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Privacy Policy

Last updated: October 16, 2026

What Is This Privacy Policy?

This Privacy Policy (the “Policy”) explains how BorealTRAXX collects, uses, discloses, retains and destroys your personal information. We take the privacy of the personal information you provide to us seriously. When you provide us with personal information, you acknowledge that it will be handled in accordance with this Policy and authorize BorealTRAXX and its service providers to process your personal information for the purposes described herein. BorealTRAXX is responsible for the processing of your personal information unless otherwise stated.

 

BorealTRAXX determines the purposes for which personal information in its possession is processed and how that processing is carried out.

Collection of Personal Information

When you communicate with us, we may need to collect certain personal information about you. In connection with our services and business activities, the information collected may include:

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  • Contact information: first and last name, home address, home, mobile or business telephone number, and email address.

  • Business information: role, position, company or organization name, and company or organization address.

  • Identification and background verification documents: copies of a driver's licence, health insurance card or other identification documents, where applicable.

  • Billing and financial information: billing address, banking details and payment information.

  • Consent records: where consent is required to process personal information.

  • Marketing, communication and website preferences: communication preferences, comments, survey responses, consent preferences, information collected through cookies, website visits and content views, IP address and network information.

  • Recruitment information: résumés, references from previous employers, employment history and professional affiliations.

  • Publicly available information: information from social networks or public websites, including social media interactions.

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Your personal information is collected only when you voluntarily provide it to us.

Sharing of Personal Information

Personal information may be shared with the parties identified below. Such information will be shared solely to achieve the primary and legitimate purpose for which it was collected, or for purposes compatible with that purpose. Only the information necessary for these purposes will be shared.

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  • BorealTRAXX employees: Where required for recruitment, human resources or other business purposes.

  • Service providers: These may include IT, hosting and other service providers. Depending on the services provided, they may access or process personal information. Only the information strictly necessary to fulfil their contractual obligations will be provided. Each service provider has agreed in writing to maintain the confidentiality of the information received or accessed.

  • Government authorities or law enforcement agencies: Where disclosure is required by law, made in good faith to meet a legal obligation, or necessary in response to a court order, subpoena, search warrant or request from government authorities or law enforcement agencies.

  • A purchaser or successor of BorealTRAXX: Where required in connection with a business reorganization, merger, acquisition, financing, asset sale, insolvency or bankruptcy, in which personal information may be considered a business asset.

Methods of Collection

Most personal information is collected directly from you through our communications regarding the provision of services, your visits to our website, your communications with our office by any means, and your registration for activities organized by BorealTRAXX.

Use of Personal Information

Where applicable, personal information is used for the following purposes:

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  • Providing services: To conduct our business, administer and deliver our services, and fulfil our obligations under a contract entered into between you and us.

  • Business relationships: To personalize our services, manage and strengthen our relationships with customers, understand our customers' needs and strengthen our relationships with business partners.

  • Fraud prevention: To conduct background checks, make disclosures required by applicable laws or regulations, and provide information to law enforcement agencies where required by law.

  • Debt collection: To ensure that invoices for services provided are paid.

  • Business reorganization: In the event of a BorealTRAXX reorganization, we may need to disclose information as part of a due diligence process conducted by another company.

  • Regulatory compliance: To meet our legal, regulatory and risk management obligations.

  • Events, marketing and business development: To organize events, inform you about new services and invite you to events that may be of interest to you.

  • Recruitment: To review submitted applications, assess applicants' qualifications and support the recruitment process.

  • Website use: To ensure that the content published on our website is relevant, understand how visitors use the website and ensure that online content is properly displayed across different devices and connection types.

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BorealTRAXX undertakes not to use personal information collected in accordance with this Policy or applicable legislation for other purposes, unless you provide your prior consent or exceptional circumstances allow or require such use under the law.

Retention of Personal Information

Personal information is retained only for as long as necessary to fulfil the purposes set out in this Policy and to comply with our legal and regulatory obligations. Personal information is retained for a period of three to seven years after the purposes described in this Policy have been fully fulfilled.

Protection of Personal Information

Your personal information is protected in accordance with applicable requirements through physical, technical and administrative safeguards designed to reduce the risk of unauthorized access. These safeguards are intended to protect your information against theft, loss, accidental destruction, unauthorized use or access, alteration and other prohibited processing of personal information.

Access to personal information is restricted to personnel who need to know or access the information to perform their duties.

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Your data is hosted in Canada at all times. The applicable data protection requirements depend on the location where the data is hosted. Accordingly, the applicable obligations are those established by Canadian laws and regulations governing the protection of personal information. Our practices are governed by this Policy and the applicable laws.

 

Please note that no transmission of personal information over the internet and no electronic storage method is 100% secure. BorealTRAXX cannot guarantee the security of information transmitted in this manner, and you accept the associated risks. BorealTRAXX also cannot guarantee that personal information will never be accessed, destroyed, altered or disclosed despite the safeguards in place.

Rights of Individuals Whose Personal Information Is Collected

In accordance with applicable personal information protection laws and regulations, if BorealTRAXX holds personal information about you, you have rights concerning that information. To exercise your rights, please refer to the “Contact Us” section for the contact information of BorealTRAXX's Privacy Officer.

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Under applicable laws and regulations, you have the following rights:

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  • Access: You may request access to the personal information we hold about you. Upon receiving your request, BorealTRAXX's Privacy Officer will review the personal information held and provide you with a copy, subject to applicable law and any applicable fees.

  • Accuracy: We are required by law to take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up to date.

  • Correction: You may request that any personal information about you that is inaccurate or incomplete be corrected.

  • Withdrawal of consent: You may withdraw your consent to the collection, use and disclosure of your personal information at any time.

  • Right to be forgotten: You may request that the dissemination of your personal information cease or that it be de-indexed from any hyperlink that provides access to it through technological means.

Contact Us

If you have any questions or comments about this Policy, wish to exercise your rights regarding your personal information, submit an access request or file a complaint, please contact our Privacy Officer using the following information:

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Privacy Officer

Pierre-Olivier Brault

info@borealtraxx.com

Changes to This Policy

Our website, its content and this Policy may be amended in the future without prior notice. We encourage you to review this Policy when visiting our website to stay informed about how BorealTRAXX handles personal information. This Policy was last updated in October 2026.

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