Privacy Policy and Protection of Personal Information

Robert Davidson Inc., are concerned about the protection of privacy and the protection of personal information. The integrity of information and data transmitted by Internet, email, telephone or any other technological means, and that it uses or communicates to third parties during its activities, regardless of the medium or origin. Respect for the privacy of our customers and prospects is an important element of our commitment to offer superior quality service. This Privacy Policy sets out how Robert Davidson Inc. protects the personal information they hold. Being subject to federal and provincial laws regarding the protection of personal information, in particular the Act to modernize legislative provisions relating to the protection of personal information, the Act respecting the protection of personal information in the private sector, the Personal Information Protection and Electronic Documents Act and the Canadian Anti-Spam Legislation (C-28), we are firmly committed to protecting the information that our clients and prospects entrust to us and we take the necessary measures to ensure that their rights are respected.

1. Collection and Use of Information

Personal information collected by Robert Davidson Inc. is confidential, only personnel authorized to respond to requests have access to it. The client file contains only the essential information we need to:

• carry out an analysis of the needs of the client or prospect;

• initiate a submission for the requested product(s) or service(s);

• issue a contract to this effect, if applicable.

2. Responsibility

Robert Davidson Inc. is responsible for protecting the personal information it holds or entrusts, where applicable, to third parties.

Robert Davidson Inc. ensures that its personnel, as well as authorized third parties, protect the confidentiality of personal information to which they have access, regardless of the nature of its medium or the form in which it is accessible.

3. Personal information collected

Personal information is information that relates to a natural person and allows them to be identified. This includes, among other things, their contact details, email address, telephone number, date of birth, gender and banking information.

In order to adequately fulfill its mission of protecting the public, Robert Davidson Inc. collects several types of personal information. Personal information is collected in several ways, including through websites powered by Robert Davidson Inc., forms, in-person, telephone, mail and email exchanges or from other suppliers. Robert Davidson Inc. takes steps to ensure that the personal information collected is adequate, relevant, not excessive and used for limited purposes. The information collected varies depending on the individual's status and needs.

More specifically, and without limitation, here is the type of personal information that Robert Davidson Inc. may collect:

• Employee: Name, first name , gender, date of birth, email address, telephone number , work permit, financial institution

• Public member: surname, first name , all contact details , any information necessary to process their request, credit card number

• Person applying for a job offer published by Robert Davidson Inc.: name, first name, email address, telephone number and curriculum vitae. And when the nature of the position requires it, criminal and credit history during hiring checks

4. Collection of information by Google Analytics

Anonymous and confidential information is collected through Google Analytics to analyze the traffic on our website (Robert Davidson Inc.). Robert Davidson Inc. uses this data only for the purpose of improving the quality of the services and information offered on the website.

5. Information on file

We strive to keep the information on file accurate, complete and up-to-date. If an individual wishes to verify the accuracy of or make any changes to their personal information, they may contact the Privacy Officer whose contact information is provided in section 15 of this policy.

If the Manager finds that an error has crept into the file, despite all the attention we give to it, we will correct it as soon as possible and inform the person concerned.

6. Consent – Collection, Use and Disclosure

Robert Davidson Inc. obtains the consent of the person concerned before collecting, using or disclosing to others his or her personal information, except in cases provided by law. The law also provides that certain personal information is public. This information is then not confidential and Robert Davidson Inc. may disclose it without prior authorization. This includes the following information:

• Name of the person;

• Name of office or employer;

• Business address and telephone number;

7. Access to personal information

Within Robert Davidson Inc., only those employees on the team who need it to perform their duties have access to personal information . Robert Davidson Inc. has implemented internal mechanisms to ensure that each staff member only has access to the information necessary to perform their assigned tasks . In the same vein , access privileges (read only, modification, administrator) have been determined for each.

8. Telephone Submissions and Transactions

When we analyze the needs of the client or prospect, establish a quote, a service offer or a contract by telephone :

• It is understood that our interlocutor gives us his consent and that he has also obtained the consent of all persons interested or mentioned in the submission or contract that concerns him. This consent includes the collection, retention, use and communication of their personal information for the purposes established;

• If the submission or contract concerns a person other than the contact, at all times our employee will ensure that consent is obtained directly from the person concerned , all in accordance with the Act respecting the protection of personal information in the private sector.

For reasons of information integrity , training and customer service quality control , telephone conversations may be monitored.

With regard to the use of the email address, Robert Davidson Inc.'s anti-spam policy provides that its teams ensure that consent is requested in a manner that: detailed and structured.

9. Online Submissions

When a customer or prospect completes and submits a quote form through Robert Davidson Inc. for various products:

• he automatically consents to Robert Davidson Inc. using his personal information to analyze his needs and make a quote for the requested product;

• he authorizes an employee of Robert Davidson Inc. to contact him by telephone , email, or other means in order to discuss his file, provide him with the requested quote and promote the products and services of Robert Davidson Inc.;

• he understands that the use of his email address will be made in accordance with the anti-spam policy of Robert Davidson Inc., that is to say only once, if necessary , and always for the purpose of responding to his request;

• he understands that, still under the anti-spam policy of Robert Davidson Inc., he will have the opportunity, during a telephone contact with our employee , to confirm or withdraw his consent for subsequent uses of his email address.

10. Online subscription and unsubscription

In accordance with Robert Davidson Inc.'s anti-spam policy , at any time, it is possible to confirm or withdraw consent to the use of the email address through our online subscription and unsubscribe page or by contacting Robert Davidson Inc. customer service.

11. Transmission of information by electronic mail

Robert Davidson Inc. is not responsible for any damages resulting from the interception, loss or alteration of any email transmitted to us. When our customers and prospects transmit information by email, this communication is not secure . We therefore recommend that you exercise caution when sending confidential information to us by email (e.g. account number , address, etc.).

12. Possibility that personal information may be communicated outside Quebec

In the event that a transfer of personal information outside Quebec is necessary in the exercise of Robert Davidson Inc.'s functions, this transfer will only take place if it is assessed that the information would benefit from adequate protection , in particular by considering the sensitivity of the information, the purpose of its use, the protection measures that the information would benefit from and the legal regime applicable in the state or province where this information would be communicated. The transfer will also be subject to the appropriate agreements to ensure this adequate protection .

13. Measures taken to ensure the confidentiality and security of personal information

Robert Davidson Inc. protects personal information by security measures (physical, technical or administrative) appropriate to the nature of the information, in order to prevent a person from having access to it , using it or communicating it to others when they are not authorized to do so , or to prevent losses or any other breach of the protection of the information.

The Robert Davidson Inc. website server uses Secure Socket Layer (SSL) technology to ensure the confidentiality of data transmitted to Robert Davidson Inc.. Grace With this technology, all personal information is encrypted , including addresses, telephone and fax numbers and credit card numbers , so that it is impossible to read the information as it travels over the web. Robert Davidson Inc. is not responsible for the possible transmission of computer viruses in any way .

Although Robert Davidson Inc. implements security measures to protect personal information and reduce the risk of compromise, a risk always remains present and does not allow it to guarantee 100 % that personal information will not be subject to a breach of confidentiality or integrity in the event of a breach of its security measures . Robert Davidson Inc. invites anyone who has reason to believe that personal information has been compromised to contact the person responsible for applying the policy .

14. Cookies

A cookie is a small text file saved on the hard drive of the user's computer. This file is completely harmless and cannot contain viruses. To analyze visits to its website, the Order uses Google Analytics software. The latter uses cookies to record certain visitor behaviors, such as the number of visits to the site, the path taken and the duration of the visit. Under no circumstances does the cookie allow a visitor to be identified. The data remains completely anonymous and is only intended to improve the Order's website according to the needs of visitors.

15. Responsible for the application of the policy

The person responsible for the application of this policy within Robert Davidson Inc. is:

Privacy Officer

Mrs. Liette Beaudoin, Human Resources Manager
ROBERT DAVIDSON INC.
10, Roger Dorais, Saint-Rémi (Quebec) Canada
Telephone: 450-357-3425, ext. 3015
confidentiality@davidsoninc.com

In this capacity , the Manager ensures in particular that employees are aware of the statement of the policy and that they are trained in its proper application.

In accordance with the law, the Manager ensures the creation , maintenance and updating of a register of confidentiality incidents . Upon request by the Commission for Access to Information, a declaration of this register is transmitted to it.

16. Work environment at Robert Davidson Inc.

Robert Davidson Inc. ensures the protection of the personal information of all its representatives , employees and job applicants. The legislative provisions are applied fully in order to promote a healthy work environment that respects the privacy of all employees