Privacy Statement

1. Person in Charge of Processing

This privacy policy applies to the website operated by Vie North Hatley (referred to in this policy as “we,” “us,” or “our”). By visiting our website, you acknowledge that we collect and use personal information as described below.

Vie North Hatley is subject to Quebec Law 25 (An Act to modernize legislative provisions as regards the protection of personal information, S.Q. 2021, c. 25), which governs how we collect, use, disclose, and retain personal information about you.

Our website is hosted in Quebec, Canada, through Horizon-Cumulus (9322-8310 Québec inc.), with servers located at OVH Beauharnois, Quebec. Your personal information collected through our hosting infrastructure remains in Quebec.

2. Personal Information Collected

We collect the following categories of personal information when you visit our website. We collect only what is necessary for the purposes described in this policy.

• Device and network identifiers: Your IP address, collected by our analytics platform, web font providers, and our consent management tool.
• Browsing behavior: Pages you visit, duration of your session, navigation patterns, and approximate geographic location, collected through our analytics platform.
• Device identifiers: Technical identifiers associated with your browser or device, collected through our analytics platform.
• Consent preferences: Your cookie consent choices, stored locally in your browser via a cookie named moelleux_{site_key} and recorded in our consent management system hosted in Quebec.

We do not collect your name, email address, phone number, or any other directly identifying information through our website unless you contact us directly.

3. Purposes of Processing

We use the personal information we collect for the following purposes, each tied to a legal basis under Quebec Law 25:

• Website analytics and audience measurement — We use Google Analytics 4 to understand how visitors use our website, which pages are most visited, and how long sessions last. This helps us improve our content and user experience. The legal basis is your consent, which you provide through our cookie consent banner. You may withdraw this consent at any time.
• Display of web fonts — We use Google Fonts and Adobe Fonts (Typekit) to render text on our website in a visually consistent way. These services receive your IP address as a technical necessity of loading the fonts. The legal basis is our legitimate interest in presenting a functional and readable website. Font requests do not involve any profiling or tracking.
• Consent management — We use Moelleux (operated by Horizon-Cumulus, Joliette, Quebec) to record and manage your cookie consent preferences. This is an essential function of our website and does not require separate consent. Consent records are stored in Quebec.
• Business email communications — When you contact us directly, your email may be processed through our business email infrastructure, which includes Horizon-Cumulus Email (Quebec) and Microsoft 365 (United States). See Section 5 for details on cross-border transfers.

4. Third Parties and Processors

The following third-party services process personal information on our behalf or in connection with your use of our website:

5. Transfers Outside Quebec

Some of the services we use transfer personal information outside Quebec, including to the United States. Under section 17 of Quebec Law 25, we are required to disclose these transfers and ensure that personal information communicated outside Quebec receives protection equivalent to that provided by Quebec law.

The following transfers outside Quebec occur in connection with our website:

• Google Analytics 4 (United States): When you visit our website and analytics cookies are active, your device identifiers, IP address, browsing behavior, and approximate location are transmitted to Google LLC, based in the United States. Google Analytics 4 offers data processing terms and IP anonymization features. We have enabled these safeguards. You may opt out of analytics tracking at any time through our consent banner.
• Google Fonts (United States): Loading web fonts from Google’s servers transmits your IP address to Google LLC in the United States. This is a technical necessity of font delivery and involves no profiling.
• Adobe Fonts / Typekit (United States): Loading web fonts from Adobe’s servers transmits your IP address to Adobe Inc. in the United States. This is a technical necessity of font delivery and involves no profiling.
• Microsoft 365 (United States): When you contact us by email, your message and contact details may be processed through Microsoft 365, operated by Microsoft Corporation in the United States. Microsoft provides standard contractual clauses and data processing agreements to safeguard personal information transferred outside Canada.

Before communicating personal information to these service providers, we have assessed or rely on the providers’ published safeguards to confirm that the information will receive adequate protection. A Privacy Impact Assessment (PIA) has been or will be conducted as required by Quebec Law 25 for transfers involving personal information of Quebec residents.

6. Retention Period

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.

When personal information is no longer needed, it is securely deleted or anonymized in accordance with our data destruction practices.

7. Your Rights

Under Quebec Law 25, you have the following rights regarding your personal information. To exercise any of these rights, please contact us using the information in Section 8.

• Right of access: You may request a copy of the personal information we hold about you, along with information about how it is used and with whom it has been shared.
• Right of rectification: If any personal information we hold about you is inaccurate, incomplete, or ambiguous, you may ask us to correct it.
• Right of erasure: You may ask us to delete personal information that we collected unlawfully, that is no longer necessary for the purposes for which it was collected, or where you have withdrawn your consent and no other legal basis applies.
• Right of portability: You may request that we provide you with the personal information you have given us in a structured, commonly used, and machine-readable format, or that we transmit it directly to another organization where technically feasible.
• Right to withdraw consent: Where we rely on your consent to process personal information (such as for analytics cookies), you may withdraw that consent at any time by updating your preferences through our cookie consent banner. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

We will respond to your request within 30 days of receipt, as required by Quebec Law 25.

If you are not satisfied with our response, you have the right to file a complaint with the Quebec Information Access Commission (CAI) at www.cai.gouv.qc.ca.

8. Person Responsible for the Protection of Personal Information

In accordance with section 3.1 of Quebec Law 25, Vie North Hatley has designated a Person responsible for the protection of personal information. This person oversees compliance with Quebec Law 25 and handles all requests and inquiries related to personal information.

• Name: —
• Title: —
• Email: info@vienorthhatley.com
• Phone: ————————

You may contact the Person responsible for the protection of personal information at any time to exercise your rights, ask questions about this policy, or raise a concern about how your personal information is handled. We will acknowledge your request promptly and provide a full response within 30 days, as required by Quebec Law 25.

9. Effective Date and Versioning

This privacy policy takes effect on 19 juin 2026 and supersedes any prior version.

Version: 1

We may update this policy from time to time to reflect changes in our practices, the services we use, or applicable law. When we make material changes, we will update the effective date above and, where appropriate, notify you through our website. We encourage you to review this policy periodically.