This Privacy Policy applies to any personal information we collect or receive about you, from you or any other source. “Personal information” as used in this Privacy Policy refers to any information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual and that is recorded in any form (such as your name, your phone number, your postal and email address and your payment information), as further defined in PIPEDA and applicable provincial legislation. It may also include technical information such as your IP address, browser settings and device ID, but only when this information can identify you as an individual. Please note that personal information excludes information that is anonymized and cannot be associated with an identifiable individual and aggregate information which represents compiled data from a group of individuals who can no longer be individually identified. Please note that we do not intend to collect information from a minor. If you believe we may have collected information from your child, please contact us as indicated in the “Contact Us” section so that we can endeavor to delete it.

We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. Depending on your interaction with us, we may collect: • Personal identifiers, such as name, postal address, phone number, email address, account number, or Internet Protocol (IP) addresses, signatures. • Payment information, such as credit or debit card number when you make purchases or other information required by Axis Lighting to complete a payment; • Professional or employment-related information and other information you submit to us when applying for an employment opportunity or when acting for a consultant, which may include some of the information described above, as well as letters of motivation, your resume, ID numbers for tax purposes, references and any additional information provided by you in an application; • Internet or other electronic network activity information (i.e. technical information when you visit our Sites). This information is collected via automated means, such as cookies, authorized token, web beacons and similar technologies, and may include your IP address, device ID, browser type, data about the web pages you visited on our Sites, time and duration of a visit, information about your location, your language preferences; • Video images, such as footage collected by our surveillance cameras.

We will generally collect personal information directly from you when you purchase a product, browse a Site or interact with us directly, as deemed necessary for the purposes defined in Section 5 below. a. Directly from you We may collect your personal information directly from you such as: • when you place an order with one of our sales representatives or make inquiries regarding your purchases or products, we may collect information about the transaction, payment or shipment (including information about the recipient of such shipment, if applicable); • when you contact us or send us questions, comments, suggestions or complaints, or complete a form on our Sites or by email, we may collect contact information and information about your inquiry that is necessary in order to address it or to respond to you; • when you apply for a position or fill documents in relation to a position with us, through a partner’s Sites (Indeed, LinkedIn, etc.) or from third parties (recruitment agencies, outsourcing company, referral, etc.), we may collect contact information and other information to process your application for employment; • when you use our Sites, we may collect information about how you use the Sites and where you are located, as further discussed below; and • we may collect any other personal information you voluntarily provide to us in connection with any other matter. b. Through our Sites or other technologies We or our service providers that help us maintain and operate our Sites may also automatically collect the following information relating to your access to and use of our Sites and applications through cookies (small data files stored on your device used to access and use our Sites), Web beacons (small transparent images used to track Sites visits and effectiveness of advertising) and other similar technologies: your domain name; your browser type and operating system; your type of computer or mobile device; pages you view; links you click; your IP address; the length of time you visit or use the service, and how you use the service. However, please note that cookies and beacons might be necessary to access or use certain features of our Sites. We may also collect information you share regarding Axis Lighting on social media such as Facebook and Twitter. We may also be collecting information about your approximate physical location when you use a mobile device to access our Sites. If you do not want us to collect such information, please adjust or modify the settings of your mobile device accordingly. Please be aware that we may use cameras on our properties to protect our rights, property and safety and those of our employees, customers and the public and in order to look for ways to improve our customers’ experiences. We do not use these cameras to identify people except when reasonably necessary for these purposes or as required by law. Where this is applicable, signs will be posted to indicate that cameras are in use.

We will generally use your personal information as part of our normal business operations in order to provide you with our products and services through our Sites, and to support our business, for research and development purposes, for marketing purposes or otherwise, with your consent or as permitted or required by law: a. General business purpose More specifically, we may use your personal information for the following business purposes: • to process your purchases and related transactions; • to provide customer service and to respond to your inquiries or requests; • to elaborate and improve our product offerings and our services; • to manage and improve our customers’ experiences and our Sites; • to monitor, analyze and assess the access and use of our Sites; • to customize the content of our Sites and advertising; • to help you locate a sales representative; • to protect our rights, property and safety and those of our employees, customers and the public; • to detect and prevent fraud and for accounting purposes; • to maintain appropriate records for internal administrative purposes, including for staffing and management of personnel and other professional related purposes; and • to comply with legal requirements. b. Research and development purpose We may use personal information to understand and assess your interests and changing needs with a view to improve our products and services and developing new ones, as well as to evaluate potential improvements or other modifications to the functionality of our Sites. For instance, we may use third-party web analytics services, such as Google Analytics and Double-click, to help us analyze how visitors use our Sites. When required by law, we will use anonymized information for these purposes. c. Marketing purposes We may use your personal information to provide you with personalized content and services, such as tailoring our products and services, our digital experience and offerings. We may also use your personal information to communicate with you in a variety of ways (for example, by email, telephone, text message, direct mail or through our online support services) about our programs, products, services or events that may be of interest to you in compliance with applicable laws. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages. For more information on this topic, see Your Privacy Rights.

Please note that we will only retain your personal information for as long as reasonably necessary for the above purposes in accordance with our retention policy or as required by law. Once no longer required, your personal information will be securely destroyed or anonymized, in compliance with applicable laws.

We shall not disclose or share your personal information without your consent to any company or person other than as authorized by law or as follows: • to those entities affiliated to Axis Lighting for the purposes detailed in this Privacy Policy; • with service providers who are assisting us with respect to any of the purposes stated in Section 5 above (including the following categories of service providers: payment solution providers, sales representatives, background checks service providers, recruitment agencies, shipping organizations, etc.) require such information to perform their services for us, it being understood that they will only be permitted to use the information as part of the performance of their work for us or when the disclosure of your information is required by law and that such third parties will have appropriate privacy standards in place; • if we believe that the disclosure of personal information is required by law; • if we believe that the disclosure of personal information will help us protect our rights, our property and our safety and those of our employees, customers and the public; • if we believe that the disclosure of personal information is necessary in the investigation of suspected or actual illegal activity or in response to a request by law enforcement authorities; • if such disclosure would be in a way that it would not directly identify you, such as through aggregate information as mentioned in Section 2 above; and • when required in the context of a prospective or completed business transaction, such as a transfer of assets or shares or merger, in accordance with applicable legal requirements. For example, we may make your personal information available to advisors or (potential) buyers of our business if necessary for concluding the transaction and continuing operating the business.

For the most part, provincial privacy legislation in Canada provides that if we notify you (for example, through the distribution of this Privacy Policy) of the purposes for which we intend to collect, use or disclose your personal information, and those purposes are reasonable, we will have your implied consent to act in accordance with the Privacy Policy. You have choices about the way Axis Lighting handles your personal information. a. Changing your communication preferences You can always choose not to receive marketing or promotional messages from Axis Lighting by email by clicking on “unsubscribe” in any email you receive. Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with a service, in accordance with applicable law (for example, to send you important product information, service notification or recall). In addition, it may take up to ten (10) business days to register a change of preference across all our records. b. Changing your browser settings on your device We use technology to enhance your experience and present you with offers, including personalized advertising. Through technologies such as cookies, our Sites recognize you when you use or return to them and can provide you with a seamless experience. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features of our Sites. Please refer to your browser instructions or help screen to learn how to block, delete and manage cookies on your computer or mobile device. c. Withdrawal of consent You may withdraw your consent to the collection, use and disclosure of personal information in accordance with this Privacy Policy at any time upon reasonable notice to Axis Lighting in writing, subject to legal or contractual restrictions. To do so, you may communicate with us through the Contact Us section below. The withdrawal of your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive because the continued use and disclosure of your personal information is a necessary part of making the product or service available to you. In some circumstances, legal requirements may prevent you from withdrawing consent and/or we may be required to retain some of your personal information as detail in Section 6.

We maintain policies and practices which ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including: • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis; • If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, antivirus software and similar measures; • A designated Privacy Officer to monitor Axis Lighting’s compliance with applicable data protection laws;• Employee privacy and data security training; • Procedures for receiving, investigating and responding to complaints or inquiries regarding Axis Lighting’s information handling practices, including any security incidents involving personal information; • Framework governing the retention and destruction of personal information, as more fully described above in the Retention of Personal Information section of this Privacy Policy; • Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate privacy protections and standards. For example, we generally require our service providers to limit their use and retention of personal information to what is necessary to provide their services and to notify us in case of any actual or suspected security incident.

Your personal information may be transferred, stored, accessed, or used in a jurisdiction outside your jurisdiction of residence (for example, outside your province or outside Canada) in connection with our use of third-party service providers engaged by us. We engage these third-party service providers to assist us in providing our services to you; for example, in order to process payment, fulfil product orders, provide e-commerce functions, or manage our communications with you. We use contractual measures to ensure that all of our third-party service providers take reasonable security measures to protect your personal information (this includes technical, administrative, and physical safeguards to protect your personal information) in compliance with applicable laws. Where personal information is located outside of your province of residence or outside Canada, it is subject to the laws of that jurisdiction which may differ from those in your jurisdiction and any personal information transferred to another jurisdiction will be subject to law enforcement, regulatory, and national security authorities in that jurisdiction.

You may be entitled to access your personal information and request the rectification of information that is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws. Depending on the law applicable in the jurisdiction where you reside and subject to legal or contractual restrictions, you may also be entitled to: • request that we stop or restrict processing your personal information; • obtain a copy of the personal information we collected from you; and • obtain additional information about data processing, including the personal information collected and how it is processed by Axis Lighting. To submit a request, please contact us in writing using the relevant contact information listed in the Contact Us section below and provide relevant documentation to confirm your identity.

You can contact our Privacy Officer at the address and email found below if you wish to ask questions, express concerns or submit a complaint regarding this Privacy Policy. To ensure that your personal information is accurate, complete and up to date, you may contact us if any changes or modifications are required at the contact information below or through your usual Axis Lighting contact. You may also send us a written request if you wish to access the personal information we have collected about you. Please be advised that in order for you to modify, access or review your personal information, we may ask you to provide us with sufficient identification. In all cases, we will generally attempt to answer your request within thirty (30) days or we will advise you if we require a longer response time. Axis Lighting Inc. Attn: Privacy Officer 2505 Senkus St. Lasalle, Quebec J8N 2X8 Email: PrivacyOfficer@axislighting.com