CONFIDENTIALITY

OUR POLICY ON THE PROTECTION OF PERSONAL INFORMATION.

FINEFLEUR INC. (“FINEFLEUR”) AND ITS AFFILIATES ARE DETERMINED TO MAINTAIN THE ACCURACY, CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION (AS DEFINED IN THIS CONCEPT). THIS PRIVACY POLICY (“POLICY”) DESCRIBES THE PERSONAL INFORMATION THAT FINEFLEUR COLLECTS FROM YOU OR YOU AND DESCRIBES HOW WE USE THEM AND TO WHOM WE DISCLOSE THEM. PLEASE READ THE FOLLOWING DOCUMENT CAREFULLY.

PRIVACY POLICY APPLICABLE TO CANADA

Finefleur’s policy is to respect the privacy legislation and personal health information in effect in each jurisdiction in which we operate. From time to time, legislation about individual privacy rights may vary from jurisdiction to jurisdiction. This policy covers only those activities that are subject to the federal and provincial privacy and personal health information provisions, if applicable.

This policy is limited in scope and application. As a result, the rights and obligations contained therein may not be applicable to all persons or territories.

WHAT ARE PERSONAL INFORMATION?

For the purpose of this policy, the term “personal information” means all information about an identifiable individual, other than the professional contact information thereof that is collected, used or disclosed for the purpose of communicating with the person in the performance of their duties professional.

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

We collect and retain different types of personal information about the people we interact with, including:

Information to contact you or identify you, including your name, address, phone number, email address, date of birth and gender; Personal Information in connection with your requests for some of our products or services you wish to obtain; Additional information about the products or services we provide or obtain from you; and Information about our business relationships, including agreements, preferences, advisors or suppliers, as well as any comments or information you request from us or that we transmit to you. We may also collect market-related information, which may include Personal Information, about market trends and activities affecting our business. We may also collect information from our public relations activities, with investors or in the media and information related to our interactions with financial advisers or others.

As a general rule, Finefleur collects personal information about you directly from you. In the majority of other circumstances where Personal Information about you is in the hands of a third party, we will obtain your permission before requesting it from such sources.

From time to time, we may use third parties and receive Personal Information collected by such third parties as part of the services they provide to us or otherwise. When such a situation occurs, we will take reasonable steps to ensure that such third parties have told us that they have the right to disclose your personal information to us.

WEBSITE

We may collect information about your visit to our website, including the IP address and domain used to access it, the type and version of your browser, the website you were on before accessing our site. Web, the page you came in and the one you came out of, all the pages of our website that were visited by that IP address and the country you are from. We use this information to measure the performance of our website (including the number of visits, the average length of visits and the number of pages visited per visit) and also, in a business context, to continually improve our site Internet.

We can encode a “cookie” on your computer’s hard drive to track your visit. A cookie is a small data folder that is transferred to your hard drive through your browser and can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identity card and allows our website to recognize you and record your password and preferences. The cookie makes it possible to follow your visits on our Internet site so that we can better appreciate your use of the site and, that thus, it is possible for us to personalize and to adapt our Internet site to your needs. Most internet browsers are set to accept cookies. However, it is possible on most internet browsers to change this configuration so that your browser: (i) warns you before a website places a cookie on your hard drive so you can decide whether you want to accept or refuse the snitch; or (ii) automatically prevent a cookie from being stored on your hard drive. You should know that by not accepting the cookie, you may not be able to access several pages of our website.

Finally, our website may contain links to other websites that may have less stringent privacy standards. We can not be held responsible for the privacy practices, policies or actions of those third parties operating these websites. Finefleur is not responsible for how third parties collect, use or disclose your Personal Information. You should read the privacy policies of these websites before providing them with personal information.


WHY DO WE COLLECT PERSONAL INFORMATION? 

Finefleur collects personal information to manage, maintain and develop its business, for example: To establish, maintain and manage our relationship with you so that we can provide you, or receive from you, the products and services that have been requested; To allow you to create and access an account with us; to allow you to register with us and access an account; to be able to review the products and services we provide to you in order to (i) understand your needs in relation to our products and services; and (ii) work to improve our products and services; To be able to review the products and services we get from you so that we can work with you and be able to understand our needs for these products and services; to be able to respond to your requests (for example, if you prefer direct contact with a company number or your home phone number and tell us about your preferences, and we will use this information to communicate with you. you to this number); to protect Finefleur against errors, fraud, theft and damage to our property and property; to enable us to comply with applicable law or regulatory processes; and for any other reasonable reason to which you consent.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use your personal information:

as permitted or required by law or applicable regulatory requirements; for the purposes described in this Privacy Policy; and for any other reason we have obtained your consent to use or disclose your personal information.

We may also use the information we collect about you as a whole for statistical purposes, for example, to identify the demographics of our customers. We may publish and / or disclose aggregated statistics to third parties, but never personally identifiable information (except in accordance with this policy).

Note: Our website gives you the opportunity to interact with others and to exchange your opinions, information, content and documents (collectively, “User Generated Content”). You are solely responsible for the user-generated content that you post on our website. Unless explicitly mentioned, all user-generated content that you post on our website (including your username) will be made public. Therefore, do not post any personal information on our website (such as your name or address) if you wish to remain anonymous.


WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION? 

We may share your Personal Information with our employees, contractors, consultants, affiliates and other parties who require this information to help us manage our relationship with you, including third parties who provide us with services or do so on our behalf. For example, we may, from time to time, share your personal information with our information technology, data processing and third-party contact center service providers to enable us to conduct our business, including some may be located in the United States. As a result, your Personal Information may be collected, used, processed, stored or disclosed in the United States and may potentially be accessible to law enforcement or national security in that jurisdiction. However, it is important to note that in the unlikely event that law enforcement or national security in the United States requests access to your Personal Information, it will only be provided in strict compliance with the law and subject to all required legal permissions. You will be informed if disclosure of your Personal Information is required by law. In addition, your Personal Information may be disclosed or transferred to another party in the course, or upon closing, a change in the ownership of or the grant of a security interest in, all or part of Finefleur or any of its subsidiaries in connection with, for example, a sale of assets or shares or any form of business combination, merger or joint venture, provided that such party is subject to the agreements or appropriate obligations and be obligated to use or disclose your Personal Information in accordance with applicable laws and regulatory requirements and with the provisions regarding the use and disclosure of this Policy, unless you agree otherwise. 

Finally, your Personal Information may be disclosed:

for the reasons described in this policy; as permitted or required by law or applicable regulatory requirements; to comply with valid judicial procedures such as search warrants, citations or court orders; as part of the normal reporting activities of Finefleur and its affiliates; to protect the rights and property of Finefleur; in emergency situations or, where applicable, to protect the safety of a person or group of persons; and with your consent. YOUR CONSENT IS IMPORTANT FOR US. It is important for us to collect, use or disclose your Personal Information only when we have your consent to do so. Depending on the sensitive nature of the personal information, your consent may be implied, presumed (using a withdrawal mechanism) or explicit. Express consent may be given verbally, electronically or in writing. There is implied consent where the individual’s conduct or inaction reasonably suggests consent. For example, when you enter into an agreement with us, we assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of this agreement and for any other purpose referred to you in this Agreement. relevant time.

Typically, we will seek your consent as we collect your Personal Information. In certain circumstances, your consent may be obtained after the collection of your Personal Information, but before it is used or disclosed. If we intend to use or disclose your Personal Information for any purpose other than the one previously identified (either in this policy or separately), we will endeavor to disclose it to you prior to such use or disclosure.

We may collect, use or disclose your Personal Information without your knowledge or consent where applicable laws or regulatory requirements permit or require it.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting us. Any communication in respect of such withdrawal or change of consent should be submitted in writing and addressed to privacy@finefleur.ca

We assume that, unless we have indicated otherwise, you have consented to the collection, use and disclosure of your Personal Information as explained in this policy.

HOW ARE YOUR PERSONAL INFORMATION PROTECTED?

Finefleur will endeavor to maintain appropriate physical, technical and procedural safeguards in light of the sensitivity of the Personal Information in question. These safeguards are designed to prevent the loss, unauthorized access, collection, use, disclosure, copying, alteration, disposal or destruction of your Personal Information.

The security of your Personal Information is important to us. Accordingly, please immediately notify us of any incident involving the loss, unauthorized access or disclosure of Personal Information in our custody.

UPDATE YOUR PERSONAL INFORMATION

It is important that the information we keep in our records is both accurate and current. If your Personal Information changes during our relationship, please let us know.

In certain circumstances, we may disagree with a request for a change of Personal Information, in which case we will attach an attached text to keep the information on file.

ACCESS TO YOUR PERSONAL INFORMATION

You can ask to see your Personal Information. If you would like to review, verify or correct your Personal Information, please contact privacy@fineflower.ca. Please note that any communication to this effect must be in writing

When requesting access to your Personal Information, please note that we may request specific information about you to allow us to confirm your identity, access and search for the Personal Information we hold in Canada. your subject and pass them on to you. We may charge an access fee to your Personal Information. Nevertheless, we will inform you of such a fee in advance.

Your right to access the Personal Information we hold about you is not absolute. There are situations where applicable laws or regulatory requirements permit or require us to refuse to provide, in whole or in part, any Personal Information about you. In addition, Personal Information may have been destroyed, erased or made anonymous in accordance with our records retention practices and obligations. In the event that we are unable to respond to your request for access to your Personal Information, we will endeavor to inform you of the reasons, subject to legal or regulatory restrictions.

Warning :

REVISIONS TO THIS PRIVACY POLICY

From time to time, Finefleur may make changes to this Privacy Policy to reflect changes in our legal or regulatory obligations or the manner in which we manage your Personal Information. We will post on our website an update of this Privacy Policy and we encourage you to refer to it on a regular basis.

The last update of this Privacy Policy was on May 18, 2019.

INTERPRETATION OF THIS PRIVACY POLICY

Any interpretation of this Privacy Policy will be made by the Director of Legal Affairs of Finefleur. This privacy policy includes examples, but it does not intend to restrict its application to these examples; therefore, when the word “including” is used, it must be understood in the sense of “including but not limited to”.

This Privacy Policy does not create or confer any right on any individual, or impose any right or obligation on Finefleur outside of, or in addition to, any right or obligation imposed by Canadian and provincial copyright laws. privacy and personal information, if applicable. Should there be a discrepancy between this Privacy Policy and any of these laws in any particular case, this Privacy Policy will be construed, in this case only, to give effect to and comply with these laws. protection of privacy.

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