PRIVACY AND CONFIDENTIALITY POLICY

In accordance with applicable legislation, including the Act respecting the protection of personal information in the private sector (hereinafter the “Act“), Repaco Inc. (hereinafter “Repaco” or “we”) has adopted a policy regarding personal information, electronic documents and the confidentiality of information it obtains in the course of its operations (hereinafter the “Policy“).

Repaco takes the protection of personal information and information seriously and is committed to preserving the confidentiality of information exchanged with its users, customers and partners.

Repaco has established a rigorous privacy policy that outlines how we collect, use, communicate and transmit the information you provide to us in the course of Repaco’s operations.

The purpose of this policy is to set out the methods and means used by Repaco to comply with the legislative framework applicable to personal information and the confidentiality of the information it obtains from its users, customers and partners.

Under the Act, personal information is any information that relates to a natural person and allows that person to be identified.

In the course of our activities and the provision of our services, we collect, use and process various types of personal information, including :

• Contact information, such as name, postal address, e-mail address and telephone number;
• Financial information, such as billing information and information about your financial institution;
• If you are applying for a job with Repaco, including: your curriculum vitae, the names of your former employers and the institutions you attended;
• Official identification documents (driver’s license, passport, or other official proof of identity, for example);
• Any other personal information provided.

How we collect personnal information

Personal information is collected in the course of providing the services offered by Repaco.

When we collect personal information, we ask for your consent by various means, for example, by filling out a form, by clicking on an authorization electronically, or by any other means that ensures that you give us informed consent to transmit such information.

Furthermore, when we communicate with you or you communicate with us in the course of carrying out a professional mandate that you have entrusted to us, we assume that you consent to the transmission of your personal information to us for the purposes of carrying out this mandate.

Any action relating to a registration or contact form requires the voluntary transmission of your personal information. When this information is required to process your request, you will be notified directly on the form to be completed.

We use your personal information in accordance with the legislation currently in force in Quebec regarding the protection of personal information, and only for the purposes mentioned in this Policy.

Repaco uses and discloses your personal information only with your consent, except as permitted by law. Personal data collection is for the purpose of communicating with you, providing you with the services and information you request or providing you with information that may be of interest to you.

Unless required by law, or with your consent, and except as provided in this Policy, personal information will not be sold, distributed, traded or shared with third parties.

In particular, your personal information is used to:

• Communicate with you by e-mail, telephone, virtual meeting, text message or other equivalent forms of electronic communication or in the form of informational communications related to features, products or services, including software or security updates, when necessary or reasonable for their implementation;
• To make payments and carry out invoicing, this information then being communicated to our financial service providers, where applicable;
• To automatically personalize your documents with your contact or personal information.

All personal information we collect, whatever it may be, is confidential and will remain so. No information is passed on to anyone who is not acting as an employee, agent, subcontractor, contractor or service provider, to name but a few, on behalf of Repaco, unless we are required to do so by law.

We share your personal information with certain trusted third parties, including :

• Third-party providers of computer and internet services, financial services, credit check services and other services. We provide only the information necessary for the performance of their mandate, and we ensure that they take the necessary measures to ensure the confidentiality of the information transmitted to them;
• Our professional advisors, when personal information must be shared with them to carry out a specific mandate entrusted to them.

In doing so, your paper-based personal information is stored exclusively at our offices.

Your personal information is also stored in our databases (including local storage), affiliated company databases or databases managed by third-party service providers. These suppliers are located in Canada and may also be located abroad, including in the United States. Data will be automatically transferred to these databases in compliance with applicable legislation. By browsing our Web site, you consent to such cross-border transfers of personal information to the United States and other jurisdictions.

We strive to ensure that the personal information we transfer within Canada and, exceptionally, outside Canada, via our partners, is adequately protected. We ensure that our partners use privacy and security mechanisms that are at least as effective and secure as those we use.

Your personal information is retained for the duration of the service mandate and for the purposes for which it was collected.

In accordance with the rules that govern us, we are also required to keep our customers’ files for a minimum of seven (7) years following the closing of their file.

Given the importance of protecting your personal information, we maintain physical and administrative safeguards in our offices and storage facilities. All Repaco representatives and third-party suppliers whose services we retain and who handle personal information are required to respect the confidentiality of personal information.

Personal information on electronic media is protected by effective technological means, such as passwords, firewalls, antivirus software and other protection software, which are regularly updated by our expert IT partners.

As a user or customer, you have the right to access, portability, rectification or deletion of your personal information, as well as the right to withdraw your consent to certain processing of said information. While some of these rights apply generally, others apply only in certain very specific circumstances. These rights are described as follows:

Right of access to personal information

You have the right to access your personal information, to obtain a copy of the personal information we process and to obtain information about our internal processing of personal information. In the event that you request to know what personal information we process, we will provide you with the following information free of charge: the purposes of the processing, the categories of personal information processed, the categories of persons who have access to your personal information, the recipient(s) of the personal information, the length of time the personal information is kept and information on data transfers.

Any such request must be accompanied by all relevant details, including your full contact details, and submitted by e-mail to: info@repaco.ca.

You have the right to obtain from us confirmation as to whether or not your personal information is being processed and, if so, access to your personal information. The data controller will provide you with a copy of the personal data processed within a reasonable period of time.

Right to portability of personal information

You have the right to receive your personal information in a structured, commonly used and computer-readable format. Any such request must be accompanied by all relevant details, including your full contact details, and submitted by e-mail to the following address: info@repaco.ca.

We will make every effort to respond to your request, but serious practical difficulties may limit our ability to do so.

Right of rectification

You have the right, if necessary, to have your personal information amended, deleted or restricted. Any such request must be accompanied by all relevant details, including your full contact details, and submitted by e-mail to info@repaco.ca.

Please note that we may rectify, reconstruct or delete incomplete or inaccurate information at any time, at our own discretion. You have the right to obtain from us, within a reasonable time, the rectification of inaccurate personal information. You have the right, taking into account the purposes of the processing, to complete incomplete personal information, in particular by providing us with an additional declaration in this respect.

Right to withdraw consent

You may withdraw your consent to the processing of your personal information at any time. In this case, if there is no overriding legitimate interest in continuing to process your personal information (e.g. to comply with our legal obligations, resolve disputes, implement our agreements, etc.) and said personal information is no longer necessary for the purpose originally pursued, we will delete your personal information.

Any such request must be accompanied by all relevant details, including your full contact details, and submitted by e-mail to info@repaco.ca. In addition, you have the right to request that we delete your information and we will delete your personal information within a reasonable period of time. Your user data will be deleted within a reasonable period of time following the closure of your account. However, withdrawal of your consent may result in the termination of our provision of services or goods in cases where we are no longer able to adequately fulfill our mandate. Finally, you acknowledge that certain personal information provided in the course of providing services or goods must be kept in our files, in compliance with the rules governing our profession and applicable legislation.

Right of refusal

You can ask us not to send you commercial communications and not to use your personal information when profiling you for direct marketing purposes. You may refuse to receive electronic newsletters and other commercial communications by following the refusal instructions provided in these e-mails or by sending a request to this effect to the following address: info@repaco.ca.

Please note that messages relating to transactional accounts will not be affected even if you refuse our commercial communications.

We retain information for as long as is necessary to provide the services requested by our customers and other parties, to resolve disputes and to implement our agreements, subject to any legal obligation to retain such information longer.

Information associated with your account is generally retained until it is no longer required to provide our services, or until you request that we delete it or your account is deleted, subject to our legal retention obligations. They are then securely destroyed.

If you have a complaint regarding the application of this Policy, you may submit it in writing to the Privacy Officer indicated below. Any such complaint will be dealt with in accordance with the legislation currently in force.

We reserve the right to make changes to this Policy at any time. We therefore invite you to consult this Policy frequently.

Johanne Emery, Vice President of Repaco Inc., is our designated Privacy Officer. Her contact information is as follows: jemery@repaco.ca, telephone: 450-378- 2623.

Our company address is: 700, Cowie street, Granby (Quebec), J2G 3X6.

Last update : December 2023