FR

Privacy Policy

PRIVACY POLICY FOR THE PROTECTION OF PERSONAL INFORMATION

1. Purpose and Objectives

In accordance with the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1), as modernized by Law 25, Elevex Inc. (hereinafter “Elevex”) is committed to protecting the personal information collected in the course of its activities.

This policy is intended to inform any individual concerned of Elevex’s practices regarding the collection, use, disclosure, retention, destruction/anonymization, and protection of personal information, as well as the rights available to them.

2. Definitions

2.1 Personal Information

Personal information is any information that relates to a natural person and that allows them to be identified directly or indirectly (e.g. name, contact details, financial information, online identifiers, etc.).

Some information may be considered sensitive depending on the context (e.g. financial information, government identifiers, medical information, etc.) and requires a higher level of protection.

Note: A person’s name, title, phone number, and professional email address are not considered personal information when used in the context of carrying out their professional duties.

2.2 Non-Personal Information

Non-personal information refers to information that does not allow a natural person to be identified, including anonymized or aggregated information.

3. Governance and Responsibilities

Elevex has established governance policies and practices covering the lifecycle of personal information (collection, use, disclosure, retention, and destruction), the roles and responsibilities within the organization, as well as a complaint handling process. Access to personal information is limited to individuals who require it in the performance of their duties (need-to-know basis), and such individuals are bound by confidentiality obligations.

4. Consent and Legal Basis for Processing

Elevex collects, uses, and discloses personal information with the consent of the individual concerned, except where the law provides for an exception. Consent must be manifest, free, informed, and given for specific purposes. Where required, particularly for sensitive information or depending on the context, Elevex may request express consent. Consent may be withdrawn at any time by contacting the Privacy Officer. However, withdrawing consent may limit access to certain services or prevent Elevex from providing a requested service.

5. Personal Information Collected, Categories and Purposes

5.1 Categories of Information That May Be Collected

Depending on interactions with Elevex, the following categories may be collected:

  • Identity and contact information (name, address, email, phone number)
  • Transactional and billing information (purchase history, invoices, payment information)
  • Credit information (if applicable, for a credit or financing application)
  • Service and support (communications, requests, warranty claims, after-sales follow-up)
  • Digital information (see Section 7: IP address, cookies, browsing data)
  • Recruitment (resume, experience, references, information required to evaluate a candidacy)
  • Employment (see Section 6)

5.2 Purposes for Collection, Use and Retention

Elevex may collect and use personal information, in particular to:

  • Process warranty claims
  • Handle billing and after-sales follow-up
  • Manage service-related communications
  • Recommend products or services where permitted and in accordance with preferences and consents
  • Meet legal and regulatory obligations
  • Provide requested products and services
  • Process credit or financing applications (if applicable)
  • Enable external service providers to assist Elevex (e.g. IT, marketing, collections, delivery, payment processing), in accordance with Section 9

6. Employee Personal Information

Employee personal information is collected and used to manage employment relationships, compensation, benefits, health and safety (if applicable), and compliance with legal obligations, as well as to enable authorized service providers to assist Elevex in carrying out these functions.

7. Collection Methods

Personal information may be collected, in particular:

  • Through contracts and forms (paper or electronic)
  • Through written or verbal communications (email, phone, in person)
  • Through authorized commercial sources or third parties, where permitted by law

8. Digital Information, Cookies and Technologies

When using the website, Elevex may collect certain technical information, such as IP address, browser type, operating system, pages visited, and referring websites. This information is used to ensure the proper functioning of the site, improve its performance, and generate aggregated statistics.

Elevex uses cookies:

  • Strictly necessary cookies required for the operation of the site are used automatically.
  • Non-essential cookies (e.g. analytics, audience measurement, experience improvement) are only used with the explicit consent of the individual concerned, expressed through a positive action.

Cookie preferences may be modified at any time through the site’s cookie management tool (if available) or through browser settings.

9. Safety Measures

Elevex implements reasonable physical, administrative, and technological security measures to protect personal information against loss, theft, unauthorized access, unauthorized disclosure, use, or modification. These measures take into account the nature and sensitivity of the personal information and the risks associated with its processing.

10. Disclosure and Sharing with Third Parties

Elevex does not sell, rent, or transfer any personal information to third parties for marketing purposes without the explicit consent of the individual concerned.

Personal information may be disclosed to service providers where necessary for the operation of Elevex’s business activities (e.g. payment processing, delivery, IT services, credit management, administrative support). These service providers process personal information solely on behalf of Elevex and in accordance with its instructions.

Elevex ensures that contractual and organizational measures are in place so that these service providers offer a level of protection equivalent to that required by law.

Personal information may also be disclosed where required or authorized by law (e.g. government authorities, investigations, legal proceedings, fraud prevention and detection).


10.1 Disclosure of Personal Information Outside Quebec

When personal information must be disclosed or processed outside Quebec (in particular through technology service providers), Elevex conducts, where required, a Privacy Impact Assessment (PIA) and implements appropriate measures to ensure an equivalent level of protection.

11. Retention, Destruction and Anonymization

Elevex retains personal information only for as long as necessary to fulfill the purposes for which it was collected and to meet its legal or contractual obligations.
When personal information is no longer required, it is securely destroyed or anonymized in accordance with applicable laws and Elevex’s internal practices.
As a general indication, certain information may be retained for longer periods where required (e.g. accounting and tax obligations, dispute management, warranties, employment records).

12. Privacy Incidents

In the event of a privacy incident involving personal information, Elevex takes reasonable measures to reduce the risk of harm and prevent a similar incident from recurring.

Where the incident presents a risk of serious harm, Elevex promptly notifies the Commission d’accès à l’information du Québec (CAI) as well as the individuals concerned, in accordance with applicable law.

Elevex maintains a privacy incident register and makes it available to the Commission upon request.

13. Automated Decision-Making (if applicable)

Where Elevex uses an automated processing system to make a decision regarding an individual (where applicable), Elevex informs the individual concerned of the elements required by law and allows them to submit observations and request that a person review the decision, where provided for by law.

14. Privacy Officer

The Privacy Officer is:
Mr. Bruno Houle, CRHA
Email: protectionrp@elevex.ca
Phone: 514 405-4108, ext. 248

15. Individual Rights and Requests

  • Any individual may request:
  • Access to their personal information
  • Rectification to ensure its accuracy
  • Deletion, where permitted by law
  • Withdrawal of consent
  • Portability, where applicable (computerized information)