The Privacy Policy (hereinafter the "Policy") describes the personal information protection practices applied by X-TELIA with regard to personal information collected in the course of its activities. The Policy has the following objectives:
- To protect personal information collected by X-TELIA throughout its life cycle, from collection, use, disclosure, and retention to destruction or anonymization, in accordance with applicable legal provisions.
- To set out guidelines and principles designed to effectively protect personal information processed in connection with X-TELIA's services.
- To ensure compliance with applicable legal and regulatory requirements, including the Act respecting the protection of personal information in the private sector and recognized practices in the field of personal information protection.
Personal information ("PI") means any information that relates to an individual and that allows that individual to be identified directly or indirectly.
Sensitive personal information means any personal information that gives rise to a high degree of reasonable expectation of privacy, particularly because of the potential harm to the individual in the event of a breach of confidentiality. Examples include financial information, medical information, social security number, sexual orientation, etc.
Responsibility: X-TELIA is responsible for the processing of personal information in its possession, including information entrusted to third parties. X-TELIA has appointed a Privacy Officer, whose contact information can be found in the Error! Source of reference not found. This officer ensures that this Policy is applied and that X-TELIA complies with laws and regulations relating to personal information.
As part of its activities, X-TELIA collects personal information on behalf of partners. For example, X-TELIA acts as a subcontractor for municipalities that deploy connected equipment.
Collection: X-TELIA collects personal information directly from the individual concerned unless it has obtained their consent to collect their personal information from third parties or is authorized by law to collect it otherwise.
Directly from you: The personal information we collect directly from you is the information you provide when you contact us;
From third parties: We may collect personal information from business partners, including a municipality that deploys connected equipment. Please note that the personal information we collect is clearly defined and limited to what is strictly necessary in connection with our services.
Unless otherwise provided by law, X-TELIA ensures that it obtains the consent of the person concerned by informing them in advance of the elements prescribed by law.
X-TELIA obtains the appropriate consent depending on the nature of the personal information collected and the purposes of the collection. In general, consent must be clear. It must be expressly stated in the following cases:
- If the sensitive personal information that has been collected is to be used for a purpose other than that for which it was originally collected, subject to the exceptions provided for by law;
- If the collection is done using a technological solution, including any solution that has features that allow for the identification, location, or profiling of a person.
X-TELIA also obtains consent on behalf of its partners, including, for example, a municipality that has deployed connected equipment in a residence that you occupy.
Background
Purposes of use
Relating to a connected device
With respect to an application or in the context of the employment relationship
Any request to withdraw consent must be communicated to the privacy officer, whose contact details can be found in section 10.
Your personal information is accessible only to X-TELIA staff members who need access to it in order to perform their duties. The principle of least privilege is followed in granting access to personal information, based on the role and responsibilities of staff members. X-TELIA will only disclose your personal information with your consent, in accordance with applicable requirements, or without your consent only in cases provided for by law, such as in the context of criminal proceedings.
The categories of third parties to whom X-TELIA may disclose your personal information are as follows:
X-TELIA uses facilities and service providers that ensure your personal information is stored securely in order to preserve its confidentiality.
The personal information we collect is generally stored in Quebec.However, it is possible that data may be stored elsewhere in Canada, particularly for resilience purposes.
X-TELIA retains your personal information for as long as necessary for the purposes for which it was collected and to meet its legal obligations, which may sometimes justify longer retention periods.
When the personal information collected is no longer necessary for the purposes for which it was collected, X-TELIA destroys or anonymizes it.
X-TELIA implements security measures that are proportionate to the sensitivity of your personal information and that protect it against loss or theft and against any unauthorized access, disclosure, copying, use, or modification, in accordance with applicable legislation.
In addition, all X-TELIA staff members have committed, upon taking up their duties, to respect the confidentiality of the information to which they have access, in particular that of X-TELIA members and employees, by signing a confidentiality agreement.
Although X-TELIA implements appropriate security measures to protect your personal information and minimize the risk of compromise, there is always a risk that we cannot guarantee 100% that your personal information will not be subject to a breach of confidentiality or integrity in the event of a violation of our physical, technical, or administrative security measures. If you have reason to believe that personal information has been compromised, please contact the office of the Chief Privacy Officer, whose contact information can be found in Section 10.
X-TELIA respects your legal rights regarding your personal information and has procedures in place to handle the following requests:
Access and correction of your personal information: You may consult the personal information that X-TELIA has collected about you, verify its accuracy, and request that it be modified, subject to exceptions provided for by law. Your request for access or correction must be sent to the privacy officer at the address provided in section 10 and will be processed within thirty (30) days of receipt of your written request by X-TELIA and confirmation of its admissibility.
Withdrawal of consent: In certain circumstances, you may withdraw your consent to the processing of your personal information. Any request to withdraw consent must be communicated in writing to the Privacy Officer, whose contact information can be found in section 10.
Complaints: If you believe that your privacy rights have not been respected by X-TELIA, you may file a complaint with the Privacy Officer, whose contact information can be found in section 10.
Any questions regarding your personal information should be directed to the Privacy Officer, whose contact information can be found in Section 10, for processing and follow-up.
The Privacy Officer is responsible for ensuring compliance with and implementation of the Act respecting the protection of personal information in the private sector and, as such, is also responsible for ensuring compliance with this Policy.
The contact details for the Privacy Officer are as follows:
Email address: prp@x-telia.com
This Policy may be amended from time to time to maintain X-TELIA's compliance with the law and to reflect any changes in the process of collecting personal information.
PRIVACY POLICY
