Confidentiality Policy

What is personal information ?

When used in this Policy and in accordance with canadian and provincial privacy legislation, the term "personal information" refers to "information that directly or indirectly identifies a person", which may include, for example, name, date of birth, mailing address, e-mail address, etc.

Gathering and verifying information

In order to serve its customers, Valfei Products Inc. collects personal information from them when they apply to open an account. This personal information may be transmitted to the customer's financial institutions and suppliers for credit references.

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In order to pay its suppliers doing business under their personal names, Valfei Products Inc. collects from them, at the time of account opening, the personal information required to open the account and pay invoices for products or services.

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In order to create a new employee's file and pay his or her remuneration, Valfei Products Inc. collects an individual's personal information at the time of hiring.

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When an Internet user accesses our Valfei Products Inc. website, his or her computer and our server automatically exchange data using cookies, which are files deposited on the Internet user's computer, telephone or tablet, enabling the user to be identified each time he or she connects. This exchange is necessary because of the technological requirements inherent in Internet browsing, and enables our server, among other things, to transmit a file compatible with the computer equipment used by the Internet user.

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Most information transmitted automatically between computers does not reveal the identity of the Internet user.

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Here are some of the data that are exchanged automatically to enable the website to function properly:

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• identification of the Internet service provider;

• the type of browser (e.g. Firefox, Explorer) and operating system (e.g. Windows, Mac OS) used;

• screen resolution, to enable the server to provide images and page layouts adapted to this resolution;

• etc.

In addition, our website uses the services of providers such as Google Analytics and Wix, to inform us about the use of our site. This information enables us to optimize our visitors' browsing experience and is used for statistical purposes. This enables us to identify the most frequently visited pages, the number of visitors, their country of origin, etc.

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Google Analytics and Wix also use cookies for this purpose. The information collected includes:

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• the user's IP address (numerical address that allows a computer connected to the Internet to be precisely located, e.g. 123.45.67.890);

• the address of the referring site, if the user accesses the site from another website;

• visited pages;

• the date and time the user accesses these pages;

• etc.

If you wish, you can block cookies that are not necessary for the proper operation of the website, via the cookie consent banner.

Use, disclosure and conservation

Personal information collected from customers and suppliers is retained for as long as the customer's account is active, and for a certain period of time after termination of the account, as provided by law or regulation. At the end of this period, if there is no dispute between the parties, the personal information is securely and irreversibly destroyed, so that it is no longer possible to identify the individual to whom the information relates.

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The same process applies to personal information collected from an employee. This personal information is retained for as long as the individual is employed by Valfei Products Inc. and for a period following termination of employment as provided by law or regulation, and at the end of that period, destroyed in a secure and irreversible manner, if there is no dispute between the two parties.

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Valfei Products Inc. offers Internet users the possibility of sending any questions or comments via the "Contact Us" page of its Web site. Internet users who choose to communicate with Valfei Products Inc. via this form must provide their name, e-mail address and telephone number (optional). This personal information is stored on our server for the sole purpose of responding to the user's questions or comments. Under no circumstances we will share or sell this personal information.

Liability

The Privacy Officer ensures that Valfei Products Inc. complies with and implements the principles and procedures set out in this Confidentiality Policy and its related documents. He or she also ensures that the Policy remains compliant with laws and regulations.

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All Valfei Products Inc. employees are bound by Valfei Products Inc.'s Policy and established procedures to ensure that the personal information of its customers, suppliers and employees remains confidential.

Accuracy

Valfei Products Inc. is committed to maintaining accurate records of the personal information of its customers, suppliers and employees. From time to time, Valfei Products Inc. will request updated documentation from individuals to ensure that personal information is complete and accurate.

Information protection

Valfei Products Inc. has implemented and continues to maintain stringent safeguards to ensure that personal information remains confidential and is protected against loss or theft, as well as unauthorized access or disclosure.

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Protection methods include restricted access to premises, as well as to physical and computer files.

Requests for access to information

Customers, suppliers, employees and Internet users have the right to ask to see the information held about them, how Valfei Products Inc. has used it and to whom it may have been disclosed.

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Questions regarding the Valfei Products Inc. Confidentiality Policy and the assurance of confidentiality of personal information, if any, collected from customers, suppliers, employees and Internet users may be directed to the following address:

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In writing: 

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VALFEI PRODUCTS INC.

c/o Privacy Officer

P.O. Box 80

Coaticook (Quebec)

J1A 2S8

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By e-mail:

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valfei@valfei.com

Complaints

Any complaints regarding the Confidentiality Policy should be sent to the above address.

Valfei Products Inc. will use reasonable efforts to process your complaint or request for information within 30 days of receipt.

Breach of confidentiality

Valfei Products Inc. has procedures in place to protect the personal information entrusted to it and to prevent breaches of privacy.

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Any breach of privacy should be reported promptly to the Privacy Officer at the above address. The Privacy Officer, in consultation with Valfei Products' legal counsel, will determine the appropriate course of action, which may also include the following security breach notifications (if applicable):

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• a report to the «Commission d'accès à l'information du Québec»;

• a notice to the people affected.

 Compliance

The Privacy Officer oversees the implementation of this Policy.

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He or she ensures that the Policy and related procedures are reviewed periodically to ensure compliance and effectiveness. In addition, the Privacy Officer will send a reminder of the Policy and related procedures to all employees at least once a year, or following any change, to ensure that they have adequate knowledge.

Summary in 3 points

. Valfei Products Inc. obtains consent before collecting, using or disclosing personal information;

. Valfei Products Inc. uses personal information only for the purposes for which it was collected;

. Valfei Products Inc. has implemented specific measures to ensure the protection of personal information collected.