QUÉBECOR PRIVACY POLICY
Update date: April 2025

1. Scope of application

This privacy policy (the “Policy”) applies to all personal information of members of the public, our customers and users of our products and services, including our websites and our mobile and television applications, that we (i.e., the companies that are members of the Quebecor group^[[*]^]) collect, use or disclose in the course of our business activities, including through subscriptions to our publications, registration or sign-up forms, surveys, or participation in a contest or other promotion. This Policy also applies if you are applying for a job (see Article 6).

Some of our products and services, and those offered by third-party service providers to our customers or users, may have their own privacy policies that apply in place of this one. In this case, the privacy notice relating to these products and services will refer you to any other policy.

Various terms of service and other conditions may apply in addition to this Policy. It is therefore important to carefully review all legal terms relating to any product or service (including any website or mobile and television application) that you use.

2. Consent

Your consent to the collection, use and disclosure of your personal information may be given tacitly or expressly, including in writing, verbally or by technological means. When we process sensitive information, we will ask for your express consent in accordance with the law.

Subject to certain exceptions provided for by law, we must obtain the consent of the holder of parental authority or legal guardian to collect personal information concerning a minor under 14 years of age in Quebec or under 13 years of age in the rest of Canada. IF YOU ARE UNDER THE AGE OF FOURTEEN AND LIVE IN QUEBEC (OR IF YOU ARE UNDER THE AGE OF THIRTEEN AND LIVE IN ANOTHER PROVINCE), PLEASE ASK YOUR PARENT OR GUARDIAN TO REVIEW THIS POLICY.

You have the right to withdraw your consent to any possible collection, use or disclosure at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. Additionally, we may no longer be able to provide you with certain products or services, respond to your requests, provide technical support or otherwise assist you in using our products and services, or continue the process of evaluating and hiring you for employment (see Article 6), as applicable. If this is the case, we will inform you when you withdraw your consent.

3. Collection of personal information

“Personal information” means any information that relates to a natural person and allows them to be identified, directly or indirectly. The personal information covered by this Policy includes any information reasonably necessary to achieve the purposes described in Article 4, and may include, in particular:

• Your title, full name and contact information, such as email address, telephone number, postal address, preferred language for communication, preferred means of communication, etc.;
• Demographic data, including age, date of birth and gender;
• Transactional information, such as your product and service choices, subscriptions, service appointments, order history, etc.;
• Information relevant to your billing, including billing address, payment method, credit card number, payment history;
• Your credit score, collected from credit bureaus;
• Information relevant to our promotional and marketing activities, including your subscriptions and preferences regarding commercial electronic messages;
• Usage data of our products and services (including our websites, applications or other digital platforms), including date, average time spent, number of visits, browsing history and other analytical data about how you use our products and services. This data is collected and stored by cookies and other similar technologies (see Article 5);
• Preference data, which allows the user to personalize the behavior or display of certain features of our products and services. This data is collected and stored by cookies and other similar technologies (see Article 5);
• Technical data, including Internet protocol (IP) address, geographic area, Internet service provider, device identifier, and other technologies on the devices you use that interact with our websites, applications or other digital services. This data may in particular be collected and stored by cookies and other similar technologies (see Article 5);
• Social media account data, including information associated with your social media accounts and associated profiles, such as name, username, email address, profile picture, date of birth, and gender;
• If you are applying for a job, all information that may be included in a resume and any other relevant documentation or correspondence produced or communicated as part of the recruitment process (see Article 6 for more information on this).

We collect personal information in a variety of circumstances for the purposes set out in Article 4, including through our agents, distributors, retailers and other representatives who have contact with customers or the general public, including:

• When you communicate with us by phone, email, chat or post;
• When you browse our websites, including if you complete and submit a web form;
• When you purchase any of our products or services, including any application, purchase, activation or registration process related to a product or service;
• When you use any of our products or services, including our websites, applications and digital media, including any delivery service, after-sales service, technical support or any service under a warranty;
• When you create a user account and when you make changes to it;
• When you participate in one of our surveys, competitions or promotional activities;
• When you participate in our online discussion forums;
• When you post any content on our websites and digital media;
• When you subscribe to one of our newsletters or for any other communication of a commercial nature;
• When you interact with us through social media;
• When you use our communication networks;
• When you apply for a job (see Article 6);

We collect personal information about you primarily from you, but we may need to collect personal information about you from other sources in certain circumstances, such as credit reporting agencies. We will ensure that we inform you and obtain your consent in accordance with the law in such circumstances.

Sometimes, personal information may be collected automatically when you interact with our applications, websites and other digital services, as it is necessary to process various data (some of which may be of a personal nature) in order to establish the connection, to allow you to access your user account and to use the functionalities of our websites, applications and other digital services (including geolocation when this option is activated), and to remember your choices and preferences. This data is collected using cookies and similar technologies (see Article 5).

Additionally, if you visit one of our stores, you may be filmed by our video surveillance equipment.

4. Use of personal information

We use personal information for a variety of purposes relevant to the provision of our products and services and in the course of our business activities, but only to the extent reasonably necessary to achieve those purposes and within the limits of the law. In particular, we use your personal information for the following purposes:

• To respond to your communications, if any, including any requests for service or information, and any complaints;
• To provide you (including through third party suppliers) with the products and services you select, to bill you for them and to collect payment, when necessary;
• To validate your identity when reasonably necessary and ensure that your information is accurate and up to date;
• To verify your eligibility in connection with a product, service, contest or promotional offer;
• To conduct analyses, conduct surveys or request your feedback in order to better understand the needs and preferences of our customers and the market;
• To improve our products and services or develop new ones;
• To understand your needs, interests and habits and offer you products and services that may interest you and that are offered by members of the Quebecor group^[*] or by our business partners (which may include advertising and targeted offers subject to the requirements of the Canadian Anti-Spam Legislation (CASL), where applicable), or to personalize your experience with one of our products or services, in particular with regard to its content and the recommendations associated with it;
• To remember and apply your preferences as a user of our products and services;
• To maintain our business relationship with you and to manage our business activities responsibly and in accordance with the law;
• To detect, eliminate or prevent fraud or any other illegal activity;
• To secure and ensure the proper functioning of our products and services (including our websites, applications and other digital services) and our information assets (including our databases, servers and networks);
• To ensure compliance with our terms of service, and to enforce them where necessary, including to assert our rights and defend our legitimate interests;
• If you submit your application for employment, your personal information will be used for the purposes of the assessment and hiring process, if applicable (see Article 6 for more information on this);
• To comply with our legal obligations and regulatory requirements;

We may also collect and use your personal information for other purposes with your implied or express consent or as permitted or required by law.

5. Cookies

Witness files (commonly referred to as “cookies”) and similar technologies are tools used by websites and apps to improve your experience as a user.

Cookies are small text files stored on your device that remember your preferences, login information and browsing history. This helps websites load faster and deliver personalized content. Similar technologies, such as local storage and device identifiers, serve the same purpose by storing information directly on your device or uniquely identifying it.

Together, these tools make your interactions with websites and applications smoother and better tailored to your needs. In addition, they allow us to offer you targeted advertising based on your interests and browsing behavior. Finally, these technologies allow companies to analyze how their products and services are used in order to improve them, develop new ones or market them better. We use cookies and technologies for all these purposes.

6. Job applications

If you apply for a job, we may collect, create and infer various personal information about you. This includes all information that may be included in a CV and in any other relevant documentation or correspondence produced or communicated as part of the recruitment process, such as:

• Identifying information, for example: name, address, telephone number, email address, etc.
• Professional information, such as: employment history, job titles, responsibilities, accomplishments, and professional references.
• Academic information, for example: diplomas, certificates, transcripts, and other educational qualifications.
• Relevant demographic information, such as: date of birth, nationality, residency status, and other demographic information.
• Financial information, such as current and expected salary, benefits, and other types of compensation.
• Verification information, for example: results of reference checks, background checks, and work authorizations.
• Performance information, for example: skills assessments, skills test results, and other performance evaluations.
• Documentation relevant to the application file, for example: cover letters, application forms, and responses to interview questions, correspondence, interview notes, and other communications related to the recruitment process, etc.

This information is collected and used for the purpose of evaluating your application, verifying your qualifications, and making informed hiring decisions.

We are committed to protecting the confidentiality and security of your personal information throughout the recruitment process in the same way as any other personal information covered by this Policy.

7. Communication of personal information

We may disclose your personal information to third parties with your implied or express consent or as permitted or required by law, including in the following circumstances:

• To any person authorized to act as your agent, upon reasonable verification;
• To the account holder of a service comprising multiple user profiles or devices;
• To another communications service provider where the information is required to provide you with effective communications services (e.g., home phone services, roaming services outside our network coverage, etc.);
• To our subcontractors, service providers and partners, i.e. third parties who provide services to us or on our behalf and any other third parties we use to support our business and carry out the purposes described herein;
• To a credit reporting agency to assess your creditworthiness;
• To collection agencies for the recovery of outstanding invoices appearing on your account;
• To courts with jurisdiction, law enforcement agencies and other persons or entities charged with enforcing the law or otherwise authorized by law to collect or compel the disclosure of such information, including for investigative or judicial purposes. For example, we may be required to disclose personal information in response to a search warrant, subpoena or lawful order. We may also disclose personal information when necessary to assert our rights and exercise legal claims or to defend against such claims, to prevent actual or suspected losses, or to avoid personal injury or property damage;
• In the event that we sell all or part of our business or sell or transfer assets or otherwise participate in a merger or business transfer with another entity. Where applicable, we may transfer your personal information to a third party for the purposes of the relevant business transaction, subject to applying the safeguards required by law in such contexts;
• In cases where you have already given your consent to the communication to the third party recipient (e.g., a home automation or “smart home” device or service provider, a financial institution, an insurance company, a social network or any other technology service provider that you authorize to process your personal information);
• To comply with our legal obligations and regulatory requirements;

Your personal information may also be communicated within member companies of the Quebecor group^[*] in order to achieve the objectives described herein.

8. Transfers of personal information outside Quebec/Canada

Your personal information will be stored and processed in Quebec or other Canadian provinces. In some cases, they may also be transferred and hosted outside Quebec or Canada. Where applicable, we will take all reasonable steps to ensure that the personal information transferred receives an adequate level of protection in accordance with applicable legislation. However, your personal information may be subject to the laws of the countries or territories to which it is transferred.

9. Retention and destruction of personal information

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected and is used, such as those described in this Policy or disclosed to you at the time of collection, subject to any longer retention periods required by law or for legitimate legal or business purposes to the extent permitted by law. For example, we may retain certain personal information, even after you are no longer a customer, for tax and financial record keeping, security or fraud prevention purposes. When this information is no longer required, it is destroyed, depersonalized or anonymized in accordance with the requirements of applicable law.

10. Protection of personal information

We implement administrative, technical and physical security measures to protect the confidentiality, integrity and availability of the personal information we manage. These measures are intended to prevent unauthorized access, use, modification, disclosure or destruction, loss or any other breach of the protection of this personal information. They also apply when we destroy your personal information.

We provide access to your personal information to our employees, agents, contractors and suppliers only on a need-to-know basis to perform the specific roles and functions we have assigned to them. We raise awareness and train our employees on the protection of personal information. Information disclosed to third parties, including our agents and suppliers, is protected under the contracts we have concluded with them.

Our employees, as well as all our consultants, subcontractors, service providers and any other third parties we use to achieve the objectives described in this Policy, are all contractually bound to keep your personal information confidential according to best practices and to destroy it securely in accordance with Article 9 of this Policy.

The security of your information depends on you. In particular, you are also responsible for keeping your passwords confidential and we recommend that you do not share them or use the same password for multiple accounts. Additionally, we advise you not to disclose personal information in public or semi-private areas of the Website, such as comments sections and discussion forums, that may be viewed by others.

In the event of a breach of your personal information, such as unauthorized access, use, disclosure or loss, we have policies and processes in place to contain the incident and restore the security of our information systems, investigate the causes and review our safeguards to improve them as necessary and prevent similar incidents from occurring. In addition, we will comply with all applicable notification requirements to you and the relevant authorities. If necessary, we will provide you with the information necessary to understand the significance of the situation and take the necessary steps to reduce the risk of harm that may result.

11. Rights of access and rectification

You may ask us to provide a copy of the personal information we hold about you and to rectify any personal information that is incomplete, inaccurate, ambiguous or out of date, subject to any exceptions and conditions applicable under the law. Reasonable charges may apply for the transcription, reproduction or transmission of this information in certain cases (we will inform you in advance). To the extent possible, we will provide to you or a third party of your choice, in a structured and commonly used technological format, the computerized personal information that we have collected from you and which is the subject of your request.

To exercise any of the above rights or any other rights granted to you by law, you must contact our Privacy Officer in writing (see Article 13 for contact details). We will respond in writing to all legitimate requests within thirty (30) days of receipt. If we are unable to comply with your request, we will explain our decision to you and inform you of the avenues of appeal available to you, as well as the time limits within which you must act.

12. Changes to this Policy

This Policy may be modified at any time, at our sole discretion, with or without notice, in particular to take into account changes made to applicable laws or to our practices regarding the processing and protection of personal information.

We will post any updates on our websites and take reasonable steps to notify you, whether by notice on our sites, by email, by text message, on your invoice, or by other means.

13. To communicate with us

For any questions, comments, requests or complaints regarding this Policy and the protection of your personal information, please contact our Privacy Officer by email at vieprivee@quebecor.com or by post:

Quebecor Media Inc.
Attn.: Privacy Officer

612 rue St-Jacques, Montreal, H3C 4M8