Privacy Policy

1. Who we are and who is accountable

This Privacy Policy applies to mircompaniesgroup.com and its sections, including the MIR Foods, MIR Marché and MIR Trade pages (together, the “Site”), and to personal information collected by MIR Capital Inc., operating as MIR Group, a corporation incorporated under the Canada Business Corporations Act, with its head office at 595 King Street East, Kitchener, Ontario, N2G 2M2 (“MIR Group,” “we,” “us,” “our”).

MIR Group has designated a Privacy Officer who is accountable for our compliance with this policy and with applicable Canadian privacy law. You can reach the Privacy Officer using the details in Section 13.

This policy does not apply to our separate brand websites, including mirellasdelices.com, mir-ai.ca and mir-maisons.com. Please review the privacy information published on each of those sites. See Section 11.

2. What personal information we collect

Information you give us directly

• Contact form submissions: your name, email address, subject line and the content of your message. Our web server also records the IP address and date and time of the submission.
• Email and telephone enquiries: any information you choose to include when you contact us at the addresses or numbers in Section 13.
• Career applications: if you apply for a role through our Careers page or by email, we collect your name, contact details, résumé or CV, cover letter, work history, and any other information you choose to submit. Résumés sometimes contain sensitive information; we ask that you include only what is relevant to the role.

Information collected automatically

• Analytics data: when you visit the Site, a third-party website analytics service acting on our behalf collects your IP address (which may be truncated or anonymized), pages viewed, time on page, referring URL, approximate location derived from IP, browser type, operating system and device type. We use this information primarily in aggregate, to understand how the Site is used. You may contact our Privacy Officer at any time to be told which analytics provider we currently use and where that provider stores data.
• Cookies and similar technologies: see Section 6.

Information we do not collect

We do not collect or process payment card information on this Site. Apart from information you choose to include in a career application, we do not knowingly collect sensitive personal information (such as health, financial or biometric information) through the Site, and we ask that you not include it in contact form messages.

3. Why we collect it

We collect, use and disclose personal information for the following purposes:

If we wish to use your personal information for a purpose not listed above, we will identify that purpose and obtain your consent before doing so, except where the law permits or requires us to proceed without consent — for example to comply with a court order, subpoena, or a request from a law enforcement or regulatory authority with lawful jurisdiction.

We do not sell your personal information. We send commercial electronic messages only where we have consent as required by Canada's Anti-Spam Legislation (CASL), which may be express consent you have given us or implied consent arising from an existing business relationship or from your conspicuous publication of a business contact address. Our commercial electronic messages identify us, give our contact information, and include a working unsubscribe mechanism. You can withdraw consent at any time.

4. Who we share it with

We share personal information only in the following circumstances:

• Within MIR Group. Your enquiry may be directed to the relevant MIR Group division or brand team so it can be answered.
• Service providers. We use third-party providers to host the Site, deliver email, and provide website analytics. These providers process personal information on our behalf under contract, and are contractually required to use it only for the purpose of providing their services to us and to protect it appropriately.
• Legal and safety reasons. Where required or permitted by law, to comply with legal process, to enforce our terms, or to protect the rights, property or safety of MIR Group, our users or others.
• Business transactions. In connection with a proposed or completed merger, acquisition, financing or sale of assets, subject to appropriate confidentiality protections.

We do not otherwise sell, rent, trade or disclose your personal information to third parties.

5. Storage location and transfers outside Canada and Quebec

Personal information collected through the Site may be stored and processed outside Canada, including in the United States, by our hosting, email and analytics providers. While personal information is located in another country, it is subject to the laws of that country and may be accessible to the courts, law enforcement and national security authorities of that jurisdiction. You may contact our Privacy Officer to be told the countries in which our current service providers store personal information.

Where Quebec's Law 25 applies, before communicating personal information outside Quebec — or entrusting a person or body outside Quebec with collecting, using, communicating or keeping it on our behalf — we conduct a privacy impact assessment considering the sensitivity of the information, the purposes for which it will be used, the protection measures that would apply to it, and the legal framework of the destination jurisdiction. We communicate the information only if the assessment establishes that it would receive adequate protection in light of generally recognized personal information protection principles, and the communication is the subject of a written agreement that takes the assessment results into account.

6. Cookies and analytics

The Site uses the following categories of cookies and similar technologies:

• Strictly necessary / functional cookies — required for the Site to work, including page navigation, form submission and security. Because the Site cannot function without them, they cannot be turned off through any cookie preference control we offer, though your browser can block them.
• Analytics cookies — used to measure traffic and understand how visitors use the Site.

We do not use advertising cookies, retargeting pixels, or cross-site tracking technologies on this Site, and we do not permit third parties to use the Site to track you across other websites.

You can block or delete cookies at any time through your browser settings, and most browsers let you refuse cookies from a specific site or delete cookies already stored. Note that blocking strictly necessary or functional cookies may prevent parts of the Site from working correctly. Where the Site presents a cookie preference control, you can also accept or refuse non-essential cookies there and change your choice at any time.

Most browsers offer a “Do Not Track” setting. Because there is no consistent industry standard for responding to these signals, the Site does not currently respond to them, but we do not engage in the cross-site tracking such signals are designed to limit.

7. How long we keep it

We keep personal information only as long as necessary for the purposes described in this policy, or as required by law. Our current retention periods are:

• Contact form and email enquiries: up to 24 months from our last correspondence with you.
• Career applications, unsuccessful candidates: up to 12 months after the recruitment decision, unless you consent to us keeping it longer for future opportunities.
• Analytics data: up to 26 months at the individual-event level.
• Records we are legally required to retain: for the period required by the applicable law.

When personal information is no longer required for these purposes, we securely delete or destroy it, or de-identify it so it can no longer be used to identify you.

8. How we protect it

We maintain physical, organizational and technological safeguards appropriate to the sensitivity of the information, including encryption of the Site in transit (HTTPS/TLS), limiting access to personal information to those who need it to carry out the purposes described in this policy, contractual obligations on our service providers, and confidentiality obligations on our personnel and contractors.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send sensitive personal information to us through the contact form or by unencrypted email.

9. Privacy and security breaches

We maintain a record of every breach of security safeguards involving personal information under our control, and retain those records for at least 24 months, as required by PIPEDA.

Where a breach creates a real risk of significant harm to you under PIPEDA, we will report it to the Office of the Privacy Commissioner of Canada and notify you as soon as feasible. Where Quebec's Law 25 applies and an incident presents a risk that serious injury will be caused, we will notify the Commission d'accès à l'information du Québec and the affected individuals promptly, and take reasonable measures to reduce the risk of injury.

10. Your rights and how to exercise them

Under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), and under Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25) where it applies to you, you have the right to:

• Access the personal information we hold about you, and be told how it has been used and to whom it has been disclosed;
• Correct information that is inaccurate, incomplete or out of date;
• Withdraw consent to our use of your personal information at any time, subject to legal or contractual restrictions and reasonable notice — we will explain the consequences if withdrawal affects a service;
• Request deletion of information we hold, which we will honour where we are not legally or contractually required to retain it;
• Request portability — if you are a Quebec resident, to receive computerized personal information you provided to us in a structured, commonly used technological format, or to have it transferred to another organization;
• Request de-indexing or cessation of dissemination — if you are a Quebec resident, in the circumstances set out in Law 25;
• Be informed about automated decision-making — we do not currently use personal information collected through this Site to make a decision about you based exclusively on automated processing. If that changes, we will tell you at the time of the decision and, on request, explain the personal information and principal factors used, and give you the opportunity to submit observations to a member of our personnel.

To exercise any of these rights, contact our Privacy Officer using the details in Section 13. We may ask you for information to verify your identity before acting on a request.

Our response times. We will respond to an access or correction request within 30 days of receiving it. Under PIPEDA we may extend that period by up to a further 30 days in the limited circumstances the Act permits — for example where meeting the deadline would unreasonably interfere with our activities, or where consultations are needed. If we extend, we will tell you within the original 30 days, explain why, and tell you about your right to complain to the Privacy Commissioner. Where Law 25 applies, we respond within 30 days without extension. Access is provided free of charge in most cases; if a fee would apply, we will tell you in advance and give you the chance to withdraw your request.

11. Links to other sites

The Site links to MIR Group brand websites, including mirellasdelices.com, mir-ai.ca and mir-maisons.com, and to third-party websites. This policy does not apply to those sites, and MIR Group is not responsible for the privacy practices or content of sites we do not operate. We encourage you to review the privacy information published on any site you visit before providing personal information to it.

12. Minors

The Site is intended for a general and business audience and is not directed to children or teenagers. We do not knowingly collect personal information from anyone under 18 through the Site.

Where Quebec's Law 25 applies, we do not collect personal information from a minor under 14 years of age without the consent of the person having parental authority or of their tutor, unless collecting the information is clearly for the minor's benefit.

If you believe a minor has provided us with personal information, contact our Privacy Officer and we will delete it.

13. Contact us

We're here to help.

We welcome your questions, comments and complaints about this policy or our handling of personal information.

We will acknowledge your enquiry, investigate it, and inform you of the outcome. If you are not satisfied with our response, you may make a complaint to:

Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, QC K1A 1H3
Toll-free: 1-800-282-1376 — priv.gc.ca

Commission d'accès à l'information du Québec (Quebec residents)
Toll-free: 1-888-528-7741 — cai.gouv.qc.ca

14. Changes to this policy

We may update this policy to reflect changes in our practices or in the law. The “Last updated” date at the top of this page shows when the most recent version took effect, and we encourage you to review it periodically.

Where a change is material, we will post a notice on the Site before the change takes effect. Where a change would involve using personal information we already hold for a new purpose, we will obtain your consent to that new purpose.