PRIVACY AND PERSONAL INFORMATION PROTECTION POLICY

 

Approved by the Board of Directors and the Privacy Officer

 

Mont Expérience Hereford Inc. recognizes the importance of privacy, security, and the protection of personal information.

 

This Privacy and Personal Information Protection Policy (“Policy”) is intended to inform you of Mont Expérience Hereford Inc.’s practices regarding personal information governance. It also aims to outline the security of personal information that is collected, held, used, disclosed, and retained.

 

The Policy applies to all employees of Mont Expérience Hereford Inc., its clients, suppliers, and business partners who may have access to personal information in the course of performing their duties.

 

In this Policy, the term “client” refers to clients of Mont Expérience Hereford Inc. who temporarily rent camping sites or ready-to-camp units offered by Mont Expérience Hereford Inc.

1. General Principles of the Policy

Mont Expérience Hereford Inc. implements security measures to ensure the protection of personal information that is collected, held, used, disclosed, retained, or destroyed, which are reasonable considering, among other things, the sensitivity, purpose, quantity, distribution, and medium of the information, including by ensuring the following:

• Integrity of information, so that personal information is not destroyed or altered without authorization or in violation of applicable laws, and the medium provides stability and durability;

• Confidentiality, limiting disclosure to authorized persons only, either externally according to client agreements or internally when necessary for employees to perform their duties;

• Identification and authentication, to confirm, when required, a person’s identity or the authenticity of a document;

• Compliance with applicable legal, regulatory, or business requirements to which Mont Expérience Hereford Inc. is subject.

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2. Objectives of the Policy

The objectives of this Policy are to:

• Define the types of personal information collected, used, disclosed, and retained by Mont Expérience Hereford Inc.;

• Define the methods used to protect this information;

• Specify standards for use, retention, disclosure, and destruction of personal information;

• Determine the rights of access, correction, and deletion of personal information, regardless of its medium or form, whether written, graphic, audio, visual, computerized, or otherwise;

• Establish the roles of individuals involved, including the Privacy Officer.

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3. Definition of Personal Information

For the purposes of this Policy, “personal information” means any information about an identifiable individual that is not publicly available under the applicable private-sector privacy laws.

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4. Types of Personal Information Collected

Mont Expérience Hereford Inc. offers short-term rentals of camping sites and ready-to-camp units. In connection with these activities, personal information collected, used, disclosed, and retained may include, but is not limited to:

• Contact information such as full name, street address, email address, IP address, phone number;

• Billing information such as billing address, bank details, credit card number, or payment system data;

• Information related to the use of Mont Expérience Hereford Inc.’s services, including technical or connection data (cookies) from website visits or other similar tools;

• Any other personal information reasonably required that may be requested and provided.

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5. How Personal Information is Collected

Mont Expérience Hereford Inc. collects personal information from clients and, if applicable, third parties, in person, via secure file/data sharing platforms, email, forms, or by phone. At the time of collection, Mont Expérience Hereford Inc. provides clear and simple information, including:

• The name of Mont Expérience Hereford Inc.;

• The purposes for which the information is collected;

• The means by which the information is collected;

• Access and correction rights under the law;

• The right to withdraw consent for the use or disclosure of collected information;

• The name of the third party for whom collection is conducted, if applicable;

• The name of third parties to whom personal information may need to be disclosed, if applicable.

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6. Consent to Collection

Mont Expérience Hereford Inc. is responsible for collecting personal information with the client’s prior, free, and informed consent by clearly disclosing the purposes for which the information is collected. Consent is obtained through a detailed consent form written in simple, clear language.

In compliance with applicable laws, Mont Expérience Hereford Inc. will obtain separate consent before using personal information for purposes incompatible with those for which it was originally collected.

Any individual may withdraw consent at any time for the collection, use, disclosure, or retention of their personal information by contacting Mont Expérience Hereford Inc.’s Privacy Officer. Upon receipt of such notice, Mont Expérience Hereford Inc. will cease processing the personal information and securely destroy it, subject to any legal or regulatory retention requirements.

Mont Expérience Hereford Inc. will also notify any persons or entities to whom such personal information was disclosed so they may cease processing and securely destroy it, as applicable, subject to legal or regulatory retention obligations.

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7. Use of Collected Information

Mont Expérience Hereford Inc. uses personal information to provide safe camping site and ready-to-camp rentals, in compliance with applicable laws and safety rules, specifically for the following purposes:

• Verify client identity;

• Communicate with clients and employees;

• Provide rental services for camping sites and ready-to-camp units;

• Generate and process invoices and account statements;

• Manage client reservations;

• Share personal information with third parties when necessary to fulfill the rental service agreement;

• As permitted or required for any legal or regulatory obligation;

• Assert legal rights, if applicable;

• Any other purpose consented to by the individual.

Mont Expérience Hereford Inc. uses personal information solely for the purposes listed above. Unless specifically consented to, Mont Expérience Hereford Inc. does not disclose, sell, rent, give, exchange, share, or release personal information to third parties.

This information is accessible only to employees who need it to perform their duties, and they are required to maintain confidentiality.

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8. Disclosure of Personal Information to Third Parties

Mont Expérience Hereford Inc. requires consent from the individual before disclosing personal information to a third party, unless permitted by law without consent.

Mont Expérience Hereford Inc. and its suppliers may be required to provide personal information due to a court order, administrative investigation, or other legal situation.

In the event of a potential business restructuring, Mont Expérience Hereford Inc. may disclose personal information to potential or existing buyers and their advisors, subject to prior written confidentiality agreements.

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9. Retention and Security of Personal Information

All personal information, regardless of medium, is stored in a secure environment against unauthorized physical or technological access, disclosure, copying, use, or modification, as well as loss or theft. Security measures include, where applicable, firewalls, secure servers, encryption, access management systems, and other measures necessary to ensure protection against unauthorized use or disclosure.

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10. Destruction of Personal Information

Personal information is retained only for the period necessary to fulfill the purposes for which it was collected and is then securely destroyed. Personal information may be retained beyond this period only if legally required. Destruction will be secure and irreversible in accordance with applicable laws.

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11. Responsibility of the Person Providing Information

Clients providing personal information to Mont Expérience Hereford Inc. are responsible for its accuracy. Clients must ensure the system or equipment used to transmit or receive information is secure. Mont Expérience Hereford Inc. is not responsible for unauthorized access resulting from client negligence or equipment/system vulnerabilities. In the event of a breach or identity theft, clients must promptly notify Mont Expérience Hereford Inc. by contacting the designated Privacy Officer.

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12. Access and Correction Rights

Any individual may request access to their personal information held by Mont Expérience Hereford Inc. They may also request correction of any personal information. Requests are submitted to the Privacy Officer at the contact details below. Rights of access and correction are exercised in accordance with applicable law, within prescribed timelines, and subject to applicable limitations.

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13. Complaint Handling

Anyone wishing to file a complaint regarding the collection, use, disclosure, retention, destruction, or access and correction rights of their personal information should contact Mont Expérience Hereford Inc.’s Privacy Officer. Mont Expérience Hereford Inc. will respond within thirty (30) business days of receipt.

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14. Data, Cookies, and Privacy Settings

Mont Expérience Hereford Inc. collects connection cookies on its website to ensure proper management and provide a consistent, efficient, and personalized experience.

A cookie is a small data file stored on the user’s computer or mobile device. A consent banner appears upon visiting the website, allowing users to enable cookies. Refusing cookies may affect some website services. Cookies are categorized into four (4) types:

• Necessary cookies;

• Functionality cookies;

• Performance cookies;

• Tracking cookies.

By providing personal information under this section, users consent to its use and disclosure for the stated purposes.

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15. Policy Publication

Mont Expérience Hereford Inc. publishes this Policy on its website and distributes it by any means likely to reach affected individuals. The same applies to any updates to this Policy.

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16. Incident Reporting

In the event of a personal information protection incident, Mont Expérience Hereford Inc. will take measures to minimize risk and prevent similar future incidents.

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17. Incident Log

Mont Expérience Hereford Inc. maintains a log of all privacy incidents, even those posing no serious risk. This log is available for review by the Commission d’accès à l’information and may be provided upon request.

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18. Roles and Responsibilities

The Secretary of Mont Expérience Hereford Inc. serves as the Privacy Officer and can be reached at: montexperiencehereford@gmail.com or 819-349-8222.

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Effective Date: This Policy comes into effect on the day it is adopted by the Board of Directors of Mont Expérience Hereford Inc.

November 14, 2023

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