Privacy Policy – Job Applicant (Quebec) (ENGLISH)

LAST UPDATED: September 23, 2024

1. Overview

This Job Applicant Privacy Policy (“Policy”) sets out the manner in which KIK International LLC and KIK Holdco Company Inc. (collectively, “KIK”, “we” or “our”) collect, use, process, disclose, and store personal information provided to us in the course of applying for a role with KIK in Quebec, in order to carry out our recruitment process. This Policy applies solely to residents in the province of Quebec, Canada and the rights that residents may have under Quebec privacy laws (“Quebec Privacy Law”). This Policy does not reflect our processing of such residents’ personal information where an exception under the applicable Quebec Privacy Law applies.

This Policy may be modified by KIK from time to time in order to reflect changes in law, regulator guidance and KIK's own business needs. If you have any questions or concerns about the contents of this Policy, please contact privacyofficer@kikcorp.com.

2. What personal information we collect and why?

KIK may collect, use, disclose, store or otherwise process the following types of personal information relating to any applicant to KIK, whether in electronic, paper, or oral recorded format (“Personal Information”), for the purpose of carrying out our recruitment process, as required by applicable law in order to fulfill KIK's legal, regulatory or administrative obligations, for another purpose set out in this Policy, or for any other purpose for which KIK or its affiliates may otherwise be permitted under applicable law:

Category of Personal Information	Specific Personal Information Collected, Used, or Disclosed	Purpose(s) for Collecting, Using, or Disclosing Personal Information
Identifying Information	Name, home address, home telephone number, mobile telephone number, personal email address Date of birth Passport number and driver's licence number Immigration information Social Insurance Number Sex and gender status Professional memberships Other identifying information needed to process the application	To correspond with the applicant, whether by email, telephone, or mail To send work-related documents home, including, as applicable, work policies and offers, and other work-related information To determine whether a candidate for employment is eligible to work for KIK To satisfy KIK's legal obligations To process the candidate’s application
Recruiting Information	Information collected about a candidate for employment with KIK, including but not limited to Job application Resume, curriculum vitae, or biography Educational history, degrees, and transcripts Work experience Information we may obtain directly or through a service provider Professional and other certifications Reference letters	To screen a candidate for employment for their qualifications for employment and competences, in order to make informed hiring decisions To solicit external feedback about a candidate for employment from individuals who are more familiar with the candidate To screen a candidate for risks relating to their lack of qualifications, fraudulent applications, or lack of integrity To support, procure, or tailor training programs To reasonably accommodate a candidate in need To manage the candidate’s application process
Pre-employment health data	Information about any medical restrictions impacting a candidate’s ability to engage in the application process	To ensure that reasonable accommodations are provided where they are verifiable

In addition, our third party providers of background check services will disclose background check data including criminal records history and drug screening data they have collected to us. You will be requested to sign a consent form from such third party providers for such disclosure.

3. Disclosures

From time to time, we may need to disclose Personal Information we hold to relevant third parties in the following circumstances and for the stated purposes:

For Compliance Purposes: We may share Personal Information between KIK entities or with one of our service providers that provides administrative or other services to us, such as the management of our email system, the processing of our data, or the hosting of our databases.
Sale of KIK: Personal Information may be disclosed by KIK or one of our advisors or service providers to buyers or prospective buyers in connection with the sale of a part of or the whole of KIK or KIK's assets.
Government or Regulatory Request: We may disclose specified Personal Information to third parties in response to a valid administrative or judicial order, including court orders, subpoenas and search warrants, or similar information requests from government authorities or in order to comply with the requirements of a regulatory body that governs any of our professional practices.
Litigation: We may have to disclose Personal Information in order to establish or exercise our legal rights or to defend the rights, property, or safety of our organization or others; or in connection with litigation in response to a discovery request. This information may be disclosed by KIK or by the service provider or the entity that holds the Personal Information in its servers on behalf of KIK.
Crimes: We may disclose Personal Information to a private or public investigator in order to detect or prevent criminal activities, fraud, material misrepresentation, or material nondisclosure.
Advisors and Service Providers: We may disclose some Personal Information to KIK's legal, HR, and/or recruitment advisors as is required to efficiently proceed with the application process as well as to third party service providers that assist KIK in carrying out the purposes stated in this Policy.

4. Security

KIK takes commercially reasonable steps intended to maintain physical, procedural, and technical security in its offices, information systems, and information storage facilities in order to protect Personal Information from loss, misuse, unauthorized access, erroneous disclosure, alteration, or destruction. We restrict access to Personal Information to those individuals who need access to this information in order to assist us in performing our duties and obligations. We require all third party service providers that host or otherwise manage our information systems to safeguard the Personal Information they have access to.

KIK employees are required to keep all Personal Information strictly confidential, to access it only on a need to know basis, and not to use it or to disclose it to third parties other than as permitted under this Policy, an agreement, or as permitted or required by applicable law. Failure to do so will be regarded as serious misconduct and will be dealt with in accordance with KIK’s disciplinary policy and procedure.

5. Your rights

Quebec Privacy Laws provide Quebec residents with the following rights:

The right to be informed. You have the right to know what personal information is collected from you, the means of collection of the personal information, the purposes of use of the collected information, the categories of persons without our company who have access to collected personal information, and the duration of time that the personal information will be kept.
The right of access. You have the right to access to the personal data we hold about you (subject to certain restrictions). We may charge a reasonable fee taking into account the administrative costs of providing the information. Unfounded, excessive or repetitive requests may be ignored.
The right to rectification. You have the right to have your personal data rectified if it is incorrect or outdated and/or completed if it is incomplete.
The right to erasure/right to be forgotten. In some cases, you have the right to have your personal data erased or deleted, de-indexed from association with your name, or to otherwise have us cease disseminating your personal information. Note this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data.
The right to withdraw consent. You can withdraw your consent to our processing of your data when such processing is based on consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
The right to restrict processing. You have a right not to have your personal information subject to automated processing (e.g. profiling).
The right to data portability. You can request that computerized personal information held by KIK be provided to you in a structured and commonly used technological format.

6. How to Exercise Your Rights

Methods of Submission and Instructions: To submit a request to exercise your rights as a Quebec resident under Quebec Privacy Laws, please email privacyofficer@kikcorp.com.
Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent by taking the steps outlined under "Authorized Agent" further below. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested. We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.
Authorized Agents: You can designate an authorized agent to make a request on your behalf if the authorized agent is a natural person or a business entity registered with the Province of Quebec or other relevant competent government body, we receive a written authorization stating that you have authorized the authorized agent to submit a request on your behalf which has been signed by you and the authorized agent, and we have verified the identity of you and the authorized agent.

7. Storage, retention, and transfer of personal information

Candidate Personal Information will be stored or transferred to KIK's corporate facilities, or to service providers, in Canada and the United States as applicable. Please be aware that information we collect, including personal information involving Quebec residents, may be transferred to, and processed, stored and used by KIK or its service providers outside of the Quebec, including, for example, in other locations in Canada and the United States.

We take measures to ensure that recipients in other jurisdictions (i) provide an adequate level of protection; and (ii) will not use your Personal Information for purposes other than those described in this Policy.

We retain Personal Information and dispose of it in accordance with our records management policy or agreements, as applicable, and in accordance with applicable laws.

8. Contact information

Any candidate can contact us at any time if they have questions or requests with respect to the contents of this Policy or any matters related to KIK's handling of their personal information. Please feel free to contact privacyofficer@kikcorp.com.