1. Who we are

Mondrian Innovation Inc. is a Quebec-based consulting firm specializing in artificial intelligence and digital transformation, with its head office in Quebec, Canada. This privacy policy applies to all of our activities, including our consulting services, client relationship management, recruitment, and the operation of our digital tools. Mondrian acts as the party responsible for the personal information it collects. Our privacy officer can be reached at:

Email: info@mondrian.ca

Phone: 514-834-6211

2. Personal information we collect

In the course of our activities, Mondrian collects the following categories of personal information :

2.1 Identification information

• First and last name
• Professional email address
• Phone number
• Job title and organization name
• Mailing address

2.2 Transactional information

• Billing details
• Vendor and client account information
• Transaction and engagement history

2.3 Personnel information

• Name, contact information, and social insurance number (for payroll purposes)
• Resume, diplomas, and certifications
• Employment contract information
• Time and attendance data (e.g., hours worked per project)
• Compensation and benefits information

2.4 Browsing and cookie data

• IP address and session identifiers
• Pages visited on our digital properties
• Usage and performance data
• Browsing preferences and settings

2.5 Voluntarily provided information

• Messages sent through our contact forms
• Content of email correspondence
• Resumes and information submitted with job applications

3. Purposes of processing, and other uses permitted or required by applicable law

Mondrian collects and uses personal information for the following purposes:

3.1 Delivering our services

• Carrying out consulting and digital transformation engagements
• Managing the client relationship (communications, follow-ups, reporting)
• Billing and accounting

3.2 Improving our services and communications

• Analyzing client needs and satisfaction
• Sending professional communications and newsletters (with consent)
• Developing case studies (with the client's explicit consent)

3.3 Security and compliance

• Detecting security incidents
• Meeting our legal and regulatory obligations
• Managing access rights to our systems

4. Subcontractors and disclosure to third parties

In carrying out its activities, Mondrian works with subcontractors and third-party tools. These third parties are contractually required to protect personal information in accordance with the requirements of Law 25. The categories of subcontractors we work with include :

4.1 Cloud-based tools

Mondrian uses Microsoft solutions (Microsoft 365, Azure) and Google solutions (Google Workspace) to manage its communications, documents, and digital infrastructure. These providers may process data outside Quebec. Appropriate contractual safeguards are in place to ensure an equivalent level of protection.

4.2 Artificial intelligence platforms

In the course of our engagements, we may use AI models provided by third parties, including OpenAI and Anthropic. Mondrian ensures that no sensitive personal data is shared with these platforms without explicit consent and a prior risk assessment.

4.3 Customer relationship management (CRM) and marketing tools

Mondrian may use CRM and marketing tools to manage client communications and business development activities. These tools are configured to limit data collection to what is strictly necessary.

Mondrian does not sell or rent your personal information to third parties.

5. Transfer of information outside Quebec

Because some of our subcontractors are based outside Quebec, your personal information may be transferred to, and processed in, other Canadian provinces or abroad.

In accordance with section 17 of Quebec's Act respecting the protection of personal information in the private sector, Mondrian conducts a privacy impact assessment (PIA) before any transfer outside Quebec, to ensure that an adequate level of protection is afforded to the information.

You can obtain more information about these transfers by contacting our privacy officer.

6. Retention period

Mondrian retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, or to meet its legal obligations, including:

• Client files and engagements: 7 years after the end of the engagement (tax and accounting obligations)
• Employee files: length of employment plus 5 years after the employment relationship ends
• Browsing data: 13 months maximum
• Unsuccessful job applications: 6 months (unless consent is given to a longer retention period)

Once the retention period expires, information is securely destroyed or anonymized.

7. Exercising your rights

You may withdraw your consent to the use of your personal information for commercial or philanthropic solicitation purposes at any time. This withdrawal takes effect within 30 days of your request. If we are unable to respond within that timeframe, we will notify you.

To exercise this right, or any other data access right available to you under applicable law, send a written request to our privacy officer at info@mondrian.ca, along with sufficient proof of identity. We will respond within a reasonable time after receiving your request. Access to your information is free of charge, although reasonable fees may apply for transcription or reproduction.

8. Security of personal information

Mondrian implements appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures may include:

• Role-based access controls
• Encryption of data in transit and at rest
• Periodic privacy risk assessments
• Employee training on personal information protection
• Confidentiality incident management and notification protocols

In the event of a confidentiality incident likely to cause serious harm, Mondrian commits to notifying the Commission d'accès à l'information (CAI) and the affected individuals within the timeframes prescribed by applicable law.

9. Cookies and similar technologies

Our digital properties may use cookies and similar technologies for functional, analytical, and personalization purposes. On your first visit, you will be asked to consent to the use of non-essential cookies.

You can change your cookie preferences at any time through your browser settings or by contacting us.

10. Changes to this policy

Mondrian reserves the right to modify this privacy policy at any time, including to reflect legislative, regulatory, or operational changes. The current version is always available upon request.

11. Contact us

For any questions about this policy or the protection of your personal information, contact our officer

Privacy Officer

Mondrian

Email: info@mondrian.ca

Address: 5455 Avenue de Gaspé, Suite 710, Montreal, Quebec H2T 3B3

You may also contact Quebec's Commission d'accès à l'information (CAI):

• Website: www.cai.gouv.qc.ca
• Phone: 1-888-528-7741