GROUPE NORDIQUE

Privacy and Personal Information Protection Policy

1. Introduction

Purpose of this Policy

The protection of privacy is important to Location Nordique Inc. (hereinafter the « Company », « We », « Our », « Us »). For this reason, We have implemented safeguards and sound management practices for Your Personal Information in accordance with applicable laws in Quebec and Canada.

Complementary to the Terms and Conditions

This Privacy Policy (the « Policy »), which must be read in conjunction with Our Terms and Conditions, describes Our practices regarding the collection, use, processing, communication, retention, and destruction of Personal Information of individuals benefiting from Our Services, visitors to this Website, and its users (hereinafter « You », « Your »).

By using our website https://www.equipementsnordiques.com (the « Website ») or any of Our Services, You agree that We may collect, use, disclose, communicate, and retain (hereinafter « Processing » or « Process ») Your Personal Information in accordance with the terms described herein. If You do not agree to comply with and be bound by this Policy, You are not authorized to visit, access, or use Our Website or Our Services, or to share Your Personal Information with Us.

Limits of the Policy

This Policy does not apply to the Personal Information of the Company’s employees, representatives, and consultants, or any other person affiliated with the Company, nor to any information that does not constitute Personal Information as defined by applicable laws in Quebec and Canada.

2. Person in charge of the protection of Personal Information

Contact Information for the Person in charge of Personal Information Protection

All comments, questions, and complaints regarding the Policy and the Company’s privacy practices may be addressed to Our Person in charge of the protection of Personal Information at the following coordinates:
Name: Gabriel Morin
Title: Person in charge of the protection of Personal Information
Email: gmorin@grnordique.ca
Address: 440 Holliday, C.P. 1200 Sept-Îles (Québec) G4R 4X6

3. Definitions

Definitions of certain concepts or expressions

The following concepts and expressions, when they appear with a capitalized initial letter in the Policy, shall have the meaning attributed to them below, unless there is an implicit or explicit deviation in the text:

« Company », « We », « Our », « Us »: Location Nordique Inc.
« Service Provider »: any natural or legal person who Processes Personal Information on behalf of the Company.
« Cookie Banner »: pop-up window requesting Your consent to certain collections of Your Personal Information on the Website.
« Personal Information Governance and Management Policy »: document describing Our rules framing Our governance of Your Personal Information.
« Personal Information »: any information that concerns a natural person and allows them to be identified.
« Person in charge of the protection of Personal Information »: the person responsible for the application of this Policy and whose contact information is identified in Section 2 of this Policy.
« Services »: Services refers to the Website applications, Our social media pages, and all programs and services provided to You there, such as: allowing You to view Our service offerings; allowing You to be informed about Our activities; allowing and inviting You to apply for Our jobs.
« Website »: This website, which is https://www.equipementsnordiques.com/.
« Cookie »: Cookies are text files installed on Your computer or mobile device.
« Process », « Processing »: Concept encompassing all operations that may affect or concern Personal Information, including: collection, use, retention, destruction, communication, or transmission.
« You », « Your »: The individuals benefiting from Our Services, the visitors to the Website, and all users utilizing the Company’s Services.

4. Processing of Personal Information

4.1 Collection of Personal Information

Categories of Information Collected

In the context of Our activities, We may collect and Process different types of Personal Information including the information listed below:

Your contact information and identifiers, including Your first and last name, Your address, Your email address, Your phone number, and Your postal code;
information necessary for the provision of Our Services, such as information concerning the Services We have rendered to You;
information You choose to provide or transmit to Us, for example, when You contact Us by phone or on Our Website, fill out a form, respond to surveys, apply for one of Our job offers, or otherwise communicate with one of Our employees or representatives;
information collected automatically when using the Website and Our Services, including:
- connection information and other information about Your activities on the Website, such as Your IP address, the pages You viewed, the time and date of Your visits, the number of connections, the type of browser You use, the operating system of Your device, and other hardware and software information;
- geolocation data, precise or approximate location determined from Your IP address or Your device’s GPS if You wish to locate Our establishments (depending on Your device settings).

Receipt of Personal Information from Third Parties

Certain service providers communicate Personal Information to Us, such as: Names and surnames, addresses, email addresses, phone numbers, and postal codes.

Limitation of Processing to Necessary and Legitimate Purposes

In each case, this Personal Information is Processed in accordance with the legitimate and necessary purposes listed in Section 4.2 below.

4.2 Use of Personal Information

Purposes of Personal Information

We may use Your Personal Information for the purposes described below:

to operate, maintain, supervise, develop, improve, and offer the functionalities of Our Website;
to present and provide Our Services to You;
to perform Our contractual obligations towards You;
to develop, improve, and offer new Services;
to send You messages, updates, and security alerts;
for marketing and business development purposes, if You have previously consented to the Processing of Your Personal Information for these purposes;
to answer Your questions and provide You with assistance as needed;
to conduct research, analysis, and statistics related to Our Company and Our Services;
to optimize Our digital advertising strategies;
to detect and prevent fraud, errors, spam, abuse, security incidents, and other harmful activities; and
for any other purpose required or permitted by applicable laws.

4.3 Communication and Transfer of Personal Information.

Communications to Third Parties

We may transfer, communicate, or allow access to Your Personal Information to Our employees (particularly the marketing and sales departments) as well as Our Service Providers, who need this information to help Us operate Our Website, perform Our Services, carry out Our activities, or serve You.

Safeguards when Communicating to Third Parties

We only communicate Your Personal Information to Our Service Providers if they have previously committed in writing to ensure the confidentiality of Your Personal Information in accordance with applicable laws and Our Information Governance Program by implementing various protective and information governance measures.

4.3.1 Service Providers and Other Third Parties

Our Service Providers

Although We attempt to avoid communicating Your Personal Information to third parties, We may use Service Providers to perform various services on Our behalf, such as IT management and security, marketing, and data analysis, hosting, and storage.

4.3.2 Communication Outside Quebec

Communication of Personal Information Outside Quebec

We may communicate Your Personal Information outside Quebec and mandate an entity located outside Quebec to collect, use, or retain Your Personal Information on Our behalf.

Safeguards when Communicating Outside Quebec

Before communicating Your Personal Information to third parties outside the province of Quebec, We conduct a privacy impact assessment to evaluate the risks that may affect the security of Your Personal Information. This assessment also helps to identify the adequate security measures that will mitigate or eliminate these risks.

4.3.3 Compliance with Legislation, Response to Legal Requests, Prevention of Harm, and Protection of Our Rights

Specific Communications of Your Personal Information

We may communicate Your Personal Information when We believe such disclosure is authorized, necessary, or appropriate, including:

to respond to requests from public and governmental authorities, including public and governmental authorities outside of Your country of residence;
to protect Our operations;
to comply with legal proceedings;
to protect Our rights, the privacy of Our employees, officers, and directors, Our safety, and Our property;
to protect Your privacy and Your rights, or the privacy and rights of third parties;
to allow Us to pursue available remedies or limit the damages We may sustain; and
in accordance with applicable laws in force, including laws outside of Your country of residence.

4.3.4 Business Transaction

Possibility of Business Transactions

We may share, transfer, or communicate, in strict compliance with this Policy and the provisions of the Act respecting the protection of personal information in the private sector, CQLR c P-39.1 (the « Private Sector Act ») and the Act to modernize legislative provisions as regards the protection of personal information, SQ 2021, c 25 (the « Act 25 »), Your Personal Information in the event of a sale, transfer, or assignment, in whole or in part, of the Company or Our assets (for example, following a merger, consolidation, change of control, reorganization, bankruptcy, liquidation, or any other business transaction). In this case, We will inform You before Your Personal Information is transferred.

4.4 Consents

Consents for the Collection, Use, or Communication of Personal Information

Unless otherwise provided by law, the Company obtains Your consent for Us to collect, use, and communicate Your Personal Information. However, if You provide Us with Personal Information about other individuals, You must ensure that You have duly notified them that You are providing Us with their information and have obtained their consent to such communication.

We will seek Your manifest, free, informed consent, given for specific purposes, before using or communicating Your Personal Information for purposes other than those set out herein. We will also seek Your explicit consent whenever sensitive Personal Information is involved in any of the Company’s Processing activities. We will ask for Your consent for each specific purpose in simple and clear terms, distinctly from any other information communicated to You.

BY USING OUR WEBSITES, BY TRANSMITTING YOUR PERSONAL INFORMATION VIA EMAIL OR USING AN ONLINE FORM, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.

Refusal to Use the Website

If You do not consent, please stop using the Websites. Except where the law provides otherwise, You may withdraw Your consent at any time, upon giving reasonable notice. Please note that if You choose to withdraw Your consent to the collection, use, or communication of Your Personal Information, certain features of Our Website may no longer be available to You, or We may no longer be able to offer You certain of Our Services.

4.5 Retention of Personal Information

Retention

Subject to applicable laws, We retain Your Personal Information only for the time necessary to fulfill the purposes for which it was collected, unless You consent to Your Personal Information being used or Processed for another purpose. For indication, the retention period for some information may extend up to 7 years following the end of the Services rendered by the Company to You. Furthermore, Our retention periods may be modified in a timely manner due to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and violations, or to prosecute criminals).

Inquiries

To obtain more information about the periods during which Your Personal Information is retained, please contact Our Person in charge of the protection of Personal Information using the contact information provided in Section 2 of this Policy.

5. Your Rights

List of Rights

As a data subject, You may exercise the rights set out below by communicating in writing with Our Person in charge of the protection of Personal Information using the contact information provided in Section 2 of the Policy. Please note that We may ask You to verify Your identity before responding to any of these requests.

You have the right to be informed of the Personal Information We hold about You, its use, communication, retention, and destruction, subject to exceptions provided by applicable law;
You have the right to access Your Personal Information, to request a copy, including a paper copy of the documents containing Your Personal Information, subject to exceptions provided by applicable law;
You have the right to have the Personal Information We hold about You rectified, modified, and updated if it is incomplete, ambiguous, outdated, or inaccurate;
You have the right to withdraw or modify Your consent to the collection, use, and communication of Your Personal Information at any time, subject to applicable legal and contractual restrictions;
You have the right to ask Us to cease disseminating Your Personal Information and to de-index any link attached to Your name that provides access to this information if this dissemination contravenes the law or a court order;
You have the right to request that Your Personal Information be communicated to You or transferred to another organization in a structured and commonly used technological format;
The right to be informed of a confidentiality incident concerning Your Personal Information that could cause You serious harm. For this purpose, We maintain a register that lists all confidentiality incidents and We evaluate the harm they may cause;
You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions provided by applicable law.

6. Questions and Complaints

Complaints

You may address all complaints regarding Our privacy protection practices and policies by contacting Our Person in charge of the protection of Personal Information using the contact information identified in Section 2.

Need to Identify Yourself

In order to follow up on Your request, You may be asked to provide appropriate identification documentation or to otherwise identify Yourself.

Questions

You may also contact Our Person in charge of the protection of Personal Information for any questions regarding this Privacy Policy.

7. Cookies and other tracking technologies

Use of Cookies

We use Cookies and other similar technologies (collectively, « Cookies ») to help Us operate, protect, and optimize the Website and the Services We offer. Cookies are small text files that are stored on Your device or on Your browser. They allow certain information to be collected during Your visit to the Website, including Your preferred language, the type and version of Your browser, the type of device You use, and the unique identifier of Your device.

Deleting Cookies

While some of the Cookies We use are deleted after Your browser session ends, other Cookies are retained on Your device or browser to allow Us to recognize Your browser upon Your next visit to the Website. Cookies do not cause any harm to Your device and cannot be used to extract Your Personal Information.

Browser Configuration

You can configure Your browser to be informed of the placement of Cookies during Your visit to the Website, so that You can decide, in each case, whether to accept or refuse the use of some or all Cookies. Please note that disabling Cookies on Your browser may impair Your browsing experience on the Website and prevent You from using some of its features.

To learn more about how We use Cookies, You can consult Our « Cookie Policy ».

8. Security Measures

Objectives of Our Security Measures

We have implemented physical, technological, and organizational security measures aimed at adequately protecting the confidentiality and security of Your Personal Information against loss, theft, or any unauthorized access, breach, disclosure, reproduction, communication, use, or modification. These measures notably include:

Administrative Measures: The adoption of a series of measures, policies, and procedures as part of the implementation of Our information governance program, which notably: frame the access, communication, retention, de-identification, including the destruction or anonymization of Personal Information; determine the roles and responsibilities of Our employees throughout the life cycle of Personal Information and documents; establish intervention and response procedures in the event of a confidentiality incident; frame the process for requests and complaints regarding the protection and Processing of Personal Information.
Technical Measures: The use of several means such as: the use of a secure server. All information provided is transmitted via « Secure Socket Layer (SSL) » technology; the use of backup systems, network monitoring software, etc.; a firewall system; the use of job separation systems and access controls.

Inability to Guarantee Complete Absence of Risk

Despite the measures described above, We cannot guarantee the absolute security of Your Personal Information. If You have reason to believe that Your Personal Information is no longer protected, please contact Our Person in charge of the protection of Personal Information immediately using the contact information provided in Section 2.

9. Modification of this Privacy Policy

We reserve the right to modify this Policy at any time in accordance with applicable legislation. In the event of a modification, We will publish the revised version of the Privacy Policy and update the effective date located in the footer thereof. If You continue to use Our Website or Our Services after the new version of Our Policy takes effect, Your use of Our Website and Our Services will then be governed by this new version of the Policy.

10. Links to Third-Party Websites

Responsibility for Third-Party Websites

We may occasionally include on Our Website references or links to websites, products, or services provided by third parties (the « Third-Party Services »). These Third-Party Services, which are neither operated nor controlled by the Company, are governed by privacy policies that are entirely separate and independent from Ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services We offer.

11. Invisible reCAPTCHA

The invisible reCAPTCHA analyzes activity on a Web page function (e.g., mouse movements and typing patterns) to determine if a user is a bot. The invisible reCAPTCHA service may collect information from Your device. Information collected by reCAPTCHA is retained in accordance with its privacy policy.

12. Individuals Under 14 Years of Age

We do not knowingly collect or use Personal Information from individuals under 14 years of age. If You are under 14 years of age, You must not provide Us with Your Personal Information without the consent of Your parents or guardian. If You are a parent or guardian and You learn that Your child has provided Us with Personal Information without consent, please contact Us using the contact information provided in Section 2 above to request that We delete that child’s Personal Information from Our systems.

13. Applicable Laws

The laws of Canada and Quebec, excluding its conflict of law rules, shall govern this agreement and Your use of the Website. Your use of the Website may also be subject to other local, provincial, national, or international laws.