Protection of personal information
The Policy at a glance
Does this policy apply to you?
If you are a customer (individual), an Énergir geothermal solution* employee, if you browse the Énergir geothermal solution or Énergir geothermal solution’s applications (collectively “Énergir’s Websites”) or if you are a natural person (individual) who does business with Énergir geothermal solution (such as a supplier or consultant), this Policy applies to you.
Types of personal information we collect:
Mainly:
- Information on your identity (last name, first name, marital status)
- Contact information (physical and electronic address, telephone number)
- Professional information (resume, employment status, employer name, references, etc.)
- Billing information for our services and financial information
- Information needed to meet our legal obligations (as an employer or to operate our business)
- Information needed to provide our services and conduct our business in (installed natural gas equipment, gas consumption profile, etc.)
- Information required to operate our gas network (safety, metering devices, etc.)
- Information related to recruitment and market analysis
- Information related to marketing and communication preferences
- Information on the use of Énergir geothermal solution’s Websites (IP addresses, logs, cookies, etc.)
- Any other personal information provided
Why we collect it
Mainly to :
- Provide you with our usual services, administer them and conduct our business
- Communicate with you
- Track relationships with our clients, analyze markets and promote our services
- Answer your questions
- Understand and improve your experience as a client or applicant to ensure that it is positive for you;
- Make Énergir geothermal solution’s Websites easier to use and make sure their content is relevant
- Provide information and content that is useful to you
- Recruit new talent and manage our staff (testing, pension forecasting analysis, etc.)
- Complete applications for private education teaching licences and hiring dispensations
- Deliver our training courses (use of our suppliers’ training sites, etc.)
Who handles your personal information
- Our employees and our partners to install your equipment
- Service providers including but not limited to:
- Survey firms
- Technology infrastructure companies: SAP, Oracle, Salesforce, SuccessFinder, Genesys
- Analytical services providers: SurveyMonkey
- Communications companies
- Consultants like Mintz, Microsoft
How we protect your personal information
We protect your personal information by technological, physical and administrative means.
You have the right to
- Request access to the personal information we hold about you
- Request changes to your personal information if it is inaccurate, incomplete, confusing or is not legally authorized to be collected, disclosed or stored (However, if the information is necessary to provide the requested service, we will not be able to provide that service.)
- Complain about how we handle your personal information.
- Request that we stop disseminating your personal information or de-index any hyperlinks connected to your name that provides access to your personal information if this causes you harm or contravenes the law (right to de-indexing)
- Request that Énergir geothermal solution provide you (or any other company you have specified) with computerized personal information about you in a commonly used digital format (right to portability)emander d’accéder aux renseignements personnels que nous détenons sur vous;
How to exercise your rights
You can communicate with us at the following address. I If it is a complaint about the processing of your personal information by Énergir geothermal solution, in addition to being able to communicate with us, you can contact the appropriate authority (Québec’s Commission d’accès à l’information and, if applicable, the Office of the Privacy Commissioner of Canada).
Cookies
- We use cookies.
- Our service providers also use cookies (which they control).
- You may enable or disable cookies that are not strictly necessary for the proper operation of Énergir geothermal solution’s Websites.
Governance measures we have put in place
We have appointed a privacy officer and set up a privacy program to ensure that your personal information is properly protected.
If you have any questions or concerns about how Énergir geothermal solution or the gas technology school protects your personal information,
please email Énergir geothermal solution’s privacy officer
If you are a customer (individual), an employee of Énergir geothermal solution, or a person browsing Énergir’s geothermal solution or Énergir’s geothermal solution applications, or if you are a natural person (individual) who has dealings with Énergir geothermal solution (for example, as a supplier or consultant), this Policy applies to you.
(“Énergir geothermal solution” or “we”) is a diversified company in the energy sector.
As such, whether it is to run our business, supply you with energy, provide you with our services and programs (energy efficiency program, etc.) or meet our legal obligations, we collect, use and disclose personal information on a daily basis. At each of these stages, respect for your personal information is important to us and we are concerned about how it is treated. We take confidentiality seriously and it is an essential part of our relationship.
This Policy sets out our commitments regarding the handling of your personal information. Its purpose is to:
- Help you understand our practices regarding the collection (what information we collect), use, disclosure, protection, retention and destruction of personal information.
- Explain how and for what purposes we collect, use and disclose your personal information as a service provider or employer
- Explain how you can assert your privacy rights (including how you can access, update or correct your personal information)
By providing us with the requested personal information (via our website www.energir.com, our customer space, career space, supplier space, the École de technologie gazière website, by email, in person, by telephone or any other means that we make available to you) and, provided that we have notified you in advance of the purposes for which it will be used, in accordance with applicable law, you:
- Agree that we can use or disclose it for those purposes
- Agree that it will be treated in accordance with this Policy
We may also, in certain cases, obtain express consent from you for the use or disclosure of your personal information. For more details, refer to the question “When and how do we obtain your consent.”
Unless we notify you otherwise, we are “responsible for handling” your personal information; in other words, it is Énergir geothermal solution, alone or jointly, who determines how and for what purposes your personal information will be used or is likely to be used.
Personal information is information about you as an individual that allows you to be identified, directly or indirectly.
This Policy applies to the personal information we collect, regardless of the means used (for example, in person, through our representatives, by telephone, or through our website www.energir.com, the website of our École de technologie gazière, our online portals such as the Customer Space or Supplier Space, or our mobile applications) (collectively, the “Énergir Websites”). This Policy does not apply to third-party websites that may be accessed by clicking on links found on the Énergir Websites, and we are not responsible in any way for such third‑party websites. If you follow a link to a third‑party website, that website will have its own personal information protection policies, which you should review before submitting your personal information.
We have a privacy policy in place to protect the personal information we collect and hold in accordance with applicable privacy laws. For example, this policy sets out the rules Énergir geothermal solution must follow for each of the applicable personal information principles (including the principles of accountability, determining the purpose of collection, limiting collection, consent, transparency, etc.) and to enable the individuals concerned to assert their privacy rights (including their right to access or correct their personal information, withdraw consent, and make a complaint). It also establishes Énergir geothermal solution’s roles and responsibilities with respect to personal information.
To follow up on this policy, we have adopted the following guidelines and procedures:
| Description | |
| Guideline on managing incidents related to personal information | It establishes the procedure to follow in the event of an incident involving personal information. For example, how to report such an incident to Énergir geothermal solution’s privacy officer and how to conduct a serious risk of harm assessment to determine whether the incident should be reported to the appropriate authorities, to the persons concerned or to any other authority. |
| Procedure for the collection, use and disclosure of personal information | It sets out the rules we must follow to collect, use and disclose personal information in accordance with applicable legislation. It also describes the bases of valid consent. |
| Procedure for managing individual rights | It sets out how we manage requests to exercise privacy rights provided for in the applicable regulations (such as the right to access or correct your personal information). |
| Complaint handling procedure | It sets out the various actions that we must implement upon receipt of a complaint by a person about the collection, use, disclosure, detention or destruction of their personal information, all to process this complaint. |
| Procedure for privacy impact assessments | It sets out the roles and responsibilities related to privacy impact assessments, when they are required, and how they must be conducted. |
| Training program | Our training courses, which are mandatory for all our employees, are designed to make our employees aware of the importance of protecting personal information and teach them the rules about its collection right through to its destruction. In addition, some training courses target specific sectors according to their activities. |
| Document retention schedule | It sets out how long we must keep our records, including your personal information. |
| Destruction guide | It provides for the secure destruction of personal information on all media. |
We may collect various types of personal information in the course of our activities and the operation of our business. We collect this information only if we have a serious and legitimate interest in doing so.
We collect only the information necessary for the purposes that we have determined in advance.
We primarily collect your personal information directly from you. However, there may be circumstances where we collect information from a third party if you have consented to it or if we are authorized to do so by law.
Your personal information is generally collected by our employees. However, we may entrust this task to a third party (for example, our Énergir partners, a service provider such as in the context of surveys, our consultants, or a credit reporting agency). In such cases, we require them to inform you that they are collecting your personal information on behalf of Énergir.
Gas Distribution Network
- provide you with our standard services, administer them, and conduct our business activities;
- inform you of meter replacement operations or work carried out on our gas distribution network, as well as of any incidents that may occur on that network;
- contact you when we need to carry out work on our equipment that requires your presence; carry out awareness initiatives related to the safety of our network;
- maintain the safety and reliability of our gas distribution network and natural gas supply, and properly forecast our customers’ gas demand.
Managing our business relationship with you
- manage the various programs for which we are responsible (including energy efficiency programs and grants) and promote them;
- communicate with you;
- respond to your requests for information;
- continuously ensure the efficiency and quality of our business processes; monitor our relationship with our customers (such as satisfaction surveys and business statistics) and promote our services or new services (by carrying out marketing campaigns);
- enforce our rights, including ensuring payment, for example by using debt collection agencies or other legal means; create your learner profile at the École de technologie gazière.
Being able to offer you services that meet your expectations
- inform you about our programs and offers, particularly those that may allow you, if you wish, to reduce your energy consumption and greenhouse gas emissions;
- provide you with useful information and content;
- maintain a good understanding of our customers, understand and improve your experience as a customer in order to ensure it is positive for you;
- facilitate the use of Énergir’s Websites by ensuring that their content is relevant and presented in the most effective manner for you and for your devices (desktop, mobile, or otherwise).
Producing statistics
- produce and analyze statistics, in particular to maintain a good understanding of our customers and to improve customer satisfaction and the quality of our services.
Complying with our legal and regulatory obligations
Recruiting and managing our workforce
- recruit new talent and process your application for the positions we offer (candidate assessments, pre‑employment background checks (employment history, credit, etc.));
- manage our workforce.
However, we may wish to use your personal information for purposes other than those listed above. In such cases, we will inform you of the new purpose and obtain your consent in advance. To learn more about consent, please refer to the section “For more information: When do we obtain your consent to collect and use your personal information?” Despite the foregoing, please note that the law allows us to use your personal information without your consent in certain situations, including where such use:
- is for compatible purposes (a relevant and direct link to the purpose for which consent was obtained);
- is manifestly for your benefit;
- is necessary for fraud prevention and detection purposes or for evaluating and improving protection and security measures;
- is necessary for the supply or delivery of natural gas or a service you have requested from us.
For example, we may rely on your gas consumption data to determine whether you are eligible for a program that could allow you to save money, as this is manifestly for your benefit.
Only our employees whose duties require access to your personal information have access to it. However, we may also need to share your personal information with third parties so that they can perform certain tasks or functions on our behalf. We also disclose your personal information to third parties when you request it or consent to it.
In some cases provided for by law, we may disclose your personal information to third parties without your consent, as mentioned in the section “For more information: When and how do we obtain your consent to collect and use your personal information?”
When we entrust your personal information to service providers so that they can deliver the required services, we ensure that the written contracts entered into with them clearly set out our requirements, including the measures they must take to protect your personal information as we would ourselves. Among other things, we ensure that our service providers use your personal information solely for the purpose of providing the services we have retained them to perform.
If you have reason to believe that personal information about you has been compromised, please contact us using the contact details provided in the section “How to contact us.”
We retain your personal information for as long as we are fulfilling the purposes for which it was collected. We then retain it for the additional period provided for in the retention schedules we have adopted. This additional period is provided for in accordance with certain legislative or regulatory requirements or in order to produce such information as evidence should we be a party to a claim or legal proceeding.
To learn more about how long we retain your personal information, please contact us using the contact details provided in the section “How to contact us?”
We may store and process your personal information in our various facilities in Québec and in the countries where we engage third‑party service providers (for example, elsewhere in Canada or in the United States). You therefore consent to the transfer of information to locations outside Québec, where personal information protection rules may differ from those in Québec. When personal information is located outside Québec, it is subject to the laws of the country in which it is located and may be disclosed to governments, courts, or law enforcement or regulatory authorities of that country in accordance with its laws.
However, our practices regarding your personal information are, at all times, governed by this Policy.
Committed to earning and maintaining your trust, we implement generally recognized and accepted security standards in the field to protect your personal information throughout the entire period during which we are responsible for it (from collection to destruction). When determining which measures to apply, we ensure that they are reasonable, taking into account certain factors, including the sensitivity of the personal information in question, the purpose for which it is used, the volume of information, and the medium on which it is stored. The security measures we implement to protect against accidental loss, alteration, disclosure or unauthorized access, misuse, accidental or unlawful destruction, or any other unlawful processing of the personal information in our possession fall into three categories:
- Technological security measures (such as, for example, the use of a VPN, firewalls, logging of Énergir employees’ actions involving your personal information, and restricting access to personal information to staff members who need to know it);
- Physical security measures (such as, for example, access cards to our facilities, cameras, and locked premises and storage areas);
- Organizational security measures (such as, for example, authentication procedures when you communicate with us or use our online portals such as your Customer Space, training and awareness initiatives related to cybersecurity and personal information protection, internal governance, information security and personal information breach response policies, and procedures for detecting and managing security incidents that could affect your personal information).
We periodically review these security measures to ensure that they are properly implemented, remain fully effective, and continue to be appropriate in light of the evolution of our systems and available technologies. However, it is important to note that no method of transmission over the Internet or method of electronic storage is 100% secure. We therefore cannot ensure or guarantee the absolute security of the personal information you transmit to us, which means that you do so at your own risk. We also cannot guarantee that such information will not be accessed, obtained, disclosed, altered, or destroyed as a result of a breach of our physical, technical, or administrative safeguards.
In certain circumstances and in accordance with applicable personal information protection laws, you have the following rights:
Access to your personal information: the right to request that Énergir confirm whether it holds personal information about you and to provide you with access to that information by giving you a copy. At your request, computerized personal information will be communicated to you in the form of a written and intelligible transcription.
In the case of an access request, we will require you to identify yourself to ensure that the request is indeed coming from you. Reasonable fees may also be charged for the transcription, copying, or transmission of such information.
Rectification: the right to request the correction of (1) any personal information that is inaccurate, incomplete, or equivocal (that is, subject to more than one interpretation) that we hold, or (2) any information whose collection, disclosure, or retention is not authorized by law. In the case of a rectification request, we will require you to identify yourself to ensure that the request is indeed coming from you.
Withdrawal of consent: where we have obtained your consent to the processing of your personal information, the right to withdraw your consent to the disclosure or use of your collected personal information. However, we may have the right to continue processing certain information as permitted by law.
Complaint: the right to file a complaint with the Commission d’accès à l’information du Québec or any other competent privacy oversight authority regarding the application of a legislative provision relating to access to or rectification of personal information.
Decision based exclusively on automated processing: if we must make such a decision, we will inform you of it no later than at the time we notify you of the decision. We will also inform you of:
- the personal information used to make the decision;
- the reasons for the decision, as well as the main factors and parameters that led to it;
- and your right to have the personal information used to make the decision corrected.
Automated decisions: the right to contest any automated decision where such a decision has a legal or similarly significant effect, and the right to request that the decision be reviewed.
Right to de‑indexation: the right to request that Énergir cease disseminating your personal information or de‑index any hyperlink associated with your name that provides access to such information, where such dissemination causes you harm or contravenes the law. To exercise any of these rights, please contact us in the manner indicated in the section “How to contact us?”
For detailed information about the cookies we use, please refer to our Cookies Policy, which is part of this Privacy Policy.
To ask questions or make comments about this Policy or about personal information, personal information collected from you, the categories of people who have access to that information at Énergir, the length of time your information is retained, how to exercise your rights, file a complaint or obtain information about our policies and practices regarding our service providers outside Canada, please contact our privacy officer in one of two ways:
- By email at [email protected]
- By regular mail at the following address:
Privacy Officer
Executive Director Legal Affairs
Énergir
1717 rue du Havre
Montréal, QC H2K 2X3
We reserve the right, at our sole discretion, to amend this policy at any time, in whole or in part, in accordance with applicable privacy regulations.
These changes will come into effect as of the publication of the new policy or as of a specified future date. This publication will serve as notification of the changes to you. We encourage you to visit this page regularly to review the changes and stay informed about the handling of your personal information.
Your use of Énergir’s Websites once these amendments come into force will constitute recognition and acceptance of the new policy. If you are not satisfied with the new policy, please discontinue all use of these sites.
This policy came into effect on September 2023.