Privacy Policy

Top Aces Inc. (“Top Aces”, “we”, “our”) takes your privacy seriously. Our Privacy Policy (the “Policy”) is intended to describe how we collect, use, and disclose your personal information when you use our website, and what your rights are in this regard.

This Policy does not apply to third-party websites including those that can be accessed through hyperlinks made available on our website. If you consult a third-party website, such website will have its own policies and we invite you to consult them before submitting any personal information, where applicable.

 

What personal information do we collect?

We collect certain information through cookies and other tracking technologies (collectively, “cookies”), when you browse our website, including IP address, device information and usage data.

Cookies are small text files containing a unique identification number which are automatically placed on a visitor's device. We use the following categories of cookies:

  • Necessary (essential) cookies: These cookies are required for the website to function properly and enable core features such as page navigation, security, and access to embedded content. The website cannot operate correctly without these cookies.
     
  • Functional (or preference) cookies: These cookies allow the website to remember user preferences and settings and enable the display of embedded third‑party content such as videos and interactive maps.
     
  • Analytics (or performance) cookies: These cookies, including Google Analytics cookies, are used to collect aggregated and anonymized information about how visitors use our website (for example, pages visited and time spent on the site) in order to measure performance and improve the website.
     

Where required by applicable privacy laws, the analytics and functional cookies are activated only after you have provided your consent and may be managed through our cookie consent settings. Personal information collected through cookies is limited to what is necessary for the purposes described below and does not include sensitive personal information. By clicking on “Allow all” when you first browse the site, you agree to the storage of cookies on your device. If you refuse, your browsing may be affected. If you wish to modify your consent, you can do so directly in the cookies settings.


How do we collect your personal information?

We collect your personal information directly from you when you browse our website, with your consent where required by applicable privacy laws.


How do we obtain your consent?

In general, we only collect, use, and disclose your personal information with your consent. In some cases, however, the law provides that we may collect, use, or disclose your personal information without your consent (for example, when we are required to disclose your information under a subpoena or court order).

By browsing our website, you consent to the collection, use, and disclosure of your personal information in accordance with this Policy.


For what purposes do we use your personal information?

In general, we use your personal information for the following purposes:

  • To ensure the proper functioning, security, and performance of the website
  • To display embedded multimedia content, including videos and interactive maps
  • To analyze website usage and traffic in order to improve content, usability, and user experience
  • To manage website tags, analytics, and performance measurement tools
  • To facilitate access to our external recruitment platform when you choose to apply for a position
  • Any other purpose that is authorized by law or to which you consent.

We do not use personal information collected through the website for profiling, automated decision‑making, or marketing purposes.


Who do we share your personal information with?

Your personal information is only made available to our employees and agents whose duties require it. We may also share your personal information with third parties when required by law, or with service providers. Our website uses the following thirdparty and external services to provide multimedia content, interactive features, website analytics, and recruitment functionality.


Application or Platform

We use YouTube to display embedded video content on our website.
YouTube videos are embedded using a privacyenhanced configuration and are loaded only after consent has been provided through our cookie consent mechanism.

 

We use Google Maps to display interactive maps and locationbased information.
Google Maps content is loaded only after consent has been provided.

We use Google Tag technologies to manage website tags and to better understand how visitors interact with our website.
Tracking and analytics technologies are activated only after your explicit consent.

  • Purpose: Website analytics and performance measurement
  • Provider: Google LLC
  • Personal Data: IP address; Usage statistics; Browser information
  • Privacy Policy: https://policies.google.com/privacy
     

Our website contains links to our careers and recruitment platform, which is hosted and operated through UltiPro (UKG Pro).
When you click on a careers or job application link, you are redirected to an external website that is not operated by Top Aces and is governed by UltiPro’s own privacy practices.

  • Purpose: Job applications and recruitment management
  • Provider: UltiPro (UKG Pro), operated by UKG
  • Personal Data: Personal data submitted during the application process is collected and processed directly by UltiPro after redirection
  • Privacy Policy: https://www.ukg.com/about-us/privacy 
    *We encourage applicants to review UltiPro’s privacy policy before submitting any personal information through the recruitment platform.

 

When we share your personal information with service providers, we take all necessary measures to protect your personal information (for example, by adopting specific contractual measures and limiting the sharing of your personal information).


Is your personal information transferred outside Quebec?

We may share your personal information with the above-mentioned service providers who may be located outside Quebec, namely elsewhere in Canada and is the United States of America. When your personal information is thus transferred outside Quebec, we carry out an assessment of the privacy factors and we put in place contractual commitments to protect the confidentiality of this information where required by applicable privacy laws.


How long do we keep your personal information?

We will retain your personal information only for as long as necessary to fulfill the purposes listed in this Policy, or as required to comply with our legal and regulatory obligations. After this time, your personal information will be securely destroyed or anonymized.


How do we protect the confidentiality of your personal information?

The personal information that we collect is kept confidential in accordance with applicable laws. We take reasonable organizational, technical, and physical measures to protect your personal information against loss, theft, unauthorized access, use or disclosure. For example, we make sure that access to our offices and computer equipment is restricted, in addition to training our staff about the security and confidentiality of the personal information to which they have access.


What are your rights?

You have the following rights:

  • The right to access your personal information;
  • The right to have your personal information corrected;
  • To the extent applicable, the right to withdraw your consent to the disclosure or use of your personal information;
  • File a complaint regarding the processing of your personal information.

To exercise any of the above-mentioned rights, please contact us in the manner as set forth in the “How to Contact Us?” section.


How to contact us?

If you would like to learn more about the protection of your personal information or would like to exercise your rights or file a complaint, please contact our Privacy Officer, as follows:

 


How do we update our Policy?

Our Policy may be updated from time to time to reflect legislative or operational changes within our company. Although update notices may be used, the display of the revised Policy will be considered sufficient notice. Your continued use of our website or services is an acceptance on your part of this Policy and any update thereof.

The Policy was last updated on April 28, 2026.