(Version date: 20-09-2023)

1. General information

1.1 Introduction

Protecting your privacy is important to Industrie Lemieux inc (hereinafter "IL", the "Organization", "we", "our"). For this reason, we have implemented safeguards and sound management practices for your personal information in accordance with applicable laws, including Bill 25.

This Privacy Policy (the "Policy") describes our practices regarding the collection, use, processing, disclosure and retention of Personal Information of our customers, visitors and users.

By using our website [ https://www.indlemieux.com ] (the "Website") or by doing business with us, 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 abide by and be bound by this Policy, you may not visit, access or use our Website or share your Personal Information with us.

This Policy does not apply to Personal Information of employees, representatives and consultants of IL, or any other person affiliated with IL, or to any information that does not constitute Personal Information as defined by applicable law.

1.2 Chief Privacy Officer ("CPO")

Questions, comments and complaints regarding IL's Privacy Policy and practices may be directed to our Privacy Officer Haris Fyaz at the following coordinates:

• E-mail: haris.fyaz@indlemieux.com
• Address: 1401 Graham-Bell Street, Bourcherville, Quebec J4B 6A1, Canada

2. Definitions

The following words and expressions, when appearing with a capitalized first letter in the Policy, have the meanings attributed to them hereinafter, unless otherwise implied or explicit in the text:

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

"Personal information" means any information that relates to a natural person and allows that person to be identified, i.e., that directly or indirectly reveals something about the identity, characteristics (e.g., abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour of the person concerned) or activities of that person, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, sound, visual, computerized or other).

"Sensitive Personal Information" means Personal Information which, by its nature or the context in which it is used or disclosed, gives rise to a high reasonable expectation of privacy. It may include, for example, medical, biometric, genetic or financial information, or information about a person's life or sexual orientation, religious or philosophical beliefs, trade-union membership or ethnic origin.

"Privacy Officer": the person who is responsible for the application of this Policy and whose contact information is identified in section 1.2 of this Policy.

"Services": Services refers to the Website and all related products and services offered by IL, which may include associated media, printed materials and "online" or electronic documentation.

3. Treatment of Personal Information

3.1 Collection of personal information

Your consent to share your personal information with us

For IL, respecting your privacy and the confidentiality of your data is paramount. That's why we've developed this privacy policy to tell you what information we collect, how we process it, and when we need to pass it on to subcontractors or third parties.

By giving your consent, you authorize IL to proceed with the collection and processing of your personal information that is required to offer you our Services. Please be aware that you remain in control of your personal information at all times and that the consent you give us to collect or process your personal information may be withdrawn at any time. We will respect your choice in accordance with our legal obligations.

In the course of our activities, we may collect, process and use various types of Personal Information that you provide to us only if we are permitted to do so by law, including the information listed below:

Via our website:

• contact information, such as your first and last name, e-mail address, telephone number, the type of job you are interested in and the information on your résumé when you apply (spontaneously or otherwise) for a career with us;
• information such as your first and last name, e-mail address, postal code, telephone number and any other information you provide when you request a quote from us;
• information automatically collected through the use of the Website and our Services, including :
  • connection and other information about your activities on the Website, such as your IP address, the pages you visit, the time and date of your visits, the type of browser you use, the operating system of your device and other hardware and software information;
  • geolocation data, such as your IP address, a precise or approximate location determined from your IP address or the GPS of your mobile device (depending on your device's settings).

When you interact with us :

• professional or employment-related information, such as your resume, place of employment, government titles or positions, employers, companies owned, salary or self-employment income, as well as information regarding your criminal history and other information you provide to us;
• contact information, such as your first and last name, e-mail address, telephone number, address and company number for the creation of a customer account;
• tax information, including your income and other information about your personal finances;
• information about products or services, such as information about the services we have provided to you;
• transaction and payment information, such as the payment method used, date and time, payment amount, billing zip code, your address and other related information;
• information you choose to provide or transmit to us, for example, when you fill out a form, respond to a survey or communicate with one of our employees or representatives.

In each case, such Personal Information is processed in accordance with the legitimate and necessary purposes listed in section 3.2 below. In addition, we ensure that we only collect and process data and Personal Information that is strictly necessary for the purposes for which you provide it to us. In the event of any subsequent use of your Personal Information, we will notify you as required by law.

3.2 Use of Personal Information

As stated in section 3.1, we only use your Personal Information to the extent permitted by law. We may use your Personal Information for the legitimate purposes described below:

• provide you with Services;
• allow you to subscribe to our newsletter;
• to verify your identity and review your personal history, as permitted by law;
• operate, maintain, supervise, develop, improve and offer all the functionalities of our Website;
• to manage risk and operations;
• to meet our obligations under applicable laws and regulations;
• develop new Services and improve our Web Site and Services;
• for marketing and business development purposes, if you have previously consented to the processing of your personal information for these purposes;
• send you messages, updates and security alerts;
• answer your questions and provide assistance when needed;
• administer a contest, promotion, survey or other feature of the Website or our Services;
• gather opinions and comments on our Services;
• conduct research and analysis related to our business and Services;
• detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities;
• to establish, exercise or defend a right or legal claim;
• send you communications in accordance with the law;
• enable the function to apply for a job with IL;
• for any other purpose permitted or required by law.

Please note that we do not use the information we collect to draw any inferences or interpretations whatsoever.

The Personal Information we collect and store is securely archived on servers located in Quebec, Canada and Ontario, Canada. Rest assured that this Personal Information is disclosed only when we are legally required to do so.

3.3 Disclosure of Personal Information

We may disclose your Personal Information to our employees, contractors, consultants, agents, Service Providers and other trusted third parties who require such information to help us operate our Website, carry out and protect our business activities or serve you, provided that such Service Providers have previously agreed in writing to maintain the confidentiality of your Personal Information in accordance with applicable laws and our Information Governance Program, as described in more detail in section 3.1.1. In addition, only those members of our Organization's Staff who have a need to access and process your Personal Information will have access to it, in accordance with our internal Privacy Policy.

We do not sell, trade or otherwise disclose your personal information to third parties, subject to exceptions provided by law.

3.3.1 Service providers and other third parties

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. We have defined below the cases in which such sharing may take place:

• We use the services of SV2 Marketing Inc. for the creation and management of our Website. See their privacy policy.
• We use the services of Salesforce to provide our CRM system. Read their privacy policy

When we disclose your Personal Information to Service Providers, we are committed to ensuring that the principles set out in this Policy are respected, and such Service Providers are required to use Personal Information in accordance with our instructions and only for the purposes for which it was provided. In addition, these Service Providers provide us with sufficient guarantees that they implement adequate safeguards that are proportionate to the sensitivity of the Personal Information processed or communicated. When our Service Providers no longer need your Personal Information, we ask them to destroy this data in an appropriate manner.

3.3.2 Complying with legislation, responding to legal requests, preventing harm and protecting our rights

We may disclose your Personal Information when we believe such disclosure is authorized, 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 proceedings ;
• to protect our rights, our privacy, our safety, our property, yours or that of third parties;
• to enable us to pursue available remedies or limit the damages we may suffer; and
• in accordance with applicable laws, including laws outside your country of residence.

3.3.3 Commercial transactions

We may share, transfer or disclose, strictly in accordance with this Policy, your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of IL or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or other business transaction, including in connection with the negotiation of such transactions). In such cases, if the transaction is completed, we will notify you before your Personal Information is transferred and becomes subject to another privacy policy.

3.3.4 Consent for Personal Information

Wherever possible, IL obtains consent directly from the individual concerned for us to collect, use and disclose his or her 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, in addition to obtaining their consent to such disclosure.
We will seek your consent before using or disclosing your Personal Information for purposes other than those described herein.

3.3.5 Retention of Personal Information
Subject to applicable laws, we retain your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected, unless you consent to your Personal Information being used or processed for another purpose. In addition, our retention periods may be modified from time to time due to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and breaches or to prosecute criminals).

Rest assured that when the purpose for which the information was collected has been fulfilled, we will destroy or anonymize the information in accordance with applicable legislation.

For more information on the periods during which your Personal Information is kept, please contact our Privacy Officer using the contact details provided in section 1.2 of this Policy.

3.4 Sensitive personal information

In the course of our activities, we collect Personal Information considered to be of a sensitive nature, when it is strictly necessary for our operations. In such cases, we ensure that we have your explicit consent to do so, in accordance with the law.
In addition, before collecting any such Sensitive Personal Information, we will ensure that we have your express consent to do so, as required by law.

4. Your rights

As a data subject, you may exercise the rights set out below by completing the available form and sending it by secure e-mail or by mail to the attention of our Privacy Officer at the contact information provided in section 1.2 of the Policy:

• You have the right to access the Personal Information we hold about you and to request a paper copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;
• You have the right to have the Personal Information we hold about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
• You have the right to withdraw or change your consent to IL's collection, use, disclosure or retention of your Personal Information at any time, subject to applicable legal and contractual restrictions.
• You have the right to ask us to stop disseminating your Personal Information and to de-index any link attached to your name that gives access to this information if such dissemination contravenes the law or a court order; and
• You have the right to file a complaint with the Commission d'accès à l'information, subject to the conditions set out in the applicable law.

In order to process your request, you may be asked to provide appropriate identification or to identify yourself in some other way.
We encourage all our customers to keep their personal information with us up to date. Decisions regarding the various services we can offer our customers may vary according to the accuracy of this data. It is therefore essential to ensure that we have an accurate picture of your situation.

5. Cookies and other tracking technologies

We use cookies and 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. While some of the Cookies we use are deleted after your browser session ends, other Cookies are retained on your device or browser to enable us to recognize your browser the next time you visit the Website. The data collected via these cookies is not intended to identify you. In particular, they enable us to guarantee the operation of the Website, to improve the user's browsing experience and to provide certain data that enables 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 damage your device and cannot be used to extract personal information.

Among the Cookies we collect via our Website are the following:

• Functionality cookies: these allow the Website to remember the choices you make (such as your username, preferred language, etc.) to provide you with a personalized and enhanced experience on future visits.
• Analysis cookies: these help us to analyze and understand how you use our website, in order to improve its user-friendliness, functionality and content.
• Advertising cookies: These cookies are used to display relevant advertising based on your interests and browsing history.

You can set your browser to notify you when Cookies are set on your visit to the Website, so that you can decide in each case whether or not to accept the use of some or all Cookies. Please note that deactivating Cookies on your browser may impair your browsing experience on the Website and prevent you from using some of its features.

6. Safety measures

The Organization has implemented physical, technological and organizational security measures to adequately protect the confidentiality and security of your personal information against loss, theft or any unauthorized access, disclosure, reproduction, communication, use or modification.

Among the various measures put in place :

• Our website uses Secure Sockets Layer (SSL) technology to ensure a secure connection between your device and our server;
• IL's employees have read this Policy and have undertaken to comply with it and to respect the confidentiality of Personal Information concerning our potential and existing customers. In addition, each employee undertakes to follow and respect a data governance policy applicable to all IL personnel;
• As mentioned in section 3.3, we have implemented measures to restrict access to Personal Information to persons who have a valid reason to consult, process, communicate or otherwise use your information;
• As mentioned in section 3.3, the subcontractors and third parties who do business with IL and with whom we may need to communicate your Personal Information have previously undertaken to protect the confidentiality and privacy of such information;
• When the purpose for which your Personal Information was collected has been fulfilled and we no longer need to retain it, IL will destroy or anonymize such data, subject to applicable laws.

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 details provided in section 1.2 above.

7. Changes to this Privacy Policy

We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a change, we will post the revised Privacy Policy and update the update date in the footer of the Privacy Policy. If you do not agree to the new terms of the Privacy Policy, please do not continue to use our Website and Services. If you choose to continue using our Web Site or Services after the new version of our Policy becomes effective, your use of our Web Site and Services will be governed by the new version of the Policy.

8. Links to third-party websites

From time to time, we may include on our Website references or links to websites, products or services provided by third parties ("Third Party Services"). These Third Party Services, which are not operated or controlled by IL, are governed by privacy policies 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. This Policy does not extend to Third Party Services.

9. Limitation of liability

The Organization undertakes to take all reasonable steps to ensure the confidentiality and security of Personal Information in accordance with technological standards appropriate to its sector of activity.

Notwithstanding the foregoing, you declare that you understand and acknowledge that no computer system offers absolute security and that there is always some degree of risk involved in transmitting Personal Information over the public network that is the Internet.

You hereby agree that IL shall not be liable for any breach of confidentiality, hacking, virus, loss, theft, misuse or alteration of Personal Information transmitted or hosted on its systems or those of a third party. You also waive any claim in this regard, except in the case of gross negligence or wilful misconduct on the part of IL. Accordingly, you agree to hold IL and its officers, directors, affiliates and business partners harmless from any and all damages of any kind, whether direct or indirect, incidental, special or consequential, arising out of or in connection with the use of your Personal Information.

In the event of a breach of confidentiality or security of your Personal Information that presents a high risk to your rights and freedom, you will be notified of such breach as soon as possible, and IL will take the necessary steps to preserve the confidentiality and security of your Personal Information.

10. Individuals under 14 years of age

If you are under 14 years of age, you must not provide us with your Personal Information without the consent of your parent or guardian. If you are a parent or guardian and become aware that your child has provided us with Personal Information without consent, please contact us using the contact details set out in section 1.2 above to request that we delete that child's Personal Information from our systems.

11. Contact us

Any questions, comments, requests or concerns regarding this Privacy Policy should be directed to our Privacy Officer at the contact information provided in section 1.2 of this Privacy Policy.