Last update: 10, 2025

PRIVACY POLICY OF

Luminaires PauL Grégoire Inc.

Luminaires Paul Grégoire Inc. (“Luminaires Grégoire“, “we” or “us“) is committed to protecting the personal information we collect in the course of our business. This privacy policy (the “Policy“) describes in clear and simple terms how we meet our obligations to protect personal information and more specifically our practices regarding the collection, use, disclosure, retention and destruction of your personal information. Our Privacy Officer (the “Privacy Officer“), whose full contact details can be found in Section 10, is responsible for ensuring that the Policy is complied with and implemented.

In order to ensure the implementation of the Policy, please be assured that we have put in place internal practices concerning the management of your personal information. These practices include a framework on :

• The security of your personal information;
• Managing and preventing confidentiality incidents;
• Conducting privacy impact assessments; and
• Preserving your information throughout its life cycle.

Our Commitment to You is Clear:

• Be concise, clear and transparent;
• Obtain your consent where necessary;
• Allow you to exercise your rights with respect to your personal information; and
• Protect the confidentiality of your personal information.

Our Policy has been developed in accordance with applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, the Act respecting the protection of personal information in the private sector, C.Q.L.R., c. P-39.1 and other similar provincial legislation.

Content of the Policy

1. WHO IS OUR POLICY AIMED AT?
2. WHAT PERSONAL INFORMATION DO WE COLLECT AND FOR WHAT PURPOSES?
3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES?
5. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
6. TO WHOM MAY WE COMMUNICATE YOUR PERSONAL INFORMATION?
7. MAY YOUR PERSONAL INFORMATION BE DISCLOSED OR STORED OUTSIDE QUEBEC OR CANADA?
8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
9. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?
10. HOW TO CONTACT OUR PRIVACY OFFICER
11. POLICY UPDATE

1.              WHO IS OUR POLICY AIMED AT?

The Policy applies to personal information collected in the course of all our activities, with the exception of personal information collected in respect of our employees, former employees and applicants for employment with us. In particular, it applies to personal information collected when you visit our website https://luminairesgregoire.com/en/ (the “Website“), when you purchase products online or in-store, when you visit us in-store, or when you contact us by any other means of communication. The Policy therefore applies, for example:

• To our past, present and future customers;
• To all users of our Website;
• To everyone who contacts us.

Please note, however, that you are always responsible for protecting your personal information when you visit third party websites. Our policy does not apply to the collection, use, disclosure or retention of your personal information by other websites, although certain links on our Website may allow you to access the content of other third parties. We are not responsible for their privacy policies and encourage you to read their privacy notices or privacy policies.

This Policy does not apply to the personal information of our employees, former employees or candidates for employment with us, as another policy applies specifically to them and they can consult it by contacting the Privacy Officer.

2.              WHAT PERSONAL INFORMATION DO WE COLLECT AND FOR WHAT PURPOSES?

Personal information is any information relating to a natural person that directly or indirectly allows that person to be identified, whether this information is taken in isolation or in combination with other information. For greater clarity, personal information is any information that makes it possible to identify:

• a person directly, for example, an identifier such as a name, email address and government identification number; or
• indirectly through the combination of several specific elements specific to its physical, physiological, genetic, psychological, economic, cultural or social identity.

Please note that we only collect personal information necessary to provide you with our products and services. Below are the categories of personal information we collect and examples of each category. This information is all collected for a specific purpose detailed in the table below.

Generally speaking, we collect your personal information in order to offer you our products and services and to improve them. Except as provided by law, if we need to use your personal information for purposes other than those set out in this Policy, we will obtain your consent before using that information.

We collect your personal information, to the extent permitted by law, in order to:

2.1           To Identify or Authenticate You

When we want to register you as a new customer, we need certain information to identify you. This information will be used in particular to find your file and ensure that your details are associated with your account when you wish to benefit from our products and services.

In general, we collect identity and contact information for this purpose. Your information may also be used in certain cases to authenticate you, for example, to ensure that you are the right person when you wish to access your file.

2.2           To Provide You with Our Products and Services

When you do business with us, it is necessary for us to process some of your information in order to advise you appropriately according to your needs, to deliver your products, to answer your questions, to process your requests and to assist you in all your dealings.

2.3           Contact You

As part of our commercial relationship with you, we may contact you from time to time to inform you of important changes applicable to your products and services and to inform you of changes to our Policy.

In general, we collect identity and contact information for this purpose.

2.4           Managing Our Risks

As a business, we need to take a number of preventive measures to manage the risks associated with our activities, in order to avoid financial losses, operational breakdowns and internal and external fraud.

2.5           Meeting Our Legal and Regulatory Obligations

In the course of our business and due to the nature of our activities, we must comply with certain legal and regulatory obligations. We are therefore obliged to use your personal information in order to, for example:

• Comply with the applicable income tax acts;
• To defend itself in the event of legal claims or demands.

2.6           To Send You Advertising Offers, Promotions or Any Other Communication by Email, Mail or Telephone

In order to offer you a more personalized service, we may use your personal information to send you offers likely to meet your needs, our latest promotions, newsletters or surveys, for example.

In order to personalize these communications appropriately, we may analyze your personal information to avoid sending you communications that do not correspond to your expectations.

Please note that we will only send you these communications if you have chosen to receive them, where required by law, and that you may withdraw your consent at any time.

3.              HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Most of the time, we collect your personal information directly from you. However, in certain situations, we may collect your personal information from other sources, with your consent or as required by law:

• Other third parties, to help us serve or protect you, such as commercial partners;
• By analyzing your use of our products and services and our Website.

4.              DO WE USE COOKIES?

Cookies are files containing an identifier (a series of letters and numbers) sent by a web server to a web browser and stored by the browser. The identifier is then sent to the server each time the browser requests a page from the server. Although cookies do not generally contain any information that could personally identify a user, the personal information that Luminaires Grégoire stores about you may be linked to the information contained in or obtained from cookies.

Our service providers also use cookies which may be stored on your computer or device when you browse our Website.

You can set your preferences and manage the types of cookies you wish to allow by consulting our Cookie Policy available here.

Blocking access to all cookies will adversely affect the quality of use of several websites. If you refuse the use of all cookies, you may not be able to use all the functions of the service.

5.              HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We are committed to protecting personal information in our possession in accordance with applicable standards. To this end, we implement reasonable security measures to protect your personal information against loss, theft, unauthorized access, disclosure and unauthorized use. Our security measures are appropriate to the amount and sensitivity of the personal information.

Please note, however, that the transmission of personal information over the Internet is never completely secure. Although we take every precaution to protect your personal information, we cannot guarantee the security of personal information transmitted over the Internet. You choose to transmit information via this channel at your own risk.

If you believe that your personal information has been compromised or if you have any concerns in this regard, we invite you to contact our Privacy Officer using the contact details provided in Section 10.

6.              TO WHOM MAY WE COMMUNICATE YOUR PERSONAL INFORMATION?

Within our enterprise, access to your personal information is limited to those employees who need it to carry out their duties. These employees are made aware of the need to protect personal information, and policies are in place to ensure its protection.

However, in order to offer you affordable, quality products and services, we must communicate some of your personal information outside our enterprise. Rest assured that we require the third parties to whom we disclose your personal information to comply with the standards set by law and the security measures required to protect your personal information. We never sell your personal information and only disclose it in compliance with applicable privacy laws.

6.1           To Our Service Providers

In order to achieve certain objectives described in the Policy, we work with service providers to whom we may communicate or give access to your personal information when this is necessary for the performance of their service contract.

However, please be assured that we have put in place written contracts with our service providers in order, in particular, to:

• Guarantee the confidentiality of your personal information;
• Ensure that the information is only used to carry out the services;
• Ensure that the service provider does not retain any personal information when it is no longer required for the performance of the services, with the exception of information contained in backup systems, which will be deleted according to the deletion cycle predetermined by the service provider;
• Ensure that the service provider contacts us immediately in the event of a confidentiality incident or attempted incident.

The categories of service providers we work with are as follows:

• Cloud hosting service;
• IT and technical services;
• Online shopping platform;
• Platform offering payment services.

6.2           Courts, Law Enforcement Authorities, Regulators, Government Officials or Prosecutors

Specifically, we may disclose your personal information to comply with a search warrant, to respond to an investigative body, to comply with a court order, if we believe disclosure is necessary to comply with applicable laws, if required by law, to respond to a legal claim or to assert a defence.

6.3           To Other Third Parties

We may disclose your personal information to other third parties in certain specific circumstances, always within the limits authorized by law or after obtaining your consent, for example:

• As part of a commercial transaction (merger, acquisition by another company, obtaining a loan or financing, for example).
• In the event of insolvency or bankruptcy.

7.              MAY YOUR PERSONAL INFORMATION BE DISCLOSED OR STORED OUTSIDE THE PROVINCE OF QUÉBEC OR CANADA?

Yes. The subcontractors with whom we do business and other third parties to whom we disclose your personal information may carry out their activities or have access to your personal information outside Québec and Canada.

In all cases where we disclose your personal information outside Québec or Canada, we ensure that your personal information is handled securely and in accordance with this Policy, and that there is a written agreement with the third party regarding the handling of your personal information. In addition, before disclosing your personal information outside Québec, we conduct a privacy impact assessment to evaluate, among other things, the risks inherent in disclosure as well as the legal regime applicable in the state where your information would be disclosed.

We will not disclose your personal information unless we are satisfied that it will be adequately protected.

8.              HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

The personal information we collect is retained only as long as necessary for the purposes set out in Section 2 of this Policy and to comply with our legal and regulatory obligations. We have implemented internal procedures and policies to ensure that your personal information is subject to a specific retention schedule and that it is securely destroyed or, where permitted by privacy laws, made anonymous at the end of that period. If the information has been rendered anonymous, it is no longer possible to identify you directly or indirectly, as this is an irreversible process.

If you have any questions about the retention of your personal information, please contact our Privacy Officer using the contact details provided in Section 10.

9.              WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

9.1           Access to Your Personal Information

Subject to the exceptions provided by law, you have the right to request a copy of, or access to, the personal information we hold about you. At your request, we will confirm the existence of the personal information, disclose it to you and allow you to obtain a copy. At your request, computerized personal information will be provided to you in the form of an intelligible written transcript. If you have certain limitations, reasonable accommodation will be provided on request to enable you to exercise your right of access under this section. You may exercise your right of access by contacting our Privacy Officer using the contact details set out in Section 10. Please also note that:

• Access to your personal information is free of charge. However, in certain circumstances, for example, if the request is excessive or unfounded, we may charge an administrative fee for transcribing, reproducing, transmitting or requesting additional copies of your personal information. We will inform you of any such charges before processing your request;
• We generally respond to all requests for access within 30 days of receiving the necessary information. If we are unable to grant access or if additional time is required to respond to a request, we will inform you in writing;
• Unless this raises serious practical difficulties, computerized personal information collected from you which is not created or deduced from personal information about you will be communicated to you, at your request, in a structured and commonly used technological format. It will also be communicated, at your request, to any person or body authorized by law to collect such information.

9.2           Rectifying Your Personal Information

If you believe that your personal information is inaccurate or incomplete, you may rectify it by contacting our Privacy Officer using the contact details provided in Section 10. It is your responsibility to inform us of any changes to your personal information so that we can ensure that your personal information is kept up to date.

9.3           Obtain Information on the Processing of Your Personal Information

You have the right to obtain further information about the processing of your personal information. If you do not find the answer to your questions in the Policy, you can contact our Privacy Officer using the contact details provided in Section 10.

9.4           Withdraw Your Consent

When you give your consent for secondary purposes, i.e. purposes that are not essential for offering you our products and services, you may withdraw it at any time, without any consequences.

However, if you refuse to provide us with personal information that is necessary for us to offer you our products and services or that is required by law, we may no longer be able to provide you with some of our services. In this case, we may have to cancel our commitment with you. You will, however, be informed of the occurrence of such a situation.

9.5           Dissatisfaction with the Management of Your Personal Information

If you have any questions, concerns or dissatisfaction about this Policy or the processing of your personal information, or if you wish to lodge a complaint, you can contact our Privacy Officer using the contact details given in Section 10.

10.           HOW TO CONTACT OUR PRIVACY OFFICER?

The protection of your personal information is important to us. We have appointed a Privacy Officer who is responsible for ensuring compliance with and implementation of the applicable legislation on the protection of personal information and acts as the person responsible for the protection of personal information. You can contact her using the following details:

Ms. Johanne Grégoire,
Privacy Officer and President, General Manager
4820 Route 132 Sainte-Catherine (Québec) J5C 1V9 Canada

Phone: (450)-638-3866
Email: vieprivée@paulgregoire.com

11.           POLICY UPDATE

This Policy takes effect on the date mentioned at the top of the page and replaces all previous versions. The history of previous versions of the Policy may be obtained upon request from our Privacy Officer.

The Policy may be updated at our sole discretion to reflect changes in our practices and in privacy legislation. When the Policy is updated, the changes will be specifically brought to your attention and a notice will be available on the home page of our Website. Where the changes are material or require your consent, we will notify you by email if we have your email address.