Personal Information Protection Policy and Privacy Policy

1 - Context

Hydro ECI Inc., hereinafter referred to as "Hydro ECI", is committed to the preservation and protection of your personal information.

The purpose of this policy is to inform you of Hydro ECI’s practices regarding the use of personal information that we collect or that you provide to us when you use the Hydro ECI website and its various features (under the domain name www.hydro-eci.com (https://www.hydro-eci.com)).

This policy is intended to ensure the protection of personal information and to govern the way Hydro ECI manages it. That is, how that information is collected, used, disclosed, retained, and destroyed. This policy is also intended to inform any interested person about how Hydro ECI handles their personal information.

2 - Definitions

For the purposes of this document, personal information is information that relates to a natural person and allows, directly or indirectly, to identify that natural person. Like what:

Your name,
Your address,
Your email address,
Your phone number,
Your gender,
Your banking information,
Etc.

Generally, an individual’s professional or business contact information is not personal information. For example, a person’s name, title, address, email address or business telephone number. More specifically and for the sake of clarity, within the meaning of Québec’s Ac respecting the protection of personal information in the private sector, and as of September 22, 2023, sections 3 (Collection, use, disclosure), 4 (Curriculum Vitae), 6 (Retention and destruction) and 8 (Data security) do not apply to information of an individual relating to the exercise of a function in an enterprise, such as name, title, position, and the address, email address and telephone number of their place of work.

These same paragraphs also do not apply to personal information that is public by law, as soon as this policy comes into force.

3 - Collection, Use and Disclosure

During its operations, Hydro ECI may collect different types of information for different purposes.

In all cases, Hydro ECI collects information only if it has a valid reason to do so. In addition, collection will be limited to that which is necessary to fulfill the intended purpose.

Please note that Hydro ECI’s services and programs are not directed to minors, and more generally, Hydro ECI does not knowingly obtain personal information from minors (in these cases, information cannot be collected from Hydro ECI without the consent of a parent or guardian).

3.1 - How is your personal information collected?

Through requests or queries addressed to Hydro ECI by email, via the contact page of Hydro ECI’s website or on social media.
Through your access to the Hydro ECI website, cookies may be placed on your computer or mobile device.

3.2 - For what purposes is your personal information used?

Establish and manage client relationships (and obtain a means of communication).
Offer or provide a professional service.
Collect information as part of a program. Note that it is sometimes necessary to share the information provided to the program in question.
Respond to a request for information (current or future).
Comply with its legal obligations.
Investigate and prevent fraud or misconduct.
Issue communications or invoices relating to projects, contracts, or joint ventures.
Explore business opportunities or obtain projects.
Evaluate potential service providers.
Manage communication with job candidates.

3.3 - With whom will Hydro ECI share your personal information?

Hydro ECI will not sell, rent, or trade your personal information with third parties and will only share it with:

Third party service providers who process data on behalf of, provide support to, or manage its website.
Third parties when it is reasonable to believe that disclosure of the information is necessary to ensure the safety of individuals and protect their rights and property, or as permitted under applicable laws.
Police or financial crime and fraud detection agencies in connection with fraud or corruption investigations, or for any other purpose permitted under applicable laws.
A government entity in response to a government request.

4 - Curriculum vitae

It is possible to send your curriculum vitae to Hydro ECI via the contact page of its website. Hydro ECI may retain the information you have provided when you apply for a job or for future reference.

4.1 - What information is collected?

Your name.
Your address.
Your contact information.
Your level of education.
Your employment history.
Your references or the result of your employment background check.
Your curriculum vitae.
The information provided in your cover letter and as part of your application.

To request that Hydro ECI delete information about you, you may send an email request to the Privacy Officer (set out in this policy).

4.2 - How is your personal information collected?

Directly from you when you provide them on your resume or as part of a job application.
From the people you indicate for references.
From references obtained from third parties such as educational institutions, your current employer, or past employers.
Based on your work history check results, including publicly available sources such as Google and LinkedIn.

4.3 - For what purposes is your personal information used?

To consider your application and assess your suitability for the coveted position or any other position that may suit your profile.
To verify or obtain information or references about you from third parties.
To inform you of employment opportunities that may be of interest to you.
To evaluate Hydro ECI’s recruitment practices.

4.4 - With whom will Hydro ECI share your personal information?

Hydro ECI will not sell, rent, or trade your personal information with third parties and will only share it with:

Third parties with whom Hydro ECI communicates to verify your personal information and obtain references, including previous employers or educational institutions.
Service providers that Hydro ECI uses as part of the application process.

5 - Use of technology

5.1 - Use of cookies

Cookies are data files that are transmitted to a website visitor’s computer by their web browser when they visit that site and can serve several purposes.
Websites controlled by Hydro ECI use cookies, including:

To remember visitors’ settings and preferences, e.g. for language selection and to enable tracking of the current session.
For statistical purposes to know the behavior of visitors, the content consulted and allow the improvement of the website.

Websites controlled by Hydro ECI use the following types of cookies:

Session cookies: These are session cookies that are stored for the duration of the website visit only.
Persistent cookies: These are kept on the computer until they expire and will be retrieved the next time you visit the site.

5.2 Use of Google Analytics

The Hydro ECI (https://hydro-eci.com/) website uses Google Analytics to enable continuous improvement. Google Analytics makes it possible to analyse how a visitor interacts with a Hydro ECI website. Google Analytics uses cookies to generate statistical reports on the behaviour of visitors to these websites and the content viewed.

Information from Google Analytics will never be shared by Hydro ECI with third parties.

It is possible to install a browser add-on to disable Google Analytics.

5.3 - Other technological means used

Hydro ECI also collects personal information through technological means such as web forms embedded on a website controlled by Hydro ECI (e.g. its contact form), questionnaires available online on its platforms and applications, and other forms platforms or tools (e.g., Microsoft Forms).

If Hydro ECI collects personal information by offering a technology product or service that has privacy settings, Hydro ECI must ensure that these settings provide the highest level of confidentiality by default (cookies are not covered).

5.4 - Social Media

Hydro ECI publishes, among other things, content on digital platforms such as LinkedIn.

All information you post or disclose on social media is in the public domain. Hydro ECI cannot control the use of information that is disclosed on social media. Please exercise caution when disclosing information on public platforms.

Hydro ECI’s website may use widgets on its website to directly access certain social media including, but not limited to, Facebook, YouTube, LinkedIn, Instagram, and Twitter. These social networks are likely to identify you, even if you have not used these applications during your consultation of our websites, because your personal account can be activated on your terminal (open session).

We have no control over the processes used by these social networks to collect browsing information on our sites. We invite you to read their policies and inform yourself of your rights or how to set up your personal accounts.

6 - Retention and Destruction of Personal Information

Unless a minimum retention period is required by applicable law or regulation, Hydro ECI will retain personal information only for as long as necessary to fulfill the purposes for which it was collected.

At the end of the retention period or when the personal information is no longer required, Hydro ECI will ensure that:

To destroy them; or
Anonymize it (i.e. it no longer irreversibly identifies the individual and can no longer be linked to personal information) for serious and legitimate purposes.

The destruction of information by Hydro ECI must be done in a secure manner to ensure the protection of that information.

This section may be supplemented by any policy or procedure adopted by Hydro ECI regarding the retention and destruction of personal information, if any. Please contact Hydro ECI’s Privacy Officer (identified in this policy) for more information.

7 - Hydro ECI Responsibilities

In general, Hydro ECI is responsible for the protection of the personal information it holds.

Hydro ECI’s Privacy Officer is the Director of Operations of the organization. He or she must, in general, ensure compliance with applicable legislation concerning the protection of personal information. The manager must approve the policies and practices governing the governance of personal information. Specifically, this person is responsible for implementing this policy and ensuring that it is known, understood, and applied. In the event of the absence or inability to act of this person in charge, Hydro ECI’s IT manager will assume the functions of the person responsible for the protection of personal information.

Hydro ECI personnel who have access to or are otherwise involved in the management of personal information must ensure its protection and comply with this policy.

The roles and responsibilities of Hydro ECI employees throughout the life cycle of personal information may be specified by any other Hydro ECI policy in this regard, as applicable.

8 - Data security

Hydro ECI is committed to implementing reasonable security measures to ensure the protection of the personal information it manages. The security safeguards in place include, among other things, the purpose, amount, distribution, medium and sensitivity of the information. Thus, this means that information that qualifies as sensitive will have to be subject to greater security measures and will have to be better protected. In particular, and consistent with the above-mentioned limited access to personal information, Hydro ECI must put in place the necessary measures to impose constraints on the rights to use its information systems so that only those employees who need to have access to them are authorized to access them.

9 - Rights of access, rectification, and withdrawal of consent

To exercise your access rights, rectification or withdrawal of consent, the data subject must submit a written request to that effect to Hydro ECI’s Privacy Officer (indicated in this policy).

Subject to certain legal restrictions, individuals may request access to their personal information held by Hydro ECI and request its correction if it is inaccurate, incomplete, or ambiguous. They may also require the cessation of the dissemination of personal information concerning them or that any hyperlink attached to their name allowing access to the information by technological means be deindexed, where the dissemination of the information contravenes the law or a court order. They may do the same, or require that the hyperlink to access this information be re-indexed, when certain conditions set out in the law are met.

Hydro ECI’s Privacy Officer must respond in writing to such requests within 30 days of the date of receipt of the request. Any refusal must be justified and accompanied by the legal provision justifying the refusal. In these cases, the response must indicate the remedies under the law and the time limit for exercising them. The person in charge must help the applicant understand the refusal if necessary.

Subject to applicable legal and contractual restrictions, individuals may withdraw their consent to the disclosure or use of the information collected.

They may also ask Hydro ECI what personal information it collects, the categories of individuals at Hydro ECI who have access to it and how long it is retained.

10 - Complaint Process

10.1 - Reception

Any individual who wishes to make a complaint regarding the application of this Policy or, more generally, the protection of his or her personal information by Hydro ECI, must do so in writing by contacting Hydro ECI’s Privacy Officer (indicated in this Policy).

The individual will be asked to provide their name, contact information, including a telephone number, and the subject matter and reasons for the complaint, with sufficient detail for it to be assessed by Hydro ECI. If the complaint is not sufficiently specific, the Privacy Officer may request any additional information it considers necessary to assess the complaint.

10.2 - Treatment

Hydro ECI undertakes to treat any complaint received confidentially.

Within 30 days of receipt of the complaint or receipt of any additional information deemed necessary and required by Hydro ECI’s Privacy Officer to process the complaint, Hydro ECI’s Privacy Officer must assess the complaint and provide a written reasoned response by email to the complainant. This assessment will determine whether Hydro ECI’s handling of personal information complies with this policy, any other policies, and practices in place within the organization and applicable legislation or regulations.

If the complaint cannot be processed within this period, the complainant must be informed of the reasons justifying the extension of the time limit, the progress made in dealing with his complaint and the reasonable time required to be able to provide a definitive response.

Hydro ECI must establish a separate file for each complaint addressed to it. Each file contains the complaint, the analysis and documentation to support its assessment, as well as the response sent to the person making the complaint.

It is also possible to file a complaint with the Commission d’accès à l’information du Québec or any other privacy oversight body responsible for enforcing the law concerned by the subject matter of the complaint.

However, Hydro ECI invites all interested persons to first contact their Privacy Officer and wait until the completion of the processing process by Hydro ECI.

11 - Approval

This policy is approved by Hydro ECI’s Privacy Officer, whose business contact information is as follows:

Privacy Officer:
1200 Arthur-Danis, Granby (Quebec) Canada J2J 0T3
Tel.: (450) 777-0808
privacy@hydro-eci.com

For any requests, questions, or comments under this policy, please contact the person in charge by email.

12 - Publication and changes

This policy is published on Hydro ECI’s website, as well as on all websites controlled and maintained by Hydro ECI, to which this policy applies, with respect to the personal information collected therein. This policy is also disseminated by any means likely to reach the persons concerned.

Hydro ECI shall also do the same for all changes to this policy, which shall also be notified to inform affected individuals.

*Notes: Please note that the use of the masculine gender is intended to lighten this policy and make it easier to read.