Privacy Policy

CLUB PISCINE is concerned about respecting your privacy and protecting your personal information. When you use our services, Club Piscine may collect, and you may provide, personal information. The purpose of this policy is to inform users of the services offered by Club Piscine about the following:

- How their personal data is collected and processed;

- What their rights are regarding their data;

- Who is responsible for processing the personal data collected and processed;

- To whom this data is transmitted;

- The use of "cookies" by Club Piscine on its websites.

In connection with the use of our services, CLUB PISCINE may collect and you may provide personal information. The collection, use, disclosure and retention of your personal information are subject to the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1).

Any information about a natural person that allows them to be identified is considered personal. Your personal information may include, but is not limited to, first and last name, date of birth, residential address, telephone numbers, gender, email address, information about your family situation, and the information you enter when you create a profile to subscribe to one of our services.

However, information concerning the exercise by the person concerned of a function within a company, such as their name, title and function, as well as the address, email address and telephone number of their workplace, will not be considered personal information.

We have established and implemented internal policies and procedures to adequately protect the personal information in our possession, regardless of its medium or form. We review them regularly.

We raise our employees' awareness of the importance of protecting personal information by requiring them to undergo training on this subject and by periodically issuing directives outlining their role and obligations in this regard.

As part of our duties, we collect your personal and confidential information only to enable us to provide you with the requested services in an adequate and personalized manner. In all cases, the communication of your personal and confidential information will be subject to obligations of confidentiality and compliance with applicable laws.

Subject to the exceptions and requirements of applicable laws, we will not communicate or disclose your personal information to any other third parties without your consent.

By using our services, you consent to the collection, use, and disclosure of your personal and confidential information in accordance with this policy. The form of consent may vary depending on the context or the service requested.

- A representative from our general management or a franchisee for contractual purposes

- A representative from our human resources department

- A representative from one of the services you wish to join

- A primary service provider in cases where Club Piscine acts as or retains the services of a subcontractor

You may withdraw your consent at any time, subject to certain legal or contractual restrictions.

In certain particular circumstances, we may collect, use, or disclose personal information without your knowledge or consent. Such circumstances arise, among others, when, for legal, medical, or security reasons, it is impossible or unlikely to obtain your consent, or when the information is necessary to investigate a possible breach of contract, to prevent or to

Before disclosing personal information to us concerning another person, you must obtain that person's consent regarding the disclosure and processing of such personal information under the terms of this policy.

Personal information concerning a minor under 14 years of age will not be collected from them without the consent of the holder of parental authority or the guardian.

We limit the collection, use, and disclosure of your personal information to the purposes we have indicated to you. Personal information is accessible to any person authorized to receive it within Club Piscine when such information is necessary for the performance of their duties.

If you submit personal information on one of our websites for publication, we will publish it and may use this information in accordance with the permissions you grant us.

- To provide the requested service;

- To confirm your identity and respond to your requests for information;

- To improve our service offering;

- To operate and improve the website and our solutions while understanding user usage patterns;

- To provide any other complementary service associated with the requested service;

- To comply with laws and regulations;

- To monitor the quality of customer service and prevent errors and cases of fraud;

- To send electronic communications, including newsletters, promotions, and updates from Club Piscine and its franchisees;

- To display personalized digital advertising on third-party platforms such as Meta and Google, based on your preferences and online behavior.

We may disclose your personal information to any of our employees, professional advisors, suppliers, or subcontractors or affiliates to the extent that this is reasonably necessary for the provision of the requested services and for the purposes set out in this policy.

Generally, we do not disclose your personal information. Occasionally, we may communicate your personal information to certain suppliers or agents in order to provide the services you have requested from us. In all cases, we comply with the restrictions and requirements provided by law when disclosing your personal information and this is, in certain circumstances, subject to a written agreement and a security assessment that demonstrates that your personal information benefits from adequate protection similar to that implemented within Club Piscine.

Your personal information will not be disclosed to third parties other than in accordance with this Privacy Policy, except as required or authorized by law, or as ordered by a competent court.

We do not sell your personal information to third parties.

A Privacy Impact Assessment (PIA) on the use of personal information by our services and/or systems is carried out before any personal information is collected by Club Piscine. When transfers are made outside of Quebec, the impact on such a transfer will also be assessed.

The information we collect may be stored, processed, and transferred in any country where Club Piscine or its subcontractors offer their services, in order to allow us to use the information in accordance with this policy.

The information we collect may be transferred or processed in the following countries: the United States of America and certain countries of the European Union.

Personal information you publish on our website or submit for publication may be available, via the Internet, worldwide. We cannot prevent the use, good or bad, of this information by third parties.

You expressly agree to the transfer of personal information described in this section.

We automatically collect certain non-personal information using third-party analytics programs such as Google Analytics to help us understand how our visitors use our web services, but none of this information can identify you. The following information may be collected, stored, and used:

- Information about your computer, including your IP address, geographical location, browser type and version, and operating system;

- Information about your visits to and use of our websites, including referrer source, length of visit, page views, and website navigation paths;

- Information generated while using our site, including when, how often, and under what circumstances you use it.

Club Piscine and affiliates' web services use "cookies." Cookies are small data files stored on your computer's or mobile device's memory when you visit a website or application. They are used to enhance your user experience by recording certain data. By using Club Piscine's web services, you consent to this use.

We use cookies for the following purposes:

a) Authentication: We use cookies to identify you when you visit and browse our website and web platforms. Cookies collected for these purposes are used for connection and session management.

b) Personalization: We use cookies to store information about your preferences and allow us to personalize the service according to your needs. Cookies used for these purposes serve to capture the language used on Club Piscine's websites.

In certain situations, it is possible that one of our services may be provided by one of our external suppliers, who may use cookies that will be stored on your computer or mobile device.

You can adjust your browser or device to refuse cookies or to delete them after they have been saved. Please refer to the "Help" section of your browser or device for instructions. Please note that deleting or refusing these cookies may negatively impact your user experience.

For more details, please refer to the cookie management policy available on our website.

When your personal information is no longer needed, it is destroyed in accordance with the law and our record retention policy. In certain circumstances, we may anonymize the personal information we hold.

Your personal and confidential information is retained, directly or through subcontractors, only for the duration necessary for the purposes of the services requested and to meet applicable legal and regulatory requirements. We require our subcontractors to adhere to confidentiality commitments and to apply policies equivalent to ours. In all cases, access to your personal and confidential information is restricted to individuals for whom access is required in the performance of their duties.

We are responsible for the personal information in our possession or under our custody, including information we entrust to third parties for the purpose of providing you with the requested service. We require these third parties to maintain this information according to strict confidentiality and security standards.

We adhere to the principles set forth by law. We have implemented policies and guidelines to ensure the protection of your privacy. The Privacy Officer oversees this Privacy Policy as well as the various frameworks within the company.

Our staff is informed and adequately trained on personal information protection policies and practices.

We have implemented several security measures regarding the personal information and confidential data we hold to protect them against loss, theft, and to prevent unauthorized access, transmission, use, or modification of this personal information, particularly through the following subsections:

CLUB PISCINE conducts a privacy impact assessment for any project involving the acquisition, development, or redesign of an information system or electronic service delivery that involves the collection, use, communication, retention, or destruction of personal information. This assessment documents the serious and legitimate interest in using personal information.

Infrastructure and equipment are hosted in a secure environment in a data center located in North America. In cases where it is not possible to host a solution or service in Quebec, we ensure that security measures equivalent or superior to those required by this Policy are implemented.

Access to Club Piscine's web services is via a secure transmission channel using an SSL certificate (HTTPS).

Only employees whose job duties require it have access to personal or confidential information. Data access is logged and monitored.

Our employees and partners are trained and made aware of the importance of protecting your personal information.

Our employees sign a confidentiality agreement. Security audits are carried out by firms specializing in information security.

CLUB PISCINE ensures the physical and technological security of the personal information it holds to prevent accidental destruction, loss, disclosure, and inappropriate destruction.

We retain your personal information for as long as necessary for the purposes for which it was collected. We must destroy or anonymize this information in accordance with the law and our retention schedule. When we destroy or anonymize your personal information, we take the necessary measures to ensure its confidentiality and to ensure that no unauthorized person can access it during the destruction or anonymization process.

If Club Piscine has reasonable grounds to believe that a confidentiality incident involving personal information has occurred and that there is a risk of serious harm resulting from the incident, Club Piscine will promptly inform the Commission d'accès à l'information (Access to Information Commission) as well as any individual whose personal information is affected by the incident. It may also notify any person or organization likely to mitigate this risk, by providing them only with the personal information necessary for this purpose without the consent of the person concerned. In all cases, a register will document the incident for reference purposes.

Subject to any regulatory or contractual restrictions, you may consult, correct, or destroy personal information we hold about you.

We will provide you with such information within a maximum of 30 days from the date of receipt of the written request and in a structured and commonly used technological format. However, fees may be charged to process your request.

In certain particular circumstances, we may refuse to provide you with the requested information. Exceptions to your right of access include the fact that the information cannot be disclosed for legal or security reasons.

These limitations are described in the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1).

You can verify the accuracy and completeness of your personal information and, if necessary, request its modification. Any modification request will be processed within the framework of the law.

The user has the right to request the portability of their personal data, held by Club Piscine, to another site.

The user has the right to request the restriction of or object to the processing of their data by Club Piscine, and Club Piscine may not refuse this request unless it can demonstrate legitimate and compelling grounds that override the user's interests, rights, and freedoms.

The user has the right not to be subject to a decision based solely on automated processing if the decision produces legal effects concerning them, or similarly significantly affects them.

We are committed to answering your questions and concerns regarding the protection of your personal information. If you are not satisfied with the answer, you can contact the Personal Information Protection Officer at the address mentioned below.

Any request or complaint regarding the protection of personal information must be sent to the Privacy Officer at the address listed below:

Privacy Officer CLUB PISCINE 888 Boul. Industriel Bois des Filion, Quebec, J6Z 4V1 Email: vieprivee@clubpiscine.ca

If the Club Piscine Privacy Officer decides not to respond to a user's request, and the user wishes to challenge this decision, or if they believe that one of their rights has been infringed, they are entitled to contact the Commission d'accès à l'information du Québec.

This Policy comes into effect upon its adoption by the Information Access and Privacy Committee and may be reviewed at any time by the Privacy Officer.

Amendments may be proposed by various Club Piscine stakeholders and must be submitted in writing to the Access and Privacy Officer.

CLUB PISCINE reserves the right to amend this Policy at any time. Any amendments will be published on Club Piscine's various web platforms. Your use of the services following the posting of amendments to the Policy constitutes acceptance of these amendments.

This Policy should be reviewed at least every two years to ensure its relevance given CLUB PISCINE's mission, user activities, and any substantial changes in legislation or regulatory requirements.

This Policy comes into effect on August 30, 2024. It supersedes and replaces all previous frameworks on this subject.