PREAMBLE

This Confidentiality and Privacy Policy is intended to help you better understand our practices regarding the collection, use, disclosure and retention of personal information of users of our website. You consent to the processing of such personal information as set out in this Confidentiality and Privacy Policy and authorize Saturnia Holdings, their third parties and service providers to process your personal information for the purposes set out below.

This website may contain links to third-party sites, including plug-ins, social media or other sites that may be accessed by clicking on links on our website. This Confidentiality and Privacy Policy does not apply to such third-party websites and Saturnia Holdings is not responsible for such third-party websites. If you follow a link to a third-party website, that site will have its own privacy policies that we encourage you to review before submitting any personal information.

WHAT IS CONSIDERED PERSONAL INFORMATION?

“Personal information” is any factual or subjective information, recorded or not, about an identifiable individual. This information can take many forms, including: 

• Age, name, identification numbers, e-mail address, income, ethnic origin or blood type;
• Opinions, evaluations, comments, social status or disciplinary measures;
• Employment records, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (e.g.: for the acquisition of goods or services, or a change of employment).

Exceptions:

Business contact information and certain public information. For example, names, addresses and telephone numbers published in telephone directories are not considered personal information. When a person uses his or her home contact information as business contact information, we consider that the contact information provided is business information and is therefore not subject to the protection of personal information.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We may collect and process various types of personal information in the course of our business and service provision, including:

• Professional and/or personal contact information, such as first name, last name, address(es), e-mail address(es), and telephone number(s);
• Information about your professional background, networks, social involvement, professional affiliations and family ties;
• Recruitment information, such as curriculum vitae, education and employment history, details of professional affiliations and other information relevant to potential recruitment by Saturnia Holdings;
• Website usage and other technical information, such as details regarding visits to our website, your interaction with our advertising and online content, Internet Protocol (IP) address or information collected through cookies and other tracking technologies.
  
  

We do not knowingly collect information from children or others under the age of fourteen (14). If you are a minor under the age of fourteen (14), please do not provide us with any personal information without the express written consent of a parent or guardian.

If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we learn that we have collected personal information from minor children without verification of parental consent, we will take steps to delete that information from our servers.

HOW DO YOU SHARE YOUR PERSONAL INFORMATION WITH US?

You share your personal information with us when you share your personal information with our organization when you share information on our website.

HOW MAY WE USE PERSONAL INFORMATION?

We may use personal information in any of the ways set out below, with your consent or, where applicable, on another lawful basis. In each case, we will indicate the purposes for which we use your personal information:

A. In order to provide our services and for the conduct of our business, to administer and perform our services, including to carry out our obligations arising from any agreement entered into between you and us.

B. In order to facilitate the use of our website and to ensure that the content is relevant and to ensure that the content of our website is presented in the most effective manner for you and your device.

C. For marketing and philanthropic development purposes to provide details of new services, information on developments in our organization and sector and invitations to seminars and events where an individual has opted to receive such information.

D. For research and development purposes (including security) – to conduct analyses to better understand our customers’ service and marketing requirements and to better understand our organization and develop our services and offerings.

E. For recruitment purposes – to enable us to process job applications and assess whether an individual meets the requirements of the position for which they may be applying at Saturnia Holdings.

F. To meet our legal, regulatory or risk management obligations.

G. To prevent fraud and/or conduct other background checks that may be required at any time by applicable law, regulation and/or best practices (if false or inaccurate information is provided or fraud is detected or suspected, information may be forwarded to fraud prevention organizations and may be recorded by us or such organizations). When processing special categories of personal information, we may also rely on important public interests (crime prevention or detection) or legally founded claims.

H. To ensure we get paid – to collect payments owed to us and, where appropriate, to enforce such collections by debt collection agencies or other legal means (including legal proceedings).

I. In order to reorganize or modify our organization if we undertake a reorganization (for example, by merging, consolidating or divesting part of our organization’s mission), we may need to transfer some or all of the personal information to an applicable third party (or its advisors) as part of any due diligence process or transfer to such reorganized entity or third party for the same purposes as set forth in this Confidentiality and Privacy Policy or for the purpose of analyzing any proposed reorganization. In such a situation, we will take all possible steps to ensure the protection and security of personal information.

WITH WHOM MAY WE SHARE PERSONAL INFORMATION?

We may share personal information with certain third parties, including the following:

• Third-party service providers and/or partners, including those who provide us with database analysis services, websites, hosting and other services. These third parties may access or process personal information in connection with the services they provide to us. We limit the information we provide to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with these service providers require them to maintain the confidentiality of such information;
  
  

When you visit our website, these third parties may use cookies, web beacons or similar technologies on your hard drive to collect or receive information about your browsing on the website and elsewhere on the Internet. These technologies enable us to deliver relevant and targeted advertising based on your areas of interest. You can consult cookies and delete them if you wish. You therefore have full control. We advise you to refer to your browser settings to make the appropriate changes.

If you wish third-party sites to store “cookies” on your hard drive to offer you targeted advertising, you can activate this option.

HOW LONG DO WE KEEP PERSONAL INFORMATION?

We will retain your personal information for a reasonably appropriate period of time to fulfill the purposes for which it was collected, including any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal information longer in the event of a complaint or if we have reasonable grounds to believe that our relationship with you may be the subject of litigation. In certain circumstances, you may ask us to delete your personal information.

WHERE DO WE KEEP PERSONAL INFORMATION AND WHAT ABOUT DATA TRANSFERS OUTSIDE QUEBEC?

Saturnia Holdings does not transfer or trade any of its data, whether confidential or not, outside the province of Quebec.

HOW DO WE PROTECT PERSONAL INFORMATION?

We follow the most rigorous and generally recommended industry standards to protect the information submitted to us, both at the time of transmission and once we have received it. We maintain appropriate physical, technical or administrative safeguards to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, misuse or other unlawful forms of processing of personal information in our possession. We have taken steps to ensure that the only employees who have access to your personal information are those who have a need to know or whose duties reasonably require them to know it.

However, no method of transmission over the Internet, nor any means of electronic storage, is 100% secure. We therefore cannot ensure or warrant the security of any information you transmit or provide to us, and you do so at your own risk. Nor can we guarantee that such information will not be accessed, obtained, disclosed, modified, or destroyed as a result of a breach of our physical, technical or administrative safeguards. If you have reason to believe that personal information has been compromised, please contact us at contact@saturniaholdings.com.

In the event of a privacy incident involving your personal information, we will notify you as soon as we become aware of the incident. We will take reasonable steps to minimize the risk of harm and to prevent similar incidents in the future.

WHAT RIGHTS DOES AN INDIVIDUAL HAVE WITH REGARD TO THEIR PERSONAL INFORMATION?

Under certain circumstances and in accordance with applicable data protection laws, an individual has the following rights:

A. Access: the right to ask whether we process information and, if so, to request access to personal information. Subject to applicable law and, where applicable, the payment of a monetary sum, the individual may thus receive a copy of the personal information we hold and certain other information concerning them;

B. Accuracy: we are required to take reasonable steps to ensure that personal information in our possession is accurate, complete, non-misleading and up to date;

C. Rectification: the right to request rectification of any incomplete or inaccurate personal information held by us;

D. De-indexing: the right to request that we cease disseminating their personal information or de-index any hyperlink attached to their name giving access to information if such dissemination causes them prejudice or contravenes the law or a court order (right to erasure or oblivion);

E. Anonymization: the fact that our organization may, instead of destroying it, anonymize personal information to use it, but only for serious and legitimate purposes (e.g.: keeping information required for possible tax inspection purposes) (It may be simpler to destroy it than to anonymize it);

F. The right to be informed when you are the subject of a decision based exclusively on automated processing;

G. The right to be informed when identification, location or profiling technology is used, and of the means available to activate these functions.

Finally, it is also possible to lodge a complaint with a data protection supervisory authority, more specifically in the country, province or state in which you normally reside (in Quebec, the Commission d’accès à l’information), in which we are located or in which an alleged breach of data protection laws has occurred.

To exercise any of these rights, please contact us at contact@saturniaholdings.com.

If you have an account or if you have left comments on our site or our social networks, you can request to receive a file containing all the personal data we hold about you, including that which you have provided to us. You can also request the deletion of your personal data. This does not include data held for administrative, legal or security purposes.

To obtain your data or to ask Saturnia Holdings to remove your personal information from our database, all requests must be made in writing.

Please contact our Privacy Officer by e-mail at: contact@saturniaholdings.com or by mail at the following address:

Saturnia Holdings

Att: Roberto Longo

Chief Financial officer

1751 Richardson Street, Suite 4.600,
Montreal, Quebec H3K 1G6

You may ask us to stop sending you marketing communications at any time by following the opt-out steps that appear on all messages sent to you, or by contacting us at any time. If you choose not to receive these marketing messages, we may continue to use your personal information to provide you with the services you have requested. Telephone requests will not be accepted or recorded.

CONFIDENTIALITY AND PRIVACY POLICY UPDATE

We regularly review our privacy practices. Saturnia Holdings reserves the right to modify or supplement its Confidentiality and Privacy Policy at any time. If changes are made to this policy, the revised policy will be posted on our website as soon as possible after the update.

This policy was last updated on September 22, 2023.