PRIVACY POLICY
Privacy and Personal Information Protection Policy
Organization: POL R Enterprises Inc., POL R International Holding inc, and its entities (collectively, the “Organization,” “We,” “Us,” “Our”).
Effective date: 2026-01-01
Privacy Policy Version: 1 (2026-01-01)
1. General Information
a) Introduction
Purpose of this Policy. Privacy is important to POL R Enterprises Inc., POL R International Holding inc and its entities (hereinafter collectively referred to as the “Organization,” “We,” “Us,” “Our”). For this reason, We have implemented safeguards and sound management practices for Your Personal Information in accordance with applicable laws in Quebec and Canada.
Supplemental to the Terms and Conditions. This privacy policy (the “Policy”), which should be read in conjunction with Our Terms and Conditions, describes Our practices regarding the collection, use, processing, disclosure, retention, and destruction of Personal Information of individuals who use Our Services, visitors to this Website, and its users (hereinafter “You,” “Your,” “Yours”).
Consent. By using any of Our Websites (https://www.polrcorp.com/, https://www.artikoem.com/, https://www.mecart-cleanrooms.com/ and https://mecart.com/) (hereinafter collectively referred to as the “Website”) or any of Our Services, You agree that We may collect, use, communicate, disclose, and retain (hereinafter “Process” or “Processing”) Your Personal Information in accordance with the terms described herein. If You do not agree to comply with and be bound by this Policy, You are not authorized to visit, access, or use Our Website or Our Services, or share Your Personal Information with Us.
Limitations of the Policy. This Policy does not apply to the Personal Information of employees, representatives, and consultants of the Organization, or any other person affiliated with the Organization, as well as any information that does not constitute Personal Information as defined by applicable laws in Quebec and Canada.
b) Personal Information Protection Officer
Contact information for the Privacy Officer. Any comments, questions, or complaints regarding the Organization’s privacy policy and practices may be directed to our Privacy Officer:
Phone: (418) 872-4615
Email: [email protected]
Address: 5085 Rideau Street, Quebec City, Quebec, G2E 5H5, Canada
2. Definitions
Definitions of certain terms and expressions. The following terms and expressions, when appearing with a capital letter in the Policy, have the meanings assigned to them below, unless there is an implicit or explicit exception in the text.
“Organization,” “We,” “Us,” “Our”: POL R Enterprises Inc. and its entities.
“Service Provider”: any natural or legal person who processes Personal Information on behalf of the Organization. These are third-party companies or individuals employed by the Organization to facilitate the Services, provide the Services on behalf of the Organization, perform Services related to the Services, or assist the Organization in analyzing the use of the Services.
“Cookie Banner”: a pop-up window requesting Your consent to certain collections of Your Personal Information on the Website.
“Personal Information”: any information that relates to a natural person and allows that person to be identified, i.e., that directly or indirectly reveals something about the identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental abilities, character, and behavior of the person concerned) or the activities of that person, regardless of the nature of the medium and regardless of the form in which this information is accessible (written, graphic, audio, visual, computerized, or other).
“Personal Information Protection Officer”: the person responsible for the application of this Policy, whose contact information is identified in section 1b) of this Policy.
“Services”: refers to the Website applications, our social media pages, and all programs and Services provided to you therein, such as contact forms, online quote requests, careers pages with online applications, and social media pages where we share information about products, Services, news, and career opportunities.
“Website”: https://www.polrcorp.com/, https://www.artikoem.com/, https://www.mecart-cleanrooms.com/ or https://mecart.com/.
“Cookie”: cookies are text files installed on your computer or mobile device. They may contain information about your search history, web pages visited, and web browser.
“Process,” “Processing”: a concept encompassing all operations that may affect or concern Personal Information, including collection, use, storage, destruction, disclosure, or transmission.
“You,” “Your,” “Yours”: persons benefiting from Our Services, visitors to the Website, and all users who use the Organization’s Services.
3. Processing of Personal Information
3.1 Collection of Personal Information
3.1.1 Means of collection
Various means. We collect Your Personal Information through Our Website or other technological means in several ways. This may occur automatically when You connect to Our Website (your device provides certain information), when You fill out an electronic form or apply online, when You email Us using addresses available on Our Website, and through cookies (as described in the Cookies section). We may also receive Personal Information through partners or third parties who collect information for Us, as described in this Policy.
Profiling, identification, or location. Our Website includes features that may allow profiling of activities, identification, or location. These features are used by third parties identified in the section addressing cookies and similar technologies. We disable these features by default, and You may enable them through the Cookie Banner.
3.1.2 Personal Information Collected
Categories of information collected. In the course of Our activities, We may collect and Process various types of Personal Information. This may include identification and contact details (such as first and last name, postal address, email address, company name, and telephone number). These details are generally professional, as forms on Our Website often request business contact information, though Personal Information may be required in some cases.
We may also collect information submitted through online forms. For online submissions, this can include personal and professional contact details, technical details, uploaded documents, and other related information. For career opportunities, this can include your resume, cover letter (if applicable), a personalized message, and personal contact information, so We can evaluate your application and determine suitability for positions.
We may also collect technical or digital information relating to your activity on the Website, such as IP address, browser and operating system configuration, mobile device configuration (if applicable), geographic location and location data, pages visited, products viewed, path taken through the Website, keywords used in searches, and the date and time of visits. This information is generally collected via cookies and similar tools while browsing.
Finally, We may collect information that You choose to provide to Us, such as when You submit a form, make a request through the contact form, or communicate with a member of Our staff.
Limitation of Processing to Necessary and Legitimate Purposes. In each case, Personal Information is processed in accordance with the legitimate and necessary purposes described in the “Use of Personal Information” section below.
3.2 Collection of Personal Information by a Third Party
Third parties collecting Personal Information on Our behalf. When You use the Services of Our suppliers, they may collect certain Personal Information. This may occur through recruitment platforms (such as Jobillico, LinkedIn, and Indeed), partner recruitment agencies who send Us candidate information, and surveillance camera system providers used for security and prevention purposes (including their recording and viewing software).
For more information about our suppliers, please refer to the “Access, Disclosure, and Transfer of Personal Information” subsection of this Policy.
3.3 Refusing collection
Refusing to consent. Unless otherwise provided by law or Your contractual obligations, You may refuse or withdraw Your consent to certain uses or disclosures of Personal Information. You may do this by leaving optional fields blank when completing forms, selecting “decline” in the Cookie Banner, or sending a request to Our Privacy Officer using the contact details in section 1b).
Alternative ways to provide information. You may also provide Personal Information by means other than technological methods, such as by email, telephone, or in person.
3.4 Use of Personal Information
Purposes. We may use Personal Information to operate, maintain, develop, and improve Our Website and Services; to respond to inquiries and provide Services; to fulfill contractual obligations; and to manage billing and payments.
We may also use Personal Information to handle complaints or dissatisfaction and, where applicable, to offer personalized recommendations based on purchase profiles.
For business development and advertising, we may develop and offer new Services, conduct marketing activities (with Your prior consent), and organize or participate in events (conferences, trade shows, promotional activities). At events, certain Personal Information may be requested for professional purposes (such as identification badges) and retained for contact, follow-up, or professional reference purposes, in accordance with this Policy.
We may also use Personal Information for analytics and security, including research, statistics, and detecting or preventing fraud, errors, spam, abuse, security incidents, and other harmful activities.
Finally, we may use Personal Information for legal compliance or other purposes required or permitted by applicable laws.
3.5 Access, Disclosure, and Transfer of Personal Information
Possible access and communications. We may transfer, communicate, or allow access to Personal Information to Our employees and Service Providers who need it to operate Our Website, provide Services, carry out Our activities, or serve You.
3.5.1 Access within the Organization
Limitation of access. Personal Information is accessible only to administrators, employees, and representatives whose duties require it. This may include the Privacy Officer and departments such as IT, Sales, Human Resources, and Customer Service.
3.5.2 Communication to third parties
Protective measures. We disclose Personal Information to Service Providers only after they agree in writing to confidentiality obligations consistent with applicable laws and Our Information Governance Program. Service Providers may only use Personal Information according to Our instructions and solely for the purposes for which it was provided. We only disclose the Personal Information necessary for their mandate, and We require appropriate destruction upon contract termination or when use is no longer necessary.
Service Providers we may use. We may use providers for IT management and security, hosting and storage, marketing and analytics, invoicing and administrative operations, surveillance camera systems, and professional services such as legal or accounting support. We may also use platforms and services such as Google Analytics/DoubleClick, Google Ads, YouTube, Meta (Facebook Pixel), Microsoft Office 365, recruitment platforms, advertising agencies, and domain/website infrastructure providers (such as GoDaddy, Cloudflare, and DigitalOcean). These services may use cookies or similar technologies that can identify You and profile web activities for analytics or targeted advertising, as described in the Cookies section of this Policy.
Metatracer. We use Metatracer on Our digital systems to facilitate the detection and management of Personal Information for compliance purposes. Metatracer only collects identifying information as Personal Information.
3.5.3 Disclosure outside Quebec
Communication outside Quebec. We may communicate Personal Information outside Quebec and mandate an entity located outside Quebec to collect, use, or retain Personal Information on Our behalf.
Protections. Before communicating Personal Information outside Quebec, We conduct a privacy impact assessment to evaluate risks affecting the security of Personal Information. This assessment identifies appropriate security measures to mitigate or eliminate risks, and the communication is then governed by a written agreement requiring compliance with those measures.
3.5.4 Legal requests, prevention of harm, and protection of rights
Specific disclosures. We may disclose Personal Information when We believe disclosure is authorized, necessary, or appropriate, including to comply with legal and regulatory obligations, respond to government requests, protect Our rights and interests, protect the privacy and rights of individuals, protect Our business and ensure continuity, or enable remedies and limit damages.
Business transactions. We may share or transfer Personal Information in accordance with this Policy and applicable Quebec law in the event of a sale, transfer, merger, reorganization, liquidation, or other business transaction.
3.6 Consent
Consent. Unless otherwise required by law, the Organization obtains your consent to collect, use, and disclose Personal Information. If You provide Personal Information about other individuals, You must ensure that You have notified them and obtained their consent for disclosure.
BY USING OUR WEBSITE, TRANSMITTING YOUR PERSONAL INFORMATION BY EMAIL OR USING AN ONLINE FORM, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.
Withdrawal of consent. If You do not agree, please stop using the Website. Except where otherwise provided by law, You may withdraw consent at any time with reasonable notice. If You withdraw consent, certain features of the Website may no longer be available, or We may no longer be able to offer certain Services.
3.7 Retention of Personal Information
Retention. Subject to applicable laws, We retain Personal Information only as long as necessary to fulfill the purposes for which it was collected, unless You consent to processing for another purpose.
Additional information. For details about retention periods, please contact Our Privacy Officer using the contact information in section 1b).
4. Your Rights
Your rights. You may exercise the rights below by contacting Our Privacy Officer in writing at the contact details provided in section 1b). We may ask You to verify Your identity before responding.
You have the right to be informed of the Personal Information We hold about You and how it is used, disclosed, retained, and destroyed, subject to applicable legal exceptions. You may request access to your Personal Information and request copies of documents containing it, and obtain additional details about how We handle it. You may request correction of Personal Information that is incomplete, ambiguous, outdated, or inaccurate.
You may withdraw or modify consent to the collection, use, or disclosure of certain Personal Information (as described in this Policy), subject to legal and contractual restrictions. You may request that We stop disseminating Personal Information or de-index links associated with Your name where dissemination contravenes the law or a court order. You may request that Your Personal Information be disclosed to You or transferred to another organization in a structured and commonly used technological format.
You have the right to be informed of a privacy incident involving Your Personal Information that could cause serious harm. We maintain a register of privacy incidents and assess the harm they may cause. You also have the right to file a complaint with the Commission d’accès à l’information, subject to conditions in applicable law.
5. Questions and Complaints
Complaints. You may address complaints regarding Our practices and policies by contacting Our Privacy Officer using the contact information identified in section 1b).
Questions. You may contact Our Privacy Officer with any questions regarding this Policy using the contact information identified in section 1b).
Identification. To respond to your request, You may be asked to provide appropriate identification.
6. Cookies and other similar technologies
Use of Cookies. Cookies are small text files stored on Your device or browser. They enable collection of information such as preferred language, browser type and version, device type, and device identifier. Some Cookies are deleted at the end of a browser session, while others remain to recognize Your browser on a future visit. We use cookies and similar technologies such as pixels (collectively, “Cookies”) to operate, protect, and optimize the Website and Services. Cookies do not damage devices and cannot be used to extract Personal Information.
Browser settings. You can configure your browser to notify You about Cookies and accept or reject them. Disabling Cookies may affect browsing experience and limit certain features.
Categories of Cookies. Our Website uses Cookies to distinguish You from other users and improve your experience. To view the categories of Cookies used, consult the cookie manager accessible at the bottom of Our web page. Cookies may be strictly necessary (site functionality and security), performance-focused (analytics and diagnostics), functionality-focused (preferences and embedded content), or targeting-focused (personalized advertising and campaign measurement).
Consent to Cookies. We ask for consent before placing Cookies on your device. You may consent via the cookie banner. You may withdraw consent at any time by deleting, blocking, or disabling Cookies through the cookie banner settings or your browser settings. Disabling Cookies may prevent certain Website features from working properly.
List of Cookies. To see the complete list of our Cookies, use our cookie manager.
7. Security Measures
Purpose. We implement physical, technological, and organizational measures to protect confidentiality and security of Personal Information against loss, theft, unauthorized access, or use. These measures include administrative controls (governance policies and procedures) and technical controls (secure servers, SSL, access limitation, backups, and firewalls).
Incomplete list. We do not list all measures given the public nature of this Policy.
No absolute guarantee. Despite these measures, We cannot guarantee absolute security. If you believe your Personal Information is no longer secure, please contact the Privacy Officer immediately using the contact details in section 1b).
8. Changes to this Privacy Policy
Changes. We reserve the right to change this Policy at any time in accordance with applicable law. If changes are made, We will post the revised Policy and update the date. We will notify You reasonably in advance of the effective date of the new version. If You do not agree, We encourage You to stop using the Website and Services. Continued use after the new version takes effect means your use is governed by the updated Policy.
9. Links to third-party websites
Third-Party Services. We may include references or links to third-party websites, products, or Services. These Third-Party Services are not operated or controlled by the Organization and are governed by their own privacy policies, separate from ours. We assume no responsibility for the content and activities of these sites. This Policy applies solely to the Website and Services We offer.
10. Invisible reCAPTCHA
What reCAPTCHA does. Invisible reCAPTCHA analyzes activity (such as mouse movements and typing patterns) to determine whether a user is a robot. The reCAPTCHA service may collect information from Your device and retain it according to its privacy policy.
11. Individuals under the age of 14
Minors. We do not knowingly collect or use Personal Information from individuals under the age of 14. If You are under 14, You must not provide Personal Information without consent of a parent or guardian. If a parent or guardian learns a child has provided Personal Information without consent, they may contact Us using the contact details in section 1b) to request deletion.
12. Applicable Laws
Governing law. The laws of Canada and Quebec, excluding conflict of law rules, govern this agreement and Your use of the Website. Accessing the Website from other jurisdictions may subject You to additional laws that apply to your situation.