POLICY CONCERNING CONFIDENTIALITY and PROTECTION OF PERSONAL INFORMATION

1. INTRODUCTION

Groupe Gecko Alliance, its subsidiaries and affiliates (“ Gecko ” or the “ Company ”) recognizes the importance of protecting Personal Information, that is, any Information concerning an individual that directly or indirectly identifies that individual (“ Personal Information ”).

This Policy Concerning Confidentiality and Protection of Personal Information (the “ Policy ”) describes the measures taken by Gecko to protect the Personal Information that it collects, uses, discloses, processes and retains as part of the operation of its websites and its current operational activities.

This policy is defined by and complies with the provisions of the Act respecting the protection of personal information in the private sector (ARPPIPS), as amended by S.Q. 2021, ch. 25 and the Personal Information Protection and Electronic Documents Act (PIPED).

2. PERSONAL INFORMATION COLLECTED

For the purposes of this Policy, collection of Personal Information by Gecko includes only that information necessary for its activities. This concerns information relative to your identity, such as your names, addresses, telephone numbers, demographic information and information on the use of websites.

3. CONSENTEMENT

Gecko collects, uses and communicates Personal Information for the purposes stipulated when it is collected, for example, when a person completes a request for information via the contact page on a website

Here is a non-exhaustive list of examples of purposes for which Gecko collects Personal Information:

  • -To manage requests about the products and services offered;
  • -To personalize and adapt the browsing experience on the Company’s website;
  • -To assess a dossier as part of an application for a position identified in the Careers section;;
  • -To manage registrations for the launch of a new product or service;
  • -To meet regulatory and legal obligations;
  • -To confirm the identity of individuals and to verify the accuracy of and update Personal Information;

By using the websites, you consent to the collection, use and storage of the Personal Information listed in this policy.

4. COLLECTION OF PERSONAL INFORMATION

Gecko gathers Personal Information in the following ways:

1. Directly from you:

Most Personal Information collected is provided directly at these times:

  • – Communication at a point of service via a website “Support” page;
  • – Subscription to online documentation portals;
  • – Specific requests about products and services;
  • – Application for a position;

2. Through the Company’s website:

Gecko can also gather information about visitors to its websites or to the online service portals, including the identification of the computer equipment used (IP address). This information is collected using files commonly known as “cookies”. Among other things, these files allow for recognizing website users when they access the sites and go from one page to another. When required, Gecko will ask for consent before collecting the information.

5. ACCESS TO AND COMMUNICATION OF PERSONAL INFORMATION

Personal Information is disclosed and accessible to Gecko employees who have a reasonable need to access it to carry out the objectives stated in this Policy. All Personal Information stored on Gecko’s servers is secured and it is only accessible to those employees who are entitled to access it in the course of their duties. The least privilege principle is followed when assigning access to Personal Information, based on users’ role and responsibilities.

Third parties (partners and suppliers) may also access Personal Information gathered to carry out the objectives stated in this Policy. They will not be able to access Personal Information beyond that which is reasonably necessary to attain the given objective.

Gecko is committed to neither selling Personal Information nor sharing it with third parties, except in the following cases:

  • 1. Gecko is required by law to do so;
  • 2. the information is required for any legal proceedings;
  • 3. the information is required to prove or protect legal rights;
  • 4. as part of a commercial transaction, to potential buyers if the corporation changes hands.
6. WHERE IS YOUR PERSONAL INFORMATION RETAINED

The servers containing the Personal Information are located in Québec, Canada. It is s possible, however, that communicating Personal Information to certain suppliers of technical solutions may involve transferring this Information outside of Québec. In such cases, Gecko will validate in advance the legislation and practices concerning protection of Personal Information applicable in the jurisdiction in question and ensure adequate protection of your Personal Information.

7. LENGTH OF RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

Gecko has established measures to ensure compliance with its obligations for the retention and destruction of Personal Information.

Personal Information gathered by Gecko shall not be retained beyond what is necessary to achieve the ends for which it is gathered.

Notwithstanding the foregoing, Gecko shall retain your Personal Information when this is required to comply with applicable legal obligations.

8. PROTECTION MEASURES FOR PERSONAL INFORMATION WITHIN THE COMPANY

Gecko has established physical, organizational, contractual and technological security measures to adequate protect Personal Information from theft, loss, unauthorized access, transfer, copying or alteration.

Gecko employees are bound by confidentiality agreements. Training and awareness activities on Data Security and Protection of Personal Information are offered regularly to Gecko employees. Computer systems meet the security protocols and frameworks recommended by the industry.

9. RIGHTS OF WEBSITE USERS

As a person whose Personal Information has been collected by Gecko, you may exercise the following rights:

Right to access, correct or complete your Personal Information: Gecko makes reasonable efforts to ensure that the Personal Information it collects is accurate and complete for the ends to which it is used. You may consult your Personal Information, verify its accuracy and amend it if necessary, except for those exceptions in the legislation. Your request for access or rectification must be transmitted to the Protection of Personal Information Officer at the address found in Section 11 and it shall be processed no later than thirty (30) days following the date of receipt of your written request.

Right to withdraw your consent: You can withdraw your consent to having your Personal Information used by Gecko for purposes that are not essential to the management and administration of its products and services.

In general, it will not be possible to withdraw your consent to the use of your Personal Information for a purpose related to the management and administration of products and services without putting an end to your contract.

Any request to withdraw consent shall be communicated to the Protection of Personal Information Officer at the address found in Section 11.

Right to file a complaint: Any question with respect to your Personal Information or complaint based on noncompliance with the principles stated in the Policy shall be sent to the Protection of Personal Information Officer at the address found in Section 11.

10. POLICY UPDATES

This Policy may be amended on occasion to maintain compliance with legislation and shall take into account any change in the process of collecting Personal Information. Gecko recommends that its users check the Policy from time to time to make sure that they are informed of any updates.

11. CONTACT

The Protection of Personal Information Officer is responsible for ensuring the protection of your Personal Information.

Contact information is as follows:

Protection of Personal Information Officer

450 Des Canetons Street, Québec City, Québec, Canada G2E 5W6

+1 418.872.4411

All requests shall be acknowledged and processed with due respect. It will be impossible to respond to your request if Gecko no longer retains your Personal Information.

Effective date: September 22, 2022
Last update: April 2023
Approved by: VP Human Resources