PRIVACY POLICY

1.1This policy describes how MAGIECHEM® Inc., MAGIECHEM® Ontario Inc. and any affiliate, subsidiary, parent or sister company of the same group (collectively, “MAGIECHEM®”, “we”, “us” or “our”) collect, use, disclose, retain, protect and destroy personal information.

1.2It applies to personal information collected through magiechem.com and its subdomains, our restricted portals for architects, professionals and contractors, our forms, our electronic communications, our commercial activities and our business relationships, regardless of the medium used.

1.3It is adopted 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 (“Law 25”), and, where applicable, the Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial legislation.

1.4For the purposes of this policy, “personal information” means any information that relates to a natural person and allows that person to be identified, directly or indirectly. Information concerning a legal entity is not personal information; however, the contact details of a natural person acting in a business capacity remain covered where they allow that person to be identified.

2.1In accordance with section 3.1 of Law 25, the following person acts as the person in charge of the protection of personal information within MAGIECHEM®:

Name: Hamza Telhouni

Title: Vice-President

Address: 1365 Volta Street, Boucherville, Quebec J4B 7H5

Email: privacy@magiechem.com

Telephone: 450 444-4949, ext. 101

2.2The person in charge ensures compliance with this policy, handles requests for access, correction and withdrawal of consent, maintains the register of confidentiality incidents, and oversees privacy impact assessments.

2.3Any question, request or complaint regarding personal information must be addressed to the person in charge at the contact details above.

3.1Through our website. The only form through which you voluntarily provide personal information to us is our contact form. There we collect your name, your company name, your email address, your telephone number, the content of your message and, where applicable, any documents you choose to attach.

3.2Access to restricted portals. Access to our portals for architects, professionals and contractors is protected by a shared password whose sole function is to restrict access to our technical documentation. No individual account is created, no personal identifier is requested, and we are not able to identify the persons who consult these portals.

3.3Technical logs. Like any web server, our servers record technical logs including IP address, timestamp and resources requested, solely for security, abuse prevention and diagnostic purposes.

3.4In the course of our business relationships. Outside the website, we may collect the following:

• Business contact details — first and last name, title, company, address, email, telephone.
• Project information — nature of the project, location, area, substrate conditions, performance requirements, schedule, drawings and documents you provide.
• Billing and credit information — billing details, order history, financial information provided in support of a commercial credit application, trade references.
• Content of communications — emails, notes of calls and meetings, attachments.

3.5We collect only the information necessary for the purposes set out in Section 4. Where information is optional, this is indicated at the time of collection.

3.6We do not knowingly collect personal information from persons under the age of 14. Should such information be provided to us, it would be destroyed without delay.

3.7We do not collect sensitive personal information within the meaning of Law 25, including health, biometric or judicial information.

4.1We collect and use personal information for the following purposes:

• responding to your requests for information, quotations, samples or technical documentation;
• recommending products and systems suited to the parameters you provide;
• preparing, negotiating, entering into and performing sales contracts and following up on them;
• processing orders, invoicing, collection and commercial credit assessment;
• providing technical support, handling claims and after-sales service;
• improving our website, tools, products and documentation;
• sending you, with your consent, commercial communications and our newsletter;
• ensuring the security of our systems and preventing fraud and unauthorized access;
• complying with our legal, regulatory, tax and contractual obligations.

4.2We do not use personal information for purposes incompatible with those for which it was collected, except with your consent or where permitted by law.

5.1We collect personal information with your consent, except where otherwise permitted by law. Depending on the context, consent is given expressly (unchecked box, signature, written confirmation) or arises from your request where the collection is manifestly necessary to fulfil it.

5.2Consent is requested for each purpose, in clear and simple terms, separately from any other information.

5.3You may withdraw your consent at any time by contacting the person in charge. Withdrawal is not retroactive and may prevent us from providing certain services. Some information must nonetheless be retained for the period prescribed by law.

6.1We do not sell or rent your personal information.

6.2We may disclose personal information, without your consent where permitted by law, to the following categories of recipients, only to the extent necessary:

• service providers acting on our behalf — hosting, managed services, transactional email, newsletter platform, payment processing, accounting, transport and logistics;
• professional advisors — lawyers, accountants, insurers, auditors;
• certified contractors and applicators, where necessary to carry out your project and with your agreement;
• MAGIECHEM® group companies, for the purposes described in Section 4;
• public authorities, courts and regulatory bodies, where required by law;
• parties to a contemplated business transaction (sale of assets, merger, reorganization), subject to confidentiality undertakings.

6.3Every agent or service provider is bound by a written agreement containing confidentiality obligations, a restriction of use to the agreed purposes only, and appropriate security measures.

7.1Our business records are kept on our own facilities in Quebec. However, our website and its supporting infrastructure — application server, content management system and file storage — are hosted with a hosting provider whose servers are located in Boston, in the United States. Information you send us through the contact form, including any documents you attach, therefore transits through and is stored on those servers until it is transmitted and processed.

7.2Before any disclosure of personal information outside Quebec, we conduct a privacy impact assessment to determine whether the information will receive adequate protection, in particular in light of generally recognized principles regarding the protection of personal information. The disclosure is the subject of a written agreement that takes the findings of that assessment into account.

7.3Information so disclosed may be subject to the laws of the jurisdiction in which it is located, including access requests from foreign authorities.

8.1A cookie is a small file placed on your device when you visit a website. Our site uses only cookies that are strictly necessary to its operation and security.

8.2The only cookies placed are the following:

• a session cookie, placed only after you have entered the password for access to a restricted portal, in order to maintain your session for a maximum of seven (7) days. This cookie is protected and is not accessible to scripts.

8.3We also use your device’s local storage to remember your display preferences, including light or dark theme and language, as well as your product comparison list. This information remains on your device and is never transmitted to us.

8.4We use no audience measurement, analytics, advertising or profiling cookies. Our site loads no third-party analytics tool, no tracking pixel, no tag manager, no external font, and no third-party map or video that loads automatically. No information about you is transmitted to a third party as a result of your browsing our site.

8.5Profiling, geolocation and identification functions within the meaning of Law 25 are not used.

8.6Because no non-essential cookie is placed, no prior consent is required and no cookie management banner is displayed. You may nonetheless block or delete cookies through your browser settings; blocking strictly necessary cookies will prevent access to the restricted portals.

8.7Where video content is embedded in a product page, it loads only after you click to view it and uses a playback mode without tracking cookies. No connection to a third-party service is established until you activate playback.

9.1Our online tools, including the system selector and the quantity calculator, produce recommendations and estimates based on the parameters you enter. These results are provided for guidance only, must be validated by a qualified professional, and do not constitute a decision producing legal effects concerning you.

9.2Should we ever make a decision based exclusively on automated processing and producing legal effects or significantly affecting you, we would inform you at the time of the decision, provide the information used, the principal factors and parameters that led to the result, and allow you to submit observations to a person able to review the decision.

10.1We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, plus any applicable limitation periods and retention periods imposed by law, including tax, accounting and contractual liability requirements.

10.2We apply an internal retention schedule. At the end of the applicable period, information is securely destroyed or anonymized in accordance with a recognized process, irreversibly.

11.1We take reasonable security measures to protect personal information, proportionate to its sensitivity, purpose, quantity, distribution and medium. These include encryption of communications, access control on a least-privilege basis, password protection of portals, logging, backups and staff awareness.

11.2As no system is infallible, we cannot guarantee absolute security. You are responsible for keeping confidential any access password issued to you and must notify us without delay of any unauthorized use.

12.1Subject to the conditions and exceptions provided by law, you may exercise the following rights:

• Access — obtain confirmation that we hold information about you and obtain communication of it.
• Correction — have inaccurate, incomplete or ambiguous information corrected, or have information whose collection was not authorized deleted.
• Withdrawal of consent — withdraw at any time a consent previously given.
• De-indexing — require that the dissemination of information cease or that any hyperlink giving access to it be de-indexed, where dissemination causes serious injury to your reputation or privacy.
• Portability — obtain, in a structured and commonly used technological format, the computerized information you have provided to us, or request that it be communicated to a third party.

12.2Any request must be made in writing to the person in charge and be accompanied by information allowing your identity to be verified. We respond within thirty (30) days of receiving the request.

12.3Exercising these rights is free of charge. Reasonable fees may be charged for transcription, reproduction or transmission of information, in which case you will be informed in advance.

12.4In the event of a total or partial refusal, we will inform you in writing of the reasons, the applicable legislative provisions, the recourses available to you and the time limit for exercising them.

13.1We maintain a register of confidentiality incidents in accordance with the law.

13.2In the event of an incident presenting a risk of serious injury, we promptly notify the Commission d’accès à l’information and the persons concerned, and take reasonable measures to reduce the risk and prevent the recurrence of similar incidents.

14.1Our commercial electronic messages, including our newsletter, are sent in accordance with Canada’s Anti-Spam Legislation (CASL). Subscription is by express consent, using an unchecked box, followed by email confirmation (double opt-in).

14.2Every message includes our full contact details and a functional, free unsubscribe mechanism processed within ten (10) business days.

15.1If you believe we have not respected your rights or this policy, please first contact the person in charge, who will handle your complaint promptly and inform you in writing of the outcome.

15.2You may also file a complaint with the Commission d’accès à l’information du Québec or, as applicable, with the Office of the Privacy Commissioner of Canada.

16.1We may amend this policy to reflect changes in our practices or in the applicable legal framework. The version in force is the one published at magiechem.com, with its update date. In the event of a material change, we will inform you by reasonable means.