PRIVACY OFFICER

Hugo Girard:

hgirard@elgirard.com

418-570-9109 ext. 4

PRIVACY POLICY

0.Background

ELG Group places great importance on everyone's right to privacy. That is why we have put in place this Privacy Policy to ensure the protection of your integrity and your right to protect your personal information. The purpose of this policy is to govern the use and collection of information on our Web site (http:// www.groupeelg.com) and any information you voluntarily provide to us as part of your participation in any service offered by ELG Group, subject to any refusal you may duly express to us in this regard.

For the foregoing reason, Groupe ÉLG diligently complies with the requirements of Law 25 and therefore adheres to its definitions. The term "privacy incident" is defined as any unauthorized access, use or disclosure of personal information, as well as the loss of personal information or any other breach of its protection.

The term "personal information" is therefore defined as any information, taken alone or in combination with other available information, about an individual that allows that person to be identified, such as information about his or her financial situation, lifestyle, or health.

However, an individual's name and professional contact information (title, address, telephone number and professional e-mail address) are not personal information.

Personal information must be protected regardless of the medium in which it is held or its form: written, graphic, audio, visual, computerized or other.

1.Our responsibility

Groupe ÉLG is responsible for all personal information in its possession or control, including personal information we receive directly - for example, from our customers and employees.

Groupe ÉLG adheres to cybersecurity best practices by conducting, in conjunction with our IT partner, a cyber risk management strategy aimed at applying a series of mitigation measures for our personal information.

We have also assigned a privacy officer and delegated certain cybersecurity responsibilities to our IT partner via a Law 25 service offering. The execution of this service offering ensures the protection of privacy and personal information on behalf of Groupe ÉLG. We have also published on our website and informed our staff of the existence of our Privacy Policy and of our Personal Information Governance Policies and Practices, as well as of the role everyone must play to ensure the protection of the personal information of our customers and team members.

If you have any questions about our privacy practices, please contact our Privacy Officer at hgirard@elgirard.com or 418-570-9109.

2.Purpose of collecting personal information

Groupe ÉLG collects, uses, and discloses personal information about its team members to comply with laws, regulations, and professional standards; to provide benefits; to administer performance management tools; to administer, manage, monitor, and enforce Groupe ÉLG's programs and policies and its relationship with its employees; and generally, to establish, manage or terminate employment or partnership relationships.

Groupe ÉLG may also collect, use, and disclose personal information about individuals who apply for employment with us. If we are not in a hiring phase or that your application is not considered for any other reason, the information you send us will be immediately destroyed without even being consulted.

Groupe ÉLG may collect and use personal information about its current and future customers to offer its services to them.

3.The consent

Groupe ÉLG ensures that it obtains the consent of the persons concerned before collecting, using, or communicating personal information, except in cases authorized or required by law.

As part of the administration of a survey, promotion and/or contest, the ELG Group may use, subject to any refusal expressed by you, personal information as provided to it on a voluntary basis, by sending message(s) or because of participation in a survey, promotion, or contest. Information collected for such purposes will be used primarily to contact you if you win. Promotions and/or contests offered by the ELG Group may be subject to special rules that will be more fully described in connection with the launch of any promotion or contest.

4.Collection limits

Groupe ÉLG collects by lawful means only the personal information it reasonably deems necessary to meet its legal obligations and provide its services.

5.Limits of use and communication

Groupe ÉLG uses and discloses your personal information only for the purposes for which it has obtained your consent, or as permitted or required by law. If Groupe ÉLG requires the need to use or disclose personal information about an individual for a purpose not´ previously identified, Groupe ÉLG will first seek the consent of the individual concerned, unless the law requires or permits the use or disclosure of personal information without obtaining the individual's consent.

Personal information is retained only as long as necessary for the fulfillment of those purposes, except as authorized or required by law. All files containing personal information about Groupe ÉLG employees and customers are destroyed when the information can no longer be reasonably considered necessary for legal, regulatory, or administrative purposes.

6.Accuracy

To ensure that the personal information collected is relevant to the purposes for which it is to be used, Groupe ÉLG makes reasonable efforts to maintain the integrity of the personal information of individuals and to update it on a regular basis.

Individuals concerned by the personal information collected must contact the Privacy Officer in writing to make a request for rectification if a change is required to their personal information held by the company.

7.Transparency

Groupe ÉLG will make information about its Privacy Policy and Personal Information Governance Policies and Practices available to interested parties upon request. Groupe ÉLG also undertakes to respond to any written request for information submitted to the Privacy Officer regarding issues related to its personal information management policies and practices.

8.Access

The persons concerned have the right to examine the personal information in our possession and to obtain a copy. To do so, they must contact the Privacy Officer.

The right to access personal information is subject to certain legal restrictions, and we will take reasonable steps to verify the appropriateness of the request and the identity of an individual before granting access.

In most cases, requesters will receive a response within 30 days. If you have any concerns about access, we encourage you to contact our Privacy Officer at hgirard@elgirard.com or 418-570-9109.

9.Complaints

We recognize the importance of protecting the privacy and personal information of individuals. If you have any questions or concerns about your privacy and the role, we play in protecting your personal information, please contact our Privacy Officer at hgirard@elgirard.com or 418-570-9109.

Groupe ÉLG has established a procedure for receiving and processing complaints regarding this policy and its personal information handling practices. An individual about whom Groupe ÉLG holds personal information may complain about non-compliance with this policy. Any complaint concerning the protection of personal information should be forwarded to the Privacy Officer at the above address. In most cases, complainants will receive a response within 30 days.

If an individual is not satisfied with Groupe ÉLG's response to a complaint or with Groupe ÉLG's personal information handling policies and practices, he or she may file a complaint with the Commission d'accès à l'information du Québec on the Commissioner's website at https://www.cai.gouv.qc.ca/a-propos/nous-joindre/.