Privacy Policy

1. General information

Purpose of this Policy. This privacy policy (the “Policy”) describes the practices of Groupe Abbatiello inc. and its related entities (the “Company”) regarding the collection, use, disclosure, retention and destruction (collectively, “Process” or “Processing”) of information relating to a natural person and allowing that person to be directly or indirectly identified (“Personal Information”).

1.1 Introduction

Scope of the Policy. This Policy applies to users and visitors (collectively “you”, “your”) of https://salvatore.com/fr/, https://jacklecoq.com/, https://topla.com/fr/, https://www.cremeriechezmamie.com/fr/ and https://www.loeufrier.ca/ (collectively, the “Website”). This Policy does not apply to the Personal Information of the Company’s employees.

Consent. By using the Website, you agree that the Company will process your Personal Information in accordance with the terms set out in this Policy. If you do not agree to be bound by this Policy, please do not access or use the Website.

Cookie banner. You may also change your consent regarding the use of cookies at any time through the cookie banner, which you can open by clicking “Settings” in your web browser, then selecting “Privacy and security”.

1.2 Person responsible for the protection of personal information

Contact details of the Privacy Officer. Any comments, questions or complaints regarding this Policy and the Company’s privacy practices may be directed to the Company’s Privacy Officer at the following contact details:

2. Processing of personal information

The following sections describe the collection methods, the categories of information collected, the purposes for which it is used, disclosure to third parties, and retention periods.

2.1 How personal information is collected

Collection methods. The Company collects your Personal Information:

• Automatically. Technical personal information is transmitted by the device you use to connect to the Website when you access it;
• Electronic forms. You may provide Personal Information to the Company by submitting forms available on the Website;
• Emails sent. The Company may receive Personal Information when you send emails;
• Cookies. Through the cookies identified in the cookie banner;
• Third parties. Through third parties that collect your Personal Information on behalf of the Company, including those listed in the cookie banner;
• Profiling, identification or location. The Website includes features that allow profiling of your activities on the Website, identification and location. These features are enabled through certain cookies when you consent to their use via the cookie banner.

2.2 Categories of personal information collected

Categories of information collected. The Company collects various types of Personal Information in the course of its activities, including:

• Your identifiers , such as your first and last name;
• Your contact details , such as your address, email address and telephone number;
• Demographic information , such as your age or place of residence;
• Technical information such as your IP address, pages visited, time and date of visits, domain name, referring website (if you access the Website from another site), your device operating system and other hardware and software information;
• Your consent to a use or disclosure of Personal Information (for example, if you accept a cookie via the cookie banner, that consent is communicated to the Company);
• Information you choose to provide to the Company, for example when you complete an online form.

2.3 How personal information is used

Purposes. The Company may use your Personal Information to:

• Carry out the purposes indicated in the cookie banner;
• Provide online ordering services, loyalty and rewards programs, sponsorships and gift cards;
• Operate, maintain, monitor, develop and improve the Website;
• Process requests regarding Personal Information;
• Manage job applications;
• Process and resolve complaints and dissatisfaction;
• Develop, improve and offer new services;
• Answer your questions and provide assistance when needed;
• Conduct research, analysis and statistics related to Website use and the Company’s services;
• Detect and prevent fraud, errors, spam, abuse, privacy incidents and other harmful events;
• Any other purpose required or permitted by applicable laws.

2.4 Disclosure of personal information

The Company discloses your information to third parties. Accordingly:

Certain cookies collect Personal Information. The purposes for which they are used and the third parties to whom the information is disclosed are identified in the cookie banner. These include:

• Alphabet (Google) , due to the use of Google Analytics, Google Tag Manager, Google Ad Services and YouTube cookies. The purposes of these cookies are set out in the cookie banner. These cookies may enable profiling of your online activities, targeted advertising, identification and location.

The Company uses Google services to store documents and manage emails. This means Google may have access to your Personal Information. All categories of Personal Information identified in section 2.2 may be disclosed or stored through the use of these services.

• The Company uses the services of a website hosting provider. All Personal Information transmitted through the Website will be disclosed to it;
• The Company uses Instagram, Facebook, TikTok and YouTube to share content and keep you informed of the latest news;
• The Company uses LinkedIn to share content, for recruitment purposes, and to keep you informed of the latest news;
• The Company uses Monday to store our documents;
• The Company uses the Metatracer tool to facilitate the detection and management of your Personal Information and support compliance with privacy laws. Metatracer only collects identifiers.

Outside Québec. As part of these disclosures, Personal Information may be disclosed outside Québec.

2.5 Retention period for personal information

Retention period. Subject to applicable laws, the Company retains your Personal Information only for as long as necessary to fulfill the purposes for which it was collected.

Additional information. To learn more about the periods during which your Personal Information is retained, please contact the Privacy Officer using the contact details provided in section 1.2.

3. Rights

Rights of individuals. Subject to the limits set out by law, you may exercise the rights listed below by contacting the Privacy Officer in writing using the contact details provided in section 1.2. In accordance with the law, the Company may and sometimes must verify your identity before responding to such requests:

Right of access

You have a right of access to your Personal Information. In particular, you have the right, among other things, to:

• Be informed of the Personal Information the Company holds about you;
• Receive computerized Personal Information in the form of a written and intelligible transcription;
• Receive the Personal Information and obtain a copy of it;
• Consult your Personal Information free of charge.

Right to rectification

You have the right to rectify your Personal Information. In particular, you have the right, among other things, to:

• Request that inaccurate, incomplete or ambiguous Personal Information be corrected, amended or updated;
• Request that any Personal Information whose collection, disclosure or retention was not authorized by law be deleted, corrected, amended or updated;
• Request that any outdated or unjustified Personal Information be deleted, corrected, amended or updated;
• Request that you be allowed to submit written comments to be added to your Personal Information or, where applicable, your file.

Option to withdraw consent

Within the limits of the law and your contractual obligations, you may withdraw your consent to certain uses or disclosures of Personal Information.

Right to file a complaint

You have the right to file a complaint with the Privacy Officer.

Questions

You may also contact the Privacy Officer with any questions regarding this Policy.

4. Security measures

The Company has implemented measures intended to adequately protect the confidentiality and security of your Personal Information, including:

Administrative measures

The adoption of a series of measures, policies and procedures that, among other things:

• Govern access, disclosure, retention and de-personalization, including the destruction or anonymization of Personal Information;
• Impose contractual obligations on certain third parties aimed at promoting the security of Personal Information disclosed to them;
• Define employee roles and responsibilities throughout the lifecycle of Personal Information;
• Establish procedures for responding to privacy incidents;
• Govern the process for requests and complaints relating to the protection and processing of Personal Information.

Technical measures

From a technical standpoint, the Company:

• Uses “Secure Sockets Layer (SSL)” technology;
• Implements access restrictions to prevent employees from accessing Personal Information that is not necessary to perform their duties;
• Uses backup systems;
• Uses network monitoring software;
• Uses a firewall system.

Despite the measures described above, the Company cannot guarantee absolute security of Personal Information.

5. Changes to the Privacy Policy

Impact of changes. The Company reserves the right to amend this Policy at any time in accordance with applicable legislation. If you continue to use the Website after the new version comes into effect, your use of the Website will be governed by that new version.

6. Links to third-party websites

Disclaimer regarding third-party sites. The Website may include references or links to websites or services provided and operated by third parties. Such third-party websites and services are governed by privacy policies that are separate and independent from ours. The Company therefore assumes no responsibility for the content or activities of such sites. This Policy applies only to this Website.

7. Applicable laws

Laws of Québec and Canada. The laws of Canada and Québec, excluding their conflict of law rules, govern this document and your use of the Website. Your use of the Website may also be subject to other local, provincial, national or international laws.