LAST UPDATED ON SEPTEMBER 8, 2023

This privacy policy governs the way in which 9427-8264 Québec Inc. (doing business under the name “Groupe Pentagone”) (hereinafter “Groupe Pentagone”) collects, uses, retains, and discloses Personal Information collected from you and other Users (“you” or “User”) when using this website (the “Site”), whether accessed via the Internet, a mobile device, or other electronic devices, or by any other means. The Site is owned by Groupe Pentagone.

This privacy policy applies to the Site and to all the products and services that we offer on the Site.

We are committed to protecting the information that personally identifies you (as defined below) that we collect.

1. Definitions

“Collection” means the action of gathering, using, acquiring, or obtaining Personal Information in any way and by any means, including from Third Parties.

“Consent” means a free agreement to the Collection and/or disclosure of Personal Information for the purposes we have determined. Consent can be explicit or implicit, as provided by law, and can be given directly by the User or by an authorized agent. It must be unambiguous.

“Disclosure” means the action of revealing Personal Information to a Third Party.

“Personal Information” means any information relating to a natural person that allows, directly or indirectly, their identification.

“Person in Charge of Personal Information Protection” means the person at Groupe Pentagone responsible for ensuring compliance with and application of this policy in accordance with Section 3.1 of the Law modernizing legislative provisions on personal information protection.

“Third Party” means a person other than a User, that Groupe Pentagone or an agent of the latter;

“User” means any customer or any person accessing any customer service provided by Groupe Pentagone or the Site.

“Use” means the processing, handling, and management of Personal Information by Groupe Pentagone.

2. Responsibility

We will inform you at the time of Collection and subsequently upon request:

1. of the purposes for which the Personal Information is collected;
2. of the means by which it is collected;
3. of the rights of access and correction provided by law which stipulate that anyone can, free of charge, consult and have corrected a file or information that Groupe Pentagone holds about them. As such, they can correct inaccurate, incomplete or ambiguous information and they can also have outdated or unjustified information removed from the file;
4. of your right to withdraw your Consent;
5. if applicable, of the name of the Third Party for whom the Collection is made, of the names of the Third Parties or categories of Third Parties to whom it is necessary to disclose the Personal Information for the purposes for which they were collected; and
6. if applicable, the possibility that this Personal Information may be communicated outside of Québec.

Any User who provides their Personal Information following the preceding paragraph consents to its use and its disclosure for the purposes set out in paragraph i) of the preceding paragraph.

We are responsible for the Personal Information we hold or of which we have custody, which includes Personal Information entrusted to a Third Party for processing purposes.

Furthermore, we have appointed a Person in Charge of Personal Information Protection who will ensure compliance with and application of the principles stated in this policy and the Law modernizing legislative provisions on personal information protection. Other individuals may also be designated, from time to time and at the discretion of the Person in Charge of Personal Information Protection, to carry out, in whole or in part, the duties of the Person in Charge of Personal Information Protection. We will provide, upon request, the name of the Person in Charge of Personal Information Protection whose contact details are set out below.

Where applicable, we will ensure we obtain the Consent of the holder of parental authority or the guardian when collecting Personal Information from a child under 14 years of age.

We have developed various guidelines and practices for the concrete implementation of this policy, including:

• The establishment of policies and practices framing our governance regarding Personal Information and aimed at protecting Personal Information and ensuring compliance with this policy, which provide for:
  • the framework applicable to the retention and destruction of Personal Information; and
  • the roles and responsibilities of our staff throughout the lifecycle of Personal Information.
• The implementation of procedures related to the reception and processing of information requests or complaints;

• The establishment of a confidentiality incident registry;

• The establishment of a Personal Information retention schedule;

• Providing information and training to employees on the protection of Personal Information.

3. What personal information do we collect?

We might collect two types of information from Users of our Site:

• “information that personally identifies you,” which can be used to locate you, communicate with you, or establish your identity (such as your names, email address, postal address, phone number, username, credit card details, etc.). This information is securely stored in your customer account with us;

• “aggregated information,” which is information about your activities on the Site or related to the services or products and cannot be used to identify, locate, or communicate with you (such as the frequency of visits to this Site, data entered when using the Site, the most viewed pages, the type of browser, the links users click on, the IP address, and other similar information).

4. When do we collect Personal Information?

We collect Personal Information and other data in the following situations:

• When you use a credit card or another authorized payment method according to the terms and conditions of our Site to pay for our products or services, we may ask for your names, address, and information related to your credit card or other authorized payment method, as applicable.

• When you begin to fill out a transaction form, order, service request, including snow removal, repair, maintenance, or installation, automated technologies (cookies) automatically record the filled-in information so that it’s already completed upon your next visit to the form.
• When you create an account in the “Groupe Pentagone” Customer Area.
• When you schedule an appointment with us.
• When you communicate with us via email, especially to get information about our services, to clarify invoices, or to terminate a contract when it’s possible to do so.
• When you subscribe to our newsletter.
• With every transaction or service request, including snow removal, repair, maintenance, or installation, you have the option to update your profile and provide personally identifiable information.
• When you participate in a contest or a promotional offer through the Site.
• When you leave comments, provide feedback, or submit suggestions via the Site.

• When you visit the Site, even if you don’t log in, we collect information about your computer’s operating system (i.e., Microsoft Windows, Mac OS, etc.), your IP address, the web browser (e.g., Firefox, Internet Explorer, Chrome, etc.) being used, the referring website, usage data about your activity on the Site, including the pages you visit or share, the features you use, and the total time spent on the Site. This data is used for analyzing the Site’s performance and services.

You can choose not to provide Personal Information that identifies you, but this might prevent you from accessing all the features of the Site, including making any transaction, order, or request regarding our services, such as snow removal, repair, maintenance, or installation.

5. Web Browser Cookies and Other Technologies Used to Collect Data

In addition to the data collection previously described, we use various technologies to collect information from your computer and about your activities on our site.

• When you visit our website, we may assign one or more cookies to your computer to facilitate your access and personalize your experience on our site. A cookie consists of a small text file, containing no personally identifiable information, which we install in the user’s computer browser. Using a cookie also allows us to collect data about your online activity on our site, such as the web pages you visit and the links you click. Most browsers automatically accept cookies, but you can usually modify your browser settings to decline them. If you choose to decline cookies, you may not be able to sign in or use other interactive features offered on the site.
• Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our site. Web beacons are small images embedded in a web page that serve purposes similar to cookies in tracking activity. We might also insert web beacons in emails or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner allows us to customize the services we offer to our visitors, deliver targeted advertisements, and measure the overall effectiveness of our online advertising, content, programming, or other activities.
• Information Collected by Third Parties. We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect data about users who view or interact with their ads. Our site does not provide any personal information to these third parties. This data allows them to deliver targeted advertisements and measure their effectiveness.

6. How do we use the Personal Information collected?

We collect and use Personal Information or other data for the following purposes:

• To personalize the User’s experience
  • We might use information in aggregate form to understand how Users, as a group, use the services and resources provided on our Site.
• To improve our Site and the User’s experience
  • We continually strive to enhance our Site’s offerings based on the feedback and comments we receive from you.
  • We might use the information we collect about you to, among other things, display data trends according to different demographic characteristics, or present you with offers and discounts.
• To improve customer service
  • The information you provide helps us respond more effectively to your customer service requests and support needs.
  • When you submit questions or comments to us, we might use this information to respond to you.
  • By providing us with your Personal Information, you are deemed to consent to us contacting you by phone, email, mail, or text message i) to answer the questions you submit to us or ii) to follow up on a request from you regarding our products or services, or about the purchase or execution of products or services.
• To process transactions
  • We might use the information provided by Users when making a request for services or products, for instance for roof installation or repair, solely to process that request.
  • We do not share any information with Third Parties related to a credit card except as necessary to provide the service.
  • If a transaction occurs, such as the conclusion of a roof snow removal service contract, we might need to communicate Personal Information to a Third Party if this communication is required for the contract’s execution.
  • We might use your Personal Information to ensure the payment of sums owed in exchange for purchased or provided products and services.
• To communicate with you and keep you informed
  • The postal and electronic addresses provided by the User will be used to send information, promotional offers, and updates related to our services. These addresses may also be used to respond to Users or other requests or questions.
  • When purchasing services or products, you agree to sign up for our commercial electronic messages mailing list by ticking the designated box on the product or service request form. In addition to ticking this box, indicating your consent, a request for subscription reconfirmation (double opt-in) for our newsletter via email, text message, and postal mail will be sent to you through each of these means. From your double confirmation onward, you will receive emails and text messages that may include company news, updates, information about our products and services. If at any time you no longer wish to receive emails or text messages, you can unsubscribe by contacting us through our Site or by directly communicating with the Personal Information Protection Officer.
• For commercial purposes
  • We might use the information provided by Users to display targeted advertisements or content that, in our opinion, may be of interest to the User based on the information provided by the User.
  • We could provide data mining services to Third Parties wishing to better understand our Users by transmitting aggregated information based on the Users of the Site, such as interests and purchases made.
  • By providing us with your Personal Information, you consent to us contacting you, for marketing and business prospecting purposes, at the phone number you provided and your email address.

We might also use or sell aggregated information, including data related to visited pages, to improve the design, content, and performance of our Site, or to analyze the usage and popularity of certain pages of the Site.

7. Limit on the Collection of Personal Information

We can only collect Personal Information necessary for purposes determined before the Collection. We collect Personal Information from the User only, unless the User consents or the law permits collection from a Third Party.

We will ensure that you are informed of the purposes and means for which your Personal Information is Collected.

8. Limit on the Use of Personal Information

We may provide information that personally identifies you to authorized service providers who help us deliver services and perform functions on our behalf. They are not authorized to use this information otherwise. Where applicable, we will enter into a contract with these partners providing i) the implementation of measures to protect the confidentiality of your Personal Information, ii) the commitment to use this Personal Information only within the framework of their assignment or the execution of the contract, and iii) the commitment not to retain this Information after the contract expires.

We may disclose the Personal Information we hold when required by law, for instance, in response to a court order.

We may also disclose such Personal Information in response to requests from law enforcement or other public agencies if we believe that this disclosure could prevent the incitement to commit a criminal act.

We may disclose depersonalized information to a person or organization wishing to use this information for studies, research, or the production of statistics.

Lastly, we may disclose Personal Information in the event of a transfer of our assets or property in the context of a proposed or actual corporate reorganization, such as a merger or acquisition, within the limits authorized by law. If such a reorganization, merger, or acquisition takes place, we may use or disclose Personal Information in the course of our activities, in accordance with this privacy policy. In such a case, we will notify you of the fact that your Personal Information has been disclosed within a reasonable time following the reorganization, merger, or acquisition.

We may communicate or use your Personal Information to recover a debt that we hold against you.

9. How do we protect your Personal Information?

We adopt appropriate practices for the Collection, storage, and processing of data, as well as security measures to ensure protection against unauthorized access to your Personal Information, your Username, your password, transaction information, and your data stored on our Site, as well as their protection against alteration, disclosure, or destruction.

The exchange of sensitive and private data between the Site and its Users takes place via a secure communication channel and is encrypted and protected by digital signatures.

When you purchase our products or services, we (or our partners) will ask you to provide credit card information or billing data and an email address. We will use the information provided in relation to a purchase made by a User to process the order and for no other purpose.

We want you to use our Site with confidence. However, no system is entirely secure. Therefore, although we take all necessary measures to protect your Personal Information, we cannot guarantee that such personal information, searches, or other communications will always remain secure. Users acknowledge providing this Personal Information at their own risk. In this regard, Users should also remain vigilant in the processing and disclosure of their Personal Information and should avoid transmitting Personal Information via unsecured email. For more information on ways to protect yourself from identity theft, please visit the Federal Trade Commission’s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm.

10. Third-party Websites

On our Site, Users may find advertising or other content that leads to the websites and services of our partners, suppliers, advertising agencies, sponsors, licensors, or other third parties. We do not control the content or the links that appear on these sites and we are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may change constantly. These sites and services may have their own privacy policies and customer service policies.

Browsing on other sites and interactions with these, including sites that link to our Site, are subject to the policies and terms of these sites. Under no circumstances can we be held responsible for the personal information protection practices of websites not owned by Groupe Pentagone.

11. Accuracy and Access to Personal Information

We ensure that the Personal Information we hold about a User is up-to-date and accurate when making a decision related to a request. We will update a User’s Personal Information when necessary to make a decision, to fulfill the specified purposes, or to correct, upon a User’s request, erroneous personal information.

You can, by writing to the Data Protection Officer, obtain a copy of the Personal Information record we hold about you and collected from you. Additionally, you can, by writing to the Data Protection Officer, inquire about the categories of individuals who have access to your Personal Information, its usage, including its disclosure to third parties, and its retention duration.

If you demonstrate in your written request that the Personal Information we hold about you is inaccurate or incomplete, we will make the necessary modifications. We will address and respond to any such access or modification request promptly and within a reasonable time frame not exceeding 30 days.

We will not charge any fees for accessing the Personal Information record we hold about you. However, we may charge certain fees in cases of reproduction, transmission, or transcription of the Information.

We may refuse to disclose Personal Information if such disclosure is likely to harm Groupe Pentagone, a third party, or if it violates any law. If so, we will justify our refusal.

12. Retention of Your Personal Information

Your Personal Information is stored on a server located in Canada for a duration that allows us to achieve the purposes specified in this privacy policy. However, your Personal Information may be communicated and stored outside of Quebec by one of our partners. In doing so, we commit to adhering to the conditions outlined in Article 17 of the Act Respecting the Protection of Personal Information in the Private Sector. Once our purposes have been achieved, and in accordance with our schedule for retaining your Personal Information (which notably specifies that our client files are completely destroyed after a period of 7 years from the payment of the invoice associated with the provided services), we will destroy, remove, or anonymize your Personal Information. However, if a law specifies a specific retention period, we may keep them for the duration provided by that law.

When information is destroyed or removed, we ensure that the process is secure to irreversibly destroy the Personal Information or its medium, making it impossible to reconstruct them in any way.

We are committed to ensuring the confidentiality of Personal Information, notably by ensuring that our server meets the applicable IT security and protection standards. Access to personal information will only be possible for authorized persons for business purposes or as required by their functions.

13. Your Acceptance of This Policy and its Amendments

By using this Site, you confirm your acceptance of this policy. If you disagree with this policy, please refrain from using our Site. Continuing to use this Site after the publication of amendments to this policy means you are deemed to have accepted these changes.

We encourage all Users to frequently check this page to stay informed about changes to this policy and how we help protect the Personal Information we collect. Any changes to this policy will be published on the Site. Any change to this policy takes effect upon its publication.

14. Withdrawal of Your Consent

You can contact the Data Protection Officer at the details provided below to withdraw your Consent regarding the Collection or Disclosure of your Personal Information in our possession. Please note that such withdrawal may result in making our services unavailable to you.

15. Subsidiaries and Related Entities

You consent to Groupe Pentagone, its subsidiaries, and its related entities sharing Personal Information collected by one or the other in accordance with this privacy policy.

16. Password

To access your Client Area via the Site, you must create and maintain a password. This password is confidential and should not be shared with anyone. You are responsible for any use made from your Client Area by a Third Party.

17. Complaint

Anyone can file a complaint by contacting the Data Protection Officer. For this purpose, Groupe Pentagone has established a complaint process related to the processing of Personal Information.

18. Intellectual Property, Copyright, and Trademarks

All content (information, writings, images, logos, icons, etc.) on this Site is the exclusive property of Groupe Pentagone, its subsidiaries, its related entities, or Third Parties who have granted licenses and cannot be used, reproduced, distributed, displayed, or sold in any way without written permission from Groupe Pentagone. All content on this Site is protected by copyright laws applicable in Canada.

Only downloading and printing the content for purely personal and non-commercial use is permitted. Downloading and printing content does not expressly or implicitly grant any license or any other right to the User.

Trademarks appearing on this Site (both written and visual aspects) are the exclusive property of Groupe Pentagone, its subsidiaries, its related entities, or third parties who have granted licenses, and cannot be used, reproduced, or imitated without written permission from Groupe Pentagone and are subject to trademark laws applicable in Canada.

19. Official Version

The French version of this policy is the official version and prevails over the English version.

20. Applicable Laws

This privacy policy is governed by provincial and federal laws applicable in the province of the User’s residence.

21. Contact Us

For any questions or complaints related to this Privacy Policy, practices on this Site, or your interaction with this Site, or for any other request, please contact us at:

https://groupepentagone.com/contact/

OR

AS :Christine Pontbriand
Data protection officer
Controller
9427-8264 Québec Inc.
20550, Chemin Côte Nord
Mirabel, QC
J7J 2B7
vieprivé@groupepentagone.com