GROUPE NORBEC INC. / NORBEC GROUP INC.

(“Norbec”)

1.          Background and Scope

Norbec acknowledges the importance of safeguarding the personal data it collects via its website or by any other technological means and undertakes the responsibility of protecting any personal information it may hold or entrust to a third party.

By visiting our website or by providing us with personal information, Norbec considers that you have read this Privacy Policy (the “Policy”) and that you consent to the collection, use, and disclosure of such information to third parties for the purposes set out below.

“Personal information” means any information pertaining to a natural person that enables that person to be identified, whether directly or indirectly. Personal information does not include information regarding an individual’s position within an organization, such as name, position, work address, e-mail address, or telephone number.

This Policy applies to anyone who visits our website, uses the services presented on our website, and interacts with us through our website or by any other technological means.

This Policy sets forth the manner in which we protect your personal data, in compliance with the requirements of applicable laws in Quebec, namely the Act Respecting the Protection of Personal Information in the Private Sector, as amended by the Act to Modernize Legislative Provisions as Regards the Protection of Personal Information.

2.          Person in charge of the protection of personal information

To assist Norbec in fulfilling its privacy protection responsibilities and obligations, management has designated a person in charge of the protection of personal information (“PCPPI”), Mr. Brad Tomalty, Director of Human Resources, who may be contacted by e-mail at: infoprotection@norbec.com.

3.          Collection of Personal Information

In the context of your interactions with us, Norbec collects information that is necessary to render the requested services. This information includes:

• Personal information that we may reasonably use to identify you either directly or indirectly, such as your name, mailing address, e-mail address, telephone number, Internet Protocol (IP) address used to connect your computer to the internet, username or similar identifier, and any other identifier that we may use to contact you either online or offline (“Personal Information”).

• Non-personal information, which does not directly or indirectly reveal your identity or relate directly to an identified person, such as demographic information or statistical or aggregate data. Statistical or aggregate data do not directly identify a specific person; however, we may derive non-personal statistical or aggregate data from personal information. For example, we may aggregate personal data to calculate the percentage of users accessing a specific feature of our website.

• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your internet connection, the equipment you use to access our website, and usage details.

• Non-personal details about your website interactions, including complete Uniform Resource Locators (URLs), clickstream data to, through and from our website (including date and time stamp), products you have viewed or searched for, page response times, download errors, time spent on pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to leave the page, or the telephone number used to call our customer service department.

4.          Purpose of Collection

Norbec collects your personal information for the purposes described herein:

• To present our website and its content to you

• To provide you with the information, products or services you request from us

• To fulfill the operations for which you provided the information as described at the time of collection, or any other purpose for which you provide the information

• To provide you with notices regarding your account, including but not limited to expiration and renewal notices

• To fulfill our obligations and enforce our rights under any contract with you, including but not limited to billing and collection purposes or to comply with legal requirements

• To inform you of changes to our website or to any products or services we provide

• To improve our website, products or services, marketing, or customer relations and experiences

• To enable you to participate in interactive features, social media or similar features on our website

• For any other purpose that we may disclose to you when you provide the information

• For any other purpose with your consent

We may also use your information to contact you about our own products and services which may be of interest to you, in compliance with the law. For more information, please see the Your choices about the use and disclosure of your Personal Information section of this Policy.

5.          Means by which your Personal Information is collected

We use a variety of means to collect your information, including:

• Direct interactions with you when you provide your information to us, for example by filling in forms or corresponding with us by telephone, e-mail or otherwise

• User contributions: You may provide us with information that we may publish or display on public areas of the website or transmit to other users of website or to third parties

• Automated technologies or interactions as you browse our website: Information collected automatically may include details of usage, IP addresses and information collected via cookies, web beacons and other tracking technologies

• Third parties or publicly available sources, such as our business partners

We also collect personal information about you through cookies and other automatic data collection technologies.

As you browse and interact with our website, we may use cookies or other automatic data collection technologies to collect specific information about your equipment, browsing actions and patterns, including:

• Details about your visits to our website, such as location data, logs and other communication data, and the resources you access and use on the website

• Information about your computer and internet connection, such as your IP address, operating system and browser

The information we collect automatically consists of statistical information and may include personal information, and we may store it or aggregate it with personal information we collect by other means, that you provide to us, or received from third parties. This information enables us to improve our website to provide better and more personalized service, in particular by allowing us to:

• Estimate the size of our audience and its usage behavior

• Store information about your preferences, enabling us to customize our website to your individual interests

• Accelerate your searches

• Recognize you when you return to our website

The technological means we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on your computer’s hard drive. You can refuse to accept browser cookies by selecting the appropriate setting on your browser. However, if you choose to opt out of cookies, you may not be able to access certain features of our website. Unless you have set your browser settings to refuse cookies, our system will issue cookies when you direct your browser to our website.

• Flash cookies. Some features of our website may use locally stored Flash cookies to collect and store information about your preferences and about your navigation to, on, and from our website. Flash cookies are not managed by the same browser settings as those used for browser cookies. For more information on how to manage your privacy and security settings for Flash cookies, see the section on Your choices about the use and disclosure of your Personal Information.

• Web beacons. Our website pages and e-mails may contain small electronic files called Web beacons (also known as clear gifs or single-pixel gifs) that allow Norbec, for example, to count site visitors, the number of pages visited, or e-mails opened, and to track other related website statistics (e.g., the popularity of certain website content or to verify system and server integrity).

6.          Use and Disclosure

We may disclose aggregate information and non-identifying information about our users, without restriction.

We may disclose personal information that we collect or that you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates

• In compliance with applicable law, to a purchaser or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of all or part of the assets of Norbec whether in the ordinary course of business or as a result of a bankruptcy, liquidation or similar proceeding, in which personal information held by Norbec about our customers and users is one of the transferred assets

• To subcontractors, service providers and other third parties we call upon to support our business operations (such as analytics and search engine providers who help us improve and optimize the website) and who are contractually bound to keep personal information confidential, to use it solely for the purposes for which we disclose it to them, and to treat personal data in compliance with the standards set out in this Policy

• To fulfill the purpose for which you provide it

• For any other purpose that we disclose to you when you provide the information

• With your consent

We may also disclose your personal information to:

• Comply with any court order, legal process or law, including but not limited to responding to any governmental or regulatory request, in accordance with applicable law

• Enforce or apply our Terms of Use and other agreements

• Protect the rights, property or safety of Norbec or our customers or other parties. If we believe that disclosure is necessary or appropriate, this disclosure includes exchanging information with other companies or organizations for fraud protection and credit risk mitigation.

7.          Storage of Personal Information

Norbec retains your personal information solely as long as necessary to fulfill the purposes for which it was collected, except where the law provides for a different retention period to comply with legal requirements.

In general, your personal information is processed and stored in Quebec. However, it may be transferred out of province. For example, some of the subcontractors, service providers and third parties we call upon to support our business operations (such as analytics and search engine providers that help us optimize the website) may access, process or store your personal information outside of Quebec as part of their service contract with us. In such cases, Norbec ensures that your personal information is protected in an adequately and contractual manner.

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 further notice or consent.

8.          Security Measures

Norbec protects your personal information through appropriate security safeguards relative to the sensitivity of the information, to prevent unauthorized access, use, disclosure or loss, and to protect your personal information from any unauthorized access, use, disclosure or loss.

We have taken steps to ensure that only those members of our personnel who require access to your personal information to perform their duties shall be authorized to access it. We also ensure that third parties to whom we disclose your personal information take steps to guarantee the confidentiality of the information we entrust to them, and that they use the data solely for the purposes set out in the agreement entered into with them.

9. Your choices about the use and disclosure of your Personal Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to grant you control over your information, as follows:

Tracking technologies and advertising. You may choose to set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To manage your Flash cookie settings, please visit the Flash Player settings on the Adobe website. Note that, should you choose to disable or refuse cookies, some features of our website may not be accessible or may not function properly. For more information on tracking technologies, refer to Means by which your Personal Information is collected.

Company promotional offers. If you have chosen to receive e-mails from us but no longer wish your e-mail address or contact information be used by Norbec Inc. to promote our own or third-party products or services, you may unsubscribe by checking the appropriate box located on the form on which we collect your data (order form or registration form) or at any other time by logging into the website and modifying your user preferences in your account profile by checking or unchecking the corresponding box. You may also notify us of your preference by e-mail to: marketing@norbec.com. If we have sent you a promotional e-mail, you may unsubscribe by clicking on the unsubscribe link included in the e-mail. However, this deactivation does not apply to information provided to Norbec Inc. as part of a product purchase, warranty registration, product service experience or other transaction.

Targeted advertising. If you do not wish for us to use the information we collect or that you provide to us to direct advertisements based on our advertisers’ target audience preferences, you may opt out by checking the corresponding box located on the form on which we collect your data (order form or registration form) or at any other time by logging into the website and modifying your user preferences in your account profile by checking or unchecking the corresponding box. You may also notify us of your preference by e-mail to: marketing@norbec.com.

We do not control the collection or use of your information by third parties to direct interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used for this purpose. You may also access these websites to learn more about online behavioral advertising and how to prevent websites from placing cookies on your device. Deactivating a network does not mean that you will no longer receive online advertising. It means that the network from which you have opted out will no longer serve ads tailored to your web preferences and usage habits.

10.          Access and Accuracy of Personal Information

It is important that the personal information we retain about you is accurate and up-to-date. Please inform us of any changes to this information.

In addition, you may submit a request to:

• access to your personal information
• rectify your personal information
• withdraw your consent to the use or disclosure of your personal information
• cease the distribution of your personal information and de-index it
• exercise your right to data portability

by written request to the person in charge of the protection of personal information at infoprotection@norbec.com.

You may also unsubscribe from marketing communications via our website, using the unsubscribe link at the bottom of our marketing e-mails or by e-mailing us directly at marketing@norbec.com.

We recognize the importance of protecting your personal information. We are committed to granting a right of access and rectification to persons who wish to consult, modify or delete their personal information. These rights must be exercised in writing to Norbec’s head office:

Norbec Group Inc.
97 Rue de Vaudreuil, Boucherville, Québec, Canada, J4B 1K7

For any questions about our privacy and confidentiality practices, please contact our CPO, Brad Tomalty, by e-mail at infoprotection@norbec.com.

Contact Us

You may contact us regarding this Privacy Policy by writing to the Privacy Officer at infoprotection@norbec.com.

Update of the Privacy Policy

We encourage you to read this Policy carefully, as it may be updated periodically. Your continued use of our website after our changes to this Policy indicates your acknowledgment of and consent to those changes, so please ensure that you consult the Policy periodically for any updates. We will notify you in advance of any material changes to this Policy and will obtain your consent for changes in how we collect, use, and disclose your personal information.

Last updated: 2 October 2024