Privacy policy

Groupe Montoni (1995) Division Construction Inc., a construction and property development industry leader, along with its affiliate companies as defined by law (“MONTONI,” “we,” “us,” “our”), are firmly committed to protecting your privacy and the confidentiality of your personal information. We wish to assure you that only necessary personal information is collected, and that its use, retention and disclosure are limited to the purposes for which it is collected.

To provide you with a comprehensive and optimized experience, we need to have access to certain personal information about you. This Confidentiality and Privacy Policy (the “Policy”) therefore aims to provide you with information about our practices, as well as how we collect, use, disclose, protect, retain and destroy your personal information.

The Policy applies to personal information collected in the course of our operations about our clients, our partners and all employees, applicants and persons seeking employment with MONTONI, as well as to personal information collected when you visit our website (the “Site”).

Note that the Policy does not apply to third-party websites and software to which you may be redirected when you use our Site, such as Google reCAPTCHA (a service that distinguishes humanfrom computers). We are not responsible for these third-party sites, their content nor access to them. Consequently, any personal information you transmit through these sites is subject to those third parties’ privacy policies. It is your responsibility to review each of those privacy policies to ensure the protection of your personal information.

In addition, all of our employees have been made aware of and trained in how to properly manage your personal information so that it is treated with the necessary confidentiality, discretion and care, in accordance with current legislation.

If you have any questions or comments, or you have reasonable grounds to believe that there has been a breach of confidentiality involving any of your personal information held by MONTONI, please refer to the QUESTIONS, COMMENTS OR COMPLAINTS section hereunder.

The Act Respecting the Protection of Personal Information in the Private Sector (RSQ c. P-39.1), as amended by the Act to Modernize Legislative Provisions as Regards the Protection of Personal Information (SQ 2021, c. 25), defines “personal information” as “any information which relates to a natural person and directly or indirectly allows that person to be identified.”

When you communicate with us, voluntarily fill out a form with your personal information, submit a job application or browse our Site, you consent to the collection, use and disclosure of your personal information in accordance with the Policy. If you provide us with the personal information of a third party, you declare that you have the consent and authorisation under applicable laws to allow us to collect, use and disclose such information in accordance with the Policy.

You have the right to withdraw or modify your consent at any time by writing to us using the contact information provided in the QUESTIONS, COMMENTS OR COMPLAINTS section of this Policy. Note that certain personal information is required for service provision and that your withdrawal of consent may result in the suspension of that service. If this is the case, you will be notified in advance or at the time you withdraw your consent.

What personal information do we collect?

When you use our Site, personal information collected may include, but is not limited to:

• Your contact details (e.g., full name, e-mail address, postal address, phone number, etc.);
• Information about the use of the Site, including technical information about visits and other information essential to the proper operation of the Site;
• Information about your preferences, interests and other information collected via our Site that enables us to send you targeted advertising based on your interests;

• Recruitment information such as your resume and references;

• Information about a complaint that you make; your complaint will be treated in strict confidence, just as personal information is, and its treatment will be protected;
• Any other personal information provided directly by you.

Please be aware that we collect only the personal information that is necessary for our business purposes, such as providing you with our services or managing your employment and/or business relationship with us.

Moreover, we do not purposefully collect personal information from children under the age of 14. Any information collected in error may be destroyed upon request; simply make a request to this effect using the contact information provided in the QUESTIONS, COMMENTS OR COMPLAINTS section of this Policy.

Personal information collected by MONTONI will be used for the following purposes:

• Building and managing our business relationship with you;
• Ensuring the proper operation of our business and real-estate operations;
• Providing and maintaining the services requested;
• Making it easier to use our Site, ensuring its relevance and following up on how it is used;
• Responding to your requests for information;
• Conducting research and development and understanding our clients’ expectations so as to improve our offers and services;
• Recruiting staff and meeting legal requirements for hiring;
• Enabling us to meet our legal obligations;
• Any other purpose to which you expressly consent.

Personal information may be provided by you, for example, when you contact us, fill out an application form online, etc.

Personal information may be provided by third parties or publicly available records, for example:

• Other affiliates of MONTONI;
• Our commercial business partners;
• Credit-evaluation, background-check and fraud-detection;
• A former employer of yours;
• Court records;
• The Québec Enterprise Register;
• The Québec Land Register and Québec Securities Register.

We will obtain the necessary consent when required to by law.

Personal information may be collected through cookies when you use our Site. Cookies are small data files commonly stored on computers or mobile devices when you use websites and online services. They are used for the efficient operation of websites and, in some cases, can provide information and help customize services. MONTONI uses, among others, browsing analysis and advertising targeting tools, such as Google Analytics and Facebook pixel, which enable Google and Meta to collect personal information about your use of our Site.

• Essential cookies: These cookies help make the Site usable by enabling basic functions like page navigation and access to secure areas of the Site. The Site cannot function properly without them.

• Preference cookies: These cookies enable the Site to remember information that changes how the Site is displayed or behaves, such as your preferred language or the region that you are in. These cookies are optional and not essential for the provision of our services. You can change the settings for these cookies.

• Statistical cookies: These cookies help the Site owners, by collecting and communicating information, to understand how visitors interact with the Site. In other words, they help us understand your behaviour and, in turn, to improve our Site. These cookies are optional and not essential for the provision of our services. You can change the settings for these cookies.

• Marketing cookies: These cookies are used to track visitors across websites. The intention is to display advertisements that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. When activated, these cookies tell us, among other things, which pages you are interested in, and display advertising that matches your areas of interest. If you use our Site to access one of your social media networks, such as LinkedIn, Instagram or Facebook, our Site will record your IP address for advertising purposes. With regard to your use of social networks, these sites are governed by the respective privacy policies of the companies providing the services. These cookies are optional and not essential for the provision of our services. You can change the settings for these Cookies.

When you connect to our Site, you can enable and/or disable cookies as you prefer; consequently, you can consent or not to the activation of optional cookies. However, if you decide to refuse them, certain pages or sections of our Site may not be displayed correctly, or certain features may not be available.

We collect, use and disclose your personal information only with your consent, except where otherwise provided by law; for example, if we are required to disclose your information under a subpoena or court order.

Disclosure

Access to your personal information is limited to employees of our company for whom such access is necessary and essential for the performance of their duties. We may, however, need to share your personal information outside our company, to the extent permitted by law and/or after obtaining your consent.

Following are the categories of service providers and partners or third parties to whom we disclose or may disclose your personal information.

Examples of services that may be provided by partners or third-party providers:

• Information (Technology (IT) (e.g., websites, cloud hosting, application developers);
• Marketing and business development (e.g., browsing data analysis, targeted advertising);
• Printing;
• Mail delivery;
• Professional services (e.g., architects, engineers, lawyers, notaries, accountants);
• Hiring services (e.g., recruitment agencies, credit evaluation, background check, psychometric evaluation, payroll);
• Security and surveillance camera services;
• Business partners (e.g., parking management);
• Companies affiliated with MONTONI as defined by law.

The latter are subject by written contracts that include all clauses prescribed by law. These contracts specify, among other things, that these partners or service providers will have access only to the personal information they need to perform their tasks on our behalf and that they are prohibited from disclosing it or using it for any other purpose. The contracts are a way for us to ensure the security of your data. Note that some partners or service providers may be located outside Québec; in such cases, we perform an assessment of the risk to your privacy and personal information.

Other examples of third parties with whom we may be required to share your personal information:

• Courts or public authorities (e.g., court order, when required by law enforcement legislation or to protect ownership or safety of our or others’ rights);
• Other third parties (e.g., certain specific circumstances, for example as part of a business transaction [a merger, an acquisition by another company, obtaining a loan or financing] or in the event of insolvency or bankruptcy).

Retention

The security and confidentiality of your personal information is important to us. We apply the necessary and appropriate security measures to ensure the confidentiality of the personal information in our possession. To do so, we follow generally accepted industry standards, among others. The personal information in our possession is therefore accessible only to those persons authorized to have access to it, and they consult it only when necessary for the performance of their duties.

Personal information in digital formats is stored on cloud computing sites, and personal information in material form is stored in our offices.

Protection

Physical, technical and/or administrative protection and security measures have been implemented and maintained in order to avoid:

• Any unauthorized use;
• Any unauthorized communication or disclosure;
• Any loss or theft;
• Any unauthorized access;
• Any other breach of your personal information.

Protection of the person information hosted on cloud computing sites is subject to those sites’ policies. As noted above, MONTONI ensures that its contractual agreements with these providers are appropriately worded.

Protection of personal information in material form is ensured, among other means, by placing it under lock and key, with access limited to staff who require it to perform their duties.

Moreover, with regard to all personal information whether hosted on cloud computing sites and accessible from our offices or in material form stored in our offices, we make sure that:

• Access to our offices is restricted to authorized personnel (visitors are not permitted to access all office spaces unaccompanied);
• Access to IT hardware is restricted by means of strong passwords and two-factor authentication;
• Our premises are constantly monitored by surveillance cameras and a security guard is on duty outside business hours;
• Employees’ awareness is raised when policies are adopted and is maintained through training sessions;
• Our contractual agreements with agents and goods and services providers who have access to personal information contain security measures deemed equivalent.

If you believe that your personal information has been compromised, please write to us using the contact information in the QUESTIONS, COMMENTS OR COMPLAINTS section of this Policy.

Destruction

How long we keep your personal information varies depending on the type of information and the purpose for which it was provided. Consequently, we keep our personal information for as long as we require it to fulfil the purpose for which it was collected, and as required for us to comply with our legal and regulatory obligations. Subsequently, it will be destroyed or anonymized in accordance with a retention schedule.

All personal information held in material form will be destroyed by a certified provider of confidential document destruction services.

All personal information held in digital formats will be deleted from our systems and/or those of our providers, as applicable. When personal information is destroyed or deleted from our systems, we ensure that this process is secure, such that it will be impossible to reconstitute the information.

Access to and correction of your personal information

You may request access to your personal information or information about the existence of such information, or request corrections to information held by us if it is found to be inaccurate, ambiguous or incomplete, by writing to us using the contact information in the QUESTIONS, COMMENTS OR COMPLAINTS section of this Policy.

If you wish to obtain copies of your personal information, we may have to charge an administrative fee, of which you would be notified in advance, simply to cover the costs of transcription, reproduction, redaction of any personal information about someone other than you, and transmission.

Modification to your consent

You may also request withdrawal of your consent to the use or communication of your personal information for non-essential purposes, by writing to us using the contact information in the QUESTIONS, COMMENTS OR COMPLAINTS section of this Policy, if you wish to withdraw your consent to use for purposes that are not necessary as part of our service.

The content of our Site may be modified at any time. MONTONI reserves the right, at its discretion, to update, revise, modify or supplement the Policy from time to time. If so, the Site will be updated and our employees will be notified of and receive training on the changes. As the Policy may change over time, we recommend that you review it frequently to stay informed about how we handle your personal information.

For any requests, questions, comments, complaints, or additional information, or to exercise your rights, please contact the Privacy Officer at the following address:

Groupe Montoni (1995) Division Construction Inc.

Mtre Franca Riso, Vice-President, Corporate Affairs

600, rue Lucien-Paiement, 2^nd Floor

Laval, Québec

H7N 0H7

confidentialite@groupemontoni.com

MONTONI wants you to know that we are committed to responding promptly to any questions or concerns you may have about the confidentiality and security of your personal information and about our privacy policies and procedures.

In the event of a complaint from you regarding the exercise of your rights as set out in the Policy, your file will be handled by our Privacy Officer, who will inform you of the procedure to follow. Every complaint is investigated, and if it is found to be justified, the specific situation will be corrected and you will be informed of the outcome.