At Groupe Trium Inc, we are committed to protecting your privacy and applying strict practices regarding the handling of personal information. This Privacy Policy (the "Policy") complies with current legislation on the protection of personal information. This Policy covers the personal information we collect, use, and share as part of our business activities. It does not apply to personal information about our employees or job applicants, nor to data not considered personal.

Here, we explain:

• The information we collect and why,
• With whom we share it,
• How we protect it.

The designated Privacy Officer (PO) is Stéphane Busilacchi, Director of Operations and Customer Service: confidentiality@groupetrium.com.

2. DEFINITION OF PERSONAL INFORMATION

Personal information refers to data that identifies an individual. This Policy does not apply to anonymous, aggregated, or non-identifiable data.

3. YOUR CONSENT

We collect, use, and disclose your information with your consent or as permitted by law. By providing us with your data, you agree to its use for the purposes described in this Policy. In certain cases, we may be legally required to use or disclose your information without consent (e.g., legal obligations, government investigations, debt collection). You may withdraw your consent at any time, subject to contractual and legal restrictions. However, this may limit our ability to provide certain services to you.

4. PURPOSE OF COLLECTING INFORMATION

We collect information to:

• Manage our business activities and identify you,
• Provide our products and services,
• Comply with our contractual and legal obligations.

5. INFORMATION COLLECTED

We collect, among other things:

• Name, address, email, phone number,
• Payment information,
• Data on your interactions with Groupe Trium Inc,
• Information from public or third-party sources,
• Automatically collected data from our website (see Cookies).

We retain this data for the period required by law and our Retention and Disposal Schedule for Personal Information.

6. USE OF INFORMATION

We use your information to:

• Manage your accounts and transactions,
• Contact you about our products and services,
• Protect against fraud and unauthorized access,
• Conduct internal analysis and audits.

7. INFORMATION SHARING

We may share your information:

• With service providers under contract,
• To comply with legal or regulatory obligations,
• With your consent or as permitted by law.

We only share this information with government agencies that have legitimate authorization.

8. USE FOR MARKETING PURPOSES

With your consent, we may use your information to:

• Identify your preferences,
• Determine your eligibility for special offers and discounts,
• ontact you about these offers and promotions.

You can unsubscribe from our marketing emails by clicking the unsubscribe link at the bottom of the message. Please note that even if you unsubscribe from marketing communications, we may still send you information related to your account or Groupe Trium Inc products and services.

9. COOKIES AND SIMILAR TECHNOLOGIES

When you visit the Groupe Trium Inc website, we may collect and use your Internet Protocol (IP) address to diagnose server issues, administer our website, identify users and their activities, and gather general demographic information. We may also collect website page choices, browser type, operating system, and time spent on the site to enhance your experience. We use cookies, a technology that installs a small amount of information on a user's computer, to allow our website to recognize future visits using that computer and to avoid requiring login information for each visit. Cookies improve the convenience and usability of our website.

10. PROTECTION OF INFORMATION IN CANADA

We take reasonable measures to maintain the security, integrity, and confidentiality of your information and to prevent it from being altered, damaged, or accessed by unauthorized parties. We also ensure that our employees handle your information with care at all times.

We use strict security measures, including:

• Data encryption,
• SSL protocols, firewalls, and two-factor authentication,
• Regular monitoring of our systems,
• IT backups,
• Firewalls.

We are committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure the security of your transactions. However, no method of Internet transmission or electronic storage is 100% secure. In the event of an unforeseen incident, such as a data breach or harm caused by malicious actors, we have procedures in place to identify, assess, and mitigate any additional risks and determine whether there is a real risk of significant harm to affected individuals.

11. PROTECTION OF CROSS-BORDER INFORMATION

Your data may be processed outside of Canada (e.g., USA, EU). We require our partners to provide the same level of protection as applied in Canada.

12. ACCESS, CORRECTION, AND COMPLAINTS

You have the right to access, modify, or delete your information. For any request: Groupe Trium Inc 9031 avenue du Parc, Montréal (QC), Canada, H2N 1Z1 confidentiality@groupetrium.com

For any questions, complaints, or requests regarding privacy, please contact us at confidentiality@groupetrium.com.