Privacy Policy

Last updated: March 16, 2026

Clemex Technologies Inc. (“Clemex”, “we”, “our”, or “us”) is committed to protecting the privacy and security of personal information in accordance with applicable privacy laws, including Québec’s Act respecting the protection of personal information in the private sector (Law 25) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

This Privacy Policy explains how Clemex collects, uses, discloses, and protects personal information in the course of its activities and through the use of our website and services.

1. Person Responsible for Personal Information

Clemex has designated a person responsible for the protection of personal information in accordance with applicable law.

Privacy Officer Clemex Technologies Inc. 9935 rue de Châteauneuf, Suite 130 Brossard, Québec J4Z 3V4, Canada

Email: emmasd@clemex.com

2. Personal Information We Collect

Clemex collects only the personal information necessary for the purposes described in this Policy.

The types of personal information we may collect include:

• Name • Company name • Email address • Phone number • Mailing address • Information contained in communications you send to us • Information relating to your use of our website or services • Technical information (e.g., IP address, browser type, device information)

If you contact us directly, we may receive additional information such as message content, attachments, and any other information you choose to provide.

3. How We Collect Personal Information

Information You Provide Directly

We collect personal information when you:

• Contact us (email, phone, forms) • Request information or services • Create an account • Subscribe to communications • Complete surveys or provide feedback

Information Collected Automatically

When you use our website, certain information is collected automatically through cookies, analytics tools, and server logs.

Information from Third Parties

We may collect personal information from third parties where you have consented or where permitted by law.

4. How We Use Personal Information

We use personal information for the following purposes:

• To provide, operate, and maintain our website and services • To respond to inquiries and provide customer support • To improve and personalize our services • To develop new products, services, and features • To communicate with you, including marketing communications where permitted by law • To manage relationships with job applicants and candidates • To verify information and prevent fraud • To comply with legal and regulatory obligations

Personal information is used only for the purposes for which it was collected or for compatible purposes permitted by law.

5. Consent

Clemex collects, uses, and discloses personal information with your consent, except where permitted or required by law.

Consent may be express or implied depending on the circumstances and sensitivity of the information.

You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting the Privacy Officer.

6. Cookies and Similar Technologies

Our website uses cookies and similar technologies to ensure proper functionality, improve user experience, and analyze website usage.

Types of cookies we use:

• Essential cookies: Required for the website to function properly • Analytics cookies: Help us understand how users interact with the site • Marketing cookies (if applicable): Used to deliver relevant content or advertising

Non-essential cookies are used only with your consent.

You may accept, refuse, or customize your cookie preferences through our cookie management tool. You may also configure your browser settings; however, disabling certain cookies may affect website functionality.

7. Log Files

We use log files to collect information such as:

• IP address • Browser type • Internet service provider • Date and time of visits • Pages visited and navigation behavior

This information is used for analytics, security, and website administration.

8. Disclosure of Personal Information

Access to personal information is restricted to employees who require it to perform their duties.

We may disclose personal information to:

• Service providers and partners • Technology and IT providers • Professional advisors • Authorities or regulators where required by law • Individuals authorized to act on your behalf

All service providers are contractually required to protect personal information.

9. Cross-Border Transfers

Personal information is generally stored in Québec or Canada. However, some service providers may process personal information outside Québec.

Before transferring personal information outside Québec, Clemex conducts a privacy impact assessment and ensures that the information will receive protection equivalent to that required under Québec law. Appropriate contractual safeguards are implemented.

10. Retention of Personal Information

Personal information is retained only as long as necessary for the purposes for which it was collected and to comply with legal obligations.

When no longer required, personal information is securely destroyed or anonymized.

11. Protection of Personal Information

Clemex applies administrative, physical, and technical safeguards appropriate to the sensitivity of personal information.

Administrative safeguards

• Privacy governance policies • Employee training • Risk monitoring

Physical safeguards

• Restricted access to facilities • Secure equipment storage

Technical safeguards

• Access controls based on need-to-know • Encryption where appropriate • Monitoring and detection systems

While we take reasonable measures, no system can guarantee absolute security.

12. Confidentiality Incidents

In the event of a confidentiality incident presenting a risk of serious harm, Clemex will notify affected individuals and the Commission d’accès à l’information du Québec in accordance with applicable law.

13. Your Rights

Subject to applicable legal limitations, you have the following rights:

• Right of access to your personal information • Right of correction of inaccurate or incomplete information • Right to withdraw consent • Right to deletion of personal information where appropriate • Right to de-indexation, where applicable • Right to data portability (for computerized data in a structured format)

Requests are processed within 30 days.

14. Automated Decision-Making

If Clemex uses automated decision-making processes, you will be informed.

You may:

• Request information about the decision • Understand the factors involved • Request correction of personal information • Request human review of the decision

15. Children’s Privacy

Clemex does not knowingly collect personal information from children under the age of 14.

If such information is collected inadvertently, it will be deleted promptly or parental consent will be obtained.

16. Privacy by Default

Clemex applies privacy-by-default principles, ensuring that only necessary personal information is collected and that default settings provide the highest level of confidentiality.

17. Complaints

If you have concerns or complaints regarding the handling of your personal information, you may contact the Privacy Officer.

If you are not satisfied with our response, you may file a complaint with the Commission d’accès à l’information du Québec.

18. Changes to This Policy

Clemex may update this Privacy Policy from time to time. The updated version will be posted on our website with the revision date.