Privacy Policy

5C Group Inc. or its subsidiaries or affiliated companies (collectively “5C”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

1. Important Information and Who We Are

1.1. Purpose of This Policy

This privacy policy aims to give you information on how 5C collects and processes your personal data. Notably how we collect, use, disclose, retain, and destroy, in compliance with applicable privacy laws, any data you may provide through our websites, when you sign up to our newsletter, apply for employment and/or work at 5C or purchase a product or a service.

Our businesses and websites are not intended for children and we do not knowingly process data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

1.2. Definitions

“Personal data” means any information relating to an identified or identifiable natural person, but excludes any information that is not considered as such by privacy laws.

“Processing” means any operation or set of operations which are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“You” means an identified or identifiable individual on whom 5C processes personal data. It includes, but is not limited to, clients of 5C, employees of clients, past, present or future members of the 5C team, visitors to 5C’s internet site, suppliers, contractors and sub-contractors. It does not include data where the identity has been removed (anonymous data).

1.3. Controller of Personal Data

5C is the controller and responsible for your personal data. Reference to 5C (or “we”, “us” or “our”) in this policy refers to all companies within 5C.

1.4. Data Privacy Officer

5C currently has one Privacy Officer. Contact details are as follows:

Email: privacy@5croup.ai

Postal Address: 9300 TransCanada Hwy, Saint-Laurent, Quebec Canada H4S 1K5

Please contact the Privacy Officer with any questions about the application of this policy or if you have any concerns that this policy is not being or has not been complied with. You have the right to make a complaint at any time to your national supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach your national supervisory authority, so please do not hesitate to contact us in the first instance.

1.5. Your Duty to Inform Us of Changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.6. Third Party Content and Privacy Statements

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their content or privacy statements. We encourage you to read the privacy policy or notice of every website you visit or service you use.

2. The Data We Collect About You

We may process different kinds of personal data about you which we have grouped together as follows:

• Identity Data, which includes first name, last name, username or similar identifier;
• Contact Data, which includes billing address, delivery address, residential address, email address and telephone numbers;
• Financial Data, which includes bank account and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
• Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us;
• Technical Data, which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites;
• Profile Data, which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
• Usage Data, which includes information about how you use our websites, products and services, including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs); and
• Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also process aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data (described above) with that of other users to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal information which will be processed in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

3. If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • purchase our products or services;
  • create an account on our websites;
  • apply for, or accept employment at 5C;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from third parties, notably analytics providers.

5. How We Process Your Personal Data

5.1. General Approach and Guidelines

We will only process your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:

• Where we need to perform the contract that we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have provided us your consent to such processing.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. When we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time by contacting us.

5.2. Purposes for Which We Will Process Your Personal Data

We have set out below, in a table format, a description of all the ways we may process your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

In this policy, a legitimate interest means our interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out in the table below.

5.3. Limiting Collection

5C limits the personal data it collects to what is necessary for managing its business and maintaining and developing its commercial relationships.

5.4. Third Party Information Collection

From time to time, you may provide 5C with the personal data of individuals other than yourselves. You agree to obtain, prior to disclosing such information to 5C, the knowledge and consent of each individual to the disclosure, and to subsequent use by 5C, of such personal data, in accordance with this policy, unless otherwise permitted by law.

5.5. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

5.6. Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion, and in each case you have opted into receiving that marketing communication.

5.7. Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside the 5C group of companies for marketing purposes.

5.8. Social Media Widgets

5C’s internet site may include widgets, such as interactive mini programs that run on 5C’s internet site. These features may collect your IP address, which page you are visiting on 5C’s internet site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on 5C’s internet site. Your interactions with these features are governed by the privacy policy of the company providing such service.

5.9. Opting Out

You can ask us or third parties to stop sending you online marketing messages at any time by using the “Unsubscribe” feature contained at the bottom of each such email message. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

5.10. Cookies

You can set your browser to refuse all or some browser cookies, or to when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. Please also refer to any policies governing cookies that we may adopt from time to time (which will be found on our websites).

5.11. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 5.2 above.

• Internal third parties, notably other companies within the 5C group of companies;
• External third parties, notably service providers acting as processors who provide IT and system administration services to 5C, professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, and regulators and other authorities who require reporting of processing activities in certain circumstances; and
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Transfers (Transferring Data Outside of the EEA)

We share your personal data within the entities comprising 5C Group, which are located in the following jurisdictions: Canada and the United States of America. While some of those entities are located outside of the European Economic Area (EEA), this will involve transferring your data outside the EEA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Where necessary by law, we formalize these transfers with binding corporate rules.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. How Long Will You Use my Personal Data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for; including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be requested from us by contacting us.

In some circumstances you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. This includes the following:

• The right to be informed about our collection and use of personal data;
• The right of access to the personal data we hold about you;
• The right to rectification if any personal data we hold about you is inaccurate or incomplete;
• The right to be forgotten – i.e., the right to ask us to delete any personal data we hold about you;
• The right to restrict (i.e., prevent) the processing of your personal data;
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
  The right to object to us using your personal data for particular purposes;
• Rights with respect to automated decision making and profiling; and
• The right to withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

11. Administrative Fees

Where permitted under law, we may charge a reasonable administrative fee to process any request you may have with respect to your personal data or this policy.

12. What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

13. Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex, but we will contact you if this is the case.

14. Modifications to This Privacy Policy

5C reserves the right to modify or update this policy at its entire discretion in order to follow the evolution of our business activities and privacy legislation, by posting changes on our website and a notice will be available on our website home page. If the modifications are material or require your consent, you shall be informed by email.

Rev 04/04/2025