Privacy
Protection of Personal Information
Rad Industries Inc. (Rocky Mountain) (the "Company") recognizes the importance of protecting personal information and is concerned about how it handles such information.
It therefore undertakes to collect, use, disclose and retain only the personal information necessary to carry out its activities and during its business.
The Company has adopted a policy on the protection of personal information, applies it during its business, and has designated, in accordance with the Act respecting the protection of personal information in the private sector (the "Privacy Act"), a person responsible for the protection of personal information and privacy within its company. The identity and contact information of this person are set out at the end of this section.
When and how is personal information collected?
In the normal course of business, during its business and the provision of services, the Company collects certain personal information that is necessary for these purposes or for any other compatible purpose if the criteria of the Privacy Act and other applicable privacy laws and regulations are met (collectively, the "Act"). Personal information may also be collected by the Company in the context of employment, know-your-customer, collection, consultation, and business relationships.
The personal information collected by the Company may relate to the identity, contact information, health, social or family situation, employment, recruitment, financial information, training, or education of the individuals concerned, depending on the nature of the relationship between them and the Company. Identification documents containing personal information may also be collected by the Company. The necessity guides the Company's collection of personal information.
The Company ensures that the individuals affected by the personal information collected consent and are notified of such collection, prior to such collection. The Company is also transparent and takes steps to ensure that the individuals concerned by the personal information collected understand the purposes for which it is collected.
Except as otherwise provided in the Act, consents are free, clear, precise, manifest, informed and distinctively presented if given in writing. If sensitive information is collected by the Company, the individuals concerned provide express consent in advance.
The Company may collect personal information with technology that includes features that can identify, locate, or profile an individual. In such a case, consent in accordance with the Act will be sought from the individual concerned. Information about the use of the Company's website and other technical information or the interaction of the website visitor may be collected. A privacy policy is available to provide clear and simple information in this regard as well as regarding any collection of personal information by technological means.
In cases where the personal information collected by the Company is communicated to it by a third party, i.e., a person other than the person to whom the information relates, the person making the disclosure must ensure that he or she has obtained the consent of the person concerned and that he or she has notified him or her of such disclosure in advance.
What is the purpose for which personal information is used?
The personal information collected by the Company is used in the context of the provision of its services and, in some cases, to meet legal obligations arising from the Act, among other things. The personal information collected by the Company may also be required to enable it to meet its contractual obligations towards its customers and other third parties.
When may personal information be disclosed by the Company?
The Company may disclose personal information under its control to third parties, including companies that act as subcontractors for the Company or as a service provider. These third parties may, in some cases, be located outside the province of Quebec so that the personal information that the Company collects and holds may be in a location with an applicable legal regime different from that of Quebec.
The contracts that the Company enters with third parties require them to maintain the confidentiality of personal information and provide for the obligation of the latter to comply with the legal framework applicable to the Company with respect to the protection of personal information and privacy.
Subject to an exception provided for in the Act, consent will be sought from individuals to whom the personal information relates if the Company were to disclose to third parties’ personal information that is not related to its day-to-day operations and activities or that is not compatible with the purposes for which it was collected.
The Company may also disclose certain personal information it holds during a business transaction or in other cases provided for in the Act. If the circumstances of the disclosure such that the Company does not have to seek the consent of the individuals to whom the personal information relates, the Company will comply with the requirements of the Act to make such disclosure.
In addition, the Company may be required to disclose certain personal information under its control to government authorities or law enforcement agencies.
What security measures does the Company take with respect to the personal information it holds?
The Company implements policies and practices governing corporate governance and the protection of personal information.
Personal information held by the Company is stored in secure locations, in accordance with generally accepted practices, and access to such information is limited to those employees who need to know it in the course of their duties.
The Company's employees are made aware of the importance of protecting personal information and the measures to be taken to ensure that the confidentiality of this information is respected. In the course of their duties, employees follow procedures that protect the confidentiality of personal information and promote best practices in this regard.
The Company ensures the protection of personal information as soon as it is collected and implements security measures to protect it against use that does not comply with the legislation in force, to prevent accidental loss, modification, unauthorized disclosure or access, misuse, or any illegal form of use. However, the Company cannot guarantee that the personal information it collects is guaranteed to be protected against breaches.
Where is the personal information collected by the Company stored?
The Company's personal information may be held or transferred outside the province of Quebec, including to countries other than Canada and whose privacy rules differ from those of Quebec and Canada. When information is located outside of Quebec or Canada, it is subject to the laws of the country in which it is located and its collection, disclosure, use and destruction may be carried out differently from provincial or federal requirements.
How long is personal information kept?
Except as permitted or required by applicable law, the Company retains personal information only as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying ethical, legal, tax, accounting, or notification requirements to appropriate government authorities. At the end of the retention period, the personal information is destroyed, deleted, or anonymized. The anonymized information no longer irreversibly identifies the person concerned.
In the event of a confidentiality incident involving personal information, the Company follows the provisions of the Applicable Law and takes reasonable measures to mitigate the risk of harm to the individuals affected by the personal information to which the personal information relates to the incident.
Privacy Complaint
An individual who believes that his or her own personal information or that of another individual has been the subject of:
- access not authorized by law;
- use not authorized by law;
- a disclosure not authorized by law;
- loss or other impairment of the protections provided for in the Act
- is invited to submit a complaint in writing to the Privacy Officer identified below.
The complaint must include the relevant details, i.e., the personal information involved, the context, the potential or actual harm suffered or could be suffered, and the relevant dates. The details of the reported incident should be described as accurately as possible, so that a response can be carried out quickly.
Any employee who receives a complaint must forward it to the Privacy Officer as soon as it is received.
Upon receipt of a complaint, the Company complies with its Internal Complaints Handling Procedure, to deal with the complaint fairly.
Person Responsible for the Protection of Personal Information
If you have any questions or comments regarding the Company's handling of personal information during its lifecycle within the Company or if you wish to exercise your rights under the Act with respect to the protection of personal information, you may contact the person responsible for the protection of personal information at the Company:
Marie-Claude Tremblay
Industries Rad inc. (Rocky Mountain)
9095, 25e avenue
Saint-Georges (Québec) G6A 1A1