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Privacy Policy and Personal Information Protection

1. General Information

a) Introduction

Privacy protection is important to 9378-1086 Quebec Inc, Liqui Pneus. (hereinafter “Entity”, “We”, “Our”). For this reason, We have implemented measures to protect and manage your Personal Information responsibly in accordance with applicable laws in Quebec and Canada. This privacy policy (the “Policy”), which must be read in conjunction with Our Legal Notice, describes our practices regarding the collection, use, processing, disclosure, and retention of Personal Information of our customers, visitors, and users. It applies to the Entity as a whole. By using our website www.liquipneus.com or any of our services, you agree that We may collect, use, process, disclose, and retain 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 services, or to share your personal information with us. This Policy does not apply to the personal information of employees, representatives, and consultants of the Entity, or any other person affiliated with the Entity, as well as any information that does not constitute Personal Information as defined by applicable laws in Quebec and Canada. b) Privacy Officer Questions, comments, and complaints regarding the Policy and Entity’s privacy practices can be addressed to our privacy officer at the following coordinates:

Phone: 450-256-1685

Email: rprates@liquipneus.com

Address: 1870 Cunard, Laval, H7S2B2

2. Definitions

The following words and expressions, when they appear with an initial capital letter in the Policy, have the meanings assigned to them below, unless there is implicit or explicit derogation in the text: “Service Provider”: any natural or legal person who processes Personal Information on behalf of the Entity. These are third-party companies or individuals employed by the Entity to facilitate the Services, provide the Services on behalf of the Entity, perform services related to the Services, or assist the Entity in analyzing the use of the Services. “Personal Information”: any information concerning an individual that allows for their identification, i.e., that directly or indirectly reveals something about the identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental abilities, character, and behavior of the person concerned), or activities of that person, regardless of the nature of the medium and regardless of the form in which this information is accessible (written, graphic, sound, visual, computerized, or other). “Privacy Officer”: the person responsible for enforcing this Policy and whose coordinates are identified in section 1 of this Policy. “Services”: Services refer to the Website and our social media pages, as well as the services and products provided to you.

3. Processing of Personal Information

3.1 Collection of Personal Information In the course of our activities,

  •  We may process different types of Personal Information including the information listed below:
  • Contact information, such as your name, address, email address, phone number, vehicle model, and information to verify your identity;
  • Information regarding products or services, such as information about the Services We have provided to you;
  • Information you choose to provide or transmit to Us, for example, when you fill out our forms, apply for one of our job offers (your resume), or communicate with one of our employees or representatives;
  • Transaction and payment information, such as the payment method used, date and time, payment amount, billing postal code, your address, and other related information;
  • Information automatically collected when using the Websites and our Services, including: o Connection information and other information about your activities on the Websites, such as your IP address, the pages you have viewed, the time and date of your visits, the number of connections, the type of browser you are using, your device’s operating system, and other hardware and software information; o Demographic data and geolocation data, such as your IP address, precise or approximate location determined from your IP address or your mobile device’s GPS (depending on your device’s settings); o Financial information about your activities when using the Websites and our Services such as credit card numbers when conducting commercial transactions related to the Entity. In each case, this Personal Information is processed in accordance with the legitimate and necessary purposes listed in section 3.2 below.

3.2 Use of Personal Information We may use your Personal Information for the legitimate purposes described below:

  • Operate, maintain, monitor, develop, improve, and provide all features of Our Website;
  • Present and provide you with Services;
  • Allow you to track your online order;
  • Enable you to apply for job offers;
  • Enable you to purchase our Services and perform transactions related to our Services;
  • Enable you to initiate a financing request;
  • For marketing and business development purposes, if you have previously consented to the processing of your Personal Information for these purposes;
  • Respond to your questions and provide assistance as needed;
  • Collect feedback, testimonials, and comments regarding our Services;
  • Fulfill our contractual obligations to you;
  • Develop, improve, and offer new Services;
  • Send you messages, updates, security alerts;
  • Detect and prevent fraud, errors, spam, abuse, security incidents, and other harmful activities;
  • For any other purpose permitted or required by law.

3.3 Communication of Personal Information

We may disclose your Personal Information to our employees (including human resources and IT departments), contractors, consultants, agents, providers, service providers, and other trusted third parties (collectively, “Service Providers”), who need this information to help us operate Our Website, carry out our business activities, or serve you, provided that these Service Providers have previously committed in writing to ensure the confidentiality of your Personal Information in accordance with applicable laws and Our Information Governance Program. We do not sell, trade, or otherwise disclose your Personal Information to third parties.

3.3.1 Service Providers and other third parties

Although We endeavor to avoid disclosing your Personal Information to third parties, We may engage Service Providers to perform various services on Our behalf, such as IT management and security, marketing, as well as data analysis, hosting, and storage. We have defined below the cases in which such sharing may occur:

  • We use Google Analytics to analyze the audience of the Website, establish statistics, and converse with customers and prospects. Consult theirprivacypolicy;
  • We use Google Ads to analyze the audience of Our Services, establish statistics, and converse with customers and prospects. Consult theirprivacypolicy;
  • We use Facebook Pixel services to understand and deliver ads, establish statistics, and converse with customers and prospects. Consult theirprivacypolicy;
  • We use Go Daddy services to host our website. Consult theirprivacypolicy;
  • We use MailChimp services. Consult their privacy policy;
  • We use social media services Facebook from the Meta group, Linked In, X (formerly Twitter), Tik Tok, to communicate about our Services and products. Consult theirprivacypolicy;
  • We use Sezzle services for financing the purchase of products and services. Consult theirprivacypolicy;
  • We use a management tool for Our Website, namely WordPress. Consult their privacy policy; Before disclosing your Personal Information to Service Providers outside the province of Quebec or depending on the nature of the Personal Information disclosed, We conduct a privacy impact assessment. When We disclose your Personal Information to Service Providers, We enter into written contracts with them before your Personal Information is disclosed to them and We provide them with a copy of this Policy. These Service Providers may be located inside or outside the province of Quebec or outside of Canada, and the Personal Information collected by them may be stored and processed outside the province of Quebec or outside of Canada. As a result, your Personal Information may be subject to the laws of other jurisdictions, including the laws of countries where such information is stored or processed, and these laws may provide different levels of protection for your Personal Information. By using Our Website or providing your Personal Information to Us, you consent to the transfer, processing, and storage of your Personal Information outside the province of Quebec and outside of Canada. We remain accountable for the Personal Information collected from you and transferred to a Service Provider. Therefore, We will take all reasonable steps to ensure that these Service Providers use your Personal Information for the purposes set out in this Policy and respect your rights with respect to the Personal Information you have provided.

3.3.2 Public authorities

We may also disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

3.3.3 Merger or acquisition

In the event of a merger, acquisition, reorganization, dissolution, or sale of all or part of Our assets, your Personal Information may be transferred as part of the transaction. In this case, We will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

3.4 Retention of Personal Information

We retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law, or for purposes of evidence, in which case We will retain the Personal Information in question for the duration of the relevant limitation periods. Once the retention period has expired, We will destroy, delete, or anonymize your Personal Information. The retention period for your Personal Information varies depending on the purpose for which it was collected, the nature of the Personal Information, and the legal or regulatory requirements applicable to Us. For example, We may retain your Personal Information for the duration of our contractual relationship with you, as well as for a reasonable period of time thereafter in order to respond to any questions or complaints, to maintain appropriate business records, and to comply with applicable laws or legal obligations.

3.5 Security Measures

We take the security of your Personal Information seriously and have implemented various technical and organizational measures to protect your Personal Information against unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:

  • the encryption of certain data;
  • the use of authentication and access control mechanisms;
  • the implementation of a process for managing authorizations;
  • the implementation of measures to ensure the integrity, availability, and confidentiality of Personal Information;
  • the implementation of measures to monitor and detect any security incident;
  • staff awareness and training programs on data protection;
  • the establishment of measures to ensure the resilience of systems and services;
  • the use of secure servers, firewalls, and antivirus software;

regular security assessments and audits of Our systems and infrastructure. However, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, while We strive to use commercially acceptable means to protect your Personal Information, We cannot guarantee its absolute security.

3.6 Cookies and Similar Technologies

We may use cookies and similar tracking technologies to collect and track information about how you use Our Website and Services and to improve and personalize your experience. Cookies are small files that are stored on your device when you visit Our Website. They allow Us to recognize your device and store certain information about your preferences or past actions. You can control and manage cookies and similar technologies by adjusting your browser settings. However, please note that if you disable cookies or similar technologies, you may not be able to access certain parts of Our Website or use certain features of Our Services. For more information about cookies and how to manage them, please refer to Our Cookie Policy.

3.7 Links to Other Websites

Our Website may contain links to other websites or services that are not operated or controlled by Us. This Policy applies only to Our Website and Services. We are not responsible for the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policies of any third-party websites or services that you visit.

Your Rights

  • As a data subject, you can exercise the rights listed below by contacting Our Privacy Officer in writing at the contact information provided in section 1b) 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 about the Personal Information We hold about you, its use, disclosure, retention, and destruction, subject to exceptions provided by applicable law;
  • You have the right to access your Personal Information, request a copy, including in paper format, of documents containing your Personal Information, subject to exceptions provided by applicable law, and obtain, if applicable, additional details on how We use, disclose, retain, and destroy them;
  • You have the right to have any incomplete, ambiguous, outdated, or inaccurate Personal Information We hold about you rectified, modified, and updated;
  • You have the right to withdraw or modify your consent to the Entity collecting, using, disclosing, or retaining your Personal Information at any time, subject to applicable legal and contractual restrictions;
  • You have the right to request that We cease disclosing your Personal Information and de-index any link attached to your name that provides access to this information if such disclosure 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 privacy breach concerning your Personal Information that may cause you serious harm. For this purpose, We keep a record listing all privacy breaches and assess 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. To follow up on your request, you may be asked to provide appropriate identification or otherwise identify yourself.

5. Connection Cookies and Other Tracking Technologies

We use connection 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 browser. They allow us to collect certain information when you visit the Websites, including your preferred language, the type and version of your browser, the type of device you are using, and your device’s unique identifier. While some of the Cookies we use are deleted after your browser session ends, others are retained on your device or browser to enable us to recognize your browser on your next visit to the Websites. Personal Information collected through these Cookies is not intended to identify you. They are used to ensure the Website’s operation, improve users’ browsing experience, provide certain data that allow us to better understand traffic and interactions on Our Website, and detect certain types of fraud. Cookies do not damage your device and cannot be used to extract your Personal Information. We collect your IP address, information about your device and operating system or browser, your browsing history and navigation on Our Website, as well as your queries, your browsing preferences (languages used), etc. You can configure your browser to be informed about the placement of Cookies when you visit the Website, so you can decide, in each case, whether to accept or refuse the use of certain or all 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. For more information on how we use Cookies, you can refer to Our “Cookie Policy”.

6. Security Measures

The Entity has implemented physical, technological, and organizational security measures to adequately protect the confidentiality and security of your Personal Information against loss, theft, or unauthorized access, disclosure, reproduction, communication, use, or unauthorized modification. These measures include, among others: Administratively, the adoption of a series of policies and procedures as part of the implementation of Our information governance program, which notably:

  • Govern access, disclosure, retention, depersonalization, including anonymization and/or, where applicable, destruction of Personal Information;
  • Determine the roles and responsibilities of our employees throughout the life cycle of Personal Information and documents;
  • Establish procedures for intervention and response in the event of a privacy breach;
  • Govern the process of requests and complaints regarding the protection and processing of Personal Information. Technically, the use of severalmeanssuch as:
  • Using a secure server. All sensitive information provided is transmitted via “Secure Socket Layer (SSL)” technology, then encrypted in Our payment gateway database only to be accessible by authorized persons with special access rights to these systems, and are required to keep the information confidential;
  • Using backup systems, network monitoring software, etc.;
  • Using encryption and task separation systems, access controls, and conducting internal audits. We have not exhaustively listed all the measures we put in place given the public nature of this Policy. 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 Privacy Officer immediately using the contact information provided in section 1b) above.

7. Modification of this Privacy Policy

We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a modification, We will publish the revised version of the Privacy Policy and update the effective date in the footer of the Policy. We will also notify you by email at least thirty (30) days before the effective date of the new version of Our Policy. If you do not approve of 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 effective date of the new version of Our Policy, your use of Our Website and Services will be governed by this new version of the Policy.

8. Links to Third-Party Websites

Occasionally, We may include references or links on Our Website to Our Facebook page, websites, products, or services provided by third parties (“Third-Party Services”). These Third-Party Services, which are not operated or controlled by the Entity, are governed by privacy policies entirely separate and independent from ours. Therefore, We assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services We offer. The Policy does not extend to Third-Party Services such as Our Facebook, LinkedIn, and Twitter pages.

9. Invisible reCAPTCHA

Invisible reCAPTCHA analyzes activity on a web page feature (e.g., mouse movements and typing patterns) to determine if a user is a robot. The invisible reCAPTCHA service may collect information from your device. Information collected by reCAPTCHA is stored in accordance with its privacy policy.

10. Payment Details

Regarding credit card details or other payment information you have provided to Us, We undertake to store this confidential information in the most secure manner possible.

11. Individuals Under 14 Years of Age

We do not knowingly collect or use Personal Information from individuals under the age of 14. If you are under 14 years of age, you must not provide Us with your Personal Information without the consent of your parents or legal guardian. If you are a parent or legal guardian and become aware that your child has provided Us with Personal Information without consent, please contact Us using the contact information provided in section 1b) above to request that We delete the child’s Personal Information from our systems.

12. Applicable Laws

Canadian and Quebec laws, excluding its conflict of law rules, will 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.