Confidentiality policy

The type of Personal Information We may collect from time to time may include the following:

Information pertaining to individuals or companies that is contained in written or electronic documents that are publicly available is not considered Personal Information.

Personal information is collected online when users voluntary register on the Site in order to use Our services.

We use Personal Information as part of our Services, where we conduct various investigations and verifications. Information collected and used in this context is subject to specific consent (see Consent section).

We also use Personal Information to communicate with You, to protect You and Us from errors and fraud, to follow up on personal transactions, and to comply with legal and governmental requirements. We may also use this Personal Information to send You offers, help Us grow and improve Our Site and Services, and tailor them to Your interests. We collect, use, and/or disclose Your Personal Information for the following purposes:

TRAK will only disclose Your Personal Information with Your consent or if legally authorized to do so, including in the following contexts:

The Personal Information You provide to TRAK may be transferred to third-party service providers who provide services on Our behalf. These services may include billing, marketing, IT, hosting, and data processing.

In connection with a business transaction, related to financing, securitization, insurance, sale, assignment, or other proposed or actual disposition of all or part of TRAK, or its operations or assets, for the purposes of evaluating and/or carrying out the proposed transaction. Assignees or successors of TRAK, or its operations or assets, may use and disclose Your Personal Information for similar purposes as those described in this Policy.

We may disclose Personal Information if necessary to comply with legal, regulatory, or other insurance, audit, or security requirements, and otherwise with Your consent, or as permitted or required by law (including Canadian and foreign laws applicable to us or our service providers). Therefore, in response to a verified request from law enforcement or a government representative regarding a criminal investigation or alleged illegal activity, we may (and You authorize us to) disclose Your name, city, province, phone number, email address, and order history without a subpoena. However, to balance Your privacy rights and the need to safeguard the community from bad actors, we will not disclose additional information to law enforcement or government representatives without a subpoena, court order, or similar legal process, unless additional disclosure is necessary to prevent imminent physical harm or financial loss.

We will only collect, use, or disclose Your Personal Information if You are aware and consent, unless We are permitted or required to do so by law. Consent may be granted in various ways, depending on the type of Personal Information being collected, used, or disclosed:

During investigations, TRAK will obtain Your express (written or electronic) consent to collect, use, or disclose sensitive Personal Information, such as financial Personal Information.

TRAK will ensure that Your consent is required only to the extent necessary for the purposes of the Services, activities, and programs offered.

Unless restricted by law or contract, You may withdraw Your consent at any time. TRAK will inform You of the implications of such withdrawal. To change Your consent, please notify Us by email at [email protected].

Personal Information collected will not be used, disclosed, or retained for purposes other than those specified at the time of collection, unless We obtain Your consent or are required by law. The use and disclosure of Personal Information is governed internally by our Personal Data Protection Policy.

Your personal information is retained in accordance with our information security policy and our retention schedule, which specify the applicable retention periods. Unless otherwise stated, data is retained for a period of one (1) year from the date of collection to meet legal, accounting, or auditing requirements.

We make reasonable efforts to ensure that Your Personal Information is accurate, complete, and up to date as required for the purposes for which it is intended. You may request access to Your Personal Information at any time to review and update it.

If You wish to review, verify, correct, or withdraw Your consent regarding the use of Your Personal Information, You may also email us at [email protected] to request access, correction, or deletion. We may refuse a request to modify the information if we believe the change would violate a legal requirement or result in incorrect records.

Before providing You access or making the requested changes, we may ask for information to help confirm Your identity and Your right to access the information. In some cases, applicable laws may require us to deny access to some or all of the Personal Information we hold about You, or we may have destroyed, erased, or anonymized it in accordance with our legal obligations and best practices.

If we cannot provide You access, we will explain why, subject to any legal or regulatory restrictions. These may include information about another individual, confidential business information, or data that is unreasonably difficult to obtain.

If Your Personal Information was provided by a third party, We will ask You to contact that party (e.g., credit bureaus).

We protect the Personal Information in our custody or control using physical, electronic, and administrative safeguards appropriate to the nature and sensitivity of the information. These measures include firewalls and encryption technologies. We take reasonable steps to ensure that only employees and contractors who need access to confidential data to perform, develop, or improve our Services are authorized to do so. However, no security measure can provide absolute protection.

To protect Your Personal Information, We use the following safeguards:

To provide Our Services, TRAK or its third-party service providers may collect, use, disclose, store, or process Personal Information on servers located in jurisdictions outside of Your place of residence, for the purposes described in this Policy.

Please note that the privacy laws of these jurisdictions may differ from Canadian and Quebec laws. Reasonable, contractual, or other measures that we may take to protect Your Personal Information during its handling by these providers are subject to applicable foreign legal requirements, including lawful requirements to disclose Personal Information to governmental or law enforcement authorities. By providing Your Personal Information, You consent to such transfer and hosting.

If You would like more information about TRAK’s policies and practices regarding the transfer and processing of Personal Information outside of Quebec and/or Canada, please contact TRAK’s Privacy Officer at [email protected].

This Privacy Policy and related information are always available on Our website at www.groupetrak.com under “Personal Information Protection Policy,” or upon request.

This Policy is subject to updates. The date of the latest update is indicated at the bottom of this Policy. We encourage you to review it periodically to stay informed about how we protect your personal information.

TRAK is responsible for Personal Information under its control. When We use third-party services to conduct business activities, process credit card payments, and provide customer service, We take steps to ensure that these third parties comply with this Policy and all applicable privacy laws.

TRAK’s Policy has been implemented to comply with the Personal Information Protection and Electronic Documents Act (Canada) and any applicable provincial privacy legislation, including Quebec’s Act respecting the protection of personal information in the private sector.

Individuals aged 16 and under are not permitted to provide or post Personal Information on Our Site.

If You have any questions or comments about this Policy, wish to access Your Personal Information, withdraw Your consent, or file a complaint regarding non-compliance with privacy principles, please contact Our Privacy Officer at: [email protected].

TRAK will inform individuals who submit comments or complaints of the applicable procedures. If a complaint is found to be justified, We will take appropriate steps, including amending Our policies and practices if necessary.