derived from your IP address (city or region level; not precise GPS coordinates).
- Session data — session duration and frequency of visits, used to understand overall traffic patterns.
- Advertising identifiers — identifiers associated with your browser or device used for ad targeting and conversion tracking, collected only if you consent to Marketing cookies.
- Social identifiers — identifiers linked to your social media profile (e.g., Facebook user ID) if you interact with social features on our site, collected only if you consent to Marketing cookies.
- Consent preferences — your cookie consent choices, stored locally in your browser to remember your selections across visits.
We do not knowingly collect sensitive personal information such as health data, financial account numbers, or government-issued identification numbers through this website.
3. Purposes of Processing
We process your personal information only for the purposes described below. Each purpose is tied to a legal basis under Quebec Law 25.
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Website operation and security (Essential) — We use session data and IP addresses to keep the site functioning correctly, prevent fraud, and maintain security. This processing is necessary for the operation of our website and does not require your consent. The Moelleux consent management platform (operated by Horizon-Cumulus, Joliette, Quebec) stores your cookie preferences for 13 months using a cookie named moelleux_{site_key} so you do not have to re-select your choices on every visit.
Legal basis: Legitimate interest in operating a secure, functional website. -
Audience measurement and site performance (Analytics) — We use Google Analytics 4 to understand how visitors use our site — which pages are most visited, how long people stay, and where traffic comes from. This helps us improve our content and user experience. This processing occurs only if you consent to Analytics cookies.
Legal basis: Consent. -
Advertising and remarketing (Marketing) — We use the Meta Pixel (Facebook) to measure the effectiveness of our advertising campaigns, track conversions, and show relevant ads to people who have previously visited our site. This processing occurs only if you consent to Marketing cookies.
Legal basis: Consent. -
Website display and typography (Functional) — We use Google Fonts and Adobe Fonts (Typekit) to load the typefaces that give our website its visual appearance. When your browser requests a font file, your IP address is transmitted to the font provider's servers. This processing occurs only if you consent to Functional cookies.
Legal basis: Consent.
4. Third Parties and Processors
We work with the following third-party service providers. Each one receives only the personal information necessary to perform its function.
| Service | Purpose | Category | Transfer Outside Quebec |
|---|---|---|---|
| Moelleux (by Horizon-Cumulus) | Consent management and privacy policy hosting; consent records stored in Quebec (OVH Beauharnois) | Essential | No — data stays in Quebec |
| Google Analytics 4 | Audience measurement and traffic analysis | Analytics | Yes — United States |
| Meta Pixel (Facebook) | Conversion tracking, remarketing, and ad campaign optimization | Marketing | Yes — United States |
| Google Fonts | Web font delivery for site typography | Functional | Yes — United States |
| Adobe Fonts (Typekit) | Web font delivery for site typography | Functional | Yes — United States |
We do not sell your personal information to any third party.
5. Transfers Outside Quebec
Several of our third-party service providers process personal information outside Quebec — specifically in the United States. Under section 17 of Quebec Law 25, we are required to inform you of these transfers and to take steps to ensure your personal information receives an adequate level of protection.
The services that transfer personal information to the United States are:
- Google Analytics 4 (Google LLC, United States) — your device identifiers, IP address, browsing behavior, session data, and approximate location may be processed on Google's servers in the United States. Google's data processing terms incorporate standard contractual clauses and other safeguards.
- Meta Pixel (Facebook) (Meta Platforms, Inc., United States) — your device identifiers, IP address, browsing behavior, advertising identifiers, and social identifiers may be processed on Meta's servers in the United States. Meta's data processing terms incorporate standard contractual clauses and other safeguards.
- Google Fonts (Google LLC, United States) — your IP address is transmitted to Google's servers when font files are loaded. Google's terms apply to this processing.
- Adobe Fonts / Typekit (Adobe Inc., United States) — your IP address is transmitted to Adobe's servers when font files are loaded. Adobe's terms apply to this processing.
Before activating these services, we conducted or reviewed a Privacy Impact Assessment (PIA) to evaluate the risks associated with transferring personal information outside Quebec, as required by Quebec Law 25. We activate Analytics and Marketing services only after obtaining your consent through our cookie banner.
Please be aware that privacy laws in the United States may differ from those in Quebec and may not offer the same level of protection. By consenting to Analytics, Marketing, or Functional cookies, you acknowledge that your personal information may be transferred to and processed in the United States under the conditions described above.
6. Retention Period
We retain personal information only for as long as necessary to fulfill the purposes described in this policy or as required by law.
| Data Type | Retention Period | Justification |
|---|---|---|
| Cookie consent preferences (Moelleux) | 13 months | Standard consent-record retention period; allows us to honor your choices without asking again on every visit |
| Analytics data (Google Analytics 4) | Up to 14 months (configurable in Google Analytics settings) | Sufficient to identify seasonal traffic trends relevant to a restaurant and sugarbush operation; data is aggregated and anonymized after this period |
| Marketing / advertising data (Meta Pixel) | Up to 180 days (Meta platform default for event data) | Required for conversion attribution and remarketing audience building; governed by Meta's data retention policies |
| IP addresses logged by font providers (Google Fonts, Adobe Fonts) | Short-term server logs, typically up to 30 days | Standard server log retention for security and debugging; governed by Google's and Adobe's respective policies |
When personal information is no longer needed, it is deleted, anonymized, or aggregated so that it can no longer identify you.
7. Your Rights
Under Quebec Law 25, you have the following rights regarding your personal information. To exercise any of these rights, please contact us using the information in Section 8. We will respond within 30 days of receiving your request.
- Right of access — You may ask us to confirm whether we hold personal information about you and to receive a copy of that information in a clear and understandable format.
- Right of rectification — If any personal information we hold about you is inaccurate, incomplete, or ambiguous, you may ask us to correct it.
- Right to erasure (de-indexing) — In certain circumstances — for example, if the information was collected unlawfully or is no longer necessary for the purpose for which it was collected — you may ask us to delete your personal information.
- Right to portability — You may ask us to provide you with the personal information you have communicated to us in a structured, commonly used technological format, or to transmit it directly to another organization where technically feasible.
- Right to withdraw consent — Where we rely on your consent to process your personal information (Analytics, Marketing, and Functional cookies), you may withdraw that consent at any time by updating your cookie preferences through our consent banner. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
If you believe your rights have not been respected, you have the right to file a complaint with the Quebec Information Access Commission (CAI) at https://www.cai.gouv.qc.ca.
8. Person Responsible for the Protection of Personal Information
In accordance with section 3.1 of Quebec Law 25, Turkey Hill Sugarbush LTD. has designated a Person responsible for the protection of personal information. This person is your primary point of contact for any question, request, or concern related to your personal information.
- Name: Jaana Tornikoski
- Title / Role: --
- Email: rp@turkeyhill.ca
- Phone: (450) 539-4822
We will acknowledge your request promptly and provide a substantive response within 30 days, as required by Quebec Law 25. If your request is complex or if we receive a high volume of requests, we may extend this period by an additional 30 days, in which case we will notify you of the extension and the reason for it.
9. Effective Date and Versioning
This Privacy Policy takes effect on 16 juin 2026 and supersedes any previous version of our privacy policy.
Version: 1
We may update this policy from time to time to reflect changes in our practices, the services we use, or applicable law. When we make material changes, we will update the effective date above and, where appropriate, notify you through our website. We encourage you to review this policy periodically.