Protection of personal information

Human Resources Policies

Effective: July 2023

Scope

This policy applies to all VIF Group employees and subcontractors.

Goal

Following the adoption of the Act to modernize the legislative provisions governing 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 needed to be put in place.

Objectives

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

Policy

Groupe VIF respects your privacy and is committed to protecting your personal information in accordance with applicable laws. This policy concerns the protection of personal information by Groupe VIF and is applicable to all 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 Groupe VIF. The terms “we”, “us” and “our” refer to Groupe VIF. The masculine gender is used in the Policy for the sole purpose of lightening the text.

The purpose of the Policy is to help you understand how Groupe VIF collects, uses, processes, discloses, maintains 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 specific individual. Information from which all direct and indirect identifiers have been removed (i.e. anonymized personal information) is not personal information.

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

personal identity information, such as first name, surname, given name, gender, date of birth and title.
personal contact information, such as e-mail address, postal address, postal code and telephone numbers.
order history, such as the names and contact details used to place an order, and information about the products you are interested in.
financial information, such as PayPal account information used to place an online order.
technical personal information, such as Internet Protocol (IP) addresses and geolocation information, cookies and other technologies on the devices you use to access this Web site.
information on Internet activity, such as browsing history, search history and interactions with our Web site and online advertisements.
Personal information on the career section, such as how you heard about us, the information of the person who referred you for a position with Groupe VIF, the legal status that allows you to work in Canada, your curriculum vitae 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 about criminal convictions or offences.

If you provide Groupe VIF with the personal information of another individual, 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 Web Site, you are communicating with us electronically. You consent to receive non-commercial electronic communications from us via the Internet, e-mail or by posting notices on any Web Site in accordance with the Policy.

You agree that by sending you agreements, notices, information and other communications electronically, we are complying with any legal requirement that such communications be in writing.

2 – How do we collect your personal information?

We use various methods to collect your personal information, including the following:

Direct interactions. When you communicate with 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 Groupe VIF;
by creating a user profile and choosing a password;
by contacting us directly via a contact form available on our Website;
when you order products via one 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 job 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 done 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 Web site, we will automatically collect personal technical and Internet activity information about the computer equipment used to use our Web site and your browsing patterns. We collect this information usingcookies, web beacons, server logs and similar technologies. We may also receive your personal technical information if you visit third-party Web sites 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
Personal technical information Internet activity information	To provide access to our Web Sites and enhance your convenient use of them.
Personal identity information Personal contact details Order history Information about your relatives	Respond to your messages and requests, including complaints or comments about our products.
Personal identity information Personal contact information Order history Personal technical information Internet activity information	Administer contests, prize draws and surveys, as well as promote Groupe VIF and the Carvin brand
Personal identity information Personal contact information Order history Financial information	Enable you to complete 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 offer employment opportunities.
Personal Identity Information Personal Contact Information Order History	Comply with obligations imposed by applicable law

As stated above in Section 10 (e), you may always choose not to receive promotional materials or commercial information from Groupe VIF. For greater certainty, we will not send commercial electronic messages without your express consent.

4 – To whom do we communicate your personal information?

Except as described below, Groupe VIF does not share or sell your personal information with third parties.

Groupe VIF communicates your personal information to third parties in the following circumstances:

to our service providers who help us fulfill the purposes for which your personal information was collected, including server hosting providers who help us store your personal information;
to service providers who help us conduct demographic studies on visitors to our Web Sites and job applicants;
comply with our obligations under any law or regulation, investigation by a governmental authority, subpoena or 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, a violation of a 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 consummation or proposal of a business transaction (including liquidation, realization, foreclosure or repossession), concession, merger, business combination or any other type of acquisition, liquidation, transfer, translative contract or financing of the VIF Group, in whole or in part, or of any property, stock, asset, share or business/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 across Canada. Where required by applicable law, we conduct Privacy Impact Assessments to evaluate the risk associated with the transfer of personal information outside your province of residence. Please note that privacy laws in other provinces may differ from those applicable in your province.

5 – How do we protect your personal information?

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

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

Although Groupe VIF makes every effort to ensure that no unauthorized third party will access or obtain your personal information through the Websites, complete confidentiality and security cannot yet be guaranteed on the Internet. Communications via the Internet are subject to possible interception, loss or alteration. You acknowledge and agree that Groupe VIF shall not be liable for any damages resulting from the transmission of confidential 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 retain your personal information only 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 such anonymized and de-identified data for legitimate business purposes without informing you or obtaining your consent.

7 – Children under 14

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 14, please do not use or provide any information on a Website or through any of its features, make any purchases from our Websites or provide us with any information about yourself, including your name, address, telephone number or e-mail 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 regarding your personal information

Subject to certain exceptions as permitted by law, you have the following rights with respect 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, upon request, provide you with 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, this 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 for rectification of personal information in a timely manner.

Your right to erasure

You may ask us to delete or withdraw your personal information in certain circumstances, for example when we no longer need your information to fulfil the purposes for which it was collected, or if you withdraw your consent (where applicable as your consent forms the legal basis for our processing of your personal information). If you have a right to erasure of your personal information and we have disclosed it to third parties, we will take reasonable steps to inform them where possible and where this would not require a disproportionate effort. If you so request, where possible and lawful, we will also inform you of the identity of 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, such withdrawal will not affect the lawfulness of any processing carried out before you withdrew 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 you withdraw your consent.

9 – Use of cookies

We may usecookies 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 that 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 on Google Search Console, please visit the following pages:

https://developers.google.com/terms and 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 https://moz.com/terms-of-use, https://moz.com/privacy-policy and https://moz.com/gdpr.
For further information, please visit Ahrefs Pte. Ltd, please visit https://ahrefs.com/fr/terms and https://www.iubenda.com/privacy-policy/794932/legal.
For more information on 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 this 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 transferred to your computer’s hard drive by a Web site. They store your preferences so that your subsequent visits to the Web Site can be more efficient. Cookies can store a variety of information, including the number of times you visit a Web Site, your registration information and the number of times you visit a page or other element of the Web Site. We use cookies on the Web Sites to :

improve online customer service and the functionality of the Websites;
customize the content of the Websites;
adapt and measure advertising; and
offer 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 blocking cookies, detecting cookies sent to you and disabling cookies.

You can also choose the exclusion 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 analysis information by Google Analytics by downloading and installing the Google Analytics exclusion browser add-on, available at the following link: https://tools.google.com/dlpage/gaoptout?hl=fr.

However, it is important for you to know that without cookies, you will not be able to access some of the functions of a Web Site and therefore will not be able to take full advantage of them.

10 – Hyperlinks to other websites

The Websites may contain hyperlinks enabling users to visit other websites operated by other entities. Groupe VIF has no control over sites operated by other entities and assumes no responsibility for their inclusion on the Websites. Any information you transmit to websites operated by other entities will be subject to the privacy policies applicable to those websites.

11 – Modifications

Groupe VIF 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. Your continued use of any Web Site after a revised version of the Policy has been posted will constitute your acceptance of and agreement to be bound by such changes. It is your responsibility to regularly review the Policy and any changes that may be made.

12 – Questions

If you have any questions about our privacy practices, this Policy, or to exercise any of your rights with respect to your personal information, please contact Groupe VIF’s Privacy Officer as follows:

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