POLICY OF COLLECTION AND PROTECTION OF PERSONAL INFORMATION
I.
INTRODUCTION
The protection of personal information is a major issue for Elmec Inc.,
and we are aware of your concerns in this regard. That is why we believe it is
important to let you know the type of personal information we collect, the
reason for and the circumstances under which we collect and use it. We
therefore ask you to carefully read this privacy policy (hereinafter the
“Policy”) and to consult it periodically in order to be aware of any changes
that may be made to it.
II.
SCOPE OF THE POLICY
The purpose of
this policy relating to the protection of Data and Personal Information
(hereinafter the "Policy") is to inform Users of our Applications of
the practices of Elmec Inc., relating to the processing of personal data
collected, and this, particularly when:
¨
collection of personal
information;
¨
the use of the data collected;
¨
data protection and personal
information;
¨
retention and destruction of
personal data and information.
The Policy
applies to all personal information that we collect through the EVduty
Applications when using our Charging Stations, or during any communication, in
particular when sending and receiving emails or telephone interviews. The
Policy is intended to govern the collection, use, disclosure, retention and
destruction of your personal information, regardless of how it was collected
(in writing, verbally or electronically through any Website. operated by or on
behalf of Elmec Inc.).
The policy also
describes the data protection rights enjoyed by Data Subjects, in particular
the right to object to some of the processing carried out by Elmec Inc.
This policy
complies with the Laws on the protection of privacy in the private sector.
III.
COLLECTION AND USE OF PERSONAL
INFORMATION
3.1.
Nature of the information we
collect
Your personal information is information that concerns you as a natural
person and allows you to be identified, such as your first and last name, home
address, email address, home telephone number, cell phone number, date of
birth, information concerning your employment, social security number, if
applicable, as well as information appearing on your credit card, if
applicable.
The collection
of this personal information occurs on various occasions. So when you subscribe
to our services through our Applications, we may automatically collect and
retain certain information, in particular when:
¨
taking out a subscription or
registering a user profile;
¨
usage of services;
¨
EVduty services payment by credit
card, etc.
When you take
an action mentioned above, we ask you for certain personal information. Only
the mandatory fields identified by an asterisk are essential, the others do not
have to be provided.
Note that any
information in the public domain is not personal information. Certain
professional information is considered to be non-personal information and
therefore is not subject to special protection and may be regularly shared with
persons both inside and outside Elmec Inc. For example, business information,
such as business name, address, business phone number, is not considered
personal information in some jurisdictions.
Please note
that we only collect personal data and information that helps us achieve the
purpose set out in this privacy policy. We will not collect additional data
without notifying you first.
3.2.
Reason for collecting personal
information
We only collect personal information that we reasonably need in order to
allow us to properly assess your file and ensure payment for services.
However, your personal information may be collected for statistical
purposes or in order to improve our services or your User experience. Thus, the
collection of this personal information allows us to offer products better
suited to the needs of consumers or Users and to reach you to provide you with
information concerning the use of our Applications. More specifically, the
collection of your personal information allows us in particular to:
¨
personalize our customer service;
¨
offer products adapted to the
needs of Users;
¨
communicate with our customers
(Users and Owners of EVduty Charging Stations);
¨
inform and propose promotional
offers if necessary; and
¨ manage user accounts, if applicable.
3.2.1.
Sharing, use and protection of
your personal information
We would like to assure you that under no circumstances will your
personal information be shared with third parties without your consent, except
in the situations specifically provided for by the Laws on the protection of
privacy in the private sector, that is to say in exceptional circumstances.
Your personal
information is stored on servers that are inaccessible to the public and hosted
by AWS in the North-Virginia US-EAST region. In addition, their access within
Elmec Inc. is restricted to the personnel who need it in order to ensure the
high quality of service that we are committed to offer to you. Elmec Inc.
employees understand the importance of protecting personal information and make
sure to maintain its confidentiality.
3.2.2.
Correction of personal
information and access to information
In accordance with applicable law, Elmec Inc.,
after having read the information and other relevant documentation, when
applicable, of any User and Owners of EVduty Applications who have consented to
the collection of their personal information, will inform said User and/or
Owner of his rights to access and rectify the file prepared by a personal
information agent, at the latter's request.
In addition, Elmec Inc., will communicate to
any person who requests it the content of any recommendation which it has taken
cognizance of in order to make a decision concerning it.
3.3.
Communication
In the course of our commercial activities, we may communicate with our
customers by email. Thus, when you subscribe to one of our services, you can
expressly consent or not to receive our newsletters and to be added to the
mailing list.
If you do not
wish or no longer wish to receive the emails we send to our customers, you can
unsubscribe at any time by updating your profile from our Applications or by
following the unsubscribe link at the bottom of all emails we send.
Some emails we
send are operational and contain information essential to the proper
functioning of our services or tools, including messages concerning updates to
our products. Thus, these operational messages will continue to be sent to our
customers when required.
3.4.
Consent
Users agree that by submitting personal information when using our EVduty
mobile applications downloadable from the Google Play store and Apple store as
well as our EVduty Web application, they agree to the conditions set out in
this privacy policy. In addition, Users consent to Elmec Inc. collecting,
using, communicating and storing their data and personal information listed in
this policy, all subject to the conditions and modalities permitted or required
by the law. Elmec Inc., collects the following information:
¨ choice of language;
¨ full name and first name of the User;
¨ e-mail;
¨ phone number;
¨ address;
¨ postal code;
¨ entered credit card number, if applicable
IV.
NON-PERSONAL INFORMATION AND USE
OF GOOGLE ANALYTICS
4.1.
Internet analysis data
The statistical information we collect is not linked to your personal
information and is not used to identify you. This information includes in
particular the browsers used (for example, Safari, Chrome or Internet Explorer)
or the application used (Apple Store or Google Play Store) and their language,
the approximate location of the IP addresses of the Users as well as the pages
visited and the duration of their consultation.
The web
analysis tool we use is Google Analytics. To learn more about the privacy
policy of Google Analytics, we invite you to click
here.
These data are
collected automatically by analysis tools and are intended to give us
information on the habits of Users and their purchasing process. Thus, this
information allows us to offer you a better experience of using our services, to
better understand the needs of our target customers, to present you with offers
adapted to your habits, and to assess the number of visitors on our products
and Applications.
In order to
collect this data, we use “cookies”, which are small files that are
automatically stored on your computer when you visit our Website or use our
mobile applications. At any time, you can reconfigure your computer's browser
to no longer allow cookies or delete these cookies from your browser. However,
if you delete, deactivate or prevent the saving of cookies, certain features
may no longer be accessible to you.
By using our
services without deleting, deactivating or preventing the recording of cookies,
you implicitly consent to the collection, use and communication of the
information necessary for the implementation of their functionalities.
4.2.
Charging session data
During a charging session on the EVduty charging network, Elmec Inc.
will collect the following data:
¨ start of session date/time;
¨ end of session date/time;
¨ session duration;
¨ energy consumed (kWh);
¨ current/voltage/power/energy/battery charging level measurements;
This data is not
linked to your personal information and is not used to identify you.
This charging
session data could be used, among other things, to: improve the quality of our
services, help resolve a technical problem, analyze the charging habits of our
users, create Clean Fuel Regulation (CFR) compliance units.
The exclusive
right to use this charging session data, among other things for the purposes of
creating Clean Fuel Regulation (CFR) compliance units, as well as the exclusive
ownership of this charging session data are transferred by Elmec Inc. to
Hydro-Québec for a period of TWO (2) years following the collection of this data.
V.
OUR PERSONAL INFORMATION
PROTECTION OFFICER
5.1. Accessibility and
updating of your personal information
By accessing your User account, you have access to the personal
information we hold about you and you can correct it if necessary.
At any time,
the User may unsubscribe from the lists we use to send press releases or
updates and choose not to receive correspondence from us by contacting our
Privacy Officer.
At any time,
you can contact Elmec Inc., to access, correct or delete your personal
information. If necessary, Elmec Inc., will contact the person in charge of the
protection of personal information responsible for responding to your request.
5.2. Destruction of personal
information data
Once
the objectives for which the personal information has been collected have been
achieved, Elmec Inc., keeps such data and said personal information using
reasonable security measures, taking into account, in particular, their
sensitivity and the purpose of their use, until at the request of their
destruction. In the event of a request to delete confidential information saved
by Elmec Inc., within a period of less than SEVEN (7) years, the requester will
communicate to Elmec Inc., reasons deemed reasonable for this purpose, which
will be analyzed at the discretion of Elmec Inc. Elmec Inc., in this case will
communicate its position to the applicant within SEVEN (7) days from when the
request is made.
5.3. Privacy comment,
question or complaint
By phone / fax 819-533-3888
/ 819-533-3074
By mail 1141,
2nd Avenue, Shawinigan (Quebec) G9T2X9, Canada
By email services@elmec.ca
VI.
CHANGES TO OUR PRIVACY POLICY
Elmec Inc., reserves the right to update this Policy whenever it sees
fit.
We encourage
you to review the Policy periodically to be informed on how Elmec Inc. protects
your information and to be notified of any changes to the Policy.
Your
subscription to EVduty products following the posting of an amended version of
the Policy constitutes your consent to be subject to these changes. This Policy
is incorporated into all the Terms that govern the various Applications,
programs, products and services used or managed for or on behalf of Elmec Inc.
Any change to
the Policy is effective immediately after being put online and incorporated
into our products by Elmec Inc.
VII.
TERMS OF USE OF EVDUTY
APPLICATIONS
The Terms governing the use of the EVduty Applications downloadable from
Google Play Store and Apple Store as well as the EVduty Web Application can be
found HERE and contain important provisions which declare and exclude the
responsibility of Elmec Inc., regarding your use of the EVduty Applications.
The Terms also
contain provisions determining applicable law and exclusive jurisdiction for
the resolution of any disagreement regarding the use of our Applications. All
these provisions apply to any disagreements or disputes that may arise in
connection with the Policy and the collection, use and disclosure of your
personal information.
These
conditions have the same effect as if they had been reproduced in full in the
Policy.