Confidentiality policy

Thank you for visiting Éco Entreprises Québec’s website (ÉEQ) and for taking the time to read this confidentiality policy.

Éco Entreprises Québec (“ÉEQ”) respects the privacy of all users of its website,the Ecodesign Portal, OptimAction tool, Reporting Portal and any other website or platform operated by ÉEQ (collectively and individually referred to as the “Website”), and pledges to maintain that privacy in accordance with this Confidentiality Policy.

Website users include corporations, companies, firms and private individuals.

This Confidentiality Policy explains how ÉEQ handles information collected as part of users’ activities on the Website.

Website users are deemed to have read, accepted and recognized the validity of this Confidentiality Policy. Should a Website user not accept the terms of this Confidentiality Policy, he or she should stop using the Website. Even in those circumstances, the user remains obligated to submit Company Reports in accordance with applicable laws and regulations. ÉEQ may change this Confidentiality Policy at any time and without notice. Website users are asked to regularly review the Confidentiality Policy to check whether changes have been made. If they continue to use the Website after changes have been published, users are deemed to have accepted said changes to the Confidentiality Policy.

COLLECTION OF PERSONAL INFORMATION

In the course of operating the Website, ÉEQ may collect personal information about its users.

“Personal information” is defined as information permitting the identification of private individuals, including their name, contact information, e-mail address, etc. ÉEQ will collect users’ personal information when they provide it at the time of registration for an ÉEQ service, particularly when subscribing to a newsletter, logging on to the reporting system, using the OptimAction tool or placing a request via the Website. ÉEQ may also receive their personal information through its commercial partners or other third parties, provided those third parties confirm that the user has agreed to the disclosure of personal information.

COLLECTION OF CONFIDENTIAL INFORMATION

In the course of operating the Website, particularly the Reporting Portal and the OptimAction tool, ÉEQ may collect confidential user information other than personal information.

“Confidential information” is defined as financial, commercial, scientific or technical information a user may provide to ÉEQ that is of a confidential nature, is not publicly available and is treated as such by the user on a continuing basis (sales figures and quantities of products marketed, for example). ÉEQ may also receive confidential information through its commercial partners or other third parties, provided those third parties confirm that the user authorized the disclosure of personal information.

USE OF PERSONAL AND/OR CONFIDENTIAL INFORMATION

ÉEQ takes seriously its responsibility to properly handle personal and/or confidential information provided by everyone it deals with. ÉEQ limits the personal and confidential information collected to that necessary for conducting business and fulfilling its mandate (including for research purposes), as well as evaluating its performance.

Only ÉEQ personnel authorized to follow up on requests for information, verification and analyses have access to personal and/or confidential information. ÉEQ informs such employees about their obligation to maintain confidentiality.

ÉEQ may use personal and confidential information for the following purposes:

a) To provide the services, products or information requested by the user, contact him or her in reply to a question, ensure quality assurance internally or manage the quality of information provided via the Website.
b) To carry out research and development efforts related to its field of practice and mandate.
c) To fulfill its mandate towards government authorities and its members, which includes data compilation concerning voluntary disclosure, the implementation of centralized recycling and eco-packaging resources, and lobbying.
d) To provide the user with the latest information and updates and offer materials and training related to our activities. Such electronic messages are, however, sent out in accordance with anti-spam legislation, and the user may ask ÉEQ to remove his or her e-mail address from its distribution list at any time.
e) ÉEQ may also use personal and confidential information if it reasonably believes that such information may be relevant to an investigation into a violation of federal, provincial or foreign law, or to ensure the protection or defence of lawful interests.
f) ÉEQ may use confidential information in accordance with ÉEQ’s Schedule of Contributions enables companies to determine whether they are subject to the Act, understand the breadth of their obligations and determine the amount of their contribution. Developed using a formula based on studies and verifiable data, the Schedule is established according to type of material and quantities generated during a given year and in consideration of environmental criteria. Framed by thoroughly developed rules, each Schedule is presented to companies for consultation before being sent to the government for approval as required by the Act.
Schedules of Contributions and the Conditions of Use of ÉEQ’s Website and Reporting System, particularly to ensure the user’s compliance with those terms or under the applicable laws.

ÉEQ keeps the personal and/or confidential information it collects for as long as deemed necessary to carry out its activities and for the aforementioned purposes.

COMMUNICATION OF PERSONAL AND/OR CONFIDENTIAL INFORMATION

ÉEQ pledges not to publicly disclose, sell, rent or share personal and/or confidential information to any third party, including its members, subject to the following.

ÉEQ will only disclose personal and/or confidential information to third parties in the following circumstances:

a) The user has specifically authorized ÉEQ to disclose personal information for a given purpose.
b) The third party involved is acting on ÉEQ’s behalf as its agent or supplier of goods or services, and the information is provided to them for the sole purpose of facilitating or ensuring the delivery of ÉEQ’s services. These third parties must respect strict contractual conditions that require them to maintain the confidentiality of all information and to use such information for the sole purpose of delivering ÉEQ’s services or fulfilling its mandate.
c) Disclosure is required to meet the requirements and facilitate the delivery of a specific ÉEQ service in accordance with applicable conditions, particularly legal obligations.
d) A lawful ruling rendered by a court, institution or relevant authority compels ÉEQ to provide personal information, summons ÉEQ to produce documents, or otherwise requires ÉEQ to disclose the information under the applicable laws. ÉEQ also reserves the right to report to authorities any activity ÉEQ believes, in good faith, to be illegal. ÉEQ may disclose certain personal and/or confidential information when it believes that disclosure is necessary to protect its own rights, property and security as well as that of third parties, or to ensure the fulfilment of the user’s obligations towards ÉEQ.

SECURITY OF PERSONAL AND CONFIDENTIAL INFORMATION

The security and protection of personal and/or confidential information are important to ÉEQ. ÉEQ implements reasonable technical, contractual, administrative and material measures to protect the personal and confidential information users provide, including secure 128 bit encryption (Secure Socket Layer – SSL) when required. Although 100% protection cannot be guaranteed, ÉEQ has implemented rigorous methods that meet strict security standards to ensure personal and confidential information is protected.

ÉEQ employees who have access to this information may only use it for the purposes indicated in the Confidentiality Policy herein and according to applicable laws and regulations.

ÉEQ employees are not authorized to discuss information concerning a user unless the correct answer to the contact’s security question recorded for the user is provided. ÉEQ reserves the right, however, to directly contact a user concerning contributions due to ÉEQ by virtue of applicable laws and regulations and to discuss related topics.

ÉEQ has implemented appropriate security measures to protect the integrity of data submitted when its members makes online payments using Moneris Solutions. All transactions conducted via Moneris Solutions online payments are 128-bit encrypted during transfer between Moneris Solutions and the user’s computer. Each session is automatically deactivated as soon as the transaction is complete. To open a new session, the user must go back to the online reporting page on the “Invoices” screen and click again on the payment button. Regardless of this safeguard, users should never leave an online payment session unattended. It is always good practice to Quit the screen or reporting session before leaving the computer, even if planning to return in a few minutes.

ACCESS TO PERSONAL INFORMATION AND CHANGES

Users may request the deletion of their personal data or access their personal information to view, update, change it or request a copy of their data by contacting Mr. Hugo Lapointe, Privacy Officer at ÉEQ, using the following email address: renseignements.perso@eeq.ca

Éco Entreprises Québec
1600 René-Lévesque West
Suite 600, Montréal, Quebec H3H 1P9

ÉEQ may refuse the user’s request for any of the following reasons:

ÉEQ is legally required to retain the user’s personal data
The request has been sent an excessive number of times
The request requires disproportionate technical efforts
The request jeopardizes the personal life of third parties
The request is impractical

UNDER-AGE USERS

ÉEQ takes appropriate precautions to comply with applicable laws concerning the privacy of under-age persons. The content of the Website is designed for a general audience and not for under-age users. ÉEQ therefore does not seek to collect personal information from under-age persons without previously checking that consent has been given by parents or other authorized persons in accordance with the law. Should the user believe otherwise, he or she should contact ÉEQ to discuss the issue.

PROCESSING OF COMPLAINTS

For any complaints related to the use of personal information, the user should contact Mr. Hugo Lapointe, ÉEQ’s Privacy Officer, using the aforementioned email address.

The process for handling security incidents concerning personal data includes the following steps:

Conducting a preliminary investigation
Informing the Commission d’accès à l’information of any incident regarding sensitive personal data
Keeping a record of the incident
Implementing measures to immediately limit any invasion of privacy
Evaluating the risks
Informing individuals affected by the loss or theft of sensitive personal data
Conducting a thorough final assessment and implementing preventative measures

COLLECTION OF NON-PERSONAL INFORMATION

In the course of operating the Website, ÉEQ may collect non-personal information about its users.

“Non-personal information” is defined as the name of the Internet domain (e.g. “xyzcompany.com”) and the Internet protocol address (IP address) used to access the Website, the date and time of the visit, the pages visited, the browser type and version or the operating system used, as well as the previous and subsequent website accessed. General information, such as demographic statistics on users, the number of visitors and the average usage time of the Website are also considered non-personal information.

ÉEQ collects or gathers non-personal information in the course of its Website operations. For example, when the user chooses to visit the Website, web servers may automatically collect non-personal information provided via the user’s browser or stored as “cookies” or other digital markers.

USE OF NON-PERSONAL INFORMATION

ÉEQ uses non-personal information to follow up on Website use and to improve its management, conduct statistical analyses on all user characteristics and behaviour, measure demographic variables and user interest in particular services, describe its services to third parties and potential business partners, and determine how ÉEQ resources should be applied and/or could be made more efficient. No personal information is disclosed during such activities.

Non-personal information is necessary for ÉEQ to gather required information on the number of visitors, the pages most frequently consulted, the technology used by Website users, link selection and users’ country of origin.

Cookies are fragments of information sent to your computer when a website is viewed. These are traces of the user’s visit that are recorded either temporarily or permanently on their hard drive and may include the date and time of the last visit, among other things. Cookies contribute to improving users’ online experience by recording browsing preferences on a particular website.

Cookies left on users’ hard drive are harmless and may be read or deleted at any time. Users therefore have complete control over them. The information allows us to determine the total number of visitors to each web page and the time spent on it. Every time users go to the Website, a cookie is created and left on their computer, therefore allowing ÉEQ to “recognize” them.

Many major websites use cookies, including those from the Website’s providers. The user may choose to change their browser settings so that a message is automatically sent to ask whether to accept or refuse cookies. While users are not required to accept cookies, they should be aware that certain Website functionalities may not work properly if cookies are refused.

This Website uses Google’s Remarketing service which allows Google to show our ads on sites on the internet. Google uses cookies to serve ads based on a user’s prior visits to our Website, in a way that does not personally identify users. To know more about this functionality, please click here. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

LINKS TO THIRD-PARTY SITES

The Website may contain links to third-party sites (“Third-Party Sites”) via which the user will leave the Website. ÉEQ provides these links for the user’s convenience. ÉEQ has no control over the content and use of such sites, nor on their practices relating to privacy and confidentiality. Therefore, any confidential or personal information provided through those sites will be subject to that site’s privacy policy. It is the user’s responsibility to consult such policies to ensure the privacy of their information.

QUESTIONS, COMMENT OR SUGGESTIONS

If you have questions, comments or suggestions regarding this Confidentiality Policy or ÉEQ’s practices relating to privacy that are not covered by this Confidentiality Policy, contact ÉEQ at renseignements.perso@eeq.ca.