PRIVACY POLICY

This Privacy Policy provides you with important information about how Rougié processes your personal information. Protecting your personal information is important to us and essential to our business.

Whether you use our Website, other online platforms, or our Service Centers, this Policy applies.

We encourage you to review this Policy periodically, as we may update it from time to time. Updates will be posted on our Website, and we will take reasonable steps to notify customers of any significant changes before they take effect.

This Policy may be supplemented by other consents you provide and the general terms and conditions that can be found on our website www.rougie.us.

1 - What information is covered by this Policy?

This Policy applies to personal information. Personal information means any information about an identifiable individual, such as your home address, telephone number, email address, and details about your transactions with Rougié and method of payment.

This Policy does not apply to anonymous information, which is information that does not include an individual’s name, contact information, or other information that could reasonably allow the individual to be identified.

2 - What personal information do we collect, and when?

We collect personal information when you interact with us, for example:

When you communicate with us, we collect information about that interaction, such as the time and reason for the interaction.

When you browse our Website or other online platforms, including on third-party websites collected by Rougié, we collect information including your Internet Protocol address, device type, and browsing activities. To learn more, please see our Policy and Tracking Technologies Policy.

We collect personal information when you make purchases, for example:

If you order a product, we collect the personal information you provide to us in order to:

Complete the transaction;

Be able to communicate with you, if necessary;

Assess your eligibility for a rate, such as discounts;

Verify your identity for legal and security purposes.

The personal information we collect for these purposes includes your name, address, telephone number, email address, payment card number, and expiry date.

We collect the personal information that we reasonably need to fulfill our functions, as indicated in Part 3 “Why do we use and disclose your personal information?”.

Orders for Third Parties, Modifications, and Requests

If another person, including a family member, friend, or colleague, attempts to place an order on your behalf, they must provide the same personal information that you would normally provide in order to complete your order.

We consider that this person has your consent and authorization to provide us with your personal information for the relevant purposes described in this policy, unless otherwise indicated.

In addition, if the person who placed your order or who possesses, for any reason, your full name and order number contacts us and requests information about your order or wishes to make changes to it, we will disclose your order details, including whether it has already been prepared and shipped, and we will allow that person to make the desired changes, as we will consider that you have given them authorization to do so. If you do not want a third party to be able to obtain information about you or make changes to your order, you should avoid giving them your order number.

When you place an order through a third-party website, we consider that the latter has your consent to communicate to us the same information that you would give us yourself. The collection, use, and disclosure of your personal information by this third-party website are subject to its privacy policy.

3 - Why do we use and disclose your personal information?

We use and disclose your personal information to respond to your requests or complete transactions.

Notably to:

Communicate with you, for example to inform you of changes to your order or to answer your questions;

Process your orders and respond to your requests for our products and services, including requests for special needs or products.

We also use and disclose your personal information to better serve you. Notably to:

Administer our websites, mobile applications, and online platforms, and make them easier to use, for example by pre-filling forms with your contact information or other relevant personal information;

Process questions relating to the quality, recipes, use, storage, or transportation of our products, or questions you may have about them;

Monitor and maintain the quality of our operations, for example for the tracking or recording of telephone conversations with our representatives for quality assurance purposes.

We also use and disclose your personal information to improve our products and services and to offer you relevant offers – through the following means:

An analysis to better understand your preferences, needs, and interests;

The promotion of relevant opportunities, products, and services that may be of interest to you. This includes advertisements on other websites (for more information, see the Cookie Policy and Tracking Technologies Policy and the transmission of personally identifiable information – for example, your encrypted email address – to social media providers to show you relevant offers on their platform.

We also use and disclose your personal information to meet our operational and legal needs. Notably to:

Ensure the safety and security of our operations;

Protect our business or legal interests, for example to investigate, detect, or prevent fraud or harm to our systems;

Measure the success or effectiveness of offers, promotions, privileges, content, products, and services;

Generate de-identified information for further analysis, including to identify trends regarding our customers as a whole, notably in support of decisions regarding the improvement of our products, services, or operations;

Fulfill other purposes to which you may consent, or as permitted or required by applicable law.

Transfers to our Service Providers

We may transfer your personal information to service providers who support our various functions, including orders, deliveries, information security, data storage, research, customer relations, payment processing, data analysis, email sending, IT, customer service, and marketing. These service providers process personal information on our behalf and for our purposes only, and must agree to certain obligations regarding the protection of personal information in the contracts we have entered into with them. They must notably comply with personal information protection laws, protect personal information, and only process this information under our direction for authorized purposes.

4 - What are your options regarding the processing of your personal information?

Modification of Communication Preferences

To modify your communication preferences:

Contact our Canadian service center by email at ventes@rougie.com or by phone at +1 (450) 460 2107

Contact our Chief Privacy Officer at the contact information provided in Part 8;

Use the unsubscribe mechanism in any marketing text message or email;

If you withdraw your consent to receive these electronic marketing communications, you will continue to receive service communications, such as those related to your orders or other purchases and product information.

Modification of Browser or Device Settings

We use cookies, scripts, pixels, local storage, and other tracking technologies on our Website and other online platforms to administer them, enhance your experience, and improve the program. To learn more about how we use these technologies, including how you can manage some of them, please see our Cookie Policy and Tracking Technologies Policy.

Other Data Processing Options

If you wish to withdraw from other collections, uses, or disclosures of your personal information by Rougié, please contact us (see Part 8 “How can you ask questions about privacy or raise concerns?”).

5 - Where do we store your personal information?

We generally store personal information at our offices in Canada and France, as well as at our data centers in Canada, the United States, and Europe.

Some of our service providers access, use, or store your personal information outside of your province or territory, or outside of Canada. The laws of these other locations will then apply to this information, including laws that may permit or require the disclosure of this information to government, courts, and law enforcement agencies.

If you would like more information about our policies and practices regarding the processing of personal information outside of Canada, please contact our Privacy Office directly (see Part 8 “How can you ask questions about privacy or raise concerns?”).

6 - How is your personal information protected? How long is it kept?

Rougié maintains appropriate administrative, technical, and physical safeguards to protect your personal information. These safeguards are designed to prevent the loss, theft, unauthorized access, use, disclosure, modification, or destruction of your personal information. Here are some examples:

Access to your personal information is restricted;

Electronic data is protected by technological means, such as firewalls, access controls, encryption, and pseudonymization (de-identification of information using pseudonyms);

We educate our staff on the importance of protecting personal information against loss, theft, or unauthorized access, use, or disclosure.

As many of our interactions with you occur online or by email, we rely on you to take reasonable steps to protect your personal information. Here are some examples:

We expect you to use unique passwords for any accounts you may have with us and to protect them so that they are not used without your permission;

You should not provide us with an email account that you share with another person; if you do, all emails (including password resets) sent to that account will be accessible to that other person.

In addition, when you book an order, you receive a confirmation number. You should not share this number or this information, as it could allow other people to access your personal information.

Like most businesses, we cannot guarantee that safeguards are always effective or that online communications are always secure. A breach of safeguards may result in a risk of identity theft, for example. If this occurs, we act quickly to mitigate the risks and inform you when there is a real risk of serious harm, or when required by law.

We retain your personal information for as long as necessary for the purposes for which it was collected, or for a longer period if permitted or required by law. When your personal information is no longer needed, it is destroyed, anonymized, or deleted using secure methods.

Please note that if your personal information is collected by a third party, such as a delivery person or a service company, it will be retained in accordance with that third party’s privacy policies and record retention requirements.

7 - How can you access or correct your personal information?

You have the right to access and correct your personal information.

You can make a formal request for access or correction by contacting our Privacy Officer (see Part 8 “How can you ask questions about privacy or raise concerns?”). In this case, we will respond to your request for access or correction within a reasonable time (but no later than 30 days after your request), in accordance with applicable laws.

If you demonstrate to us that your personal information in our records is inaccurate or incomplete, we will amend it as required. Where applicable, we will transmit the amended information to third parties who have access to your personal information.

It is your responsibility to provide accurate and complete information and to keep it up to date.

8 - How can you ask questions about privacy or raise concerns?

Our Chief Privacy Officer is responsible for overseeing what we do with your information and monitoring compliance with this policy and data protection laws. If you have any concerns or other questions about how we handle your personal information, or if you wish to make a formal request for access or correction, please contact our Chief Privacy Officer. Their contact information is below.

Email Address:

nikola.smatrakalev@rougie.com

Address:

Chief Privacy Officer

Palmex Inc./Aurpal Inc.

1661, rue Marcoux

Marieville (Québec) J3M 1E8 CANADA

Telephone: +1 450-460-2107

Facsimile: +1 450-460-2963

Please note that we will need to take reasonable steps to confirm your identity before disclosing personal information through the communication channels above.