PERSONAL INFORMATION PROTECTION POLICY (External opinion)

This policy sets out the principles and describes the personal information protection practices of Plastique Age

WE ARE COMMITTED TO MEET OR CUSTOMER REQUIREMENTS BY CONTINOUSLY IMPROVING THE EFFECTIVENESS OF OUR QUALITY SYSTEM

1. PREAMBLE

PLASTIC AGE recognizes the importance of preserving privacy and is committed to protecting the personal information that it collects and processes in the course of its activities.

2. OBJECTIVES

The Personal Information Protection Policy (hereinafter the “Policy”) aims to set out the principles applied by PLASTIQUE AGE which govern the personal information protection practices (hereinafter “PRP”) of the Persons concerned.

The Policy describes the PRP standards and practices applied by PLASTIQUE AGE for the purposes of:

  • Protect the personal information collected by PLASTIQUE AGE throughout its life cycle, from its collection, use, communication, conservation until its destruction or anonymization, following the applicable legislative provisions;
  • Ensure compliance with applicable legal requirements, including the Act respecting the protection of personal information in the private sector (Quebec), the Personal Information Protection Act (Alberta), the Personal Information Protection Act (British Columbia) and the Protection Act personal information and electronic documents (Canada) and recognized practices regarding PRP;
  • Ensure the trust of all stakeholders and demonstrate transparency regarding the processing of personal information and the PRP measures applied by PLASTIC AGE.

3. SCOPE OF APPLICATION

The Policy applies to any identified or identifiable person about whom PLASTIQUE AGE collects Personal Information in the course of its activities.

4. DEFINITION

Personal information (PI) means any information which concerns a natural person and which allows them to be identified directly or indirectly.

5. REQUIREMENTS FOR THE PROTECTION OF PERSONAL INFORMATION

The Policy reflects Plastique Age’s ongoing commitment to complying with the PRP requirements of the following individuals:

  1. Plastic Age customers who are natural persons (excluding businesses);
  2. Representatives of Plastique Age service providers who must provide PI in order to establish a business relationship with it, except with regard to business contact details;
  3. Current or former employees and other personnel of Plastique Age and candidates for employment;
    This policy sets out the principles and describes the personal information protection practices of Plastic Age
  4. Visitors to Plastic Age websites and users of mobile applications;
  5. Any other natural person whose PI is collected or processed as part of Plastic Age’s activities.

(Collectively, the “Data Subjects”)

5.1 Guiding principles

PLASTIC AGE’s PRP practices are defined and applied in accordance with the following PRP guiding principles, in accordance with applicable laws:

5.1.1 Responsibility: : PLASTIC AGE is responsible for the processing of the personal information it has in its possession, including information entrusted to third parties. A Personal Information Protection Officer, whose contact details can be found in paragraph 7, has been appointed and ensures that the Policy is applied and that PLASTIC AGE complies with applicable laws and regulations relating to PRP. Data subjects take full responsibility for the use of personal mailboxes and devices in a business context and ensure that high standard security measures are in place.

5.1.2 Purposes of collection: PLASTIC AGE determines the reasons for which it collects, uses, communicates and retains PI before collecting it. PLASTIC AGE ensures that it only collects the PI that is necessary to meet the predetermined purposes. The purposes for which the PI will be used will be specifically specified at the time of collection. On the date of adoption of the Policy, the purposes of use of the PI are, without limitation:

    • Evaluate customer needs and offer them services that meet them;
    • Confirm the identity and verify the accuracy of the Personal Information provided in requests and proposals and update them;
    • Manage the customer file;
    • Establish and maintain communication with customers;
    • Manage relationships with job candidates as well as employees.

5.1.3 Collection: PLASTIC AGE limits the collection of PI to those which are necessary for the intended purposes. PLASTIC AGE collects PI directly from the Data Subject, unless it has obtained their consent for their PI to be collected from third parties or if the law authorizes it to collect it otherwise. PLASTIC AGE may also receive PR from its partners.

PLASTIC AGE may also collect personal information when you visit our website or contact us via the contact form available on our website.

PLASTIC AGE may also collect other information regarding the use of its website, through the use of cookie files commonly called “cookies”. These files make it possible, in particular, to recognize the user of our site when they access it and when they move from one page to another. PLASTIC AGE uses these cookie files to provide a personalized welcome to users of the site by improving the service and producing statistics.

5.1.4 Limitation of use, communication and storage

5.1.4.1 Limitation
PLASTIC AGE restricts the use of Personal Information for the purposes for which it was collected and for which the Data Subject has consented, subject to exceptions provided for by law or the obtaining of new consent.

PLASTIC AGE limits access to the PRP it holds to only those for whom access is required to carry out their duties and offers training on PRP to its staff. Plastic Age personnel are also bound by a confidentiality commitment which aims in particular at the confidentiality of the personal information processed within the framework of their duties.

5.1.4.2 Communication
PLASTIIC AGE may communicate the Personal Data of the Data Subjects to various business partners, suppliers or other third parties as part of its activities. It may also disclose it to courts, regulators, officials or prosecutors or any other party responsible for investigation or law enforcement. PLASTIC AGE ensures that the Personal Information is communicated only for the purposes identified and for which the Person concerned has consented, unless the latter gives consent to the new purposes or unless exceptions provided for in the law.

5.1.4.3 Conservation
PLASTIC AGE uses technology systems and service providers that ensure the retention of Data Subjects’ Personal Information in such a way as to maintain their confidentiality. PLASTIC AGE retains data and documents containing personal information for the duration necessary for the use for which they were collected and retention periods imposed by law.

PRs are generally kept in the province of Quebec. It is nevertheless possible that the communication of PRP to certain service providers results in their transfer outside Quebec, in which case, PLASTIQUE AGE will consult the PRP laws and practices applicable in the jurisdiction concerned and will ensure that PRP benefits from adequate protection through a privacy impact assessment and that the contractual framework stipulates appropriate PRP commitments.

5.1.5 Security measures: PLASTIC AGE applies security measures which are proportional to the sensitivity of the personal information it holds in order to prevent attacks on confidentiality and integrity, in accordance with its security frameworks. ‘information.

5.1.6 Transparency: PLASTIC AGE documents its PR management practices in a simple and clear manner and makes them accessible on its websites. PLASTIC AGE provides the prescribed information to the Data Subject when the collection is made through technology including functionalities allowing the Data Subject to be identified, located or profiled through the use of technology.

5.1.7 Rights of Data Subjects: PLASTIC AGE applies procedures to process requests for exercise of rights by Data Subjects, including requests for access, rectification and withdrawal of consent. Requests to practice law should be forwarded to the office of the PRP Officer, whose contact details appear in paragraph 7, for processing in accordance with the law.
PLASTIC AGE respects the rights recognized to Data Subjects with regard to their Personal Information and has put in place procedures to process the following requests:

    1. Access: a Data Subject has the right to request a copy of his or her Personal Information kept by PLASTIC AGE or to consult them. However, the communication of Personal Information about a Data Subject is not possible when its disclosure would reveal Personal Information about another person or would constitute a violation of applicable laws. Access to PR is free. In certain circumstances, in particular if the request is excessive or unfounded, PLASTIQUE AGE may charge the Person concerned administrative costs for the purposes of transcription, reproduction or transmission of its RP. Before responding to a request, PLASTIC AGE will inform the Person concerned if any fees must be billed.
    2. Accuracy: PLASTIC AGE aims to ensure that the PI it collects and stores is accurate and carries out validations with the Data Subjects for this purpose as part of its activities. PLASTIC AGE invites Data Subjects to contact the PRP Manager, whose contact details appear in paragraph 7, to advise them if certain PRP is not accurate or if changes need to be made.
    3. Withdrawal of consent: in certain circumstances, a Data Subject may object to the processing of their PI and ask PLASTIC AGE to block, delete and limit access to it for purposes which are not essential to the management and to the administration of its products and services. A withdrawal of consent for an essential purpose for the provision of Plastic Age services will terminate the relationship between the latter and the Data Subject who requests it.
    4. Portability: any Data Subject may, upon request, obtain a copy of the PI that has been collected from them. If the person’s personal information is computerized, the person may request that it be communicated to him or her in the form of a written and understandable transcription.
    5. Complaints: If a Data Subject believes that their PRP rights may have been infringed, they have the right to lodge a complaint with the PRP Controller, the applicable supervisory authority or to have recourse to the courts.

PLASTIC AGE will respond to all requests within 30 days of receipt of such request. When PLASTIC AGE is unable to meet this deadline, or if additional time is required to satisfy a request, it will inform the Person concerned in writing.

7. THE PERSONAL INFORMATION PROTECTION MANAGER

PLASTIC AGE has appointed a Personal Information Protection Officer who ensures that PLASTIC AGE complies with applicable privacy laws.

For any questions regarding the collection, use, disclosure or retention of PRP made by PLASTIC AGE, it is possible to contact the PRP Manager whose contact details appear below:

Privacy Officer
Civic address: 7295 rue Tellier, Montreal (Quebec),
H1N 3S9, Canada
Phone: : 1-514-251-9550
Email: Confidentialiterp@plastic-age.com

8. ADOPTION AND MODIFICATION OF THE POLICY

This Policy was adopted by the PLASTIC AGE Strategic Committee and takes effect on its date of adoption. It replaces all previous versions. The version history of the Policy can be obtained upon request from the PRP Manager. The collection, use, disclosure and any other processing of a Data Subject’s PI by PLASTIC AGE will be governed by the version of the Policy in force at the time of processing.

The PRP Manager is responsible for the Policy and its revision. The Policy may be modified at the discretion of Plastic Age to reflect changes to applicable requirements or practices of PLASTIC AGE and will be reviewed at least every three years.

1 This provision will come into force from September 2024.