Objective

This policy aims to define the principles and practices of our company regarding the collection, use, disclosure, retention and protection of personal information. This policy aims to define the principles and practices of our company regarding the collection, use, disclosure, retention and protection of personal information.

Section I – Definitions and application

1. Definitions
1.1. Personal information: Personal information is any information which concerns a natural person and which allows them to be identified.
1.2. Personal information of a public nature: Personal information is of a public nature when the law or regulation expressly indicates so. These include court records, municipal archives, business registers, etc. Personal information of a public nature is not subject to this policy.
1.3. Professional or business contact information: As a general rule, professional contact information such as name, title, position, or work telephone or fax number do not constitute personal information.
2. This policy applies to managers, employees, customers and any other person who provides their personal information.
3. This policy covers all personal information collected, such as that of managers, employees, customers and any other person.

Section II – Policy

4. Responsible for the protection of personal information
4.1. We designate a personal information protection officer responsible for receiving requests for access and rectification of data, answering questions relating to the protection of personal information and implementing this policy. You can contact our privacy manager, Anny Picard, at the following address: apicard@phxindustries.com
5. Collection and use of personal information
5.1. Generally, we collect personal information directly from the person concerned and with their consent, except when a law allows this data to be collected without consent.
5.2. We will obtain the consent of the individual concerned before collecting personal information from third parties, unless otherwise provided by law.
5.3. The consent of a minor child under 14 years of age must be given by the person having parental authority or a guardian.
5.4. We collect and use personal information only for the legitimate purposes for which it was collected, or for purposes consistent with the primary purpose. At the time of collecting personal information, we will notify the individual concerned of the purposes for which it is collected.
5.5. In the event of a different use of personal information, we will need to obtain new consent, unless otherwise provided for by law.
5.6. Personal information collected may include, but is not limited to:
a. Identifying information, such as name, address, social insurance number, telephone number, email address or a copy of your driver’s license;
b. Financial information necessary for billing and payment, such as a billing address, bank account information or payment data;
c. Information relating to training, such as curriculum vitae;
d. Any other personal information necessary for the performance of our obligations.
6. Retention, destruction and security of personal information.
6.1. We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, and in accordance with applicable legal requirements. At the end of the retention period, personal information will be destroyed.
6.2. We implement appropriate security measures to protect personal information from unauthorized access, disclosure, alteration or destruction.
6.3. Access to personal information is limited to staff members and individuals for whom the information is necessary to carry out their duties.
7. Access to personal information, rectification and withdrawal of consent
7.1. Individuals whose personal information we hold have the right to access and correct their data. Requests for access or rectification must be sent to our personal information protection manager by written request.
7.2. The Privacy Officer will review requests in accordance with applicable privacy laws.
7.3. An individual can have personal information about them deleted if the collection is not authorized by law.
8. Communication of personal information to third parties
8.1. Before communicating personal information to third parties or for any secondary use thereof, we will obtain the consent of the person concerned, unless otherwise provided for by law.
8.2. Personal information may be communicated to third parties without the consent of the person concerned, in particular in the following situations:
a. When it is necessary to communicate this information to a supplier or subcontractor for the execution of the mandate. Where applicable, a written contract with this supplier or subcontractor will indicate the measures to be taken to ensure the confidentiality of this personal information;
b. When required by applicable laws.
8.3. Personal information may be communicated outside Quebec, in particular to a supplier or subcontractor located outside the province.
9. Complaint handling process
9.1. A complaint regarding the protection of personal information can be made to the person responsible for the protection of personal information.
9.2. The complaint will be processed within 30 days of receipt.
10. Training and awareness
10.1. We educate our staff about the importance of protecting personal information and provide them with the necessary training to ensure compliance with this policy.
10.2. Staff members with access to personal information must ensure its protection and comply with this policy.
11. Policy Review
11.1. We will periodically review this Privacy Policy to ensure that it remains in compliance with applicable laws and reflects our company’s current practices.
11.2. 11.2. This policy is effective September 20, 2023 and is subject to revision.
11.3. Any person is required to promptly report any suspected or actual violation of this policy to the Privacy Officer in order to enable us to investigate and take appropriate action.

Responsible for the protection of personal information:
Anny Picard
apicard@phxindustries.com
450 430-1331

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