Privacy Policy

If you are short on time, read these three bullet points to understand how we use your personal information. If you are keen to know the detail, feel free to carry on reading this policy in full.

• If you are visiting our sites, we will collect your personal information to make our sites work. We may also track your behaviour on our sites depending on your location and your cookie choices.
• If you have a user profile, we will also link information about you to that profile. We will collect your username, password, company name and such other information as we feel may be required for an individual or a business user profile.
• If you participate in our events or would like to receive information about our products and services, we will usually collect information we need through various forms on our sites.

This is not all that we do with your personal information and not a complete list of how we collect it, but these are the typical user stories we feel you should know about.

1. Introduction

This privacy policy describes how we collect, use, process, disclose and protect personal information about you. It applies to personal information we collect when you access and use the services and features offered on our websites and mobile applications that link to this policy (collectively the “Sites”).

We may change this policy from time to time. If we make significant changes, we will notify you by email, notice in your account on our Sites or another appropriate method. We encourage you to review this policy whenever you use the Sites. It is important that personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us.

The EECOL group of companies consists of all subsidiaries of EECOL Electric Corp. For simplicity throughout this policy, “we” and “us” means the EECOL group and, when we refer to EECOL affiliates, we mean all parent companies, subsidiaries and affiliates of EECOL Electric Corp.

2. What personal information do we collect?

Personal information, or personal data, means any information about an individual from which that person can be identified.

We may collect, store and use, the following categories of personal information about you:

• Identity and contact information. For example, name, telephone number, email, employer name, employer address, industry, occupation, languages, information about authorised users.
• Transaction information. For example, when you purchase or return products, use our services, register a product, contact us for technical support services, we collect information about the transaction, such as product name, purchase price, quantity ordered and services provided.
• Log information. We log information about your use of the Sites. For example, the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Sites.
  
  Device information. We collect information about the computer or mobile device you use to access our Sites, including the hardware model, operating system and version, unique device identifiers and mobile network information.
• Logical identifiers. For example, passwords, username and cookies (see below).
• Accreditation information. If you are an installer certified to install products we manufacture, your certifications.
• Financial information. For example, credit or debit card information or credit rating.
• Complaints data. We collect details of any complaints made by you via our Sites.
• Communications data. We may process information contained in or relating to any communication that you send to us or we send to you. For example, if you contact us using one of the forms on the Sites, we will use that information.

We do not specifically collect sensitive personal information about you. Whether personal information is sensitive depends on the context, but it usually includes medical and financial information. We ask you not to share sensitive personal information with us, unless specifically requested or unless necessary.

We also collect, use and share Aggregated Data such as statistical, demographic, aggregated usage and purchasing data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.

3. How do we collect your personal information?

We collect personal information using different methods:

• Directly from you. For example, when you visit the Sites, we collect information when you request a quote, create an account, participate in any interactive features of the Sites, order products, register your products with us, sign up for newsletters or provide general feedback.
• Automatically when you use our Sites. When you access the Sites, we will automatically collect transaction information, log information, device information and information collected by cookies and other tracking technologies depending on your cookie settings.
• From other sources. For example, if you create or log into an account by using social network credentials, such as LinkedIn or Facebook, we will have access to certain information from that site, in accordance with the procedures determined by such social media site.

4. How and why do we use your personal information?

4.1. Purposes for which we use your personal information

We will use your personal information for the following purposes:

• To register you or the business partner as a customer or end user
• To process orders and requests for products, including quoting, tracking orders, delivery, processing returns and exchanges, payment management, processing credit and other forms of payment and collections
• To provide, maintain, improve and protect the Sites
• To personalise and improve your experience using the Sites and provide advertisements, content and features that match user profile or interests and to measure effectiveness of content delivery
• To provide and improve our customer service, including to respond to your comments, questions and requests and provide training and technical support
• To analyse and manage our business, including our relationship with you or a business partner
• To send technical notices, updates, security alerts and support administrative messages
• To improve our products and services
• To communicate with you about the services, offers, promotions, rewards, and events offered by us and others
• To link or combine with information we get from others to help understand your needs and provide you with better service
• To comply with international trade laws and regulations and other regulatory requirements
• To prevent fraud and to keep our Sites secure

The above purposes for using your personal information will overlap and, therefore, multiple purposes may justify our use of your personal information

4.2. Lawful bases for processing your personal information

We will only use personal information where the applicable law allows us to do so. Where necessary, we will rely on the following lawful bases:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where we need to comply with a legal or regulatory obligation.
• We rely on consent as lawful basis for processing in specific circumstances. Where we do rely on consent, the relevant form on the Site will provide information on when consent is sought. Usually, this will be the case in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time.

Where the applicable law does not require us to only process personal information under a specific lawful basis but imposes other requirements such as ensuring that the purposes for which we use personal information would be considered appropriate, we will comply with such other requirements.

4.3. If you do not provide your personal information

If you do not provide personal information that we request, we may not be able to provide products or services that you or our business partner requests. You will also not be able to receive targeted offers and other relevant communication. If we enter into a contract with you, without personal information that we need, we may not be able to perform that contract.

4.4. Change of purpose

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a different purpose, we can use it provided we reasonably consider that such different purpose is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will, where required by law, notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

4.5. Automated decision making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. At EECOL, automated decision-making generally is not used and, where it is used, there usually is human intervention or ability to request human intervention.

4.6. Marketing

We may use information about how you use the Sites, your identity, the identity of a business partner you represent to form a view on the products and services you may need or be interested in or that may be relevant to you. We may also combine personal information gathered across the Sites and from third parties to bring you products, services, offers, promotions and events that are most relevant to you.

We will usually ask for your consent before sending direct marketing communications to you or, where the law allows, we may send such communications to you, unless you opt out.

Wherever you are based, you can always ask us or our nominated third parties to stop sending you marketing messages at any time by following the links on any marketing message sent to you or by contacting us at any time.

4.7. Cookies

We use cookies and other tracking technologies to distinguish you form other users of our site. For simplicity, we will refer to these technologies as “cookies”. A cookie is a small text file that is placed on your computer by the websites that you visit. On subsequent visits, cookies are sent back by the website that recognizes the cookie, to develop a record of your online activity.

There are different types of cookies.

• Required cookies are necessary for the basic functions of our Sites to work such as secure log in or remembering the items in your cart.
• Functional and analytics cookies help us analyse user behaviour and improve performance of our Sites.
• Advertising cookies are used to show you the ads that are relevant to you.

Most browsers allow you to refuse to accept cookies. You may also delete cookies. This can be found in your browser settings. Please remember that if you block all cookies in your browser, you will not be able to use all features of our Sites.

4.8. Third-party links

The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

5. Who do we share your personal information with?

5.1. Categories of recipients of personal information

We may share your personal information with the following categories of third parties:

• EECOL affiliates
  • The information will be shared with EECOL affiliates which provide IT and system administration services and with e-marketing teams.
  • Local sales teams that look after our business partner accounts.
  • Other EECOL affiliates that provide shared services, such as accounts payable and receivable and purchasing, may receive personal information.
• Service providers and suppliers of goods
  • Service providers that provide IT and administration and hosting services in relation to the Sites. Personal information may also be shared with providers of analytical services.
  • Service providers that provide ancillary services such as outsourced call centres and helpdesks.
  • The information may be shared with suppliers of products, transportation companies, payment service providers and other companies involved in fulfilling your or business partner’s orders.
• Professional advisers and insurers. We may need to share information with our lawyers, accountants and other consultants, as well as with our insurers and brokers.
  • Regulators and other authorities. It may be necessary to provide personal information to, for example, tax authorities.
  • M&A buyers and sellers. The parties to whom we may choose to sell, transfer, or merge parts of our business or assets or where we acquire or seek to acquire other businesses or merge them.

We require third parties to respect security of your personal information and treat it in accordance with the law. Where we disclose personal information to a service provider or other processor, we require them to take adequate security measures to protect your personal information in line with our policies and the law. We only permit such third parties to process your personal information for specified purposes and in accordance with our instructions

5.2. International data transfers

We may share your personal information within EECOL affiliates. This may involve transferring your personal information to servers in the US and countries where EECOL affiliates or their service providers are located.

External third parties with whom we share personal information may also be based outside of Canada. In that case, we have processes in place to ensure that your personal information is adequately protected.

6. How do we protect your personal information?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We take reasonable steps to maintain physical, procedural, and technical security in our offices, information systems, and information storage facilities in order to protect your personal information. We restrict access to personal information to those individuals who need access to it in performing our duties and obligations.

7. How long will we keep your personal information?

We will only keep your personal information for as long as is necessary for the purpose for which it was collected. That includes satisfying any legal, accounting, or reporting requirements. At the end of the retention period, personal information is deleted or anonymised (so that it can no longer be associated with you).

8. What are your rights over your personal information?

8.1. Your rights in general

Your rights may vary depending on your location. These rights may be subject to exceptions and certain limitations under the applicable law.

In certain circumstances, you have the right to:

• Request access to personal information that we hold about you.
• Request correction of your personal information when incorrect, out of date or incomplete.
• Stop consent-based processing of your personal information. If we collected personal information on the basis of consent, you have the right to withdraw consent. If you withdraw your consent, we may not be able to provide certain products or services to you and will advise you if that would be the case.
• Challenge compliance of our privacy practices by.

If you wish to exercise any of the above rights, please contact us.

8.2. Verification and unfounded requests

Please note that you will not have to pay a fee to exercise your rights. However, where allowed by law, we may charge a reasonable fee if your request is clearly unfounded or excessive or we may refuse to comply with your request in such circumstances.

When you exercise your rights, we may request information form you to confirm your identity. This is to ensure your personal information is not disclosed to any person who has no right to receive it.

9. Who to contact?

We hope that this policy has been helpful, but if you have questions, requests or complaints, please contact our Privacy Officer, Winn Tran, at [email protected].