Transcontinental Inc. and its direct and indirect subsidiaries (collectively, “TC Transcontinental”, “we”, “us” or “our”) are committed to maintaining the privacy, security and accuracy of personal information under our care and control.

TC Transcontinental is responsible for the use and protection of the personal information of individuals who work for us and those who apply for a vacant position or other work opportunity at TC Transcontinental, whether employed by us or not (“collectively, “HR Data Subjects”, “you” or “your”).

This recruitment privacy notice (“Privacy Notice“) sets out the terms and conditions under which TC Transcontinental collects, processes, discloses, and protects your personal information in accordance with applicable privacy laws (“Applicable Laws“).

Section 1. Personal Information

For the purposes of this Privacy Notice, “personal information” refers to any information which relates to a natural person and directly or indirectly allows that person to be identified including, but not limited to, an individual’s name, physical address, personal telephone number, personal email address, gender, race, ethnic information, medical information, personal contact details, financial, credit and billing information, identification and other background verification data, employment history and other information relevant to potential recruitment or association to or with the TC Transcontinental, website usage information, biometric characteristics or measurements, and other information about an identifiable individual.

Section 2. Types of Personal Information Collected

To carry out the purposes described in this Privacy Notice, we may collect and process the following personal information of HR Data Subjects:

• Identification and Contact Information. Full name, address (whether personal or work), birthdate, place of birth, telephone number (whether personal or work), mobile phone number (whether personal or work), email address (whether personal or work), civil status, current employer or business and job position.
• Academic Data. Academic background, certificates and transcripts, information about education and academic performance, and information about courses, academic and/or professional programs, trainings, recognitions or certifications.
• Employment Data. Employment history, curriculum vitae, awards or recognitions obtained, professional associations to which the HR Data Subject belongs, employment references, information related to previous jobs, position, work address, information on your performance and evaluations, promotions, disciplinary allegations, investigations and processes, participation in pension arrangements and employment benefits such as life, dental, medical and disability insurance, details of trade union membership.
• Payroll Administration. Information on your bank account, pension contributions and on tax and national insurance, information on attendance, holiday and other leave and sickness absence.
• Data from public sources and/or received through consented transfers. Data and information from public records, including criminal records, credit bureau reports, directories, social networks, and other lawful sources available in the market, as well as personal information that has been shared with us by third parties to whom you have previously authorized.
• Financial Information. Credit history and credit bureau reports, financial institution account number, salary and other forms of compensation, deductions of contributions made at source, pay and pay benefits, any bonus or share schemes.
• Sensitive Information: Images of your governmental identification cards, health information, occupational health reports, information on your nationality, racial and ethnic origin, gender, sexual orientation, religion and disabilities (only with your explicit consent).
• Metadata: Data related to your use of workplace tools and systems (e.g., email, internet usage, meeting recordings), sign-in logs, records of use of swipe and similar entry cards, CCTV images, records of your use of our systems including computers, phones and other devices and passwords.

Your personal information is collected through any of the following methods: (i) the voluntary and direct provision of your information through our printed or digital forms, by email or by phone, or through the use of professional or other online platforms or social networks (e.g., LinkedIn), (ii) the voluntary video recordings of interviews, (iii) the use of public access sources and other publicly available sources, including public records and social networks, (iv) the transfer within members of the TC Transcontinental group, and other transfers consented to by third parties, (v) from your managers and other colleagues or our IT systems, (vi) feedback and survey responses, (vii) from our customers, service providers or those with whom you communicate by email or other systems.

Your personal information may be contained in different documents, whether printed or in digital form.

Section 3. Purposes of Processing Personal Information

The personal information we collect from you will be used for the following purposes:

• to verify and confirm your identity and contact information;
• to manage your recruitment, evaluation, and selection process, as well as to review and analyze your suitability for a possible job position with us;
• to verify the provided information and analyze your job application and evaluate your knowledge, skills, abilities, and/or work skills;
• to make a job offer according to our selection and/or hiring processes and criteria;
• to request employment references, as well as to conduct statistical reports;
• to perform background checks and screening investigations as permitted by law to verify and confirm your information;
• to manage your access to our facilities;
• to review and address your requests and/or comments;
• to comply with applicable legal provisions, as well as to meet and comply with the requirements of competent authorities;
• to verify your eligibility under our employee benefits programs;
• to administrate payroll, benefits, and employment contracts;
• to communicate changes to our payroll process or new benefit programs or partners;
• for workplace safety, security, and health-related accommodations;
• to change or end your working arrangements;
• to comply with legal obligations under labor, tax, and social security laws;
• to conduct internal audits, performance reviews, and business operations;
• to monitor and investigate compliance with TC Transcontinental’s policies and rules;
• to pursue or manage disputes and legal proceedings, and provide answers to related requests, including those arising in the context of divorce proceedings or other legal proceedings involving you;
• to administrate trade union membership and deductions of contributions made at source;
• to provide information to third parties, such as a prospective purchaser or seller, adviser, or consultant, in connection with transactions that we contemplate or carry out;
• to monitor diversity and equal opportunities;
• to report to our board of directors;
• to facilitate any required data transfers; and
• to send you notifications regarding changes to this Privacy Notice.

In addition, the personal information of job applicants may be used for the following secondary purposes: (i) to maintain physical and/or electronic records of your data and information for our job pool for future employment opportunities; (ii) to evaluate and improve our recruitment, evaluation, and/or selection procedures for employment, and (iii) to communicate news and/or invite you to job-related events.

If you do not wish for your personal information to be used for these secondary purposes, please contact our Chief Privacy Officer in accordance with the procedure outlined in Section 8 of this Privacy Notice. The refusal to use and process your personal information for these secondary purposes cannot be a reason for us to deny or reject your participation in our recruitment, evaluation, and selection process for employment.

Your personal information may be used for other purposes different from those mentioned above, as long as those purposes are related and compatible with the ones described above. In the event that we need to use your personal information for purposes other than those stated in this Privacy Notice, you will be notified in writing, by phone, electronically, or by any other means, explaining the new uses and/or purposes intended for your personal information in order to obtain your consent, whether express or implied, unless otherwise permitted by law.

Section 4. Data Transfers

For business, employment, administrative and management purposes mentioned in this Privacy Notice, your personal information may be transferred to:

• Members of the TC Transcontinental group.
• Service providers (e.g., payroll processors, insurance or other benefit providers, our banks and organizations that host our IT systems and data) outside of your region, in accordance with the purposes described in this Privacy Notice.
• Regulatory bodies or government agencies to comply with legal obligations.
• External recipients of electronic communications (such as emails) which contain your personal information.
• Potential buyers of our business or company for the purposes of evaluation of the acquisition – but only if we were to contemplate selling.

When your personal information is transferred, we take appropriate measures to ensure that it is treated in a confidential and secure manner, and in accordance with Applicable Laws.

Section 5. Retention and Security Measures

Your personal information will be retained only as long as necessary for the stated purposes or as required by law, or as otherwise required under TC Transcontinental’s Data Retention Policy. Personal information relating to job applicants (other than the person who is successful) will normally be deleted after 12 months or such longer period as may be required by Applicable Laws.

TC Transcontinental implements appropriate technical and organizational measures to protect your personal information from unauthorized access, loss, or misuse. Your personal information will be kept confidential, in accordance with the administrative, technical and physical security measures that TC Transcontinental implements in its policies and security procedures that allow to protect them against unauthorized access, loss, or misuse.

Only those individuals authorized by us, including our representatives and employees, as well as those third parties who carry out the processing of your personal information on our behalf, will have access to your personal information for purposes mentioned in this Privacy Notice.

Section 6. Your Rights

At any time, you have the right to (i) request access your personal information that we hold, (ii) request us to rectify your personal information when it is inaccurate or incomplete, to the extent it is not impossible or requires disproportionate efforts, (iii) request the deletion of your personal information, except in cases provided by Applicable Laws or this Privacy Notice, (iv) oppose to the processing of your personal information for legitimate reasons and specific purposes, except when such personal information is necessary for us to fulfill our obligations, (v) withdraw or revoke your consent and object to the processing of your personal information, except in cases where such personal information is collected and/or processed for purposes necessary in connection with your recruitment, hiring and/or employment, and/or to comply with obligations derived from the legal relationship between you and us, and (vi) request that a copy of any of your computerized personal information that we have collected directly from you be provided to you or to any person or entity legally authorized to collect such information (collectively referred to as “Data Subject Rights“).

You can exercise these Data Subject Rights either directly or through your legal representative by submitting a written request (the “Data Subject Right Request“) to our Chief Privacy Officer by email at chiefprivacyofficer@tc.tc or by fax at (514) 954-2802. Alternatively, you can contact our Chief Privacy Officer by mail at:

Chief Privacy Officer Transcontinental Inc.

1 Place Ville Marie, Suite 3240

Montréal, Québec H3B 0G1 Canada

To process a Data Subject Right Request, we may require the following information and accompanying documents from which we can satisfy ourselves as to your identity:

• Your full name and email address or any other contact method to communicate the response to the Data Subject Right Request.
• Documents that verify your identity and that of your legal representative, if applicable (photocopy in printed or electronic format of your ID, and, if applicable, a photocopy in printed or electronic format of the public deed or power of attorney of your legal representative, along with a copy of their respective ID).
• A clear and precise description of the Data Subject Right you seek to exercise and the personal information to which you want to apply any of those rights.
• Any other information or document that facilitates the location of your personal information.
• In the case of rectification requests, they must indicate the modifications to be made and provide the documentation that justifies such modification (when applicable).

We will respond to the Data Subject Rights Request within thirty (30) days of receipt, or within any shorter timeframe required by Applicable Laws, subject to a notice of extension when justified.

If the documents and/or information provided in your Data Subject Right Request are incorrect or insufficient, or if the corresponding documents are not provided, we may request you to provide the necessary information or documents to process your request.

You will have ten (10) business days following the date of receiving our request for additional documents and/or information to provide such documents and/or additional information. Please note that if you fail to provide the requested documents and/or information during this period, your Data Subject Right Request will be considered as not submitted.

Section 7. Updates to This Privacy Notice

This Privacy Notice will be periodically reviewed and updated as necessary to ensure its continued relevance and compliance with Applicable Laws. You will be notified of changes through internal communications, TC Transcontinental’s intranet or emails.

Section 8. Questions and Support

For questions or concerns regarding this Privacy Notice or the handling of your personal information, please contact TC Transcontinental’s Chief Privacy Officer at chiefprivacyofficer@tc.tc. See Section 6 above for additional contact information.