PRIVACY POLICY

1. Purpose

In compliance with the Act Respecting the Protection of Personal Information in the Private Sector,
Elevex Inc. (hereinafter “Elevex”) is committed to protecting personal data collected from its clients, providers and employees. This policy describes the collection, usage, disclosure and conservation of your personal data and your right to access them.

2. Definitions

2.1. Personal Data :

Personal data is defined as data, or a combination of data which relates to a physical person and that allows to identify them such as the name, date of birth, social insurance number, postal address, email address, telephone number, financial information, etc. However, the name of an individual along with its professional coordinates (job title, address, business phone number and email address) do not constitute personal data.

2.2. Non-Personal Data :

Non-personal data consists of any type of data other than those included in paragraph 2.1. of this policy, such as the business coordinates of an individual. Anonymous data, or data that does not relate to an identifiable person (i.e. online browsing data) are also considered to be non-personal data.

3. Consent

When you submit personal data to Elevex, you accept that we collect, use and disclose it for the purposes described in this policy or for other purposes specified at the time this data is collected.

Elevex is committed to use the data provided for the purposes for which it has been collected and to keep it for the time required for the completion of the service requested or for the analysis of the application in the case of a job application, unless a specific conservation delay is prescribed by an applicable law or regulation.

You may withdraw your consent or unsubscribe from our senders’ lists and from any other form electronic communications at any time.

4. Personal data collected and purposes

Personal data may be collected and conserved by Elevex for the following purposes:

• Warranty claims processing.
• Invoicing and post-sale follow up.
• Basic communication.
• Recommendation on products or services.
• Compliance to any legal requirements.
• Delivery of requested products.
• Processing of credit applications.
• Allowing external services providers to assist us in the administration of our business by providing marketing, collections, product delivery or payment processing services.

4.1. Employee Personal Data

Employee personal data consists of personal data related to the pre-employment, employment and termination of employment processes of a person at Elevex. The collection of this data aims to :

• Allow Elevex to manage and pay its personnel.
• Manage well-being programs such as group insurance benefits.
• Allow external services providers to assist us in the administration of our business by providing employee file management services, workers compensation claim management services, background verification or other services.

5. Personal Data Collection Methods

Various methods allow Elevex to collect personal data, including:

• Credit applications and verifications.
• Purchase, rental and services contracts or other commercial agreements.
• Surveys, market studies and other sources of commercial information such as credit agencies.
• The Information request form on www.elevex.ca in the “contact us” section.
• Information collected in the normal course of business or labor relations (phone calls, in person, by email, etc.).
• Information gathered via a third party that is authorized to share such information with Elevex in the course of business, as per its own Data Privacy policy, or otherwise in compliance with application laws.

6. Electronic Information from Devices

Elevex may collect data from your computer and software which may include: your IP address, the type of browser, the operating system, the domain name, the access times and addresses of referring web sites. Elevex also collects data on the specific pages viewed on its web server and applications. Elevex does not link your IP address to the personal data you provide via our website, but such address may be used to establish your profile during the length of a session and to gather general and aggregated demographic data on the persons that browse our website.

For certain Web applications, Elevex uses cookies, which consist of data elements transmitted in your computer by the website to facilitate or improve the communication and interaction with the website. These cookies may help us providing personalized content and are an integral part of some of our Web applications. You can prevent or restrict the installation of cookies on your computer, or remove them from your browser by modifying the settings/preferences of your web browser. However, blocking certain cookies may affect functionality of the website. Elevex does not use cookies to obtain personal data from your computer for purposes other than those related to the services offered on the website or your interaction with the websiteé.

7. Personal Data Protection

Elevex is committed to the protection of your personal data against loss, theft, unauthorized access, disclosure, usage or modification. To achieve this, Elevex has implemented internal rules and practices that are communicated and applied locally in its different branches.

8. Sharing of Personal Data

We do not exchange, sell, lease or cede your personal data to third parties for marketing purposes, unless you provide us with your explicit consent. However, we may share your information with external service providers that assist us in the administration of our business (i.e. financial partners for the processing of credit applications, providers of pre-employment background screening services, etc.). We take measures to ensure that these third parties adhere to rigorous standards in terms of security and confidentiality.

Elevex may disclose your personal data if the law requires or authorizes it. In certain circumstances, we may gather, use or disclose personal data without notifying you or without your consent. Such circumstances will occur when, for legal, medical or safety reasons, it is impossible or unlikely to obtain your consent or when such data is necessary to complete an investigation on a breach of contract, to prevent or detect a fraud or to apply the law.

9. Data Retention

Elevex ratains your personal data as long as required to accomplish the purpose for which they were collected or to satisfy legal or contractual obligations. This personal data is destroyed in compliance with the law and to our file retention policy. When it is no longer necessary for Elevex to keep such data, or if they are simply not kept, the documents containing personal data are destroyed through a secure document destruction service or by deleting them from the electronic data software.

10. Personal Data Protection Officer

The Personal Data Protection Officer is :

M. Bruno Houle, CHRP
protectionrp@elevex.ca
514-694-4223 ext. 248

10.1. Access Request, Accuracy, Deletion and Complaint

All personal data access requests, modification requests aiming to ensure accuracy or deletion requests must be submitted by email to the Personal Data Protection Officer. Such request must contain sufficient information to be able to prove the identity of the requester and identify the data that is requested.

We will provide the data in a reasonable time frame from the date your written request is received. Fees may be associated with your access request and required based on the nature and the scope of your request (i.e. cost of photocopying).

An access, modification or deletion request may be refused if the releasing of such data may cause the disclosure of another person’s personal data. In such case, you will be notified in writing of the reasons justifying this refusal.

Any complaint regarding personal data protection or to contest Elevex’ compliance with the law or to such policy may be sent to protectionrp@elevex.ca.

11. Modifications to the Policy

This policy is in force at the date indicated in the heading of this document. Elevex reserves its right to update or modify it at any time without notice. You are invited to review it periodically.