Boreala Management Privacy Policy

Effective Date: May 17, 2024

Your Privacy – Our Commitment

All services provided by Boreala Management (hereinafter “Boreala“) are confidential. We are committed to respecting and protecting your privacy in accordance with the Loi sur la Protection des Renseignements Personnels dans le Secteur Privé (LPRPSP). We also commit to transparency and accountability in the proper management of the personal information you may provide to us.

This privacy policy aims to inform you of our practices regarding the collection, use, disclosure, retention, and destruction of your personal information.

As part of our activities, we collect, use, and process personal information to provide certain services.

By providing us with personal information through our website, www.borealamgmt.com , you agree that your personal information will be processed in accordance with this policy, and you authorize Boreala and its service providers to use your information for the purposes outlined below. It is therefore important to read and understand it. If you disagree with any aspect of our policy, we ask that you refrain from providing your personal information.

Definition of Personal Information

Personal information refers to any information that relates to an individual and allows that person to be directly or indirectly identified. This includes, but is not limited to, the person’s name, home address, telephone number, age, gender, marital or family status, identification number, financial information, information on donations, level of education, etc.

Who We Are

Boreala is an expert in helping organizations enhance their capabilities through their employees by offering services in human resources and organizational efficiency, specifically designed to improve organizational performance.

Boreala’s diverse and passionate team, composed of multidisciplinary experts, helps organizations achieve their goals.

What Personal Information Do We Collect?

When you visit our website, www.borealamgmt.com, or communicate with us in other ways, we may collect and process various types of personal information about you as part of our service delivery. This includes:

Identity information (first name and last name);

Politique de confidentialité 1

Contact details (email, phone number, postal address);
Academic background and professional experiences contained in your resume when applying for a job at Boreala;
Any other personal information voluntarily provided in the “Message” section of our contact form available on our website www.borealamgmt.com;.
Any other information that may indirectly identify you such as your location (including IP address), your interests and preferences (including preferred official language), saved searches, device data (including device identifiers and operating system used), and how you interact with our website.

If you are under 14 years of age, please identify yourself as such and do not provide any personal information without the express consent of your parent or guardian.

How Do We Collect Your Personal Information?

We collect your personal information in several ways:

Directly from you:

When you provide personal information by filling out our contact form on our website www.borealamgmt.com to request information about our services.

When you voluntarily provide personal information by writing in the « Message » section of our contact form available on our website www.borealamgmt.com to communicate with us.

When you voluntarily provide personal information by contacting us at the e-mail address info@dev.borealamgmt.com available on our Web site www.borealamgmt.com for more information about our services or any other relevant requests related to our activities.

Through third parties:

When applying for a job with us: by clicking on the “Join Our Team” or “View Current Job Openings” buttons in the Careers section of our website www.borealamgmt.com, you are redirected to the site https://careers.smartrecruiters.com and the page www.jobs.smartrecruiters.com.

This third party collects personal information directly from you. It is therefore your responsibility to read the privacy policy applicable to this website when you complete the application form. However, we verify that this third party complies with the provisions of the law.

Through cookies as described below in Article 11.

4.How Do We Use Your Personal Information?

Your personal information will be used in accordance with applicable privacy legislation and in accordance with the consent you have provided.

We may therefore use your personal information in the following circumstances and for the purposes indicated, in accordance with the framework defined above:

To provide, administer, perform our services and for the general conduct our business;
To respond to inquiries from individuals who visit our website

www.borealamgmt.com;

To evaluate and contact job candidates for positions posted on our websitewww.borealamgmt.com;
To comply with legal, regulatory, or risk management obligations.

We will only use your personal information to achieve the purposes for which it was collected, and any other purposes authorized by law.

Do We Share Your Personal Information?

Please note that your personal information may be shared (in addition to our authorized employees: customer service and human resources departments) with certain third parties, including:

Service providers and partners: who assist us in establishing, managing, and maintaining our relationships with you, and who provide us with products and services. These third parties may have access to or process personal information in the context of the services they provide. We limit the information we provide to these service providers to what is reasonably necessary for them to perform their functions, and the written contracts we have with them require them to take reasonable steps to ensure the confidentiality of your information;
Government, regulatory, or law enforcement agencies: when we are required to disclose this information, or if we believe in good faith that such disclosure is necessary to comply with applicable laws.

Personal information you provide through our website is not disclosed to other third parties than those expressly identified above without your consent, except as required by law.

We do not sell or exchange your personal information with other organizations or businesses.

6. How Long Do We Retain Personal Information?

Politique de confidentialité 3

We will retain your personal information for as long as necessary to fulfill the purposes for which it was provided and for any other compatible or related purposes authorized by law.

We will cease to use and retain your personal information once these purposes have been fullfilled, subject to any applicable legal or regulatory retention periods.

Where Do We Store Personal Information and International Transfers?

Your personal information is stored on a cloud server provided by a third-party service provider located in Canada (Quebec and/or Ontario) on Microsoft SharePoint.

However, your personal information may be transferred to service providers whose facilities are located outside Quebec and Canada. You consent to the transfer of your personal information to countries or provinces where privacy protection rules may differ.

However, we ensure that these providers offer adequate protection by conducting a privacy impact assessment beforehand and having them sign a written agreement to that effect.

How Do We Protect Your Personal Information?

We recognize that information security is integral to the confidentiality of personal information. We implement industry best practices to protect your personal information in accordance with applicable privacy laws.

This includes maintaining reasonable physical, technical, and procedural safeguards to protect your personal information from unauthorized access, use, disclosure, destruction, and any other breach of protection that does not comply with the law.

All Boreala employees, as well as third-party service providers who process personal information on our behalf, are also contractually obligated to respect the security and confidentiality of personal information.

Links to Other Sites

Boreala‘s website may include hyperlinks to other sites. Information exchanged on these sites is not subject to this privacy policy but to the privacy policy of the external site, if one exists. If applicable, we invite you to review it before providing your personal information to third parties.

Boreala cannot be held responsible for the privacy policies, procedures, and practices of its partners.

What Rights Do Individuals Have Regarding Their Personal Information?

Politique de confidentialité 4

10.1 Access, Rectification, and Withdrawal of Consent Rights

To access your personal information, request a correction of your personal information, or withdraw your consent to the communication or use of your personal information, you must submit a written request to Boreala‘s Privacy Officer (contact details are provided at the end of this Policy).

The rectification request must be particularly precise, identifying yourself accurately to allow Boreala to adequately correct or complete the personal information deemed inaccurate or incomplete.

The request for withdrawal of consent will result in the termination of the benefits of services offered by Boreala to the individual concerned

10.2 Handling Requests

Boreala will normally respond to requests for access, rectification, or withdrawal of consent within 30 days, as prescribed by the Loi sur la protection des renseignements personnels dans le secteur privé.

All necessary assistance will be reasonably provided to individuals who wish to access or rectify their personal information, including clarifying what they are specifically looking for.

Depending on the amount of information requested in an access request, nominal fees may be reasonably charged to cover the costs incurred in responding to the request.

Written notification will be provided if Boreala must refuse access to personal information for legal, regulatory, or other reasons.

10.3 Recourse Before the Commission d’Accès à l’Information

If you are not satisfied with how Boreala handled your request for access or rectification of your personal information, especially in the event of no response or an unsatisfactory response, you may request a review of the disagreement by the Commission d’Accès à l’Information.

How do we use cookie ?

When you use our website www.borealamgmt.com, we use cookies to help you navigate efficiently and to perform certain functions. Cookies are small data files created by your web

Politique de confidentialité 5

browser and placed on your computer. Below each consent category, you will find detailed information about the different types of cookies.

The cookies that are categorized as “Necessary” are stored on your browser as they are essential for enabling the basic functionalities of the site.

We also use third-party cookies that help us analyze how you use this website, store your preferences, and provide the content and advertisements that are relevant to you. These cookies will only be stored in your browser with your prior consent.

You can choose to enable or disable some or all of these cookies but disabling some of them may affect your browsing experience.

Cookie Name Purpose (s) Products Cookie Lifespan Domain (s)

__gsas	Advertising	AdSense for Search	3 months	Set from partner domain
__gpi	Advertising	AdSense, Google Ad Manager	13 months	Set from partner domain
__gpi_optout	Advertising	AdSense, Google Ad Manager	13 months	Set from partner domain
NID	Security, Analytics, Functionality, Advertising	AdSense for Search, Google Ads	6 months	google.com and local variations, e.g. google.de
DSID	Security, Functionality, Advertising	AdSense, Campaign Manager, Google Ad Manager, Google Analytics, Display & Video 360, Search Ads 360	2 weeks	doubleclick.net
test_cookie	Functionality	AdSense, Campaign Manager, Google Ad Manager, Google Analytics, Display & Video 360, Search Ads 360	15 minutes	doubleclick.net
id	Functionality, Advertising	AdSense, Campaign Manager, Display & Video 360, Google Ad Manager, Search Ads 360	OPT_OUT: fixed expiration (year 2030/11/09), non OPT_OUT: 13 months EEA UK / 24 months elsewhere	doubleclick.net
__gads	Advertising	AdSense, Display & Video 360, Google Ad Manager, Google Ads	13 months	Set from partner domain
GED_PLAYLIST_A CTIVITY	Advertising	AdSense, Google Ad Manager, YouTube	Session	Set from partner domain
ACLK_DATA	Advertising	AdSense, Google Ad Manager, YouTube	5 minutes	youtube.com
pm_sess	Security, Functionality	Campaign Manager, Display & Video 360,	30 minutes	doubleclick.net, google.com

Politique de confidentialité 6

Google Ads,

Search Ads 360

pm_sess_NNN	Security, Functionality	Campaign Manager, Display & Video 360, Google Ads, Search Ads 360	30 minutes	doubleclick.net, google.com
aboutads_sessNN N	Security, Functionality	Campaign Manager, Display & Video 360, Google Ads, Search Ads 360	30 minutes	doubleclick.net, google.com
FPAU	Analytics, Advertising	Campaign Manager, Display & Video 360, Google Ads, Search Ads 360	90 days	Set from partner domain
ANID	Advertising	Campaign Manager, Display & Video 360, Google Ads, Search Ads 360	13 months EEA UK / 24 months elsewhere	google.com and local variations, e.g. google.de
AID	Analytics, Advertising	Campaign Manager, Display & Video 360, Google Ads, Search Ads 360	13 months EEA UK / 540 days elsewhere	google.com/ads, google.com/ads/measurement, googleadservices.com
IDE	Advertising	Campaign Manager, Display & Video 360, Google Ad Manager, Google Analytics, Search Ads 360	13 months EEA UK / 24 months elsewhere	doubleclick.net
TAID	Analytics, Advertising	Campaign Manager, Display & Video 360, Google Ads, Search Ads 360	14 days	google.com/ads, google.com/ads/measurement, googleadservices.com
FPGCLDC	Analytics, Advertising	Campaign Manager, Display & Video 360, Search Ads 360	90 days	Set from partner domain
_gcl_dc	Analytics, Advertising	Campaign Manager, Display & Video 360, Search Ads 360	90 days	Set from partner domain
_gcl_au	Analytics, Advertising	Campaign Manager, Display & Video 360, Google Ads, Search Ads 360	90 days	Set from partner domain
FLC	Advertising	Campaign Manager, Display & Video 360, Search Ads 360	10 seconds	doubleclick.net
RUL	Advertising	Display & Video 360, Google Ads	12 months	doubleclick.net
FCCDCF	Functionality	Funding Choices	13 months	Set from partner domain
FCNEC	Analytics	Funding Choices	365 days	Set from partner domain
FPGCLAW	Analytics, Advertising	Google Ads	90 days	Set from partner domain
FPGCLGB	Analytics, Advertising	Google Ads	90 days	Set from partner domain

Politique de confidentialité 7

_gcl_gb

Analytics,

Advertising Google Ads 90 days Set from partner domain

_gac_gb_<wpid>	Analytics, Advertising	Google Ads	90 days	Set from partner domain
_gcl_aw	Analytics, Advertising	Google Ads	90 days	Set from partner domain
1P_JAR	Advertising	Google Ads	30 days	google.com and local variations, e.g. google.de
Conversion	Advertising	Google Ads	90 days	www.googleadservices.com/pagead/conversion/
YSC	Security	Google Ads, YouTube	Session	youtube.com
VISITOR_INFO1_LIVE	Security, Advertising	Google Ads, YouTube	180 days	youtube.com
VISITOR_INFO1_LIVE__k	Security, Advertising	Google Ads, YouTube	180 days	youtube.com
VISITOR_INFO1_LIVE__default	Security, Advertising	Google Ads, YouTube	180 days	youtube.com
FPLC	Analytics	Google Analytics	20 hours	Set from partner domain
_ga	Analytics	Google Analytics	2 years	Set from partner domain
_gac_<wpid>	Advertising	Google Analytics	90 days	Set from partner domain
_gid	Analytics	Google Analytics	24 hours	Set from partner domain
_gat[_<customname>]	Analytics	Google Analytics	1 minute	Set from partner domain
__utma	Analytics	Google Analytics	2 years	Set from partner domain
__utmb	Analytics	Google Analytics	30 minutes	Set from partner domain
__utmc	Analytics	Google Analytics	Session	Set from partner domain
__utmt	Analytics	Google Analytics	10 minutes	Set from partner domain
__utmz	Analytics	Google Analytics	6 months	Set from partner domain
__utmv	Analytics	Google Analytics	2 years	Set from partner domain
AMP_TOKEN	Functionality	Google Analytics	30 seconds to 1 year	Set from partner domain
FPID	Analytics	Google Analytics	2 years	Set from partner domain
GA_OPT_OUT	Functionality	Google Analytics	10 Nov 2030 (all cookies)	google-analytics.com
_ga_<wpid>	Analytics	Google Analytics 360	2 years	Set from partner domain
_dc_gtm_<proper ty-id>	Analytics	Google Analytics, Google Tag Manager	1 minute	Set from partner domain
_gaexp	Analytics	Google Analytics, Optimize	Set by customer
_gaexp_rc	Analytics	Google Analytics, Optimize	10 seconds	Set from partner domain
_opt_awcid	Analytics	Google Analytics, Optimize	24 hours	Set from partner domain
_opt_awmid	Analytics	Google Analytics, Optimize	24 hours	Set from partner domain
_opt_awgid	Analytics	Google Analytics, Optimize	24 hours	Set from partner domain
_opt_awkid	Analytics	Google Analytics, Optimize	24 hours	Set from partner domain
_opt_utmc	Analytics	Google Analytics, Optimize	24 hours	Set from partner domain
_gcl_gf	Analytics, Advertising	Google Flights	90 days	Set from partner domain
_gcl_ha	Analytics, Advertising	Google Hotel Ads	90 days	Set from partner domain
PAIDCONTENT	Analytics, Advertising	Google Surveys	30 days	doubleclick.net
_opt_expid	Analytics	Optimize	10 seconds	Set from partner domain

APC

Advertising, Security

Campaign

Manager, Display

& Video 360 6 months doubleclick.net

Our website integrates links to our social media pages (Facebook, LinkedIn). These links allow you to follow us on our social media platforms and stay informed about our activities. These platforms install their own cookies on your devices. For more information on this, please refer to the cookie usage policies of these social media websites.

How To Contact Us?

If you have any questions about this privacy policy, how we handle your personal information, or to exercise your rights, please contact our Privacy Officer by email or mail at the following addresses: