PRIVACY POLICY
Last Updated: February 11, 2026
INTRODUCTION
Direction Vert Inc. (DBA: Underbase) (“we”, “us”, “our”) is committed to protecting the privacy and personal information of individuals who visit our website underbase.ca, including subdomains operated by us (the “Website”), or use our services. This Privacy Policy explains how we collect, use, disclose, store, and protect personal information in accordance with applicable Canadian privacy laws, including Québec’s Act respecting the protection of personal information in the private sector (Law 25) and the Personal Information Protection and Electronic Documents Act (PIPEDA).
By using our Website or services, you consent to the practices described in this Policy.
PRIVACY OFFICER
We have designated a Privacy Officer responsible for personal information protection.
Privacy Officer
Shawn-Edward Cournoyer, President
Direction Vert Inc. (DBA: Underbase)
info@underbase.ca
54 rue du Roi, Sorel-Tracy, QC, J3P 4M7
Questions, requests, or complaints regarding personal information should be directed to the Privacy Officer.
PERSONAL INFORMATION WE COLLECT
We collect only the personal information necessary to operate our business and provide our services. Depending on your interaction with us, this may include:
• Name
• Billing and shipping address
• Email address
• Telephone number
• Order and transaction information
• Payment-related details (processed securely by third-party providers)
• Account credentials
• Communications with us
• Technical and usage data (IP address, browser type, device data, analytics)
We limit the collection of personal information to what is necessary for the purposes identified in this Policy and do not knowingly collect information beyond what is reasonably required.
HOW WE COLLECT INFORMATION
We collect personal information:
• When you create an account
• When you place an order
• When you contact customer support
• When you subscribe to communications
• Through cookies and analytics tools
• Through third-party integrations necessary for service delivery
PURPOSES FOR USING PERSONAL INFORMATION
We use personal information to:
• Process and fulfill orders
• Provide customer service
• Operate and maintain the Website
• Communicate transactional updates
• Improve services and user experience
• Meet legal and regulatory obligations
• Prevent fraud or misuse
• Conduct internal analytics
Marketing communications are sent only with consent and may be withdrawn at any time.
CONSENT
We obtain consent before collecting, using, or disclosing personal information, except where permitted or required by law. Consent may be express or implied depending on the context and sensitivity of the information.
You may withdraw consent at any time, subject to legal or contractual restrictions.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information to:
• Payment processors
• Order fulfillment providers
• Website and hosting platforms (including DecoNetwork)
• Analytics and technology partners
• Professional advisors
• Legal authorities where required
Third parties are contractually required to safeguard personal information. We do not sell personal information.
INTERNATIONAL DATA TRANSFERS
Some service providers may store or process personal information outside Québec or Canada. When this occurs, we implement contractual and technical safeguards to ensure protection consistent with Québec privacy requirements and applicable law.
COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar technologies to:
• Maintain session functionality
• Improve performance
• Analyze Website usage
• Support essential services
Where required by law, consent will be obtained before placing non-essential cookies. You may control cookies through browser settings. Disabling cookies may limit Website functionality.
DATA RETENTION
We retain personal information only as long as necessary to fulfill the purposes outlined in this Policy or to meet legal requirements. Retention periods are determined based on legal obligations, operational needs, and industry standards. When information is no longer required, it is securely destroyed or anonymized.
SECURITY MEASURES
We implement administrative, technical, and physical safeguards appropriate to the sensitivity of personal information, including encryption, access controls, and secure processing systems. While no system is completely secure, we continuously review and improve protections.
CONFIDENTIALITY INCIDENTS
If a confidentiality incident poses a risk of serious harm, we will notify affected individuals and applicable authorities as required by law.
AUTOMATED DECISION-MAKING
We do not use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects. If such practices are introduced in the future, individuals will be informed and provided with appropriate rights.
YOUR RIGHTS
Subject to legal limitations, individuals have the right to:
• Access their personal information
• Request correction of inaccurate data
• Withdraw consent
• Request deletion where applicable
• File a complaint
We will respond to access or correction requests within the timelines prescribed by applicable law. Individuals also have the right to file a complaint with Québec’s Commission d’accès à l’information if they believe their rights have not been respected.
Requests must be submitted to the Privacy Officer.
THIRD-PARTY WEBSITES
Our Website may link to third-party services. We are not responsible for their privacy practices. Users should review third-party policies independently.
CHILDREN’S PRIVACY
Our services are not directed to minors without parental or guardian authorization. We do not knowingly collect personal information from minors contrary to applicable law.
POLICY UPDATES
We may update this Policy periodically. The updated version will be posted on our Website with a revised date. Continued use of the Website indicates acceptance of changes.
CONTACT INFORMATION
For privacy inquiries, access requests, or complaints:
Privacy Officer
Direction Vert Inc. (DBA: Underbase)
info@underbase.ca
54 rue du Roi, Sorel-Tracy, QC, J3P 4M7
We will respond within legally required timelines.
END OF POLICY
