Effective Date: 2025-07-04

Last updated: 2025-07-04

1. General information

a) Introduction

Purpose of this Policy. Privacy is important to APP GROUP (CANADA) INC. located at 600 Chabanel Street West, Montreal, QC, Canada, H2N 2K6 and its related entities (hereinafter collectively referred to as the "Company", "We", "Us", "Our"). For this reason, We have implemented safeguards and sound management practices for Your Personal Information in accordance with the laws applicable in Quebec, Canada, the United States and the European Economic Union (hereinafter "Europe").

Additional to the Terms and Conditions. This privacy policy (the "Policy"), which should be read in conjunction with Our Terms and Conditions, describes Our practices regarding the collection, use, processing, disclosure, retention and destruction of Personal Information of individuals benefiting from Our Services, visitors to this Website and its users ("You", "  Your",  "Your").

Consent. By using any of Our  websites https://www.soiakyo.ca/, https://www.soiakyo.com as well as the Customer Portal found therein (https://www.soiakyo.ca/account/login) (hereinafter collectively Our "Website") or any of our Services, You agree that We may collect, use, disclose, communicate, disclose and retain (hereinafter "Process" or "Process")") Your Personal Information in accordance with the terms described herein. If You do not agree to abide by and be bound by this Policy, You are not permitted to visit, access or use Our Website or 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, as well as to any information that does not constitute Personal Information as defined by the laws applicable in Quebec, Canada, the United States and Europe.

b) Privacy Officer and Data Protection Officers

Contact Information for Our  Privacy Officer. Unless You reside in Europe, any comments, questions and complaints regarding the Company's Privacy Policy and practices may be directed to Our Privacy Officer at the following contact information:

Email :         dataprotection@soiakyo.com

Address :     600 Chabanel Street West, Montreal, QC, Canada, H2N 2K6

Contact details of Our DPO and Our UK DPO. If you are a resident of Europe or the United Kingdom, any comments, questions and complaints about the Company's Privacy Policy and practices may be directed to Our Data Protection Officer ("DPO") at the following contact details:

Email :         dataprotection@mackage.com

Address :     Einsteinstraße 174, 81677 Munich, Germany

2. Definitions

Definitions of certain concepts or expressions. The following concepts and expressions, when they appear with a first letter in capital letters in the Policy, have the meaning ascribed to them below, unless otherwise implicitly or explicitly stated in the text:

"Cookie Banner": pop-up window requesting Your consent to certain collections of Your Personal Information on the Website. 

"Data Protection Officer or DPO": the person in charge of applying this Policy in Europe or the UK and whose contact information is identified in section 1b) - Privacy Officer and Data Protection Officers of this Policy.

"Company", "We", "Us", "Our": APP GROUP (CANADA) INC.

"Service Provider" means any natural or legal person who processes Personal Information on behalf of the Company. These are third-party companies or individuals employed by the Company to facilitate the Services, provide the Services on behalf of the Company, perform services related to the Services, or assist the Company in analyzing the use of the Services.

"Personal Information" or "Personal Data" (for European residents) means any information that relates to and identifies a natural person, i.e., that directly or indirectly reveals something about the individual's identity, characteristics (e.g., abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour) or activities, regardless of the nature of the medium and regardless of the form in which this information is accessible (written, graphic, audio, visual, computerized or otherwise). 

«Privacy Officer": the person in charge of the application of this Policy in any territory other than Europe or the United Kingdomand whose contact information is identified in section 1b) - Privacy Officer of this Policy.

"Customer Portal": the portal available here: https://www.soiakyo.ca/account/login. 

"Services": Services refers to the applications of the Website, Our social media pages and any programs and services provided to You therein such as:

·       Online purchases;

·       Returns and repairs;

·       Gift cards;

·       Apply for a job.

"Website": The following websites: https://www.soiakyo.ca/, https://www.soiakyo.com as well as the Customer Portal found there (https://www.soiakyo.ca/account/login). 

"Cookie": Cookies are text files that are installed on Your computer or mobile device. These cookies may contain information about Your search history, the web pages You visit and Your web browser.

"Process", "Processing": Concept encompassing any operation that may affect or concern personal information, including: collection, use, retention, destruction, communication or transmission or any other operation concerning personal information. 

"  You  ", "  Your  ": Persons benefiting from Our Services, visitors to the Website and any users using the Company's Services. 

3. Processing of Personal Information 
3.1  Collection of Personal Information
3.1.1  Means of collection

· Various means. We collect Your Personal Information through Our Website or any other technological means in various ways, including:

·  Automatically. When You connect to Our Website, the device You use to connect to Us will provide Us with Personal Information; 

· Electronic forms. By completing and providing Us with one of Our electronic forms;

· Emails communicated. By emails that You communicate to Us using one of the email addresses available on Our Website; 

· Cookies. By cookies including the cookies identified in Our Cookie Policy  ; 

· Surveillance cameras. By the surveillance cameras installed on Our property; and 

· Partners. By third parties who collect Your Personal Information for Us which are identified in section 3.2 - Collection of Personal Information by a Third Party of this Policy. 

· Profiling and identification. Our Website has functions that allow you to create a profile of Your activities on Our Website and to identify You. These functions are used by third parties identified in section 3.5 - Disclosure and Transfer of Personal Information through cookies. We disable these features by default. You can enable them through the Cookie Banner.

3.1.2 Personal Information Collected from You

In the course of Our business, We may collect and process the various types of Personal Information including the information listed below:

· identification information and contact information, including Your first and last name, mailing address, email address, and telephone number; 
(Mandatory collection in case of purchase or subscription to the newsletter)
· demographic information, such as Your age group and month of birthday; (Optional collection)
· technical or numerical information, including login information and other information about Your activities on the Website, such as Your IP address, the pages You visited, the time and date of Your visits, Your number of connections, Your domain name, the address of the referring site (if you are accessing the Website from another site),  the type of browser You use, Your device's operating system, and other hardware and software information; (Optional collection)
· Your consents to the use of certain cookies on Our Website and to the disclosure or use of Your Personal Information; (Mandatory collection)
· information necessary for the provision of Our Services, such as information about the Services We have rendered to You or are providing to You; (Mandatory collection)
· information that You choose to provide or provide to Us, for example, when You fill out an online form or communicate with one of Our employees or representatives; (Optional collection) and
· financial information, such as the last four digits of Your credit card number, the type of card used, and Your method of payment, if You wish to pay for Our Services online. (Mandatory collection in case of purchase)

Restriction of processing to necessary and legitimate purposes. In each case, such Personal Information is processed in accordance with the legitimate and necessary purposes listed in section 3.4 - Use of Personal Information below.

3.2  Collection of Personal Information by a Third Party

Avalara. Avalara collects on Our behalf the amount of taxes related to Your online purchases in order to manage taxes when You make purchases on Our Website For more information about Avalara's privacy practices, you can visit their privacy policy at the Avalara Legal Center . 

Shopify. Shopify and its ShopPay service collects the following Personal Information on Our behalf in order to enable Your transactions related to Your purchases on Our Website:

· Your first and last name; and

· Your financial information. 

For more information about Shopify's privacy practices, you can visit their privacy policy at https://www.shopify.com/ca/legal/privacy.  

Klarna. Klarna, a deferred payment management platform, collects the following Personal Information on Our behalf in order to enable Your transactions related to Your purchases on Our Website:

· Your first and last name; 

· Your contact information; and

· Your financial information. 

For more information on Klarna's privacy practices, you can visit their privacy policy at https://www.klarna.com/ca/fr/confidentialite/.  

PayPal. PayPal, a transaction management platform, collects on Our behalf the following Personal Information in order to enable Your transactions related to Your purchases on Our Website:

· Your first and last name; 

· Your contact information; and

· Your financial information. 

For more information on PayPal's  privacy practices, you can consult their privacy policy at https://www.paypal.com/webapps/mpp/ua/privacy-full.

Google. GooglePay, a transaction management platform of Google, collects the following Personal Information on Our behalf in order to enable Your transactions related to Your purchases on Our Website:

· Your first and last name; 

· Your contact information; and

· Your financial information. 

For more information on Google's  privacy practices, you can visit their privacy policy at https://policies.google.com/privacy?hl=fr-CA. 

ApplePay. ApplePay, an Apple transaction management platform, on Our behalf, uses the following Personal Information to enable Your transactions related to Your purchases on Our Website:

· Your first and last name; 

· Your contact information; and

· Your financial information. 

For more information about Apple's privacy practices  , you can visit their privacy policy at https://www.apple.com/ca/fr/privacy/.

3.3  Opting out of optional collection

Withdraw consent. Unless otherwise provided by law or Your contractual obligations, You may refuse or withdraw Your consent to certain specific uses or disclosures of Your Personal Information:

· failing to include Your Personal Information in Our electronic or paper forms where the provision of such forms is indicated as optional;

· by selecting "refuse" in the Cookie Banner; or

· by communicating a request to Our Privacy Officer or, if You reside in Europe or the United Kingdom, Our DPO at the contact details identified in section 1b) of this policy.

Consequences of refusing to consent to optional collection. If you refuse to consent to the collection of Your Personal Information, We may not be able to provide You with an optimal shopping experience or advertising offers;

Measures available to opt-out of ways to collect Personal Information. You may also provide Us with Your Personal Information other than through technological means such as Our Website. You can provide us with these:

· By email;

· By phone; or

· In person. 

3.4  Use of Personal Information

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

· operate, maintain, supervise, develop, improve and offer the functionalities of Our Website; 

· to allow our customers making purchases on the Website to viewtheir order history and the status of their current order;

· To present and provide You with Our Services described in Section 2 – Descriptions of this Policy; 

· protect Our employees and property;

· promote and enforce compliance with Our Terms and Conditions; 

· evaluate a job application;

· to perform Our contractual obligations to You;

· manage invoicing and process payments;

· to process and resolve complaints and dissatisfactions;

· to track Your orders;

· to fulfil Your orders;

· Offer personalized recommendations based on the purchase profile.

· to profile and target You for advertising purposes; 

· developing, improving and offering new Services;

· Send you messages, updates, security alerts; 

· for advertising and business development purposes, if You have previously consented to the processing of Your Personal Information for such purposes;
· for order tracking purposes;

· Send you a confirmation email when You subscribe to Our newsletter if You request it and You send the newsletter;

· respond to Your questions and provide You with assistance as needed; 

· conduct research, analysis and statistics in connection with Our Company and Services;

· detect and prevent fraud, errors, spam, abuse, security incidents, and other harmful activities; or

·  for any other purpose imposed or permitted by applicable law. 

3.5  Access, Disclosure and Transfer of Personal Information

Access and communication possible. We may transfer, disclose or allow access to Your Personal Information to Our employees as Our Service Providers, who need the information to help Us operate Our Website, perform Our Services, conduct Our business or serve You. 

3.5.1 Access to Personal Information in the Company

Limiting Access to Personal Information. Your Personal Information is only accessible to Our directors, employees or representatives who need access to Your Personal Information in order for them to perform their duties. As such, Your Information may be accessible to:

· Our Privacy Officer and DPO;

· Our IT services ("Information Technology"); 

· Our business analysts;

· Our sales and e-commerce  services;

· Our advertising services; and

· Our human resources (in case of job applications).

3.5.2. Disclosures of Personal Information

Protective measures when communicating to third parties. We will only disclose 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 through the implementation of various information protection and governance measures. These measures are proportionate to the sensitivity of the Personal Information processed or disclosed. Without limitation, Our Service Providers may only use Your Personal Information on a confidential basis as directed by Us and only for the purposes for which it was provided. In addition, We provide Our Service Providers with only the Personal Information necessary for the performance of their mandate or contract and We require these Service Providers to destroy the Personal Information appropriately upon termination of the contract or as soon as its use is no longer required. 

Our Service Providers. Although We try to avoid sharing Your Personal Information with 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. Below we have defined some of the cases in which such sharing may occur: 

· We share Your Personal Information with Shopify in order to allow You to purchase Our Services and products and to complete business transactions. For more information on Shopify's privacy practices, you can visit their Privacy Policy .  

We use Shopify Cookies to allow You to log in to Your Shopify account. 

All categories of Personal Information identified in section 3.1 - Collection of Personal Information may be communicated or stored through this service. 

· We exchange Your Personal Information with FedEx in order to deliver Our products to You that You purchase. 

· We share Your Personal Information with Infor (M3 Cloud Suite (ERP)) for the distribution of Our products. For more information, you can consult Infor's privacy policy.

· We share Your Personal Information with Remco, ModExpress BV (Europe) and Fashion Distribution Services Inc.(United States), which are Our warehouse services, third party logistics services for the processing of online orders. 

· We share Your Personal Information with Ometria for advertising purposes and to manage Your Personal Information. For more information, see  Ometria's Privacy Policy.

· We share Your Personal Information with Riskified in order to detect, prevent or protect against fraud. For more information, you can consult  Riskified's privacy policy.

· We may share Your Personal Information with Loop Returns in order to make online returns. For more information, you can consult Loop Returns' privacy policy.

· We may share Your Personal Information with NewStore who offers us a smartphone platform service that allows Us to provide You with a unified shopping experience online, online and in-store. For more information, you can consult NewStore's privacy policy.

· We use Pinterest Marketing  Cookies for analytics and marketing optimization purposes. For more information, you can consult the Pinterest Marketing’s privacy policy;

· We use Klaviyo  Cookies to track when someone clicks on a Klaviyo email. These cookies are also used to profile and identify individuals who fill out a Klaviyo registration form and click on a link in a Klaviyo email or text message. For more information, you can consult Klaviyo's privacy documentation by clicking here and the "Understanding cookies in Klaviyo" page by clicking here.  

Please note that this Cookie may collect Personal Information that can identify You and can carry out profiling of Your activities on the web (targeted advertising);

These Cookies communicate with Google for the purposes identified in Our Cookie Policy ;

· We use the Google Analytics Cookie  to analyze the Website's audience and compile statistics. For more information, see Google 's privacy policy and their table of cookies for advertising and measurement ;

Please note that this Cookie may collect Personal Information that can identify You and can carry out profiling of Your activities on the web (targeted advertising);

This Cookie communicates to Google for the purposes identified in Our Cookie Policy ;

·  We use YouTube to showcase Our products and Services. For more information, you can consult Google's privacy policy;

·  We use Google Ads to analyze the audience of Our Services, compile statistics and converse with customers and prospects. For more information, see Google's privacy policy and their table of advertising and measurement cookies; 

Please note that this Cookie may identify You and profile Your web activities in order to provide You with advertising that would meet Your interests (targeted advertising);

This Cookie communicates to Google for the purposes identified in Our Cookie Policy ;

· We use the services of Microsoft (Bing) Ads to collect and store data in order to create usage profiles using pseudonyms. For more information, see Microsoft's privacy policy;  

Please note that this Cookie may collect Personal Information that can identify You and can profile Your web activities (for targeted advertising purposes);

This Cookie communicates to Microsoft for the purposes identified in Our Cookie Policy ;

· We use  Meta's services (Facebook Pixel) to help understand and serve ads, compile statistics, and engage with customers and prospects. For more information, see Meta's privacy policy; 

Please note that this Cookie may identify You and profile Your web activities for purposes in order to provide You with advertising that would meet Your interests (targeted advertising);

This Cookie communicates to Meta for the purposes identified in Our Cookie Policy ;

· We use the social network services Facebook and Instagram of the Meta group  to communicate about Our Services. For more information, see  Meta's privacy policy; 

· We use the services of the social network LinkedIn to converse with You and with candidates or prospects for recruitment purposes. For more information, you can consult LinkedIn's privacy policy;

· We use Indeed's services to engage with You and with candidates or prospects for recruitment purposes. For more information, You can consult Indeed's Privacy Policy;

· We use Twitter (X) to showcase Our products and Services. For more information, You can consult the privacy policy of Twitter (X);

· We use Tik Tok to showcase Our products and Services. For more information, you can consult Tik Tok's privacy policy;

· We use Pinterest to showcase Our products and Services. For more information, you can consult Pinterest's privacy policy;

· We use Microsoft services  (Outlook and the Microsoft Office suite) to store Our documents and emails. For more information, see Microsoft's privacy policy;  

All categories of Personal Information identified in section 3.1 - Collection of Personal Information may be communicated or stored through this service. 

· We share Your Personal Information with Pointer for the maintenance of our website;

· We may share Your Personal Information with various types of companies such as:

· Accounting firms;

· Law firms.

· We use Metatracer on Our digital systems to facilitate the detection and management of Your Personal Information and that of Our employees, all to ensure Our compliance with privacy laws. 

Metatracer collects, like Personal Information, only identifying information. 

3.5.2  Communication outside Quebec

Disclosure of Personal Information Outside Quebec. We may share Your Personal Information outside of Quebec.

Protections when communicating outside Quebec. Before disclosing Your Personal Information to third parties outside of Quebec, We conduct a privacy impact assessment to assess the risks that may affect the security of Your Personal Information. This assessment also helps to identify appropriate security measures that will reduce or eliminate these risks. The communication will then be the subject of a written agreement obliging these third parties to comply with such measures. 

3.5.3  Comply with legislation, respond to legal requests, prevent harm, and protect Our rights

Specific Communications of Your Personal Information. We may disclose Your Personal Information when We believe that such disclosure is permitted, necessary or appropriate, including: 

· to respond to requests from public and government authorities, including public and government authorities outside Your country of residence; 

· to protect Our business; 

· to comply with legal process; 

· to protect Our rights, the privacy of Our employees, officers and directors, Our safety and property; 

· to protect Your privacy and rights, or the privacy and rights of third parties; 

· to enable Us to pursue available remedies or limit the damages that We may sustain; and 

· where it is consistent with or required under applicable laws, including laws outside Your country of residence.

 3.6  Consent

Consents for the Collection, Use or Disclosure of Personal Information. Unless otherwise required by law, the Company obtains Your consent to Us collecting, using and disclosing its 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 disclosure. 

Criteria for consent required. We will seek Your manifest, free, informed consent and be given for specific purposes before using or disclosing Your Personal Information for any purpose other than those set forth herein. We will also seek Your explicit consent whenever Sensitive Personal Information is involved in any of the Company's processing activities. We will seek Your consent for each of the specific purposes in simple and clear terms, separate from any other information that will be communicated to You.

BY USING OUR WEBSITE, BY SUBMITTING YOUR PERSONAL INFORMATION BY 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 discontinue using the Website. Except where otherwise provided by law, You may withdraw Your consent at any time upon reasonable notice. Please note that if You choose to withdraw Your consent to the collection, use or disclosure 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 some of Our services. 

3.7  Retention of Personal Information

Retention of Personal Information. Your Personal Information is destroyed upon fulfillment of the purposes for which it was collected. However, legal obligations arising from a law, regulation or court order may require us to retain Personal Information for a longer period of time. This could be the case where, for example, there is a retention period imposed by a statute. 

Additional Information. For more information about the periods for which Your Personal Information is retained, please contact Our Privacy Officer or, if You reside in Europe, Our DPA using the contact information provided in the section 1b) - Privacy Officer and Data Protection Officer of this Policy.

4. Your rights

List of rights. As a data subject, You may exercise the rights set out below by contacting Our Privacy Officer in writing or, if You reside in Europe, with Our DPA to the contact details provided for in Article 1b) - Privacy Officer and Data Protection Officer of Politics. Please note that, depending on applicable law, We may require You to verify Your identity before responding to any of these requests.  

· You have the right to be informed about the Personal Information We hold about You, its use, disclosure, retention and destruction, subject to the exceptions provided by applicable law;

· You have the right to access Your Personal Information, to request a copy (including a paper copy) of documents containing Your Personal Information, subject to exceptions provided by applicable law, and to obtain, where applicable, additional details about how We use, disclose, retain and destroy it; 

· You have the right to have the Personal Information We hold about You rectified, amended 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 disclosure of some of Your Personal Information collected (as identified in section 3.1 - Collection of Personal Information of this Policy) at all times, subject to applicable legal and contractual restrictions;

· You have the right to object to the processing of Personal Information held by Us about you before profiling or making an automated decision to which you have not consented, subject to the legal exceptions provided for by the laws of the countries where any of Our Company operates their business.

· You have the right to ask Us to stop disseminating Your Personal Information and to de-index any link to Your name that provides access to such information if such dissemination contravenes the law or a court order;

· You have the right to request that Your Personal Information be communicated to You or that it be transferred to another organization in a structured and commonly used technological format; 

· You have the right to be informed of a confidentiality incident involving Your Personal Information that could cause You serious harm. To this end, we keep a register that lists all confidentiality incidents and assess the damage they may cause; and

· You have the right to complain to the local supervisory authority that ensures compliance with applicable privacy laws with respect to Our Company, subject to the conditions set forth in applicable law.

5. Questions and Complaints 

Complaints to the Company. If You are dissatisfied with Our protection of your Personal Information, You have the right to complain to our Privacy Officer using the contact information identified in section 1b) of this policy or, if you are a European resident, to Our DPA whose contact information is also specified in section 1b) of this policy. 

Complaints to the Supervisory Authorities. If You are dissatisfied with Our protection of your Personal Information, You also have the right to complain to the local supervisory authority that ensures compliance with applicable privacy laws with respect to Our Business, subject to the conditions set forth by applicable law.

Competent authorities. The relevant local supervisory authority will change depending on where you live and the law and regulation that applies to You. Examples of Local Supervisory Authorities to which You may be subject include:

· The Data Protection Authority  (Belgium)

Rue de la Presse 35, 1000 Brussels (Belgium)

+ 32 (0)2 274 48 00          
contact@apd-gba.be

· The Data Protection Commission (Netherlands)
Dutch Data Protection Authority (CBP), O. Box 93 374 NL - 2509 AJ THE HAGUE
31 70 88 88 500 
info@cbpweb.nl

· The Office of the Privacy Commissioner (Canada)         

30 Street Victoria, Gatineau, J8X 2A1, Quebec (Canada),

       1-800-282-1376 

       (819) 994-5444

       Online application form

 · The National Commission for Information Technology and Civil Liberties (France)
3 Pl. de Fontenoy, 75007 Paris (France)

 01 53 73 22 22
Online application form

· The Commission d'accès à l'information (Québec) 

René-Lévesque East, Quebec, G1R 5S9, Quebec (Canada), 

418 528-7741 

1 888 528-7741

renseignements@cai.gouv.qc.ca

 · L’Information Commissioner’s Office (Royaume Uni)

Wycliffe House, Water Ln, Wilmslow SK9 5AF (United Kingdom)

+44 303 123 1113

Online Complaint Form

In order to comply with your request, you may be asked to provide appropriate identification or otherwise identify yourself.  

6. Cookies and Other Similar Technologies

Use of Cookies. Cookies  are small text files that are stored on Your device or browser. They collect certain information when You visit the Website, including Your language preference, browser type and version, the type of device You are using, and Your device's unique identifier. If some cookies are deleted after the end of Your browser session, other cookies are stored on Your device or browser in order to allow Your browser to be recognized the next time You visit the Website.  We use cookies and other similar collection technologies such as Pixels (collectively "Cookies") to help Us operate, protect and optimize the Website and the Services We offer. 

Certain Uses of Cookies. If some of the Cookies We use are deleted after Your browser session has ended, other Cookies are stored on Your device or browser in order to allow Us to recognize Your browser the next time You visit the Website. In particular, they make it possible to guarantee the functioning of the Website, to improve the browsing experience of users and provide certain data that allows Us to better understand the traffic and interactions that take place on Our Website as well as to detect certain types of fraud. Cookies do not cause any damage to Your device and cannot be used to extract Your Personal Information.

Browser configuration possible. You can set Your browser so that you are notified when You set Cookies when You visit the Website, so that You can decide, in each case, whether to accept or refuse the use of some or all of the Cookies. Please note that disabling Cookies on Your browser may affect Your browsing experience on the Website and prevent You from using some of its features. 

Cookie Policies. To learn more about how We use Cookies, You can see Our "Cookie Policy".

7. Security measures

Purposes of Our Security Measures. We have implemented physical, technological and organizational security measures designed to adequately protect the confidentiality and security of Your Personal Information against loss, theft or unauthorized access, breach, disclosure, copying, disclosure, disclosure, use, modification. These measures include: 

· Administrative measures. On the administrative side, the adoption of a series of measures, policies and procedures as part of the implementation of our information governance program, which include: 

· govern the access, communication, retention, de-identification, including destruction or anonymization of Personal Information;

· determine the roles and responsibilities of Our employees throughout the life cycle of Personal Information and documents;

· establish procedures for responding to and responding to confidentiality incidents;

· provide a framework for the process of requests and complaints relating to the protection and handling of Personal Information.

· Technical measures. On the technical level, the use of several means such as: 

· the use of a secure server and Secure Socket Layer (SSL) technology;

· the use of a firewall system;

· the use of encryption and segregation of duties systems, access controls and internal audits.

Incomplete list of measures. We have not exhaustively listed the set of measures We are implementing given the public nature of this Policy.

It is impossible to guarantee a 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 secure, please contact Our Privacy Officer immediately using the contact information provided in section 1(b) - Privacy Officer above. 

8. Changes to this Privacy Policy

Right to Modify this Policy. We reserve the right to modify this Policy at any time in accordance with applicable law. If we make any changes, We will post the revised Privacy Policy and update the updated date in the footer of the Privacy Policy. We will also reserve and allow you to visit a page archiving the version of Our policy prior to the changes communicated. We will notify You prior to the effective date of the new version of Our Policy. If You do not agree with the new terms of the Privacy Policy, We invite You to stop using Our Website and Services. If You continue to use Our Website or Services after the new version of Our Policy comes into effect, then Your use of Our Website and Services will be governed by that new version of the Policy.

9. Links to third-party websites

Liability for third-party websites. From time to time, We may include references or links to websites, products or services provided by third parties on Our Website ("Third-Party Services"). These Third-Party Services, which are not operated or 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. Specific information for individuals benefiting from the General Data Protection Regulation (GDPR)

We are a controller of Personal Data. For the purposes of this Privacy Policy, We act as the controller of your Personal Information identified in Europe as "Personal Data". 

 Applicable legal bases. If you are a resident of Europe, Our legal basis for collecting and using your Personal Data, as described in this Privacy Policy, depends on the information We collect and the specific context in which We collect it. We may process your Personal Data because: 

· We need to perform a contract with you, such as when you use Our Service;

· Your consent, in which case You may withdraw Your consent at any time by communicating to our DPO at the contact details provided in section 1b) of this Policy;

· The processing is in Our legitimate interests and does not override Your rights;

· To comply with the law.

 Applicable rights for European residents. If you are a resident of Europe, you have certain rights to the protection of your Personal Data. In certain circumstances, you have the following protection rights: 

 · The right to access, update or delete the Personal Data We have about You;

· The right to rectification;

· The right to object/opposition (which allows you to object to your data being used by an organisation for a specific purpose under certain conditions and circumstances); 

· The right of restriction;

· The right to portability;

· The right to withdraw your consent to the data.

Please note that We may ask you to verify your identity before responding to these requests.

Complaint to a Supervisory Authority. You have the right to complain or lodge a complaint with a supervisory authority about Our collection and use of your Personal Data. For more information, please contact your local data protection authority. Contact information for these authorities is provided in Section 5 of this Policy.

Disclosure of Personal Information Outside of Europe. We may share Your Personal Information outside of Quebec.

Protections when communicating outside Europe – Impact assessment. Before transferring Your Personal Data to third parties outside of Europe, We conduct an impact assessment to assess the risks that may affect the security of Your Personal Information. This assessment also helps to identify appropriate security measures that will reduce or eliminate these risks. The communication will then be the subject of a written agreement obliging these third parties to comply with such measures. 

Various approaches. In addition to the application of impact assessment, Our processes for disclosing Personal Data outside of Europe vary depending on the jurisdiction to which the Data will be transferred. 

12. Information specific to individuals benefiting from the UK GDPR

Applicable legal bases. If you are a resident of the United Kingdom, Our legal basis for collecting and using your Personal Data, as described in this Privacy Policy, depends on the information We collect and the specific context in which We collect it. We may process your Personal Data because: 

· We have a contract with You, such as when you use Our Service;

· Your consent, in which case You may withdraw Your consent at any time by communicating to our DPO at the contact details provided in section 1b) of this Policy;

· The processing is in Our legitimate interests and it does not override Your rights; and

· To comply with the law.

Applicable Laws for Residents of the United Kingdom. If you are a resident of the United Kingdom, you have certain rights to the protection of your Personal Information. In certain circumstances, you have the following protection rights: 

· The right to access, update, or delete the Personal Information We have about You;

· The right to rectification;

· The right to object/opposition (which allows you to object to your data being used by an organisation for a specific purpose under certain conditions and circumstances); 

· The right of restriction;

· The right to portability;

· The right to withdraw your consent to the data.

Please note that We may ask you to verify your identity before responding to these requests.

How We Retain Your Personal Information. Your personal information is kept secure. We retain this information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

Complaint/complaint to the Information Commissioner's Office. You have the right to complain or lodge a complaint with theInformation Commissioner's Office about Our processing of your Personal Information. For more information, please contact theInformation Commissioner's Office.

13. Minors 

Collection of Personal Information from Minors. We do not knowingly collect or use Personal Information from minors. If, based on the laws of countries where You are only the age required to provide Your consent to the Processing of Your Personal Information, You must not provide Your Personal Information to Us without the consent of your parent or guardian. If you are a parent or guardian and you become aware that your child has provided Us with Personal Information without Your consent, please contact Us using the contact information provided in Section 1(b) above to request that We delete that child's Personal Information from Our systems.

14. Governing Law

The laws of Quebec, Canada, the United Kingdom and Europe (depending on the place of residence of the person concerned) will govern this Policy and Your use of the Website. Your use of the Website may also be subject to other local, provincial, national or international laws