PRIVACY POLICY

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES is a company subject to the Personal Information Protection Act. It is responsible for ensuring the protection of the personal information it holds and for demonstrating its compliance with its legal obligations.

This policy constitutes the general information framework governing the governance of personal information at JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES, in accordance with its legal obligations.

For any questions regarding the protection of personal information, please contact our Privacy Officer at: confidentialite@autobuscampeau.com

I. Objectives

The objective of this policy is to:

a) establish the commitments that guide the practices of JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES in its management of personal information and demonstrate compliance with legal obligations regarding the protection of personal information;

b) define the roles and responsibilities of JEAN JACQUES CAMPEAU INC. staff members. AND ITS SUBSIDIARIES with respect to personal information and standardize practices in this area;

c) enable staff members to know and understand the legal requirements and principles of personal information protection in the course of performing their duties;

II. Application

This policy applies to all officers, directors, staff members, consultants, volunteers, and any person who provides services on behalf of JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES when they collect, use, disclose, retain, or destroy personal information in the course of their duties or when they have access to personal information in any way whatsoever.

It applies to all personal information, regardless of its format, from collection to destruction.

It covers all types of personal information collected by JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES, whether it be information about its employees, directors, members, potential or current clients, consultants, or any other person.

III. Definitions

Employee

Any full-time, part-time, permanent, temporary, or student employee of JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES.

Manager

Any person within JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES who supervises one or more employees.

Legislation

The Act respecting the protection of personal information in the private sector (Chapter P-39.1)

Personal Information

Any information held by JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES that relates to a natural person and that allows, directly or indirectly, that person to be identified.

Third Party

Any natural or legal person who, without being an employee or director of JEAN JACQUES CAMPEAU INC. JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES collects, uses, stores, discloses, or destroys personal information on behalf of JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES, or who otherwise manages the personal information held by JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES.

This also includes any individual or legal entity from whom JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES obtains or discloses personal information, without being otherwise affiliated with JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES.

IV. Responsibilities

The personal information protection practices of JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES are based on the commitments below.

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES is responsible for the personal information it holds, including information whose collection, use, storage, or destruction is carried out by a third party. It implements policies and practices that demonstrate this responsibility.

1. Determining the Purposes of Information Collection

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES determine the purposes for which they collect information before collecting it.

2. Consent

No later than the time of information collection, JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES will adequately inform any individual about the collection of their personal information, how it will be used, and to whom it will be disclosed. They will obtain the individual's consent before using or disclosing their information for any other purpose, unless otherwise permitted by law. This consent may be withdrawn by the individual at any time.

3. Limiting Collection

At the time of collection, JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES will collect only the personal information necessary to fulfill the identified purposes.

4. Limitation of Use, Disclosure, Storage, and Destruction

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES limit the use and disclosure of personal information to JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES retain information only for the purposes for which the individual was informed of the collection or for which they consented, unless otherwise permitted by law. JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES retains information only for as long as necessary to fulfill the identified purposes, subject to the rules set out in its retention schedule, as permitted or required by law. JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES has implemented procedures for managing the personal information it holds. These procedures govern the collection, use, disclosure, retention, and destruction of personal information, as well as the handling of complaints, data security, and data governance.

5. Accuracy

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES ensures that the personal information it holds is up-to-date, accurate, and complete for as long as it is used.

6. Security Measures

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES take appropriate security measures to ensure the protection of the personal information it collects, uses, discloses, stores, or destroys, and which are reasonable, taking into account, in particular, its sensitivity, the purpose of its use, its quantity, its distribution, and its medium.

7. Transparency

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES make its policies and procedures concerning its management of personal information accessible.

8. Right of Access and Rectification

Subject to restrictions provided by law, JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES informs any person who requests it of the existence of personal information concerning them, its use, and the fact that it has been disclosed to third parties. It allows any person to consult or obtain a copy of their personal information and to have it corrected, if necessary.

9. Complaints

JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES responds diligently to all complaints regarding its management of the personal information it holds.

V. Governance

10. Board of Directors

a. Appoints a Privacy Officer to ensure the compliance of JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES and to promote practices that respect the right to privacy.

b. Determines the privacy policy of JEAN JACQUES CAMPEAU INC. AND ITS SUBSIDIARIES.

c. Adopts this policy.

11. Privacy Officer

a. Responsible for developing internal processes and rules regarding the protection of personal information.

b. Collaborates in the development and review of governance rules specific to the management of personal information.

c. Develops and implements an awareness and training program on the protection of personal information.

d. Conducts or commissions assessments of compliance with governance rules and of risks related to the protection of personal information.

e. Recommends the implementation of corrective measures.

f. Meets all other requirements specified by law.

12. Managers

Comply with this policy and the rules on the protection of personal information for which they are responsible.

13. Senior Management

a. Responsible for this Policy.

b. Reviews the Policy as needed, but at least every three (3) years from its date of adoption.

14. Effective Date

This policy comes into effect on the day of its adoption by the Board of Directors.