Privacy policy

INTRODUCTION

9344-0709 Québec inc. and all of its affiliates and subsidiaries (collectively the "Company" or "C'est beau" or "we") respect your privacy and are committed to protecting it by complying with this policy (our "policy").

This Policy describes:

• How we collect, use, disclose, and protect the personal information of our customers, suppliers, subcontractors, employees, job applicants and website users (“you”);

• Our policies and practices regarding the governance of personal information, such as the retention and destruction of personal information, the roles and responsibilities of our employees throughout the life cycle of such information, and our process for handling privacy complaints; and

• The types of information we may collect from you or that you may provide when you visit the website www.cestbeau.co and its subdomains (our “Website” or our “site”).

We will only use your personal information in accordance with this policy, unless otherwise required by applicable law.

PERSONAL INFORMATION

The term "personal information" refers to any information which relates to a natural person and makes it possible, directly or indirectly, to identify that person. It should be noted that our policy does not generally apply to the collection and confidentiality of information related to an individual's performance of his or her duties within an organization, such as name, title or position, as well as the address, e-mail address and telephone number associated with his or her place of employment, but we handle such information at all times in strict compliance with applicable law.

PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

The Company uses, collects, holds and discloses personal information only for the purposes identified at the time of collection, or as otherwise permitted or required by applicable law, including for the following purposes :

• to provide its services, products and other related services, as well as to process payments and billing in connection therewith;

• to establish and manage relationships with customers and suppliers, including considering whether or not to establish a relationship;

• to respond to requests for information made through the website and to ensure appropriate follow-up;

• to send updates on our products and services and those of our affiliates;

• to administer our human resources;

• for administrative, management and operational purposes, such as issuing invoices, managing accounts, sales, collecting and processing payments; and for any other purpose for which you have given your consent;

• for any other purpose to which you have consented.

EMPLOYEE AND APPLICANT INFORMATION

In the course of its activities as an employer, the Company collects, uses and discloses personal information. For our employees, this collection is part of the essential management of labour relations. As for candidates applying to us, their information is collected and used to assess their suitability for available positions, which may involve information obtained from third parties for background checks or professional references. If a candidate is not selected, his or her information is retained for a reasonable period of time for future opportunities, unless a request for deletion is made. In addition, we maintain certain personal information about our former employees, including their names and contact details, for possible professional or regulatory requirements.

LIMITATION

The Company aims to limit the amount of personal information it collects to that which is necessary and appropriate for the identified purposes. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.

CONSENT

We use, hold and disclose personal information only for the purposes for which it was collected, except with the consent of the individual concerned. If personal information relating to a third party is provided to us, the person providing such information must affirm that he or she has obtained the necessary consent from such third party, or is otherwise authorized to allow us to collect, use, hold and disclose such information in accordance with this Policy. In the case of sensitive personal information, consent must be expressly provided by the individual concerned. Exceptions to this consent requirement may arise, for example, when a medical or security emergency makes it impractical to obtain consent, or when information is collected for the detection and prevention of fraud or to meet a legal obligation. For a more complete list of exceptions, please contact our Privacy Officer (identified below).

WITHDRAWAL OF CONSENT

You may change or withdraw your consent to our use, retention and disclosure of your personal information, or refuse to consent to certain uses, retention and disclosure of your personal information, subject to legal and contractual restrictions consistent with applicable law. To change or withdraw your consent, please contact our Privacy Officer (identified below).

INFORMATION WE MAY COLLECT

We collect and use several types of information from and about you, including :

• personal information such as name, physical address, email address, social media profiles, payment information, IP address and telephone number;

• for candidates for employment with the Company, work history and curriculum vitae;

• biographical information such as job title, name of employer;

• personal information you provide to describe your needs and requirements or those of your company;

• website usage and other technical information, such as details of visits to our website, your interaction with our advertising and online content, or information collected through cookies and other tracking technologies; and

• any other personal information provided by you (which may include personal information about you or others, such as family members or employees).

HOW WE COLLECT YOUR PERSONAL INFORMATION

We use a variety of methods to collect your personal information, including:

• direct interactions with you when you provide it to us, for example by filling out forms or corresponding with us by telephone, e-mail, when you sign up to receive our newsletters, or otherwise (if we have sent you a promotional e-mail such as a newsletter, you can unsubscribe by clicking on the unsubscribe link we have included in the e-mail);

• automated technologies or interactions, when you browse our website. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies;

• from third parties you have authorized to share it with us;

• from publicly available sources.

COOKIES

Cookies are small text files that a website may place on your computer or mobile device when you first visit a website or web page. Cookies do not cause any damage to the terminal, but facilitate, for example, the search for preferences, the pre-filling of certain fields and the adaptation of the content of the services of the visited site. This data enables us to improve ergonomics and services according to your interests.

We use the following types of cookies on our website:

• Functional cookies. Functional cookies are used to remember the selections you make when you are on our website so that your selections are saved for your next visit, for example the language of the website.

• Analytical cookies. Analytical cookies allow us to improve the design and functionality of our website by collecting data on how you access our website, data on how long you stay on our website, and so on.

Alternatively, if you have concerns about our use of cookies, you can take steps to prevent their installation, for example by changing your browser settings to block certain types of cookies. You can delete cookies stored on your device at any time by accessing the appropriate settings in your web browser. You have the option of configuring your devices to accept all cookies, to notify you when a cookie is issued, or to never accept cookies. However, this last option may result in certain personalized services not being provided and, consequently, in you not being able to take full advantage of all the functionalities offered by the website. If you do not wish to receive cookies in general, or only wish to refuse certain cookies, you can modify your browser settings accordingly. Consult the website of your web browser provider (for example, visit the Google website for Google Chrome, or the Microsoft website for Microsoft Edge) to find out how to manage your cookie preferences.

EXTERNAL LINKS

Our website may occasionally contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to one of these websites, please note that these sites have their own privacy policies and that we are not responsible for these policies. Please check these policies before submitting any personal data to these websites.

HOW WE USE YOUR INFORMATION

We use the personal information we collect about you :

• to provide our services, products and other services, to conduct our business, to process payments and billing, to administer and perform our services, including to fulfill our obligations under any agreements between you and us;

• to create and manage your account and to manage your orders;

• in the case of job applicants, to contact the applicant and to assess whether we will hire him or her;

• to assess whether we will retain your services and to keep in touch with you, if necessary;

• to respond to inquiries or requests from visitors to our web site;

• to facilitate the use of our website and to ensure that the content of our website is presented in the most effective manner for you and your device;

• for marketing and business development purposes - to provide information about new services or products, updates, or newsletters when a person has chosen to receive them. You can ask us to stop at any time; and

• to fulfill our legal, regulatory or risk management obligations - to comply with our legal obligations.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose the personal information we collect or that you provide, as described in this policy:

• to third parties in connection with legal proceedings, contractors, service providers and other third parties we use to support the performance or provision of our products or services (such as administrative service providers) and who are contractually bound to keep personal information confidential, to use it only for the purposes for which we disclose it to them and to treat personal information according to the same standards as set out in this Policy;

• to fulfill the purpose for which you provided the personal information;

• for any other purpose we disclosed when you provided the personal information;

• with your consent; and

• to comply with a court order, law or legal process, including responding to a request from a government or regulatory body, in accordance with applicable law.

The Company does not sell or exchange for consideration any personal information it holds.

THIRD-PARTY SERVICE PROVIDERS

To the extent that the Company uses third-party service providers to store, manage or process personal information on its behalf (for example, data storage and processing services, cloud computing services orcloud computing), we use contractual and other means to provide a comparable level of protection while personal information is being stored, managed or processed by these service providers.

Your personal information that we collect may also be shared with certain third parties, such as our e-commerce platform provider, Shopify, which we use to operate our online store. You can find out more about how Shopify uses your personal information here: https://www.shopify.com/ca-fr/legal/confidentialite.

Our service providers have contractual agreements with us to protect your personal information from unauthorized access, collection, use or disclosure. We limit the personal information we share with them to what is reasonably necessary to perform their functions and only for the purposes for which we are authorized.

BEHAVIORAL ADVERTISING

In order to provide you with targeted advertising or marketing communications that may be of interest to you, we use and share with our advertising partners certain personal information relating to your use of the website, your purchases and your interaction with our advertisements on other websites. We collect and share some of this personal information directly with our advertising partners and, in some cases, through the use of cookies or other similar technologies.

By accessing our website, you consent to this collection, use and disclosure of your personal information. Also, to exercise your rights or opt-out of certain uses or communications by these advertising partners, you must opt-out of these services directly with these third parties by following the instructions below.

We use Google Analytics to help us understand how our customers use the website.

We also use Meta Platforms, Inc. applications to help us understand how our customers interact with social media.

For more information on how targeted advertising works, you can visit the educational page of the Network Advertising Initiative ("NAI") at the following address https://thenai.org/about-online-advertising/faq/?tab=2 (in English only).

You may also object to targeted advertising by following the procedures provided at the following links, however we are not responsible for any failure by these companies to respect or comply with your request:

FACEBOOK - https://www.facebook.com/settings/?tab=ads

GOOGLE - https://www.google.com/settings/ads/anonymous

BING - https://about.ads.microsoft.com/fr-ca/demarrer/abonnez-vous

TIK TOK - https://www.tiktok.com/privacy/ads-and-your-data/fr

In addition, you can opt-out of some of these services by visiting the Digital Advertising Alliance opt-out portal at http://optout.aboutads.info/ (in English only).

COMMUNICATION OUTSIDE QUEBEC OR CANADA

When personal information is located outside Canada, it may be accessible by foreign governments, courts and other governmental authorities, if required by law or court order. We will only disclose or transfer personal information outside Canada in accordance with applicable Canadian laws and for lawful purposes.

When we disclose personal information outside Quebec, and sometimes outside Canada, we do so only for the purpose of providing the products or services, or to support our business so that we can offer our products or services reasonably efficiently and at commercially reasonable costs.

Before disclosing personal information outside Quebec, we conduct a privacy impact assessment in accordance with applicable Quebec law. This assessment takes into account: (i) the sensitivity of the information; (ii) the purpose for which it is to be used; (iii) the safeguards, including contractual safeguards, from which the information would benefit; and (iv) the legal regime applicable in the jurisdiction where the information would be disclosed, including the generally accepted principles of privacy protection applicable there. Personal information is only disclosed if the assessment demonstrates that it would benefit from adequate protection. If you would like more information about the service providers we use to whom personal information is disclosed outside Quebec, please contact our Privacy Officer (identified below). We confirm that we may, strictly in accordance with this policy, disclose your personal information outside Quebec or Canada to third parties we retain to provide services to us involving the use, disclosure or retention of your personal information on our behalf. You consent to any such disclosure, use or retention.

TERRITORIAL RESTRICTIONS AND COMPLIANCE WITH LOCAL LAWS

The Company is established and operates in accordance with the laws of the Province of Quebec, Canada. Privacy laws may differ depending on your jurisdiction of residence. If you reside or are established outside the province of Quebec, you are responsible for ensuring that the transmission of your personal information to the Company is permitted by the local or national laws applicable to you. By transmitting your personal information to the Company, you acknowledge and agree that such information will be subject to the laws of the Province of Quebec, Canada, and that the Company cannot be held responsible for non-compliance with privacy laws in your jurisdiction.

PERSONAL INFORMATION GOVERNANCE POLICIES AND COMPUTER SECURITY

Our commitment to your privacy.We take the security and responsible management of your personal information very seriously. Our privacy governance policies have been formally approved by our Privacy Officer. These policies and practices are designed to match the scope and complexity of our various business activities. The following subsections provide detailed information, in simple and clear terms, to inform you about our personal information governance policies and practices.

Data lifecycle management.Our policies cover the entire life cycle of your personal information. We keep your personal information only as long as necessary to fulfill the purposes for which it was originally collected, unless legal obligations require us to keep it longer, such as tax laws. Once personal information has served its purpose, we ensure its secure and responsible destruction or anonymization, following strict guidelines.

Employee and service provider responsibilities.Within our organizational structure, roles and responsibilities regarding the handling and management of personal information are clearly defined for our employees. All employees receive training in this regard and are held accountable for any non-compliance with our privacy standards. With regard to service providers, we establish contractual relationships exclusively with entities that undertake to respect industry-standard security measures and comply with the law. These agreements have been carefully reviewed to ensure that they comply with applicable laws and the principles set out in this policy.

Safety and compliance assessments. To ensure ongoing compliance with our policies and practices, we conduct periodic internal assessments. These assessments examine how personal information is collected, stored, processed and disposed of, and involve a thorough review of our processes and procedures. The assessments help us to determine the effectiveness of our existing security measures and to propose ongoing improvements.

Complaints handling.In keeping with our commitment to the protection of personal information, we have established a formal process for receiving, investigating and resolving any complaints about the safeguarding of your personal information.

Security measures.To protect your personal information, we use a multi-layered security approach that includes physical, electronic and administrative measures to prevent unauthorized access, use, alteration or disclosure of your personal information.

While these policies and measures are aligned with industry best practices, it is important to recognize that the absolute security of your personal information when transmitted online or when using online services cannot be unconditionally guaranteed. Such transmissions are therefore at your own risk.

We endeavour to present this policy in a simple and easily understandable manner, to ensure that you are fully aware of how we treat your personal information.

RETENTION, DESTRUCTION AND/OR ANONYMIZATION

Unless otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as is necessary to fulfil the purposes for which we collected it, including to satisfy any legal, accounting or disclosure requirements. In certain circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymized and de-identified information for any lawful purpose without your knowledge or consent.

We further inform you that we will retain your personal information for 90 days to 2 years after you terminate your account or for as long as we need it to fulfill the purposes for which it was collected, as set forth in this Privacy Policy. We may need to retain certain personal information for longer periods, for example for record keeping or reporting purposes in accordance with applicable legislation or for other legitimate reasons such as enforcement of legal rights, fraud prevention, etc.

RESPONSIBLE FOR THE PROTECTION OF PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and up-to-date. Please keep us informed of any changes to your personal information. By law, you have the right to request access to and correction of the personal information we hold about you.

If you wish to review, verify, correct or withdraw your consent to the use of your personal information, you may send us an e-mail at the e-mail address of the Privacy Officer to request access, correction or deletion of any personal information you have provided to us.

Privacy Officer

Raphaël Ricard

E-mail: raphael@cestbeau.co

Address: 501-C-90 rue Beaubien W, Montréal (Québec) H2S 1V6, Canada

Telephone number: (514) 978-2634

We may not comply with a request if we believe that the change would violate a law or legal requirement or would render the information incorrect.

CHANGES TO OUR PRIVACY POLICY

Privacy laws change rapidly and, as a result, this Policy may be changed from time to time by the Company, in its sole discretion, without notice or liability to you or any other person. The Company's collection, use and disclosure of your personal information will be governed by the version of this Policy in effect at that time. If we are authorized to communicate with you for this purpose, we reserve the right to inform you by e-mail or any other means of communication to which we are authorized, of any material changes to this Policy. This communication will be made in addition to updating the last modification date displayed at the top of this page.

COMPLAINTS ABOUT COMPLIANCE WITH THIS POLICY

The Company will respond to complaints from individuals or questions about our compliance with this Policy and applicable privacy legislation. We will investigate and attempt to resolve all complaints. If you wish to challenge our compliance with this Policy, please contact our Privacy Officer using the contact information provided above.