PRIVACY POLICY

ARTICLE 1 — PURPOSE

This Privacy Policy describes Carnet Top’s practices regarding the collection, use, retention, disclosure and protection of personal information of platform users.

Carnet Top recognizes the importance of privacy and is committed to protecting the personal information entrusted to it.

ARTICLE 2 — SCOPE

This policy applies to all users of the Carnet Top platform, including:

• members;
• visitors;
• partner merchants;
• registration applicants;
• users of online services.

It applies to all personal information collected by Carnet Top, whether through the website, an application, an electronic form, email or any other communication.

ARTICLE 3 — DEFINITIONS

For the purposes of this policy:

Personal information: any information that allows a person to be identified directly or indirectly.

User: any person who visits or uses the Carnet Top platform.

Member: a user who has created an account.

Partner merchant: a business participating in the Carnet Top program.

Person responsible for the protection of personal information: the person designated by Groupe Maserdan Inc. to ensure compliance with this policy and applicable laws.

ARTICLE 4 — PERSON RESPONSIBLE FOR THE PROTECTION OF PERSONAL INFORMATION

The person responsible for the protection of personal information is designated by Groupe Maserdan Inc.

Any request relating to the protection of personal information may be sent using the contact details indicated in the “Contact us” section.

ARTICLE 5 — OUR PRINCIPLES

Carnet Top applies the following principles:

• transparency;
• confidentiality;
• security;
• minimization of information collected;
• accuracy of information;
• use limited to stated purposes;
• accountability.

We collect only the information necessary to administer the platform and the rewards program.

ARTICLE 6 — INFORMATION COLLECTED

Depending on your use of the platform, Carnet Top may collect, among other things:

Identification

• first name;
• last name;
• mailing address;
• city;
• province;
• postal code.

Contact details

• email address;
• phone number.

Account

• username;
• password (encrypted);
• registration code;
• account creation date.

Rewards program

• number of points;
• points history;
• gifts claimed;
• discounts used;
• transaction history.

Technical data

• IP address;
• browser used;
• device type;
• operating system;
• pages viewed;
• date and time of visits;
• connection logs.

ARTICLE 7 — COLLECTION OF INFORMATION

Personal information is collected, among other things, when you:

• create an account;
• use a registration code;
• take part in a game;
• claim a gift;
• claim a discount;
• contact our customer service;
• fill out a form;
• subscribe to the newsletter;
• take part in a survey or promotion.

We may also collect certain information automatically during your browsing through cookies.

ARTICLE 8 — USE OF INFORMATION

Personal information is used only for the following purposes:

• administer your account;
• manage your membership;
• calculate and award points;
• confirm claims;
• transmit information required by partner merchants when needed to deliver a reward;
• communicate with you;
• prevent fraudulent activities;
• improve the platform;
• comply with legal obligations.

Carnet Top does not sell its members’ personal information.

ARTICLE 9 — CONSENT

By creating an account or using Carnet Top services, you consent to the collection, use and disclosure of your personal information in accordance with this policy.

Where required by law, separate consent may be requested for certain specific uses.

You may withdraw your consent in the cases provided by law, subject to consequences that may affect certain services.