Protection of personal information

a) Introduction

Protecting privacy is important to Interlag Construction Inc. (hereafter ‘ Entity », « We », « Our ‘). For this reason, we have implemented protection measures and sound management practices for your Personal Information in accordance with the laws applicable in Quebec and Canada.

This privacy policy (the ’ Policy ‘), which should be read in conjunction with our Terms and Conditions, describes our practices for collecting, using, processing, disclosing and retaining Personal Information about our customers, visitors and users.

By using our website https://www.interlag.com/ (the ' Website ‘) or 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 follow and be bound by this Policy, you may not visit, access or use Our Website or Services or share your Personal Information with Us.

This Policy does not apply to the Personal Information of employees, representatives and consultants of Construction Interlag inc. or any other person affiliated with Construction Interlag inc. or to any information that does not constitute Personal Information as defined by the laws applicable in Quebec and Canada.

b) Person responsible for the protection of personal information

Questions, comments and complaints regarding Construction Interlag inc.'s privacy policy and practices may be addressed to our Privacy Officer at the following coordinates:

Phone :      (514) 323-6710

Email :          rprp@interlag.com

Address :          7100 rue Jean-Baptiste-Many, Chambly (Québec) J3L 2E3

The following words and expressions, when capitalized in the Policy, have the meanings attributed to them below, unless otherwise implied or explicit in the text:

' Service provider ': any individual or legal entity that processes Personal Information on behalf of Construction Interlag inc. This includes third party companies or individuals employed by Construction Interlag inc. to facilitate the Services, to provide the Services on behalf of Construction Interlag inc., to perform services related to the Services or to assist Construction Interlag inc. in analyzing the use of the Services.

' Personal information ’: means any information relating to a natural person which enables that person to be identified, i.e. which reveals, directly or indirectly, something about the identity, characteristics (e.g. the abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour of the person concerned) or activities of that person, whatever the nature of the medium and whatever the form in which the information is accessible (written, graphic, aural, visual, computerised or other).

' Person responsible for the protection of personal information ‘: the person in charge of applying this Policy, whose contact details are given in section 1 of this Policy.

' Services ': Services refers to the website and our pages on social networks, as a general civil engineering contractor for the repair and implementation of structural work.

3.1 Collection of personal information

In the course of our activities, We may process various types of Personal Information, including the information listed below:

• contact details, such as your first and last name, e-mail address and telephone number;
• information that you choose to provide or transmit to Us, for example, when you fill in a form or contact one of our employees or representatives;

In each case, this Personal Information is processed in accordance with the legitimate and necessary purposes listed in article 3.2 below.

3.2 Use of personal information

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

• provide you with a single secure link to send us your personal information once you have been hired

3.3 Disclosure of personal information

We may share your Personal Information with our employees (including Payroll and Human Resources departments, providers, service suppliers and other trusted third parties (collectively, the ’ Services supplier ’), who require such information to carry out our business activities or to 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.

We do not sell, exchange or otherwise communicate your Personal Information to third parties.

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, data analysis, hosting and storage. We have set out below the circumstances in which such sharing may take place:

• We use Google Analytics to analyse the website's audience, compile statistics and converse with customers and prospects. Consult their privacy policy
• We use Bing Ads technology to collect and store data in order to create user profiles using pseudonyms. Consult their privacy policy;
• We use the services of Jobilico, Indeed, Emploi Québec and Université Laval to recruit our employees. Consult their privacy policy;
• We use Facebook and LinkedIn to communicate about our activities and to present our products and Services. Consult Meta's privacy policy;
• We use the services of Web Hosting Canada (WHC) to host Our Website;
• We use Metatracer to ensure Our compliance with the privacy laws that apply to Us. See their privacy policy.
• We use Microsoft Sharepoint services for the storage of our data.

Where We disclose your Personal Information to Service Providers, We will enter into written contracts with them prior to disclosing your Personal Information to them and We will only provide them with the Personal Information that is necessary for the performance of their mandate. As part of these contracts with our Service Providers, We are committed to ensuring that the principles set out in this Policy are adhered to, and such Service Providers are required to use Personal Information in a confidential manner, as directed by Us and only for the purposes for which it was provided. We provide sufficient assurances that appropriate safeguards are in place which are proportionate to the sensitivity of the Personal Information being processed or disclosed. 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 that 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 security, 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 communicate, strictly in accordance with this Policy and the provisions of the Act respecting the protection of personal information in the private sector, RLRQ c P-39.1 (the ' Private Sector Act ') et la An Act to modernize legislative provisions respecting the protection of personal information, LQ 2021, c 25 (the ' Act 25 ‘, sanctioned on September 22nd 2021), your personal data, in the event of a sale, transfer or assignment, in whole or in part, of the Entity 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 any such transaction), We will inform you prior to the transfer of your Personal Information.) In such a case, We will inform you before Your Personal Information is transferred and is governed by another privacy policy.

3.4 Consent for personal information

Insofar as possible, Construction Interlag inc. obtains the consent of the person concerned for the collection, use and disclosure of his or her Personal Information. However, if you provide us with Personal Information about other persons, you must ensure that you have duly notified them that you are providing us with their information and that you have obtained their consent to such disclosure.

We will seek your express, overt, free, informed and specific consent before using or disclosing your Personal Information for purposes other than those set out herein. We will also seek your express consent whenever sensitive Personal Information is involved in any of Construction Interlag inc.'s processing activities, and we will seek your consent for each of the specific purposes in clear and simple terms, separate from any other information provided to you.

BY USING OUR WEBSITE, BY TRANSMITTING YOUR PERSONAL INFORMATION BY E-MAIL, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.

If You do not consent, please stop 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.

3.5 Retention of personal information

Subject to applicable laws, we keep your Personal Information only as long as it is required for the purposes for which it was collected, unless you consent to it being used or processed for another purpose. As an indication, the duration of certain information may extend up to 7 years following the end of the Services rendered by Construction Interlag inc. to you. 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 violations or to prosecute criminals).

For more information on the periods for which your Personal Information is kept, please contact our Privacy Officer using the contact details provided in article 1b) of this Policy.

As a data subject, you may exercise the rights set out below by contacting Our Privacy Officer in writing using the contact details 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 of 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 hard copies, of the documents containing your Personal Information, subject to the exceptions provided for by applicable law, and to obtain, where applicable, further details on how we use, disclose, store 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, out of date or inaccurate;
• You have the right to withdraw or modify your consent for Interlag Construction Inc. to collect, use, disclose or retain 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;
• You have the right to request that your Personal Information be communicated to you or transferred to another organisation in a structured and commonly used technological format;
• The right to be informed of a confidentiality incident concerning your Personal Information that may cause you serious harm. We keep a register of all confidentiality incidents and assess the harm they may cause;
• You have the right to lodge a complaint with the Commission d'accès à l'information, subject to the conditions laid down by 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 do not use cookies and other similar technologies (collectively, the ' Cookies ') to help Us operate, protect and optimise the Website and the Services We offer. Cookies’ are small text files that are stored on your device or browser. They enable us to collect certain information when you visit the Website, including your preferred language, the type and version of your browser, the type of device you are using and your device's unique identifier.

Construction Interlag inc. 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. These measures include:

On the administrative front, the adoption of a series of policies and procedures as part of the implementation of our information governance programme, including :

• govern the access, disclosure, retention, de-identification, anonymization and/or, where appropriate, destruction of Personal Information;
• define 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 confidentiality incident;
• govern the process for requests and complaints relating to the protection and processing of Personal Information.

On a technical level, the use of several means such as :

• the use of a secure server. All sensitive information provided is transmitted using Secure Socket Layer (SSL) technology;
• the use of backup systems, network monitoring software, etc. ;
• the use of encryption and segregation of duties, access controls and internal audits.

Given the public nature of this Policy, we have not provided an exhaustive list of the measures we are putting in place.

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 details provided in article 1b) above.

We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a change, We will publish the revised version of the Privacy Policy and update the update date in the footer of the Privacy Policy. We will also notify you by e-mail at least thirty (30) days prior to the effective date of the new version of our 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 continue to use Our Website or Services after the new version of our Policy becomes effective, your use of Our Website and Services will be governed by the new version of the Policy.

From time to time, We may include on Our Website references or links to Our Facebook page, websites, products or services provided by third parties (the ’ 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. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and the Services offered by Us. The Policy does not extend to third party Services such as Our Facebook page / such as Our Facebook and YouTube pages. 

We do not knowingly collect or use Personal Information from persons 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 parent or guardian. If you are a parent or guardian and become aware that your child has provided Personal Information to Us without consent, please contact Us using the contact details set out in section 1(b) above to request that We delete that child's Personal Information from our systems.

The laws of Canada and Quebec, 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.