Privacy Policy

Last update: August 19th, 2025

Thank you for visiting the website of Gentilhomme inc. (“Gentilhomme”). This Privacy Policy applies to the website accessible at the link www.gentilhomme.com (the “Website”).

1. WHO WE ARE

For the purposes of this privacy policy (the “Privacy Policy”), any reference to Gentilhomme is deemed to include its affiliated entities (including any parent company or subsidiary), as well as their respective employees, officers, administrators, shareholders, agents, subcontractors, and other representatives. When we use the expressions “we”, “us”, or “our” below, we are referring to Gentilhomme.

This Privacy Policy describes how we may collect, use, communicate, disclose, and otherwise process the personal data shared through the use of the Website. Our Privacy Policy also describes how we ensure data security, as well as your rights regarding the personal data we hold about you. In addition to this Privacy Policy, your visit of the Website is also subject to (i) our Terms & Conditions, available at [note: insert link], and (ii) any other terms or conditions that may be communicated to you from time to time by Gentilhomme.

If you do not consent to Gentilhomme’s practices regarding the collection, use, communication, disclosure, and processing ofyour personal data as set out in this Privacy Policy, please do not provide us with your personal data and do not use the Website.

2. WHEN AND HOW WE COLLECT YOUR PERSONAL DATA

2.1 Direct Interactions

We may collect your personal data in the context of the following direct interactions with you:

  • When you contact us by using a general e-mail address made available on the Website,
  • When you submit a job application; and
  • When you interact with us on social media.

2.2 Automated online technologies or interactions

We may collect certain types of information electronically when you interact with our Website, reach out to us via email or social media accounts, or through the use of our or a third party’s technology, which include cookies, web beacons, single pixel gifs, or analytics engines.

We may combine this information with other information collected online such as your browsing history.

The technologies we use include:

  • Cookies, which are small text that contains a unique identification number which is transferred from the Website to the hard drive of your computer and are used to distinctly identify users of the Website and to track some of their activities on Website.
  • Web beacons, and single pixel gifs, which are small image files that have information about you, such as your IP address, that can be downloaded when you visit a website or open an e-mail.
  • Web analytics tools such as Google Analytics, which uses cookies to analyze your use of our Website, to create reports about visitor and user activities for us and to provide further services associated with the use of our Website.
  • Analytics engines, which pull Usage data from multiple sources and help manage and collect this data to use for personalization, interest-based advertising, customizing content and other methods to gain insights into the needs and preferences of visitors to our Website.
  • Tools that help protect against inappropriate uses, such as Google Invisible reCAPTCHA, which collects hardware and software information, such as device and application data and the results of integrity checks, as well as unique online identifications such as IP address, and sends that data to Google for analysis.

You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our Website.

2.3 Third Party Sources

We may obtain information about you from other sources, including from customers, service providers and business partners, and combine such information with other data that we hold about you. For example, we may obtain some of your personal information from third parties such as Google Analytics when you submit your application for a job through a technological platform operated by a third party (i.e. the Linkedin platform or any other platform or provider whose services are retained by Gentilhomme).

3. WHAT PERSONAL DATA WE COLLECT

For the purposes of this Privacy Policy, the term “personal data” means any information about an individual from which that person can be identified. It does not include data from which identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you:

  • Contact data, which includes name, surname, email address, title, telephone number, address, postal code, and contact preferences;

  • Data from analytical tools such as Google Analytics, which may include IP address, gender, age and interests (usually in the form of Aggregated data);

  • Demographic data, which includes date of birth or gender;

  • All information that may appear in a resume or other documents submitted in connection with a job application;

  • Social media data, which includes information associated with your social media accounts and related profiles, such as name, username, email address, profile picture, date of birth and gender;

  • Technical data, which includes IP (Internet Protocol) address, your login data, your time zone and location settings, information about your type of browser, operating system and Internet service provider and other technologies on the devices you use to access our Website; and

  • Usage data, which includes clickstream, your browsing patterns, the websites you visited immediately before and immediately after visiting our Website, the pages requested, the number of times you have visited the Website, the number of visits to our Website, and the date and average time spent on our Website.

We may also collect, use, store, and share aggregated data, ( such as statistical or demographic data), which could be derived from your personal data but may not reveal your identity (e.g.: usage data to calculate the percentage of users accessing a specific Website feature). If we combine or connect Aggregated data with your personal data so that it can identify you, we will treat the combined data as personal data and use it in accordance with this Privacy Policy.

4. HOW WE USE THE PERSONAL DATA WE COLLECT ABOUT YOU

4.1 General principles

We limit the collection of personal data to what is reasonably required to fulfill the purposes for which it is collected. Most commonly, we will collect and use your personal data in the circumstances described in section 4.2 below.

4.2 Purposes for which personal data is collected and processed

We have set out below, a description of all of the ways we may use your personal data.

  • If you contact us by using an e-mail address made available on the Website, (including about the services and products we offer or for the purpose of asking a question, submitting a comment, or other written communications, we use your personal data to respond to your inquiries;
  • In the context of a job application or related request for information, we use your personal data to process and respond to your job application or request regarding present and future career prospect (data may also include information included in a resume, a cover letter or other similar documents related to a job application);
  • When we need to perform the contract that we are about to enter into or have entered into with you: for instance, processing your data where it is necessary for the performance of a contract to which you are a party or to take steps on your behalf or at your request before entering into such a contract;
  • When it is necessary to manage our business: for instance, to meet our contractual, legal, and regulatory obligations;
  • When we conduct market research and data analytics: for instance, by tracking and analyzing your personal data to better understand our customer base and behavior or to create reports on the Demographic data of internet users and their interests, in order to help us understand how visitors interact with our Website and how to improve our Website, our products and our services.
  • Send you information, promotional and marketing communications about Gentilhomme through email, with your consent (if required) or where permitted under applicable laws; you may opt-out of receiving any, or all, of these communications from us;
  • When we have to comply with a legal obligation, meaning where it is necessary for compliance with a legal obligation that we are subject to;
  • When you interact with us through third-party social media websites, plug-ins, and applications. we may use the information about your social media accounts to personalize your visit to the Website and of third-party networking websites, plug-ins and applications. We may also use this information to provide you with certain information, products or services that you have requested;
  • Perform remarketing, which consists of advertising on other websites to users who have visited our Website, including through Google Analytics (internet audience analytics solution). In such cases, relevant third parties, including Google, may advertise our content on sites across the Internet;
  • When you use our Website, We may collect certain information about you, such as the Technical data and User data described in section 3 above. We use this information to administer the Website, monitor and/or enhance our product and service offerings and our Website , determine how the Website is used, understand what parts of the Website are popular and analyze user trends and habits;
  • Usage data obtained from cookies are only used for the purpose of improving the quality of the Website, for instance, to know the traffic statistics of the Website and its various functionalities or to provide users with a better browsing experience, for instance, by memorizing their choices during a prior visit. Gentilhomme will seek your express consent for the use of cookies that are not strictly necessary for the basic functions of your Website.

5. HOW WE DISCLOSE YOUR PERSONAL DATA

5.1 Principle

Unless expressly stated in this Privacy Policy, we do not sell, rent, transfer, or disclose your personal data with third parties without your consent for purposes which are not disclosed herein.

5.2 Exceptions

  • Third-party providers: We may share all of the categories of personal data identified in Section 3 above with third parties that provide products or services to Gentilhomme. These third parties are only permitted to use your personal data for the purpose of delivering such products or services to Gentilhomme and are not permitted to use your personal data for their own internal purposes. These third-party providers help us operate our business, technology systems and applications, internal procedures, infrastructure and advertising and marketing.
  • Sale, transfer of business or other transactions: We may share your personal data with another entity in the event that we sell part or all of our business or if we sell or transfer assets or are otherwise involved in a similar business transaction. In the event the transaction is completed, your personal data will remain protected by applicable privacy laws.
  • Judicial, legal or administrative purposes: We may use, share, or disclose of personal data without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect our employees, our customers, or others or to comply with a search warrant, a legally valid inquiry or any applicable law, regulation, legal process of governmental request.
  • Our Website may contain links to other websites that we do not own or operate. In addition, links to our Website may appear on third party websites on which we advertise. Except as provided in this Privacy Policy, we will not share your personal data with these third parties without your consent. Links to third party websites are provided to the users of our Website for convenience only. These links are not intended to be an endorsement or recommendation of the linked sites. The linked websites may have separate and independent privacy statements, notices, and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose, protect or otherwise process your personal data.

6. TRANSFERS OF PERSONAL DATA TO OTHER COUNTRIES

As Gentilhomme is headquartered in Canada, your personal data will be accessible from that location. The personal data that we collect from you may be transferred to, or stored at, a destination outside Canada, for example if a service provider is located in another country. We will take steps reasonably necessary to ensure that any personal data transferred outside Canada is treated securely and in accordance with data protection laws applicable in the jurisdiction in which the information is processed or stored. These laws may not provide the same level of protection as privacy laws in Canada.

7. HOW WE HANDLE AND PROTECT YOUR PERSONAL DATA INTERNALLY

7.1 How we protect your personal data

We have put in place and use administrative, technical, and physical safeguards to protect the personal data we hold about you against unauthorized access, use, modification, and disclosure. These safeguards also apply when we dispose of or destroy your personal data.

7.2 Who has access to your personal data and how it is handled

We give access to your personal data to our employees, representatives, contractors, and third-party providers (each a “Representative”) only on a need-to-know basis, to fulfill the specific functions that we have assigned to them. During the retention period of your personal data, our Representatives are required to maintain the confidentiality of your personal data. They also have the responsibility to adhere to the administrative, technical, and physical safeguards that we prescribe in order to protect your personal data. They must otherwise comply with the policies and procedures designated in this Privacy Policy, including with respect to the retention, destruction, and anonymization of your personal data.

7.3 Our policies related to security incidents

We also take appropriate precautions and follow industry practices to assess the potential risks applicable to the disclosure of your personal data. Should we realize that your data has been compromised in a way that risks significant or serious harm, we will take the required steps under the law to notify you of this security incident.

7.4 Retention, destruction, and anonymization of personal data

We will keep your personal data as long as necessary for the fulfillment of the purposes outlined in this Privacy Policy, or longer if required or permitted under applicable laws. When this data is no longer needed, it is securely destroyed or anonymized, in accordance with generally recognized best practices and any applicable legal requirements.

7.5 Responsibilities of our Privacy Officer

We have appointed a Privacy Officer who is responsible for overseeing questions in relation to this Privacy Policy and who is in charge of the protection of personal data within our organization. If you have questions, complaints or comments regarding how we treat your personal data, including any request to exercise your rights regarding your personal data, please contact our Privacy Officer as indicated below:
Email: PRIVACY@gentilhomme.com

8. YOUR LEGAL RIGHTS

At any time, by contacting the Privacy Officer, you can exercise all the privacy rights that the law grants you:

  • Right of access, rectification and deletion: You may access and rectify or delete your data at any time. To do so, please use the same contact details above. In some cases, you have the right to have your personal data erased or deleted.
  • Right to obtain a copy of your data: you may request a copy of your data at any time by using the same contact details above.
  • Consent withdrawal: your browser allows you to withdraw your consent to certain processing of your personal data, including by preventing storage of browser cookies. You may also withdraw your consent (for example, regarding marketing emails) by contacting us at the contact details above.

If you want to exercise any of the above-mentioned rights, we may need to ask you for specific information to help us confirm your identity and ensure your right to access your personal data (or to exercise your other rights)

9. CHANGES TO PRIVACY POLICY

This Privacy Policy is regularly reviewed and may be updated from time to time to reflect changes in applicable laws or our practices regarding personal data. If we decide to change our Privacy Policy, we will post the revised policy on our Website. We will treat your personal data in accordance with the most recent version of the Privacy Policy.