Econoler Inc., its subsidiaries, and affiliates (ECONOLER or the Enterprise) recognize the importance of protecting personal information, i.e. any information concerning an individual that allows that individual to be identified directly or indirectly (Personal Information).

This Privacy Policy (the Policy) describes ECONOLER’s measures to protect the Personal Information it collects, uses, discloses, processes, and retains in connection with the operation of its website (Econoler.com) and its day-to-day business activities.

This policy is defined based on and intended to comply with the provisions of the Act Respecting the Protection of Personal Information in the Private Sector (LPRPSP in French), as amended by L.Q. 2021, c.25 and the Personal Information Protection and Electronic Documents Act (PIPEDA).

1. PERSONAL INFORMATION COLLECTED

For the purposes of this Policy, ECONOLER collects only the Personal Information that is necessary for its activities.

This includes information relating to your identity, such as your name, address, e-mail address, telephone number, company name, demographic information, and information relating to your use of the website.

ECONOLER collects Personal Information in the following ways:

1.1 Directly from you:

Most of the Personal Information collected is that which is provided directly when:

• Contacting Econoler;
• Making specific service requests;
• Applying for a position.

1.2 Through the Enterprise’s website:

ECONOLER may also collect information related to website visitors or via the online services portal, including the identifier of the computer equipment used (IP address). This information is collected through the use of cookies. These files make it possible to recognize website users when they access it and when they move from one page to another. Where required, ECONOLER seeks consent before collecting information.

1.3 Through our partners:

ECONOLER may also collect information related to its partners’ customers as part of the performance of ECONOLER’s contract with those partners. ECONOLER may therefore have access to this Personal Information to carry out the assignments submitted to it by partners. ECONOLER retains the Personal Information collected by partners solely for the purpose of carrying out assignments. Econoler partners ensure that the consent of the persons concerned is obtained prior to any transmission to ECONOLER.

2. CONSENT

ECONOLER collects, uses, and discloses Personal Information for the purposes identified at the time of collection, such as when an individual completes an information request via the website communication page.

Examples of purposes for which ECONOLER collects Personal Information include, but are not limited to, the following:

• Manage requests for services;
• Personalize and adapt the browsing experience on the Enterprise’s website;
• Evaluate an application for a position identified in the website Careers section;
• Meet regulatory and legal obligations;
• Confirm the identity of individuals, verify the accuracy of Personal Information, and update it;

By using the website, you consent to the collection, use, and retention of the Personal Information listed in this Privacy Policy.

3. ACCESS TO AND DISCLOSURE OF PERSONAL INFORMATION

Personal Information is disclosed to and accessible by ECONOLER employees who reasonably require access to it to carry out the purposes set out in this Policy. All Personal Information stored on ECONOLER’s servers is secured and accessible only to those employees who have the right to access it in the course of their duties. The principle of least privilege is followed in granting access to Personal Information according to the user’s role and responsibilities.

Third parties (partners and suppliers) may also have access to Personal Information collected for the purposes set out in this Policy. They will not be able to access Personal Information beyond what is reasonably necessary to fulfill the given purpose.

ECONOLER undertakes not to sell or share Personal Information with other third parties except in the following cases whereby:

1. The law requires it;
2. It is required for legal proceedings;
3. It is necessary to prove or protect legal rights;
4. As part of a business transaction with potential buyers if the enterprise is due to change hands.

4. WHERE YOUR PERSONAL INFORMATION IS STORED

The servers containing Personal Information are located in Quebec, Canada. However, it is possible that the communication of Personal Information to certain technological solution providers may result in the transfer of such information outside of Quebec. In such cases, ECONOLER:

• Conducts all necessary privacy risk analyses;
• Validates in advance the privacy laws and practices applicable in the relevant jurisdiction and ensures that your Personal Information is adequately protected.

5.    RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

ECONOLER has implemented measures to ensure compliance with its obligations to retain and destroy Personal Information.

Personal Information collected by ECONOLER is not retained beyond what is necessary to fulfill the purposes for which it is collected.

Notwithstanding the foregoing, ECONOLER will retain your Personal Information when such retention is required to comply with applicable legal obligations in addition to those specific to the protection of Personal Information.

6. MEASURES TO PROTECT PERSONAL INFORMATION IN THE ENTERPRISE

ECONOLER has implemented physical, organizational, contractual, and technological security measures to adequately protect Personal Information from theft, loss, unauthorized access, unauthorized transfer, as well as unauthorized copying or alteration.

ECONOLER employees are bound by confidentiality agreements. Information security and privacy training and awareness are provided to ECONOLER employees on a regular basis. IT systems comply with industry-recommended security frameworks and protocols.

7. RIGHTS OF WEBSITE USERS

As a person whose Personal Information has been collected by ECONOLER, you may exercise the rights outlined below.

Right to access, correct, or complete your Personal Information: ECONOLER makes reasonable efforts to ensure that the Personal Information it collects is accurate and complete for the purposes for which it is intended to be used. You may consult your Personal Information, verify its accuracy, and modify it if necessary subject to exceptions provided by law.

Your request for access or rectification should be forwarded to the Privacy Officer at the address provided in Section 9. Your request will be processed within thirty (30) days of receipt of your written request.

Right to withdraw your consent: You may withdraw your consent for your Personal Information to be used by ECONOLER for purposes that are not essential to the management and administration of its products and services.

It will generally not be possible to withdraw your consent to the use of your Personal Information for purposes relating to the management and administration of products and services without terminating your contract.

Any request to withdraw consent must be communicated to the Privacy Officer whose contact information is provided in Section 9.

Right to file a complaint: Any questions about your Personal Information or complaints regarding non-compliance with the principles set out in this Policy should be directed to the Privacy Officer whose contact information is provided in Section 9.4

8. POLICY UPDATE

This Policy may be amended from time to time to maintain compliance with the law and to reflect any changes to the Personal Information collection process. ECONOLER recommends that its users check the Policy from time to time to ensure that they are aware of any updates.

9. CONTACT

The Privacy Officer is responsible for ensuring the protection of your Personal Information, i.e. taking all necessary measures to guarantee your rights as described in the previous sections.

The contact details are as follows:

Privacy Officer – Econoler
Address: 2475 Bd Laurier Suite 250, Quebec City, Quebec G1T 1C4
Tel.: (418) 692-2592
E-mail: confidentialite@econoler.com

All requests will be taken into account and treated with the utmost respect. Your request will not be answered if the Personal Information is no longer held by ECONOLER.