Privacy | The VIF Group

Human Resources Policies

Effective: July 2023

Extent

This policy applies to all employees of the VIF Group and its subcontractors.

Goal

Following the adoption of the Act to modernize the legislative provisions as regards the protection of personal information (Bill 25), new responsibilities and obligations will gradually come into force in September 2022, 2023 and 2024. A policy and action plan therefore had to be put in place.

Objectives

The purpose of this policy is to provide greater control over personal information and to modernize and adapt our legal framework to today's technology.

Politics

VIF Group respects your privacy by committing to protect your personal information in accordance with applicable laws. This policy concerns the protection of personal information by VIF Group and is applicable to all of its personal information collection and processing activities, including its website (vifplastics.com) and that of its private label Carvin (carvinpoll.com).

The terms "you" and "your" refer to the individual whose personal information is collected or processed by VIVE Group. The terms "we", "us" and "our" refer to VIF Group. The masculine gender is used in the Policy for the sole purpose of lightening the text.

The purpose of this Policy is to help you understand how VIF Group collects, uses, processes, discloses, stores and protects your personal information. It is important for you to read and understand the Policy as it establishes a contract between you and us. By providing us with your personal information, you agree to be bound by this Policy. The Policy is organized by theme as follows:

1 – What categories of personal information do we collect?

Privacy laws in Canada generally define "personal information" as any information about an identifiable individual. This includes information that can be used alone or with other information to identify, contact, or locate a particular person. Information from which all direct and indirect identifiers have been removed (i.e., personal information that has been anonymized) is not personal information.

We may collect, use, store and transfer the following categories of personal information:

Personal identity information, such as first name, last name, given name, gender, date of birth and title.
Personal contact information, such as email address, mailing address, postal code, and telephone numbers.
Order history, such as the names and contact information used to place an order, and information about the products you are interested in.
Financial information, such as information related to your PayPal account used to place an online order.
Technical personal information, such as Internet Protocol (IP) address, geolocation information, cookies and other technologies on the devices you use to access this website.
Internet activity information, such as browsing history, search history, and interactions with our website and online ads.
Personal Career Information, such as how you heard about us, information about the person who referred you for a position at VIF Group, the legal status that allows you to work in Canada, your resume, and other information you choose to add to your profile on https://www.vifplastics.com (our "Career Section").

We do not collect any sensitive personal information about you (such as information about your ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health, or genetic or biometric data). We also do not collect information on criminal convictions and criminal offences.

If you provide Groupe VIF with another person's personal information, you represent that you have obtained all necessary consents from that individual to authorize us to collect, use and disclose that personal information for the purposes set out in the Policy.

By providing us with this personal information, sending us an e-mail or visiting our Website, you are communicating with us electronically. You then consent to receive non-commercial electronic communications from us, either via the Internet, e-mail or by notices posted on any Website in accordance with the Policy.

You agree that by electronically transmitting agreements, notices, disclosures and other communications to you, we comply with any legal requirement that such communications be in writing.

2 – How do we collect your personal information?

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

Direct interactions. When you contact us, you may provide us with your personal information, such as the information you provide to us at the following times:

by participating in contests or draws administered by VIF Group;
creating a user profile and choosing a password for it;
by communicating directly with us through a contact form available on our Website;
when you order products through any of the Websites;
by requesting a discount coupon for a VIF Group product; or
by applying for a job opportunity on our Website in the Careers section.
Indirect interactions. We collect certain personal information about you indirectly from our service providers with whom you also do business. This is the case when we receive your application for a vacancy through a recruitment agency, or when we obtain your contact and identity information for marketing purposes from a third party. Any indirect collection of your information is in accordance with this Policy, any privacy policy of the service provider in question, and in accordance with applicable laws.
Automated Technologies or Interactions. When you interact with our Website, we will automatically collect technical personal information and Internet activity information about the computer equipment used to use our Website and your browsing trends. We collect this information through the use of cookies, pixels, server logs, and other similar technologies. We may also receive your technical personal information if you visit third-party websites that use our cookies.

3 – Why do we collect and use your personal information?

We may use your personal information for the purposes for which it was collected, in accordance with our Policy, for other purposes permitted by law, or with your consent.

We may use the information collected for the following purposes:

Type of Personal Information	Purpose
Technical Personal Information Internet Activity Information	Provide access to our Websites and improve your practical use of them.
Personal Identity Information Personal Contact Information Order History Information About Your Loved Ones	Respond to your messages and requests, including your complaints or comments about our products.
Personal Identity Information Personal Contact Information Order History Technical Personal Information Internet Activity Information	Administer contests, prize draws and surveys, as well as promote VIF Group and the Carvin brand
Personal Identity Information Personal Contact Information Order History Financial Information	To allow you to place an order or transaction online, provide you with updates on the status of your transaction or order
Personal Identity Information Personal Contact Information Personal Career Profile Information	Provide access to our Careers section of our website and provide employment opportunities.
Personal Identity Information Personal Contact Information Order History	Comply with obligations imposed by applicable law

As set out above in Section 10(e), you can always opt out of receiving promotional materials or marketing information from VIF Group. For greater certainty, we will not send commercial electronic messages without your express consent.

4 – To whom do we share your personal information?

Except as set out below, VIF Group does not share or sell your personal information that you have provided to us to third parties.

VIF Group discloses your personal information to third parties in the following circumstances:

to our service providers who assist us in fulfilling the purposes for which your personal information was collected, including server hosting providers who assist us in storing your personal information;
to service providers who help us conduct demographic research about visitors to our Websites and job applicants;
comply with our obligations under any law or regulation, an investigation by a governmental authority, a subpoena, or an order of a court or other administrative or governmental authority;
with a law enforcement or government agency in connection with an investigation of actual or potential fraud, violation of any law, regulation or the terms of use of the Websites, or for the protection of the rights, property or safety of the VIF Group, our customers/users or our partners;
to an acquiring entity in connection with the completion or proposal of a business transaction (including liquidation, completion, seizure or takeover), concession, merger, business combination or any other type of acquisition, liquidation, transfer, transfer agreement or financing of the VIF Group, in whole or in part, or any property, share, asset, share or company/brand of the VIF Group.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not authorize our third-party service providers to use your personal information for their own purposes and we only authorize them to process your personal information for specific purposes and in accordance with our instructions.

When you provide us with personal information, you acknowledge and agree that your personal information may be transferred to other jurisdictions for processing and storage, including to servers located throughout Canada. Where required by applicable law, we conduct Privacy Impact Assessments to assess the risk associated with the transfer of personal information outside of your province of residence. Please note that privacy laws in other provinces may differ from the laws applicable in your province.

5 – How do we protect your personal information?

VIF Group has implemented reasonable physical, electronic, and administrative measures to protect your personal information from accidental loss and unauthorized access, use, modification, and disclosure.

To prevent unauthorized access to your user profile on a Website, please maintain the accuracy and integrity of the personal information associated with your user profile and ensure that such information is used appropriately.

Although efforts are made by VIF Group to ensure that no unauthorized third party will access or obtain personal information about you through the Websites, complete confidentiality and security are not currently guaranteed on the Internet. Communications via the Internet may be subject to interception, loss or alteration. You acknowledge and agree that VIF Group shall not be liable for any damages resulting from the transmission of confidential information or personal information over the Internet and that such communications are made at your own risk.

6 – How long will we keep your personal information?

Your personal information is stored securely, both on our premises and on the servers of our service providers.

We will only retain your personal information for as long as permitted or necessary under applicable laws and our data retention policies. 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 this anonymized and de-identified data for legitimate business purposes without notifying you or obtaining your consent.

7 – Children under 14 years of age

The Websites are not intended for children under the age of 14. No one under the age of 14 may provide personal information on the Websites. We do not knowingly collect personal information from children under the age of 14. If you are under the age of 14, do not use or provide information on a Website or through any of its features, make purchases on our Websites, or provide us with any information about yourself, including your name, address, telephone number, or email address. If we learn that we have collected or received personal information from a child under the age of 14 without verification of parental consent, we will delete that information.

8 – Your rights in relation to your personal information

Subject to certain exceptions, as permitted by law, you have the following rights in relation to your personal information held by us:

Your right of access

You have the right to access your personal information held by us and to receive a general account of our use of that personal information. Upon receipt of a written request from you, we will provide you with a copy of your personal information, although, in certain limited circumstances, we may not be able to make all relevant personal information available to you, for example, where that personal information also relates to another individual. In such circumstances, we will inform you, upon request, of the reasons for such refusal. We will endeavour to process all requests for access to personal information in a timely manner.

Your right to rectification

If your personal information held by us is inaccurate or incomplete, you have the right to have it rectified. Where appropriate, such corrected personal information will be provided to the parties to whom we are authorized to disclose your personal information. We will endeavour to process all requests to rectify personal information in a timely manner.

Your right to erasure

You may ask us to delete or remove your personal information in certain circumstances, such as where we no longer need your information for the fulfilment of the purposes for which it was collected, or if you withdraw your consent (where applicable given that your consent is the legal basis for our processing of your personal information). If you have the right to erasure of your personal information and we have disclosed it to third parties, we will take reasonable steps to inform them to the extent possible and in cases where it would not require disproportionate effort. If you ask us to do so, where possible and lawful, we will also inform you of the identity of the third parties with whom we have shared your personal information so that you can contact them directly.

Your Right to Withdraw Your Consent

If we rely on your implied or express consent as the legal basis for processing your personal information, you have the right to withdraw it at any time. However, this withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will inform you if this is the case at the time of withdrawing your consent.

9 – The use of cookies

We may use cookies to track your preferences and activities on the Websites. These cookies on the Websites may be generated, analyzed, and managed by Google Analytics, Google Search Console, Google Tag Manager, SEOmorz, Inc., and Ahrefs Pte. Ltd. and Facebook Pixels. By using and visiting any Website, you consent to our use of cookies on and off this Website.

For more information on how Google Analytics collects and processes data, please visit the following pages: https://policies.google.com/technologies/partner-sites?hl=fr-CA and https://marketingplatform.google.com/about/analytics/terms/fr/.
For more information about Google Search Console, please visit the following pages:

https://developers.google.com/terms et https://policies.google.com/terms?hl=fr.

For more information about Google Tag Manager and its privacy policy, please visit: https://marketingplatform.google.com/intl/fr/about/analytics/tag-manager/use-policy/.
For more information about SEOmorz, Inc., please visit the following pages: https://moz.com/terms-of-use, https://moz.com/privacy-policy, and https://moz.com/gdpr.
For more information, visit Ahrefs Pte. Ltd, please refer to the following pages: https://ahrefs.com/fr/terms and https://www.iubenda.com/privacy-policy/794932/legal.
For more information about Facebook Pixels, please visit https://fr-fr.facebook.com/legal/technology_terms. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from the Websites and elsewhere on the Internet and use that information to provide measurement services and targeted advertising. For more details on how Facebook collects and uses your personal data, and what you can do to protect your personal information, please refer to Facebook's privacy policy available at https://fr-fr.facebook.com/about/privacy/previous.

Cookies are small data files that are sent to your computer's hard drive by a Website. They save your preferences so that your subsequent visits to this Website are more efficient. Cookies can record a variety of information, including the number of times you visit a Website, your registration information, and the number of times you visit a page or other element of the Website. We use cookies on the Websites to:

improve online customer service and the functionality of the Websites;
personalize the content of the Websites;
tailor and measure advertisements; and
Provide a safer experience.

Most browsers are designed to accept cookies, but they can easily be modified to block them. Your browser's help files contain information on how to block cookies, detect cookies sent to you, and disable them.

You can also choose the opt-out option by clicking on the following link: http://optout.networkadvertising.org/?c=1 or https://optout.aboutads.info/?c=3&lang=fr.

You can also prevent the transfer and processing of analytics information by Google Analytics by downloading and installing the Google Analytics opt-out browser add-on, which can be found at the following link: https://tools.google.com/dlpage/gaoptout?hl=fr.

However, it is important for you to be aware that without cookies, you will not be able to access some of the features of a Website and therefore will not be able to take full advantage of it.

10 – Hyperlinks to other websites

The Websites may contain hyperlinks that allow users to visit other websites operated by other entities. VIF Group has no control over sites operated by other entities and is not responsible in any way for listing them on the Websites. Any information you transmit to websites operated by other entities will be subject to the privacy policies applicable on those websites.

11 – Amendments

VIF Group reserves the right to modify the Policy at any time without notice. You can consult it at any time on our Website.

We will notify you of any material changes to the Policy by posting an update notice on the Website. If you continue to use any Website after a new version of the Policy has been posted, you confirm your acceptance of the changes and are bound by those changes. It is your responsibility to regularly review the Policy and any changes to it.

12 – Questions

If you have any questions about our privacy practices, this Policy, or to exercise one or more of your rights in relation to your personal information, please contact VIF Group's Privacy Officer as follows:

By e-mail: rh@vifplastics.com, put as subject: Privacy

Protection of personal information