Privacy & policy

Last modified: 2025-01-14

1. INTRODUCTION

Groupe Sanivac Inc. inc. and all of its affiliates and subsidiaries (collectively the “Company” or “we” or “us” or “our”) respect your privacy and are committed to protecting it by complying with this policy (our “Policy”).

This policy describes:

▪ How we use, collect, hold and disclose the personal information of our customers, suppliers, subcontractors, employees, applicants for employment and users of our website (“you”) ;

▪ Our policies and practices governing the governance of personal information, including the framework applicable to the retention and destruction of such information, the roles and responsibilities of our staff members throughout the life cycle of such information, and our process for handling privacy complaints; and

▪ The types of information we may collect from you or that you may provide when you visit the www.sanivac.ca website and its subdomains (our “website”).

We will only use your personal information in accordance with this Policy, unless otherwise required by applicable law.

2. PERSONAL INFORMATION

The term “personal information” refers to any information that relates to a natural person and makes it possible, directly or indirectly, to identify that person. It should be noted that our policy does not generally apply to the collection and confidentiality of information related to an individual’s performance of his or her duties within an organization, such as name, title or position, as well as the address, e-mail address and telephone number associated with his or her place of employment, but we handle such information at all times in strict compliance with applicable law. In the course of your relationship with the Company, you may be asked to provide certain personal information about yourself and/or others (such as family members or employees). Examples of personal information include name, date of birth, residency status, telephone number, passport, driver’s license and other information relevant to the provision of international recruitment and related services by the Company.

3. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

The Company uses, collects, holds and discloses personal information only for the purposes identified at the time of collection, or as otherwise permitted or required by applicable law, including for the following purposes:

▪ To provide our products and services;

▪ For the purpose of identifying any customer and verifying their identity ;

▪ Establish and manage relationships with customers and suppliers, including considering whether or not to establish a relationship ;

▪ Respond to requests for information made through the website and ensure appropriate follow-up ;

▪ To send updates about our industry, our services and the services of companies in the same group;

▪ For administrative, management and operational purposes, such as issuing invoices, managing accounts, sales, collecting and processing payments; and for any purpose for which you have given your consent;

▪ For any other purpose to which you have consented.

4. EMPLOYEE AND APPLICANT INFORMATION

In the course of its activities as an employer and recruiter, the Company collects, uses and discloses personal information. For our employees, this collection is part of the essential management of labor relations. As for candidates, their information is collected and used to assess their suitability for available positions, which may involve information obtained from third parties for background checks or professional references. If a candidate is not selected, his or her information is retained for a reasonable period of time for future opportunities, unless a request for deletion is made. In addition, we maintain certain personal information about our former employees, including their names and contact details, for possible professional or regulatory requirements.

5. LIMITATION

The Company aims to limit the amount of personal information it collects to that which is necessary and appropriate for the identified purposes. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.

6. CONSENT

We use, hold and disclose personal information only for the purposes for which it was collected, except with the consent of the individual concerned. If personal information relating to a third party is provided to us, the person providing the information must affirm that he or she has obtained the necessary consent from that third party, or is otherwise authorized to allow us to collect, use, hold and disclose such information in accordance with this Policy. In the case of sensitive personal information, consent must be expressly provided by the individual concerned. Exceptions to this consent requirement may arise, for example, when we are acting in the legal representation of a customer, when a medical or security emergency makes it impractical to obtain consent, or when information is collected for the detection and prevention of fraud or to meet a legal obligation. For a more complete list of exceptions, please contact our Privacy Officer (identified below).

7. WITHDRAWAL OF CONSENT

You may change or withdraw your consent to the use, holding and disclosure of your personal information, or refuse certain of them, subject to legal and contractual restrictions in accordance with applicable laws. To change or withdraw your consent, please contact our Privacy Officer (identified below).

8. INFORMATION WE MAY COLLECT

We collect and use several types of information from and about you, including :

▪ Personal contact information such as name, physical address, e-mail address and telephone number ;

▪ For candidates for Company employment, work history and resume;

▪ Biographical information such as a job title, the name of an employer ;

▪ Personal information you provide to us to describe your needs and requirements or those of your business ;

▪ Website usage and other technical information, such as details about visits to our website, your interaction with our advertising and online content, or information collected through cookies and other tracking technologies; and

▪ Any other personal information provided by you.

9. HOW WE COLLECT YOUR PERSONAL INFORMATION

We use a variety of methods to collect your personal information, including the following:

▪ From direct interactions with you when you provide them to us, for example by filling out forms or corresponding with us by phone, email, when you sign up to receive our newsletters, or otherwise (if we have sent you a promotional email such as a newsletter, you can unsubscribe by clicking on the unsubscribe link we have included in the email) ;

▪ Automated technologies or interactions, as you browse our website. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies ;

▪ From third parties that you have authorized to share them with us;

▪ From publicly available sources.

10. CONNECTION COOKIES

Cookies are small text files that a website may deposit on your computer or mobile device when you first visit a website or web page. Cookies do not cause any damage to the terminal, but facilitate, for example, the search for preferences, the pre-filling of certain fields and the adaptation of the content of the services of the visited site. This data is used to improve ergonomics and services according to your interests.

We use the following types of cookies on our site:

▪ Functional cookies. Functional cookies are used to remember the selections you make while on our website so that your selections are saved for your next visit, for example the website language.

▪ Analytical cookies. Analytical cookies allow us to improve the design and functionality of our website by collecting data on how you access our website, data on how long you stay on our website, etc.

Our website allows you to accept or decline all cookies. Alternatively, if you have concerns about our use of cookies, you can take steps to prevent their installation, for example by changing your browser settings to block certain types of cookies. You can delete cookies stored on your device at any time by accessing the appropriate settings in your web browser. You have the option of configuring your devices to accept all cookies, to notify you when a cookie is issued, or to never accept cookies. However, this last option may result in certain personalized services not being provided and, consequently, in you not being able to take full advantage of all the functionalities offered by the website. If you do not wish to receive cookies in general, or only wish to refuse certain cookies, you can modify your browser settings accordingly. Instructions on how to do this are provided on each browser’s website. Consult your browser’s website to find out how to manage your cookie preferences.

11. HOW WE USE YOUR INFORMATION

We use the personal information we collect about you :

▪ To provide our products and services, to conduct our business, to administer and perform our services, including fulfilling our obligations under any agreement between you and us ;

▪ In the case of job applicants, to get in touch with the applicant and to assess whether we will proceed with their hiring;

▪ To assess whether we will retain your services and to keep in touch with you, if appropriate;

▪ To respond to information requests or queries from visitors to our website ;

▪ To make it easier for you to use our website and to ensure that the content on our website is presented in the most effective way for you and your device ;

▪ For marketing and business development purposes – to provide information about new services, updates on our industry and newsletters when a person has opted to receive them. You may request that this service cease at any time; and

▪ To fulfill our legal, regulatory or risk management obligations – to comply with our legal obligations.

12. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose personal information that we collect or that you provide, as described in this policy:

▪ To authorized third parties, contractors, service providers and other third parties we use to support our business (such as administrative service providers and manufacturers) who are contractually bound to keep personal information confidential, to use it only for the purposes for which we disclose it to them, and to treat personal information according to the same standards as set out in this policy ;

▪ To achieve the purpose for which you provided the personal information ;

▪ For any other purpose we disclosed when you provided the personal information ;

▪ With your consent; and

▪ To comply with a court order, law or legal process, including responding to a request from a government or regulatory agency, in accordance with applicable law.

The Company does not sell or exchange for consideration any personal information it holds.

13. THIRD-PARTY SERVICE PROVIDERS

To the extent that the Company uses third-party service providers to store, manage or process personal information on its behalf (e.g. data storage and processing services, cloud computing services), we use contractual and other means to provide a comparable level of protection while personal information is being stored, managed or processed by these service providers.

Our service providers have contractual agreements with us to protect your personal information from unauthorized access, collection, use or disclosure.

14. COMMUNICATION OUTSIDE QUEBEC OR CANADA

When personal information is located outside of Canada, it may be accessible by foreign governments, courts and other governmental authorities, if required by law or court order. We will only disclose or transfer personal information outside Canada in accordance with applicable Canadian laws and for lawful purposes.

When we disclose personal information outside Quebec, and sometimes outside Canada, we do so only for the purpose of providing our products and services, or to support our business so that we can offer our products and services reasonably efficiently and at commercially reasonable costs.

Before disclosing personal information outside Quebec, we conduct a privacy impact assessment in accordance with applicable Quebec law. This assessment takes into account: (i) the sensitivity of the information; (ii) the purpose for which it is to be used; (iii) the safeguards, including contractual safeguards, from which the information would benefit; and (iv) the legal regime applicable in the state to which the information would be disclosed, including the generally accepted privacy principles applicable there. Personal information is only disclosed if the assessment demonstrates that it would benefit from adequate protection. If you would like more information about the service providers we use to whom personal information is disclosed outside Quebec, please contact our Privacy Officer (identified below). We confirm that we may, strictly in accordance with this policy, disclose your personal information outside Quebec or Canada to third parties we retain to provide services to us involving the use, disclosure or retention of your personal information on our behalf. You consent to any such disclosure, use or retention.

15. TERRITORIAL RESTRICTIONS AND COMPLIANCE WITH LOCAL LAWS

The Company is established and operates under the laws of the Province of Quebec, Canada. Privacy laws may differ depending on your jurisdiction of residence. If you reside or are established outside the province of Quebec, you are responsible for ensuring that the transmission of your personal information to the Company is permitted by the local or national laws applicable to you. By transmitting your personal information to the Company, you acknowledge and agree that such information will be subject to the laws of the Province of Quebec, Canada, and that the Company cannot be held responsible for non-compliance with the privacy laws of your jurisdiction.

16. PERSONAL INFORMATION GOVERNANCE AND COMPUTER SECURITY POLICIES

Our commitment to your privacy. We take the security and responsible management of your personal information very seriously. Our privacy governance policies have been formally approved by our Privacy Officer. These policies and practices are designed to match the scope and complexity of our various business activities. The following subsections provide detailed information, in plain language, to inform you about our personal information governance policies and practices.

Data lifecycle management. Our policies cover the entire life cycle of your personal information. We keep your personal information only as long as necessary to fulfill the purposes for which it was originally collected, unless legal obligations require us to keep it longer, such as laws governing the practice of law and tax laws. Once personal information has served its purpose, we ensure its secure and responsible destruction or anonymization, following strict guidelines.

Responsibilities of employees and service providers. Within our organizational structure, roles and responsibilities regarding the handling and management of personal information are clearly defined for our employees. All employees receive training in this regard and are held accountable for any failure to comply with our privacy standards. With regard to service providers, we establish contractual relationships exclusively with entities that undertake to respect industry-standard security measures and comply with the law. These agreements have been carefully reviewed to ensure that they comply with applicable laws and the principles set out in this policy.

Safety and compliance assessments. To ensure ongoing compliance with our policies and practices, we conduct periodic internal assessments. These assessments examine how personal information is collected, stored, processed and disposed of, and involve a thorough review of our processes and procedures. The assessments help to determine the effectiveness of our existing security measures and to propose ongoing improvements.

Complaint handling. In keeping with our commitment to the protection of personal information, we have established a formal process for receiving, investigating and resolving any complaints regarding the safeguarding of your personal information.

Security measures. To protect your personal information, we use a multi-layered security approach that includes physical, electronic and administrative measures to prevent unauthorized access, use, alteration or disclosure of your personal information.

While these policies and measures are aligned with recommended practices, it is important to recognize that the absolute security of your personal information when transmitted online or when using online services cannot be unconditionally guaranteed. Such transmissions are therefore at your own risk.

We endeavour to present this policy in a simple and easily understandable way, to ensure that you are fully aware of how we treat your personal information.

17. RETENTION OF INFORMATION, DESTRUCTION AND/OR ANONYMIZATION

Unless otherwise authorized or required by applicable law or regulation, we will retain your personal information only as long as necessary for the fulfillment of the purposes for which it was collected, including any legal, accounting or disclosure requirements. In certain circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymized and de-identified information for any lawful purpose without notifying you or obtaining your consent.

18. PRIVACY OFFICER

It is important that the personal information we hold about you is accurate and up-to-date. Please keep us informed of any changes to your personal information. By law, you have the right to request access to and correction of the personal information we hold about you.

If you wish to review, verify, correct or withdraw your consent to the use of your personal information, you may e-mail us at the Privacy Officer’s e-mail address to request access, correction or deletion of any personal information you have provided to us.

Privacy Officer

Carole-Ann Kelly

confidentialite@sanivac.ca

100 rue Huot, Notre-Dame-de-l’Île-Perrot (Québec) J7W 1M4

Téléphone: 514 453-2279 # 258

We may not comply with a request if we believe that the change would violate a law or legal requirement or would render the information incorrect.

19. CHANGES TO OUR PRIVACY POLICY

Privacy laws change rapidly and, as a result, this Policy may be amended from time to time by the Company, in its sole discretion, without notice or liability to you or any other person. The Company’s collection, use and disclosure of your personal information will be governed by the version of this Policy in effect at that time. If we are authorized to communicate with you for this purpose, we reserve the right to inform you by e-mail or any other means of communication to which we are authorized, of any material changes to this Policy. This communication will be made in addition to updating the last modification date displayed at the top of this page.

20. COMPLAINT CONCERNING COMPLIANCE WITH THIS POLICY

The Company will respond to complaints from individuals or questions about our compliance with this Policy and applicable privacy laws. We will investigate and attempt to resolve all complaints. If you wish to challenge our compliance with this Policy, please contact our Privacy Officer at the coordinates indicated above.