PRIVATE SECTOR PRIVACY LEGISLATION

Personal Information Protection

KYA Verbum’s commitment is to provide the Client with exceptional-quality service. Doing that involves the collection, use, and disclosure of personal information from the Client thus protecting its personal information is our highest priority. Although KYA Verbum has always taken the utmost care of the privacy of the Client and protected its personal information, it is committed to further protecting its personal information under the Quebec PRIVATE SECTOR PERSONAL INFORMATION PROTECTION ACT, which was updated on August 1^st 2014. This act establishes the basic rules on how Quebec companies and non-profit organizations must collect, use and disclose personal information.

KYA Verbum will keep the Client informed as to the reason and the manner in which its personal information is collected, used and disclosed. KYA Verbum will obtain its consent and will only process its personal information in a manner that is reasonably appropriate under the circumstances. The personal information protection policy, in accordance with the PRIVATE SECTOR PERSONAL INFORMATION PROTECTION ACT, provides detailed information on the principles and practices to be followed, which KYA Verbum will comply with in order to protect the personal information of the Client.

KYA Verbum’s privacy commitment encompasses ensuring the confidentiality, accuracy, and protection of the Client’s personal information and allowing the Client to request access to and correction of its information. Said personal information protection policy applies to KYA Verbum, as well as to service providers that collect, use or disclose personal information on behalf of KYA Verbum.

DEFINITIONS

Personal Information: it is defined as the personal information of an individual that has not included contact information.

Contact information: it is the information provided by an individual and that allows them to be contacted at a place of business. Such information includes, without limitation, name, contact telephone number, business address, job title, business email, among others. THE PRIVATE SECTOR PERSONAL INFORMATION PROTECTION ACT does not cover contact information.

Privacy Officer: is the individual who is responsible for ensuring that KYA Verbum complies with this policy, as well as with the PRIVATE SECTOR PERSONAL INFORMATION PROTECTION ACT.

The Client: is any individual, company or organization that requests KYA Verbum to provide a service offered by KYA Verbum.

1.Collection of personal information

1.1 Unless the Client provides its personal information voluntarily, KYA Verbum will inform the purposes for which said collection of personal information is requested, either in writing or orally, prior to collection.

1.2 KYA Verbum will only collect the Client’s information that is necessary for the following purposes: review of the Client’s identity; review of your economic or credit solvency; realization and delivery of the required services; guarantee of high quality of the service required by the Client; identification of the Client’s banking needs; payment collection.

2. Consent

2.1 The Client must give consent to KYA Verbum to collect, use or disclose personal information, except when KYA Verbum is authorized to do so without the consent of the Client.

2.2 The Client will grant consent electronically by reading and accepting these privacy policies, which can be found on the KYA Verbum website. Said consent will be considered granted at the time of clicking on the box prepared for it. Consent, however, may also be given in writing by sending an email to KYA Verbum, expressing the Client’s acceptance of KYA Verbum’s privacy policies.

2.3 With some exceptions such as if it is necessary to have the personal information in order to provide the service or if the withdrawal of consent would lead to not being able to comply with a legal obligation, the Client may withdraw his consent for KYA Verbum to use its personal information. However, the Client’s decision to withdraw its consent to the use of its personal information for certain uses could limit the ability of KYA Verbum to provide a specific service. If this is the case, KYA Verbum will explain the situation in order to advise the Client to make the decision.

2.4 KYA Verbum may collect, disclose or use personal information without the Client’s consent or knowledge in the following limited circumstances: if the collection, disclosure or use of personal information is required or permitted by law; due to an emergency that endangers the integrity, for example, the life, health or personal safety of an individual; whether the Client’s personal information is publicly available; in case of requesting legal advice from a lawyer; when necessary in order to collect a debt; when it implies the need for KYA Verbum to protect itself from fraud; in order to investigate early a breach of an agreement or contract or a violation of law.

3. Use and disclosure of personal information

3.1 KYA Verbum will only use or disclose the Client’s personal information as necessary to fulfill the purposes identified at the time of such collection or for a purpose that is reasonably related to those purposes: contacting the Client in order to offer services that could be of its interest, conduct Client surveys in order to improve KYA Verbum services.

3.2 KYA Verbum will not use or disclose the Client’s personal information for any other purpose unless it has the express consent of the Client to do so.

3.3 KYA Verbum will not sell lists or personal information to third parties except with the express written consent of the Client.

4. Retention of personal information

4.1 KYA Verbum will retain the Client’s personal information even when the service has ended in case the Client requires another service in the future. However, the Client may request in writing to KYA Verbum, the removal of said information.

4.2 Subject to the previous point, (4.1), KYA Verbum will also retain the Client’s personal information as long as it leads to the fulfillment of the identified purposes or whether it is a legal or commercial purpose.

5. Accuracy of personal information

5.1 KYA Verbum will always make every effort to ensure that the Client’s personal information is up-to-date, accurate and complete if it is used to make a decision about the Client or if it is disclosed.

5.2 The Client may request KYA Verbum at any time to correct their personal information in order to ensure its accuracy and compliance. The Client must request in writing the correction of its personal information, as well as provide sufficient details to identify the personal information and carry out the requested correction.

5.3 In the event that the Client’s personal information is inaccurate or incomplete, KYA Verbum will correct such information as requested by the Client and forward such corrected information to parties to whom it has previously disclosed such information.

6. Protection of personal information

6.1 KYA Verbum is committed to guaranteeing the protection of the Client’s personal information in order to protect it from unauthorized access, collection, use, disclosure, reproduction, modification or deletion by third parties.

6.2 KYA Verbum undertakes to take the necessary security measures in order to guarantee the due protection of the Client’s personal information, among others, but not limited to passwords, firewall and other computerized security measures; restricted access to the physical premises where the Client’s information is located; contracting of computer and physical security services if necessary; access to Client files only to authorized personnel, among others.

6.3 At the time of deletion of the Client’s information, KYA Verbum will implement the appropriate security measures such as the correct and complete deletion of electronic information; complete shredding of information in physical form.

6.4 KYA Verbum will constantly update its security policy and control as technology changes in order to constantly guarantee the protection of the Client’s personal information.

7. Grant access to personal information to the Client

7.1 The Client will have the right to access its personal information, with certain exceptions such as if the Client’s information could disclose personal information of a third party; safety or health issues or a violation of attorney-client privilege.

7.2 The Client must request in writing access to the personal information and must provide sufficient details in order to identify the personal information requested.

7.3 In the event that the Client requests it, KYA Verbum will indicate to the Client the manner in which its personal information has been used and to whom it has been disclosed.

7.4 KYA Verbum reserves the right to charge a nominal fee in order to provide access to personal information. Likewise, KYA Verbum will inform the Client of the date on which the personal information will be provided.

7.5 In the event that KYA Verbum rejects the request for access to personal information, partially or completely, KYA Verbum will notify the Client in writing, detailing the reason for the rejection.

8. Questions and complaints

8.1 The Client will address any complaint or question regarding compliance with the privacy policy to the privacy officer of KYA Verbum. In the event that KYA Verbum cannot resolve the same, the Client may write directly to the Information and Privacy Commissioner of Quebec.