Effective date: 2026-01-01

1.      General Information

a) Introduction

Purpose of this Policy. Privacy is important to POL R Enterprises Inc., POL R International Holding inc and its entities (hereinafter collectively referred to as the "Organization," "We," "Us," "Our"). For this reason, We have implemented safeguards and sound management practices for Your Personal Information in accordance with applicable laws in Quebec and Canada.

Supplemental to the Terms and Conditions. This privacy policy (the "Policy"), which should be read in conjunction with Our Terms and Conditions, describes Our practices regarding the collection, use, processing, disclosure, retention, and destruction of Personal Information of individuals who use Our Services, visitors to this Website, and its users (hereinafter "You," "Your," "Yours").

Consent. By using any of Our Websites https://www.polrcorp.com/, https://www.polrinsulations.com,   https://www.artikoem.com/, https://www.mecart-cleanrooms.com/ and https://mecart.com/ (hereinafter collectively referred to as the "Website") or any of Our Services, You agree that We may collect, use, , communicate, disclose, and retain (hereinafter "Process" or "Processing") Your Personal Information in accordance with the terms described herein. If You do not agree to comply with and be bound by this Policy, You are not authorized to visit, access, or use Our Website or Our Services, or share Your Personal Information with Us.

Limitations of the Policy. This Policy does not apply to the Personal Information of employees, representatives, and consultants of the Organization, or any other person affiliated with the Organization, as well as any information that does not constitute Personal Information as defined by applicable laws in Quebec and Canada.

b) Personal Information Protection Officer

Contact information for the Privacy Officer. Any comments, questions, or complaints regarding the Organization's privacy policy and practices may be directed to our Privacy Officer at the following contact information:

Phone:                (418) 872-4615

Email:                  confidentiality@polrcorp.com

Address:              5085 Rideau Street Quebec City, Quebec G2E5H5 Canada

2.      Definitions

Definitions of certain terms and expressions. The following terms and expressions, when appearing with a capital letter in the Policy, have the meanings assigned to them below, unless there is an implicit or explicit exception in the text:

"Organization," "We," "Us," "Our": POL R Enterprises Inc. and its entities.

"Service Provider": any natural or legal person who processes Personal Information on behalf of the Organization. These are third-party companies or individuals employed by the Organization to facilitate the Services, provide the Services on behalf of the Organization, perform Services related to the Services, or assist the Organization in analyzing the use of the Services.

"Cookie Banner": a pop-up window requesting Your consent to certain collections of Your Personal Information on the Website.

"Personal Information": any information that relates to a natural person and allows that person to be identified, i.e., that directly or indirectly reveals something about the identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental abilities, character, and behavior of the person concerned) or the activities of that person, regardless of the nature of the medium and regardless of the form in which this information is accessible (written, graphic, audio, visual, computerized, or other).

"Personal Information Protection Officer": the person responsible for the application of this Policy, whose contact information is identified in section 1b) of this Policy.

"Services": Services refers to the Website applications, our social media pages, and all programs and Services provided to you therein, such as:

·        Contact forms: allow users to contact the team directly for any information or Service requests.

·        Online quote: users can request a quote for products or Services via the dedicated form.

·        Careers: Job opportunities are posted online, and candidates can apply directly via the site.

·        Social media: We use our social media pages to share information about our products, Services, news, and career opportunities.

"Website": This website, i.e., https://www.polrcorp.com/, https://www.artikoem.com/, https://www.mecart-cleanrooms.com/  or https://mecart.com/.

"Cookie": Cookies are text files that are installed on your computer or mobile device. These cookies may contain information about your search history, the web pages you visit, and your web browser.

"Process," "Processing": A concept encompassing all operations that may affect or concern Personal Information, including: collection, use, storage, destruction, disclosure, or transmission.

"You," "Your," "Yours": Persons benefiting from Our Services, visitors to the Website, and all users who use the Organization's Services.

3.      Processing of Personal Information

3.1  Collection of Personal Information

3.1.1        Means of collection

Various means. We collect Your Personal Information through Our Website or other technological means in various ways, either:

-       Automatically. When You connect to Our Website, the device You use to connect will provide Us with Personal Information;

-       Electronic forms. When you fill out one of our electronic forms, or when you apply online;

-       Emails sent. Through emails You send to Us using one of the email addresses available on Our Website;

-       Cookies. Through cookies, including the cookies identified in the Cookies and Other Similar Technologies section.

-       Partners. Through third parties who collect your Personal Information for us, as identified in the Third-Party Collection of Personal Information section of this Policy.

Profiling, identification, or location. Our Website has features that allow us to profile your activities on our Website, identify you, and locate you. These features are used by third parties identified in the section Access, Communication, and Transfer of Personal Information through Cookies. We disable these features by default. You can enable them through the Cookie Banner.

3.1.2        Personal Information Collected

Categories of information collected. In the course of Our activities, We may collect and Process various types of Personal Information, including the information listed below:

-       Identification information and Your contact details, including Your first and last name, postal address, email address, company name, and telephone number. These details are generally of a professional nature, as the forms available on Our website often request contact information related to a company. However, in some cases, Personal Information may be required.

-       Information to be provided in our online forms:

o   Online submission: We collect information such as Your personal and professional contact details, technical details, documents to be uploaded, and other related information.

o   Career opportunities: We collect information such as Your resume, cover letter (if applicable), personalized message, and Your personal contact information. This data allows us to evaluate Your application and determine Your suitability for available positions within our company.

-       Technical or digital information, including connection information and other information about Your activities on the website, such as Your IP address, browser and operating system configuration, mobile device configuration (if applicable), geographic location and location data, pages visited, products viewed, path taken on the website, keywords used in a search, date and time of visit. This information is generally collected via tools such as cookies while browsing the website.

-       Information related to cookies, used to improve website performance and user experience. Some cookies are automatically deleted when a user closes their browser, while others are stored indefinitely. The use of cookies is required for certain features, such as user authentication for certain Services offered through the website.

-       Information that you choose to provide or send to us, for example, when you fill out a form on our website, make a request via our contact form, or communicate with a member of our staff.

Limitation of Processing to Necessary and Legitimate Purposes. In each case, this Personal Information is processed in accordance with the legitimate and necessary purposes listed in the Use of Personal Information section below.

3.2  Collection of Personal Information by a Third Party

Third Parties Collecting Personal Information on Our Behalf. When You use the Services of Our Suppliers, they may collect certain Personal Information.

-       Recruitment platforms: We collect Personal Information related to Your application through recruitment platforms such as Jobillico, LinkedIn, and Indeed. Personal Information collected on these platforms may also be accessible to these Providers.

-       Partner recruitment agencies: We work with recruitment agencies that may send Us Your Personal Information for the purposes of evaluating Your application and managing the recruitment process.

-       Surveillance cameras: For security and prevention purposes, we use Providers specializing in surveillance camera systems, including their recording software, to enable the viewing of captured images.

For more information about our Suppliers, please refer to the Access, Disclosure, and Transfer of Personal Information subsection of this Policy.

3.3  Refusing collection

Refusing to consent. Unless otherwise provided by law or Your contractual obligations, You may refuse or withdraw Your consent to certain specific uses or disclosures of Your Personal Information:

-       by not entering Your Personal Information in Our electronic or paper forms when the disclosure of such information is indicated as optional.

-       by selecting "decline" in the Cookie Banner (cookie manager).

-       by sending a request to Our Privacy Officer at the contact information identified in section 1b) of this policy.

Measures available to refuse means of collecting Personal Information. You may also provide Us with Your Personal Information by means other than technological means such as Our Website. You may provide Us with this information by email, telephone, or in person.

3.4  Use of Personal Information

Purposes of Personal Information. We may use Your Personal Information for the purposes described below:

-       Service Management: to operate, maintain, develop, and improve Our Website and Our Services (as described in the Definitions section); to provide You with Our Services and respond to Your inquiries; to perform Our contractual obligations; to manage billing and payments.

-       Customer Support and User Experience: Handle complaints and dissatisfaction; offer You personalized recommendations based on Your purchase profile.

-       Business Development and Advertising: developing and offering new Services; conducting marketing and business development activities (with Your prior consent); organizing or participating in events, conferences, trade shows, or promotional activities. At these events, certain Personal Information may be requested for professional purposes, such as for the creation of identification cards. This information may also be retained by the Organization for contact, follow-up, or professional reference purposes, in accordance with this Policy.

-       Analytics and security: conducting research, analysis, and statistics; detecting and preventing fraud, errors, spam, abuse, security incidents, and other harmful activities.

-       Legal compliance: for any other purpose required or permitted by applicable laws.

3.5  Access, Disclosure, and Transfer of Personal Information

Possible access and communications. We may transfer, communicate, or allow access to Your Personal Information to Our employees and Our Service Providers, who need this information to help Us operate Our Website, perform Our Services, carry out Our activities, or serve You.

3.5.1        Access to Personal Information within the Organization

Limitation of Access to Personal Information. Your Personal Information collected is accessible to administrators, employees, and representatives whose duties require access to perform their tasks. As such, your information may be accessible to our Privacy Officer, as well as to the IT, Sales, Human Resources, and Customer Service departments.

3.5.2        Communication of Personal Information

Protective Measures When Disclosing to Third Parties. We only disclose your Personal Information to our Service Providers if they have first agreed in writing to keep your Personal Information confidential in accordance with applicable laws and our Information Governance Program by implementing various protective and information governance measures. These measures are proportional to the sensitivity of the Personal Information processed or disclosed. Without limitation, Our Service Providers may only use Your Personal Information confidentially in accordance with Our instructions and solely for the purposes for which it was provided. In addition, We only provide Our Service Providers with the Personal Information necessary to perform their mandate or contract, and We require these Service Providers to destroy Personal Information in an appropriate manner upon termination of the contract or as soon as its use is no longer necessary. 

Our Service Providers. Although We try to avoid disclosing Your Personal Information to third parties, We may use Service Providers to perform various Services on Our behalf, such as IT management and security, marketing, and data analysis, hosting, and storage. We have outlined below certain instances in which such sharing may occur:

-       We use Google Analytics and Doubleclick cookies to analyze website traffic and compile statistics. In addition, we use Google Ads to analyze traffic to our services, compile statistics, and communicate with customers and prospects. Finally, we use YouTube to showcase our products and Services. For more information, please refer to Google's privacy policy and their table of cookies used for advertising and measurement (in English only).

Please note that these cookies may collect personal information that can locate You and profile Your web activities (targeted advertising). These cookies communicate personal information to Google for the purposes identified in the section Cookies and other similar technologies of this policy.

-       We use several social media platforms to share content, for recruitment purposes, and to keep You informed of the latest news from the Organization. For more information, please consult their privacy policies:

o   LinkedIn: Privacy Policy.

o   Meta: Privacy Policy.

o   Indeed: Privacy Policy.

o   Jobillico: Privacy Policy.

Please note that their cookies may identify You and profile Your web activities in order to provide You with advertising that matches Your interests (targeted advertising). These cookies share personal information with these third parties for the purposes identified in the Cookies and Other Similar Technologies section.

-       We use the Services of various providers to manage and view Our surveillance cameras installed on Our premises for security purposes. Please consult their privacy policies.

-       We use the services of consulting firms, such as lawyers or accountants, to meet Our legal and regulatory obligations.

-       We use Meta (Facebook Pixel) services to understand and deliver ads, compile statistics, and communicate with customers and prospects. For more information, please consult Meta's privacy policy.

Please note that this Cookie may identify You and profile Your activities on the web in order to provide You with advertising that matches Your interests (targeted advertising). This Cookie shares Personal Information with these third parties for the purposes identified in the Cookies and Other Similar Technologies section.

-       We also use partner recruitment agencies, to whom we disclose Your Personal Information to evaluate Your application and manage the recruitment process.

-       We use the Services of several Providers for document destruction.

All categories of Personal Information identified in the Personal Information Collected subsection may be shared or stored through this Service.

-       We use various software and platforms for account processing, invoicing, and administrative operations.

-       We use the services of information technology firms, in particular for hosting Our data, managing Our servers, and providing IT support.

All categories of Personal Information identified in the Personal Information Collected subsection may be disclosed or retained through this Service.

-       We use Microsoft Services (Office 365) to store Our documents and emails. For more information, please refer to Microsoft's  privacy policy. 

All categories of Personal Information identified in the Personal Information Collected subsection may be disclosed or retained through this Service.

-       We use Supplier Services for the creation, management, and hosting of Our Website and Our domain name. For more information, please see their privacy policy:

o   GoDaddy: Privacy Policy (in English only).

o   Cloudflare: Privacy Policy (in English only).

o   DigitalOcean: Privacy Policy (in English only).

All categories of Personal Information identified in the Personal Information Collected subsection may be disclosed or retained through this Service.

-       We use the Services of several advertising agencies to manage Our online presence, including Our Website, Our social media, and the creation and distribution of Our advertisements.

All categories of Personal Information identified in the Personal Information Collected subsection may be disclosed or retained through this Service.

-       We use Metatracer on Our digital systems to facilitate the detection and management of Your Personal Information and that of Our employees, all to ensure Our compliance with privacy laws.

Metatracer only collects identifying information as Personal Information.

3.5.3        Disclosure outside Quebec

Communication of Personal Information outside Quebec. We may communicate Your Personal Information outside Quebec and mandate an entity located outside Quebec to collect, use, or retain Your Personal Information on Our behalf.

Protections when communicating outside Quebec. Before communicating Your Personal Information to third parties outside Quebec, We conduct a privacy impact assessment to evaluate the risks that may affect the security of Your Personal Information. This assessment also identifies the appropriate security measures that will mitigate or eliminate these risks. The communication will then be subject to a written agreement binding these third parties to comply with such measures.

3.5.4        Compliance with legislation, response to legal requests, prevention of harm, and protection of our rights

Specific disclosures of Your Personal Information. We may disclose Your Personal Information when We believe that such disclosure is authorized, necessary, or appropriate, including:

-       Legal and regulatory compliance: to respond to requests from public and government authorities (including outside Your country of residence), to comply with legal proceedings, or when it is consistent with or required by applicable laws.

-       Protection of rights and interests: to protect Our rights, the privacy of Our employees, officers, and directors, Our security, and Our property; to protect Your privacy and rights, as well as those of third parties; or to enable Us to exercise Our remedies or limit the damages We may suffer.

-       Protection of Our Business: to protect Our business and ensure its continuity.

Possibility of business transactions. We may share or transfer Your Personal Information in accordance with this policy and the provisions of the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1) in the event of a sale, transfer, merger, reorganization, liquidation, or any other business transaction.

3.6  Consent

Consent for the collection, use, or disclosure of Personal Information. Unless otherwise required by law, the Organization obtains your consent to collect, use, and disclose Personal Information. However, if You provide Us with Personal Information about other individuals, You must ensure that You have duly notified them that You are providing Us with their information and that You have obtained their consent to such disclosure.

BY USING OUR WEBSITE, TRANSMITTING YOUR PERSONAL INFORMATION BY EMAIL OR USING AN ONLINE FORM, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.

Refusal to use the Website. If You do not agree, please stop using the Website. Except where otherwise provided by law, You may withdraw Your consent at any time by giving reasonable notice. Please note that if You choose to withdraw Your consent to the collection, use, or disclosure of Your Personal Information, certain features of Our Website may no longer be available to You, or We may no longer be able to offer You certain of Our Services.

3.7  Retention of Personal Information

Retention of Personal Information. Subject to applicable laws, We retain Your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, unless You consent to Your using or processing Personal Information for another purpose.

Additional Information. For more information about the periods during which Your Personal Information is retained, please contact Our Privacy Officer using the contact details provided in section 1b) of this Policy.

4.      Your Rights

List of rights. As a data subject, You may exercise the rights set out below by contacting Our Privacy Officer in writing at the contact details provided in section 1b) of the Policy. Please note that We may ask You to verify Your identity before responding to any of these requests. 

-       You have the right to be informed of the Personal Information We hold about You, its use, disclosure, retention, and destruction, subject to the exceptions provided for by applicable law.

-       You have the right to access your Personal Information, request a copy of the documents containing Your Personal Information, subject to the exceptions provided for by applicable law, and obtain, where applicable, additional details about how We use, share, retain, and destroy it by sending a written request to Our Privacy Officer at the contact details in section 1b) of this Policy.

-       You have the right to have the Personal Information We hold about You corrected, amended, and updated if it is incomplete, ambiguous, outdated, or inaccurate by sending a written request to Our Privacy Officer at the contact details identified in section 1b) of this Policy.

-       You have the right to withdraw or modify your consent to the collection, use, and disclosure of certain of your Personal Information collected (as identified in the section entitled Collection of Personal Information by Third Parties in this Policy) at any time, subject to applicable legal and contractual restrictions.

-       You have the right to ask Us to stop disseminating Your Personal Information and to de-index any link associated with Your name that provides access to this information if such dissemination contravenes the law or a court order.

-       You have the right to request that Your Personal Information be disclosed to You or transferred to another organization in a structured and commonly used technological format.

-       You have the right to be informed of a privacy incident involving Your Personal Information that could cause You serious harm. To this end, We maintain a register of all privacy incidents and assess the harm they may cause.

-       You have the right to file a complaint with the Commission d'accès à l'information, subject to the conditions set out in applicable law.

5.      Questions and Complaints

Complaint Process. You may address any complaints regarding Our practices and policies for protecting Your Personal Information by contacting Our Privacy Officer using the contact information identified in section 1b)

Questions. You may also contact Our Privacy Officer with any questions regarding this privacy policy using the contact information identified in section 1b).

Need to identify yourself. In order to respond to your request, you may be asked to provide appropriate identification or otherwise identify yourself.

6.      Cookies and other similar technologies

Use of Cookies. Cookies are small text files that are stored on Your device or in Your browser. They enable us to collect certain information when You visit the Website, including Your preferred language, the type and version of Your browser, the type of device You are using, and Your device's unique identifier. While some Cookies are deleted after the end of Your browser session, other Cookies are stored on Your device or browser to recognize Your browser the next time You visit the Website.  We use cookies and other similar collection technologies such as pixels (collectively, "Cookies") to help us operate, protect, and optimize the Website and the Services we offer. Cookies do not cause any damage to your device and cannot be used to extract your Personal Information.

Browser settings. You can configure Your browser to notify You about cookies and accept or reject them. However, disabling Cookies may affect Your browsing experience and limit certain features of the site.

Types of Cookies.

-       First-party cookie. Placed by the site you are visiting.

-       Third-party cookies. Placed by external domains via the visited site. If a user visits a website and another entity places a cookie through that website, it would be a third-party cookie.

-       Persistent cookie. Remains on your device for a defined period of time.

-       Session cookie. Created temporarily. Once You close the browser, they will be deleted from Your browser.

Categories of Cookies. In general, the Website uses Cookies to distinguish You from other users of the site. This helps Us provide You with a good experience when You browse the Website and also allows Us to improve it. To view the categories of Cookies used on Our website, You can consult Our cookie manager, accessible at the bottom of Our web page.  

-       Strictly necessary: These cookies are essential for the website to function. They allow us to authenticate you, keep your session active, ensure the security of the site, and redirect you to the correct content when a technical change is made. Without these cookies, certain essential features of the site may be inaccessible or may not function properly.

-       Performance: These cookies help us improve the performance and efficiency of the website. They are used to:

o   perform web analytics by providing statistics on site usage;

o   track affiliates by indicating, for example, whether a user accessed their site via ours;

o   obtain data on the number of users who have viewed a product or service;

o   identify and correct technical errors detected on the site;

o   test different versions or designs of the site in order to improve the user experience.

-       Functionality: These cookies allow us to personalize Your experience and remember Your preferences. They are used in particular to:

o   remember the settings applied (layout, text size, colors, etc.);

o   remembering whether You have already been invited to respond to a survey;

o   avoid repeating certain elements or lists that have already been viewed;

o   indicate whether You are logged in to the website;

o   enable the display and playback of embedded video content.

-       Targeting: These cookies are used to track your browsing activity, both on our site and on other websites or applications. They allow Us to display personalized advertisements based on Your interests, limit the frequency of certain ads, and measure the effectiveness of Our advertising campaigns.

Consent to Cookies. All cookies require your consent. We ask for Your consent before placing them on Your device. You can give Your consent by clicking on the appropriate button on the cookie manager banner displayed to You. If You do not wish to give Your consent or if You wish to withdraw Your consent to any cookies at any time, You must delete, block, or disable cookies via the cookie banner or the available settings options, or via Your browser settings. Please note that disabling Cookies may affect Your browsing experience on the Website and prevent You from using some of its features.

List of Cookies 

To see the complete list of our cookies, use our cookie manager .

7.      Security Measures

Purpose of Our security measures. We have implemented physical, technological, and organizational measures to protect the confidentiality and security of Your Personal Information against loss, theft, unauthorized access, or use. This includes:

-       Administrative measures: adoption of information governance policies and procedures to regulate access, communication, retention, de-identification (including destruction or anonymization) of Personal Information, management of privacy incidents, and handling of complaints.

-       Technical measures: use of a secure server and SSL technology, limitation of access privileges, use of backup systems and firewalls.

Incomplete list of measures. We have not listed all of the measures we have implemented, given the public nature of this Policy.

Impossibility of guaranteeing complete absence of risk. Despite the measures described above, we cannot guarantee the absolute security of your personal information. If you have reason to believe that your personal information is no longer secure, please contact our Privacy Officer immediately using the contact details provided in section 1b) above.

8.      Changes to this Privacy Policy

Right to Change this Policy. We reserve the right to change this Policy at any time in accordance with applicable law. If we make any changes, we will post the revised Privacy Policy and update the date at the bottom of the Privacy Policy. We will notify You reasonably in advance of the effective date of the new version of our Policy. If You do not agree to the new terms of the Privacy Policy, we encourage You to stop using our Website and Services. If You continue to use our Website or Services after the new version of Our Policy takes effect, Your use of Our Website and Services will be governed by that new version of the Policy.

9.      Links to third-party websites

Responsibility for third-party websites. We may occasionally include references or links on Our Website to websites, products, or Services provided by third parties (the "Third-Party Services"). These Third-Party Services, which are not operated or controlled by the Organization, are governed by privacy policies that are entirely separate and independent from ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies solely to the Website and the Services We offer. 

10.  Invisible reCAPTCHA

What reCAPTCHA does. Invisible reCAPTCHA analyzes activity on a web page feature (e.g., mouse movements and typing patterns) to determine whether a user is a robot. The invisible reCAPTCHA Service may collect information from Your device.  The information collected by reCAPTCHA is retained in accordance with its privacy policy.

11.  Individuals under the age of 14

Consent of minors under the age of 14. We do not knowingly collect or use Personal Information from individuals under the age of 14. If You are under the age of 14, You must not provide Us with Your Personal Information without the consent of Your parents or guardian. If you are a parent or guardian and you learn that your child has provided us with Personal Information without consent, please contact us using the contact details provided in section 1b) above to request that we delete that child's Personal Information from our systems.

12.  Applicable Laws

Laws of Quebec and Canada. The laws of Canada and Quebec, excluding its conflict of law rules, will govern this agreement and Your use of the Website. However, by accessing the Website from other jurisdictions, you may be subject to additional local, provincial, national, or international laws that apply to your situation.