Privacy policy

Last updated: October 24, 2023

Privacy Policy – Fondussimo

In brief

Means

Personal information is collected:

- To visitors (hereinafter referred to as "Visitors ") to the Fondussimo website, the www.fondussimo.com (hereinafter referred to as the "Site "); and

- Through cookies.

Purposes

Personal information is collected and used for the following purposes:

- Process your completed transactions on the Site;

- Promote the services offered by Fondussimo;

- Promote the Site;

- Answer your questions (if applicable);

- To meet current legal and regulatory requirements for the protection of personal information;

- Protect your rights (for example, to ensure that unauthorized third parties do not access your personal information);

- Protect the property or safety of Fondussimo and the Site (we may, for example, use your personal information in connection with a dispute between you and Fondussimo);

- Facilitate the use of our Site and improve its performance;

- Maintain our databases and administration systems;

- To ensure the functionality of the Site;

- Count the number of visits to the Site in order to measure its performance;

- Identify the most visited pages of the Site in order to measure their performance, interest in them and the interest of our potential customers in our services;

- Identify the technology used (such as the operating system and browser used) by Visitors to ensure the compatibility of the Site and its content with respect to it;

- Identify the referring websites from which you visit our Site in order to assess their ability to provide us with visits to our Site;

- Identify the country of origin of Site Visitors in order to identify whether they can use our services and identify the applicable legal system;

- Evaluate the effectiveness of the Site in acquiring and retaining Visitors;

- Obtain or create statistics that allow us to evaluate the performance of the Site;

- To transmit communications of an informative nature about Fondussimo's services and activities;

- To ensure compliance with our Terms of Use accessible via the following hyperlink: https://fondussimo-dev.myshopify.com/en/policies/terms-of-service; and

- Disclose your information for the purposes and entities identified in the TABLE: List of Cookies Offered or Used by Third Parties .

Communications

Personal information is shared with the following entities:

- Our web and transactional service providers;

- Our shipping and delivery suppliers;

- Our payment solution providers (the "Secure Payment Platform Provider "); and

- To all persons registered with the TABLE: List of Cookies Offered or Used by Third Parties for the purposes identified therein.

Important information

Personal information is communicated outside of Quebec ;

Personal information is used and disclosed for profiling and identification purposes. The collection and use of Personal Information for profiling and identification purposes is disabled by default. You can enable these features by authorizing the collection of personal information for profiling purposes by approving the choice in the pop-up window that is provided to you when you access our Site. You can also allow this feature in our privacy settings.

Your rights

The Act gives you a right Access ,from correction and Withdrawal of consent to your personal information. For more details on the terms and conditions of your rights, please refer to the 8at 11of this Policy.

You can also formulate a complaint by following the instructions identified in 12 of this Policy.

Implied Consent

All persons who use the Site or who communicate with Fondussimo consent to the collection, use and communication of their information. Personal Information for the purposes set out above and to the entities referred to in TABLE: List of Cookies Offered or Used by Third Parties and the 3.


Table of Contents

Table of Contents. 3

1. Policy Objective. 4

2. What personal information do we collect and for what purposes?. 4

2.1. Personal Information Collected Automatically. 4

2.2. Personal Information Collected from Applicants. 5

2.3. Personal Information Collected Through Cookies ("Cookies") of third parties. 6

TABLE: List of Cookies Offered or Used by Third Parties. 7

3. For what purposes do we collect this personal information and to whom do we disclose your personal information?. 8

3.1. What are the purposes of the personal information?. 8

3.2. Collection and Use of Personal Information for Profiling and Identification Purposes. 10

3.3. To whom do we communicate the information? Personal Information ?. 10

4. Consent 11

5. How long do we keep personal information?. 11

6. How do we protect your personal information?. 11

7. Choice of Visitor. 13

8. How can you withdraw your consent to the disclosure or use?. 13

9. How to access the Personal Information about you?. 13

10. How to rectify Personal Information about you? 14

11. Procedure for requesting access, rectification and withdrawal of consent 15

12. Complaints Procedure. 15

13. Updates to this Policy. 16

14. Beware of third-party websites. 16

15. Contact information for the Privacy Officer. 16

PRIVACY POLICY – Fondussimo

1. Policy Objective

Legislative framework.In accordance with the Act respecting the protection of personal information in the private sector ( CQLR c P-39.1) as amended by the Act to modernize legislative provisions as regards the protection of personal information, International DCI inc. (hereinafter collectively "Fondussimo", "we", "us" or "our") implements measures to protect your personal information.

Policy Objectives. This privacy policy (hereinafter the "Policy ") governs Fondussimo's privacy practices with respect to Personal Information that you voluntarily share with us in connection with your visit to Fondussimo's website , i.e. www.fondussimo.com (hereinafter the " Site ")), by communicating with us through social media or when you communicate with us using the medium of your choice (e.g., telephone, email, etc.). The main purpose of this Policy is to inform you about:

• What personal information we collect from you and for what purposes;

• How we use your personal information;

• To whom we may disclose your personal information;

• What choices are available to you regarding the collection and use of personal information;

• What types of security procedures are in place to protect your personal information;

• What are your rights with respect to this personal information (right of access, rectification and withdrawal of consent);

• Retention and destruction of your personal information; and

• How to contact us if you have questions, comments or complaints.

2. What personal information do we collect and for what purposes?

2.1. Personal Information Collected Automatically

Automatic collection.When you access the Site, our server automatically collects the following personal information:

· Your IP address;

· The browser you are using (Chrome, Microsoft Edge, Firefox, etc.);

  • Your operating system (Windows, Mac OS, etc.);
  • The domain name of your Internet Service Provider;
  • The date and time of your visit to the Site;
  • The pages you visit on the Site; and

· The address of the website from which you are accessing the Site.

Collection by Cookies.This personal information may also be collected through the use of cookies . A cookie is a small data file stored on the device of a Site visitor ( a "Visitor") by a Site server.

Non-automatic collection.When you access the Site, create a customer account, or complete an online purchase, we may collect the following personal information:

  • Your first and last name;
  • Your street address and postal code;

· Your telephone number;

· Your email address; and

· Your payment information, including credit card numbers. ̧

2.2. Personal Information Collected by Third-Party Cookies

Third parties collecting personal information through cookies. Our Site holds cookies from:

· Google (Google Analytics, YouTube and Google AdSense);

  • Inspectlet;
  • Meta (Facebook); and
  • LinkedIn.

Communication outside Quebec. Some of these cookies will communicate Personal Information outside of Quebec.

Table of Cookies Offered or Used by Third Parties. For more details on the purposes and uses of Personal Information by these third parties, see our TABLE: List of Cookies Offered or Used by Third Parties .


TABLE: List of Cookies Offered or Used by Third Parties

Third Parties/Sources of Cookies

Names of cookies used

Stated Purposes Assigned to These Cookies

Links to relevant documentation provided by third parties.

Google

(Google Analytics, Doubleclick and Google AdSense)

Google Maps API

gtm-session-start

_Gid

_Ga

_Ga_*

_gat_UA-*

IDE

ads/ga-audiences

Assign a unique identifier to visitors to the Site for statistical purposes.

Count the number of visitors for each page.

Evaluate the effectiveness of advertisements across multiple websites.

Show ads on non-Google websites.

Prevent fraud, spam, or other forms of abuse by preventing malicious sites from acting on behalf of a Visitor without their consent.

We consider it possible that this witness could be used to:

- Identify visitors to the Site; and

- Carry out a profile of their activities.

Google's Privacy Policy:

https://policies.google.com/privacy?hl=fr-CA

How Google uses cookies:

https://policies.google.com/technologies/cookies?hl=fr-CA

Hotjar

hjViewportId

_hjRecordingLastActivity

_hjSessionUser_

_hjIncludedInSessionSample_

_hjAbsoluteSessionInProgress

Assign a unique identifier to visitors to the Site.

Identify the first session of a new Visitor and the first visit to a page by a Visitor.

Store actions performed by Visitors on the Site.

We consider it possible that this witness could be used to:

- Identify visitors to the Site; and

- Carry out a profile of their activities.

Privacy Policy:

https://www.hotjar.com/fr/confidentialite/

Complianz

cmplz_policy_id

cmplz_marketing

cmplz_statistics

cmplz_preferences

cmplz_functional

cmplz_banner-status

Store cookie consent preferences.

Store the ID of the accepted cookie policy.

Remember if the cookie banner has been refused.

We consider it possible that this witness could be used to:

- Identify visitors to the Site.

Privacy Policy:https://complianz.io/legal/privacy-statement/#:~:text=We%20take%20appropriate%20security%20measures%20to%20limit%20abuse%20of%20and,security%20measures%20are%20regularly%20reviewed.

Meta

(Facebook)

_fbc

FBM*

Xs

.fr

ACT

datr

c_user

sb

*_fbm

Wd

Msc

ActpPresence

Identify browsers and store a unique session ID.

Provide advertising services, including enabling ad serving or retargeting.

Provide web analytics services.

We consider it possible that this witness could be used to:

- Identify visitors to the Site; and

- Carry out a profile of their activities.

Privacy Policy:

https://www.facebook.com/privacy/policy/?section_id=0-WhatIsThePrivacy

Cookie Policy: https://www.facebook.com/privacy/policies/cookies

Microsoft

_clck

_clsk

_cltk

CLID

SM

ANONCHK

SRM_B

Cookie-1697739863

Assign a unique identifier to Site Visitors for statistical purposes.

Count the number of Visitors for each of the pages.

Store a Visitor's session ID and track interactions.

We consider it possible that this witness could be used to:

- Identify visitors to the Site; and

- Carry out a profile of their activities.

Privacy Policy:

https://privacy.microsoft.com/fr-ca/privacystatement

WPML

wp-wpml_current_language

Store language settings

Privacy Policy:https://wpml.org/documentation/privacy-policy-and-gdpr-compliance/#:~:text=The%20WPML%20plugin%20is%20fully,plugins%20your%20site%20is%20using.

WooCommerce

wc_cart_hash_

woocommerce_items_in_cart

woocommerce_cart_hash

wp_woocommerce_session_

Online Store Management

Store items in the store cart

Store actions performed by Visitors on the Site.

We consider it possible that this witness could be used to:

- Identify visitors to the Site.

Privacy Policy:https://automattic.com/privacy/

3. For what purposes do we collect this personal information and to whom do we disclose your personal information?

3.1. What are the purposes of the personal information?

Purposes of Personal Information.We also collect information for the following purposes:

· Process your completed transactions on the Site;

· Promote the services offered by Fondussimo;

  • Promote the Site;

· Answer your questions (if applicable);

· To meet current legal and regulatory requirements for the protection of personal information;

· Protect your rights (for example, to ensure that unauthorized third parties do not access your personal information);

· Protect the property or safety of Fondussimo and the Site (we may, for example, use your personal information in connection with a dispute between you and Fondussimo);

· Facilitate the use of our Site and improve its performance;

· Maintain our databases and administration systems;

· To ensure the functionality of the Site;

· Count the number of visits to the Site in order to measure its performance;

· Identify the most visited pages of the Site in order to measure their performance, interest in them and the interest of our potential customers in our services;

· Identify the technology used (such as the operating system and browser used) by Visitors to ensure the compatibility of the Site and its content with respect to it;

· Identify the referring websites from which you visit our Site in order to assess their ability to provide us with visits to our Site;

· Identify the country of origin of Site Visitors in order to identify whether they can use our services and identify the applicable legal system;

· Evaluate the effectiveness of the Site in acquiring and retaining Visitors;

· Obtain or create statistics that allow us to evaluate the performance of the Site;

· To transmit communications of an informative nature about Fondussimo's services and activities;

· Ensure compliance with our Terms of Use accessible via the following hyperlink: https://fondussimo-dev.myshopify.com/en/policies/terms-of-service; and

· Sharing your information for the purposes and entities identified in the Table above entitled TABLE: List of Cookies Offered or Used by Third Parties .

New purposes (if applicable).We will notify you and ensure that we obtain any consent necessary for collection, use or disclosure for any purpose other than those listed above, if applicable.

3.2. Collection and Use of Personal Information for Profiling and Identification Purposes

Consent to the collection of personal information for profiling purposes. Due to the use of the above-mentioned cookies, we use our Visitors' Personal Information for profiling and identification purposes. The collection and use of Personal Information for profiling and identification purposes is disabled by default. You can enable these features by authorizing the collection of personal information for profiling and identification purposes by approving the choice in the pop-up window that is provided to you when you access our Site. You can also allow this feature in our privacy settings.

Minors under the age of 14. We do not collect personal information from minors under the age of 14 without the prior consent of the parent or guardian.

3.3. To whom do we share personal information ?

Personal information is shared with the following entities:

- Our web and transactional service providers;

- Our shipping and delivery suppliers;

- Our payment solution providers (the "Secure Payment Platform Provider "); and

- To all persons registered with the TABLE: List of Cookies Offered or Used by Third Parties for the purposes identified therein.

Also, when making a payment through the secure payment platform provider's secure transaction system, which is a separate and external database from the Site, you will be required to provide your card number, expiration date (if applicable), the name of the registered cardholder and any other information necessary to complete an order for the purchase of products. You will have the option, at your option, to agree to save payment information in your account with the Secure Payment Platform Provider. You acknowledge and agree that any information and personal information associated with payment for an order that may be entered and saved in your account on the secure payment platform provider's secure transaction system will then be held by the secure payment platform provider and not by Fondussimo. Also note that if you choose a payment method that splits your payments into installments, the Secure Payment Platform Provider may use an automated processing system that uses personal information to make a decision.

Communication outside Quebec.It is possible that Fondussimo may communicate your personal information to third parties, belonging to the categories listed above, who operate outside of Quebec. To this end, Fondussimo conducts a privacy impact assessment with each of these third parties and ensures at all times that when your information is communicated outside Québec, it benefits from adequate protection, particularly with regard to generally recognized principles of the protection of personal information. As a result, your personal information will sometimes be shared outside of Quebec.

Disclosures without consent permitted by law.We may also disclose your personal information without consent in circumstances where permitted or required by applicable law.

4. Consent

Implied Consent.All persons who use the Site or who communicate with Fondussimo on their own consent to the collection, use and communication of their personal information. Personal Information for the above purposes and to the above-mentioned entities (see sections 2 and 3).

5. How long do we keep personal information?

Destruction of personal information as soon as the purposes are fulfilled, except where a retention period is required by law. In accordance with our procedures for the secure retention and destruction of personal information, we retain personal information only for as long as necessary for the purposes for which it was intended and to comply with our legal obligations. Thereafter, personal information will be destroyed in a secure and confidential manner.

6. How do we protect your personal information?

Safeguards.We adopt physical, technological and administrative safeguards to protect your personal information and reduce the risk of unauthorized and/or unlawful access, use, disclosure and destruction. Without limiting the generality of the foregoing, we:

  • Minimization: consciously limit the personal information we collect. We collect only the personal information necessary to fulfill the purposes identified in the 3-For what purposes do we collect this personal information and to whom do we disclose your personal information?
  • Two-factor authentication: We implement various two-factor authentication mechanisms to validate the identity of employees who have access to your personal information;
  • Limiting access:limit access to your personal information to those employees who need that access in order to pursue any of the purposes listed in the 3-For what purposes do we collect this personal information and to whom do we disclose your personal information? ;
  • Confidentiality Undertakings: require each of our employees and representatives who have access to your personal information to sign a confidentiality undertaking;
  • Retention Schedule: maintain a retention schedule that allows us to ensure that your personal information will be promptly destroyed upon completion of its purpose or upon the expiration of any applicable legal retention period; and
  • Privacy Incident Registry:Maintain a privacy incident log in accordance with applicable legislation. In the event of a confidentiality incident that poses a risk of serious harm to you, we will take the necessary steps to notify you in accordance with applicable law.

7. Visitor's Choice

Changing Our Privacy Settings.All Visitors can also choose the privacy settings that best suit their needs by clicking on the “Cookie Policy” button, available on all pages. By default, these settings are set to give you the best possible protection. These settings do not allow you to change the processing of personal information by cookies.

Changes to cookie settings on your web browser.You can manage the processing of your personal information by cookies by changing your browser settings. For more information on how to change your browser settings, you can refer to the information provided by your browser. For example, you can find out here (if you use Google Chrome), here (if you use Mozilla Firefox) or here (if you use Microsoft Edge). However, your refusal to accept cookies may impair or limit your access to certain features of our Site.

8. How can you withdraw your consent to the disclosure or use?

Your Right to Withdraw Your Consent to Disclosure or Use. Subject to the law and your applicable contractual obligations, you may withdraw or change your consent to the use or disclosure of your Personal Information. To do so, please contact our Privacy Officer (please refer to the procedure in 11-Procedure for requesting access, rectification and withdrawal of consent). However, if you withdraw your consent to certain uses or disclosures of your personal information, we may no longer be able to provide you with certain services or the quality of our services may be affected. We will inform you of the consequences of your choice before accepting your request to withdraw consent.

9. How can we access your Personal Information ?

Content of the right of access.You have the right to access your personal information. As such, you can ask us to:

- Inform you of the existence of personal information relating to you;

- Receive access to your personal information;

- Access the personal information we maintain about you by allowing you to view the information on-site during regular working hours or remotely and obtain a copy of it; and

- As of September 22, 2024 only, we will require us to disclose any information collected from you (excluding personal information created or inferred from personal information about you) in a structured and commonly used technological format. You may also request that we disclose your personal information to any person or body authorized by law to collect the personal information as of September 22, 2024.

(Reasonable) fees payable.A reasonable fee may be charged for transcribing, copying or transmitting your personal information. We will communicate these fees to you prior to transcribing, copying or transcribing personal information.

Applicable Procedure.Any request for access must be communicated to our Privacy Officer in accordance with the procedure identified in the 11-Procedure for requesting access, rectification and withdrawal of consent.Please note that the law may prevent us from accepting an access request for a variety of reasons.

10. How can I rectify your personal information?

Content of the right to rectification.You may also send us a request to rectify your personal information. You may make a correction request to us to ask us to correct your personal information in the following circumstances:

• Your personal information is inaccurate;

• Your personal information is incomplete;

• Your personal information is ambiguous;

• The collection, disclosure or retention of your personal information was not authorized by law.

Destruction of Personal Information.You may also ask us, in a rectification request, to destroy any personal information collected or retained if their collection, disclosure or retention of your personal information was not authorized by law.

Delivery of a copy or attestation.If we grant you your request for correction, you may ask us to provide you with a copy of any personal information that has been amended or added, or, as the case may be, an attestation of the removal of personal information.

Applicable Procedure.Any request for rectification must be communicated to our Privacy Officer according to the procedure identified in the section 11-Procedure for requesting access, rectification and withdrawal of consent.Please note that the law may prevent us from accepting a rectification request for a variety of reasons.

11. Procedure for requesting access, rectification and withdrawal of consent

Procedure.To be considered, all applications referred to in the sections 8 at 10should be addressed in writing to Dany Bernard, Fondussimo's Privacy Officer by sending an e-mail to dany.bernard@fondussimo.com .

Requirement to prove your identity. You will need to prove your identity before we can accept your request.

Response times. We have a legal obligation to respond (favourably or unfavourably) to any request for access or rectification within 30 days of receipt and confirmation of your identity. We may deny any request in accordance with applicable privacy laws.

12. Complaints Procedure

Complaint Procedure. You may address a complaint about our governance or privacy practices to Dany Bernard, Fondussimo's Privacy Officer by sending an email to dany.bernard@fondussimo.com .

Duty to assist or questions.You may also contact our Privacy Officer if you have any questions regarding your rights of access, rectification or withdrawal of consent. You may also request their assistance in order to better clarify your requests for access, rectification or withdrawal of consent or, if applicable, to better understand the reasons for refusing any of these requests.

Complaints to the Commission d'accès à l'information.If you are not satisfied with our response to your complaint or to any of your requests for access, rectification or withdrawal of consent, you may file a written complaint with the Commission d'accès à l'information du Québec. To do so, you can consult the complaint form of the Commission d'accès à l'information du Québec available here: https ://www.cai.gouv.qc.ca/diffuson-de-linformation/services-et-formulaires/ .

13. Updates to this Policy

Possible changes.We may change this Policy from time to time in accordance with applicable law. We will notify you of any changes to this Policy by indicating at the beginning of this Policy the date of the last changes. If we have your email address, we will also provide you with a notice identifying any changes to this Policy.

Implied Consent to Changes.Your continued use of the Site or your provision of personal information to us following the posting of changes to this Policy constitutes your implied acquiescence to the changes to this Policy, subject to the provisions of applicable law.

14. Beware of third-party websites

Fondussimois not responsible for the information that may be collected, used or communicated by any third-party website that you visit and Fondussimo expressly disclaims any liability related to any such collection, use, disclosure or retention by such third party.

15. Contact information for the Privacy Officer

Questions or comments.If you have any questions or comments about this Policy or our practices with respect to your Personal Information, you may contact Dany Bernard, Fondussimo's Privacy Officer by sending an email to dany.bernard@fondussimo.com or by mail at the following address:

International DCI Inc.

Attn: Dany Bernard, Head of

Protection of Personal Information

435 Route 108 East,

Saint-Victor, Quebec, G0M2B0