Privacy Policy

1. Object

LECOMTE METERS LTD. (hereinafter referred to as “we”) is a legal entity governed by the Business Corporations Act, which is required to process Personal Information in the context of its activities, systems, and/or services.

This privacy policy (hereinafter referred to as the “Policy”) aims to inform you about the personal information collection, management, and communication practices that we have adopted to ensure the protection of your Personal Information (as defined in section 2).

This Policy complies with the Act respecting the protection of personal information in the private sector as of the date it came into force (see section 16).

2. Interpretation and definitions

For the purposes of this Policy, the following words and expressions that may appear with a first capital letter shall be interpreted, unless otherwise implicitly or explicitly stated in the text, according to the definitions given to them below:

Privacy Incident:

An incident caused by any of the following:

Unauthorized access by law to personal information;
Use of personal information that is not authorized by law;
The communication of personal information not authorized by law; and
the loss of personal information or any other breach of the protection of such information.

Personal information:

Any information that concerns a natural person and that allows, directly or indirectly, that person to be identified, such as the following information if transmitted:

Your name;
Your postal address;
Your age and physical characteristics;
Your gender, ethnicity, religion, education level and marital status;
Your online identifier;
Your password;
Your permit or license numbers;
Your banking or financial information; and
Your IP address.

Professional or business contact information does not constitute personal information subject to this Policy.

Sensitive Information:

Personal information that is considered to be of a sensitive nature, requiring a higher degree of care and security due to its nature or use. Information is considered sensitive if it is of a medical, biometric, or other intimate nature such as sexual orientation, body characteristics, ethnic group, religious beliefs, financial status, etc.

3. Consent

Collection and Use: We are committed to obtaining consent before any collection and use of Personal Information, whether explicit or implicit.

Although we prefer to obtain explicit consent through acceptance of this Policy, please note that by your use of our website or services, you consent to the collection and use of your Personal Information in accordance with the purposes described herein.

Also, by transmitting any Personal Information to us, you consent to our collection and processing of said information to the extent provided for in this Policy.

In certain situations, we may collect Personal Information from third parties, including through municipalities or regional county municipalities (RCMs). Unless otherwise provided by law or the consent of the person concerned is obtained through the third party, we will directly request the consent of the person concerned. At any time, the person concerned may request the source of the information collected.

In certain cases, provided for by law, we may use Personal Information without the individual’s consent, in particular when it would clearly benefit the individual, when it would be necessary to prevent or detect fraud or when it would be necessary to evaluate or improve security measures.

Communication : In addition to consenting to the terms and conditions of this Policy, you consent to our sharing of your Personal Information that you have provided to us under the terms and conditions set forth herein.

14 and Under: We do not knowingly collect or use Personal Information from anyone under the age of 14. If you are under 14, you should not provide us with your Personal Information without the consent of your parent or guardian. If you are a parent or guardian and you learn that your child has provided us with Personal Information without consent, please contact us using the contact information provided in Section 15 below to request that we delete that child’s Personal Information from our systems.

4. Data collection

We do not collect any Personal Information data unless it is necessary to do so or unless such collection meets one of the purposes indicated below. In all cases, the collection will be limited to the Personal Information we need to fulfill the intended purpose.

The collection of your Personal Information may in particular have the following objectives:

Provide you with products and services;
Improve our products and services;
Develop new products and services including through artificial intelligence;
Offer personalized products and services;
Evaluate the quality and performance of products and services;
Protect the privacy of our users; and
To meet our legal obligations.

The collection of Personal Information through third parties (for example: Shopyfi) may also be necessary to meet one of the aforementioned objectives or to do business with us. This Policy does not cover the processing of data or Personal Information conducted by third parties. In case of doubt or problem about the collection of data by a third party, we invite you to consult the privacy policy of this person or organization and, if necessary, to contact their privacy officer.

5. Use of data

Any Confidential Information collected may only be used in accordance with applicable laws and regulations or in accordance with this Policy.

We use your Personal Information data in particular to achieve the purposes mentioned in section 4 regarding data collection. For this purpose, your Personal Information may be used for the purposes set out below:

Providing our products and/or services. We may use your Personal Information to create, manufacture or design our products and to provide our services.
Improving Products and/or Services. We may use your Personal Information to improve our products, including by adding new features or capabilities, or to improve the quality of the services offered.
Personalization of Products and/or Services. Some Products may contain personalized features, such as recommendations that optimize your experiences and satisfaction. These features use automated processes to tailor your experiences based on the data collected. Similarly, in order to provide you with the best experience with our activities, we may personalize certain services offered to our users through the data collected.
Product and/or service development. We may use data to develop new products or services; the information collected helps us know and understand our customers.
Reporting and Business Operations. We may use data to analyze our operations and improve decision-making, all in order to gain better insight into the performance of our business.
Customer Support. We may use your Personal Information to diagnose and resolve problems with products and/or services. This may include restoring access to your personal account, providing you with billing information, or providing other support and assistance services.
Help secure and troubleshoot. We may use the data we collect to improve the security and troubleshooting of our products and services. This may include ensuring the security of our services, detecting malware or malicious activity, troubleshooting performance and compatibility issues to help customers get the most out of their experience, and informing them of updates to our products and services.
Security. We may use data to protect the security of our products, services, and customers to prevent fraud, error, spam, abuse, security incidents, and other harmful activities;
Surveys and promotional communications. We may use the information collected to prepare surveys and promotional communications.
Relevant Offers. We may use the collected data to provide you with relevant information about the products and services offered in order to provide you with offers tailored to your needs. For example, we may analyze the data to predict and provide you with information that would be most interesting and relevant to you.
Advertising. We may use the collected data to inform you about new promotions or to advertise our products and/or services on third party websites. Automated processes may be used to make advertisements more relevant.
Business Transactions. We may use data to process your business transactions with us.
Legal Compliance. We process data to the extent permitted by applicable laws and regulations and to meet the requirements thereof.
Research. We may also use the data to conduct research, including for scientific purposes and in the public interest, where permitted by law.

6. Communication of data

We do not sell, transfer, or otherwise lease any of your Personal Information to third parties. However, to the extent permitted by law or this Policy, we may share certain information in the following circumstances only:

Storage: We may store data on cloud servers. In these instances, your consent will not be required, and your data may be transmitted and stored in jurisdictions outside of Quebec.

External processing: Depending on the needs, your data may be transferred to a third party in order to process said data in order to achieve the purposes sought in section 5. These service providers may be called upon to prepare, classify and process the data so that we are able to use them in accordance with this Policy.

Legal grounds: We may disclose your Personal Information without your consent if we are required to do so for legal reasons by a competent authority or in order to comply with any applicable laws and regulations.

With consent: For any other reason or motive not mentioned in this section, your consent will be requested so that we can communicate your Personal Information to third parties.

When we share your Personal Information with service providers, we enter into written contracts with them before your Personal Information is shared with them and we provide them with only the Personal Information necessary to perform their service. These service providers must provide us with sufficient guarantees regarding the implementation of adequate protection for your Personal Information.

Please note that any Personal Information transferred to us is considered an asset. In the event of a sale or transfer of our business, or in the event of a lease, merger, financing, or any other form of transaction affecting the continuation of our business, Personal Information may be subject to the transaction and transferred in full to the successor in title.

7. Technologies used

In addition to the collection of Personal Information as set out in this Policy, we may use various technologies to analyze the use of our website. Among other things, we may use cookies, web beacons, pixel tags, log files or other technologies to collect certain information about the use of our website. Here are descriptions of some of these technologies:

Cookies: Cookies are data files transmitted and stored on your computer when you visit a website. They are used to memorize preference settings, to obtain statistical data on the use of the website or to find a search history.

We may use cookies to enhance your future visits to our website. If you do not wish to receive cookies or if you would like to set your browser to notify you when a cookie is being sent, you can click on the “Refuse” cookies option when this option is displayed on your first visit. You can also go to your web browser settings, in the “Manage my cookies” option to do this. Please note that by disabling cookies, some functions of our website may not function as intended.

Internet Protocol (IP) Address: An Internet Protocol (IP) address is associated with your computer’s connection to the Internet by your Internet Service Provider. We may use this IP address to, among other things, determine where you are using the Website, diagnose problems with our web servers, and administer the Website.

Under no circumstances do we associate your IP address with your Personal Information.

Google Analytics: We may also use Google Analytics services to improve the collection of information on the navigation of our website and to promote the use of the website. If you do not want your data to be used for the purposes of Google Analytics, we invite you to consult the tools and modules for deactivating this function.

Links or References: Our website may contain links or references to third party websites, over which we have no control. This Policy ceases to apply when you leave our website, and we are not responsible for the collection or processing of Personal Information by these third parties through these external sources.

These data collection technologies are used to measure interest and usage of our website and the effectiveness of our newsletters and advertisements, if applicable. The data collected by these technologies does not identify you and does not constitute personal information for the purposes of this Policy.

8. Data retention

Unless a minimum or maximum duration is provided for by law, we retain the collected data for different periods of time depending on the nature of the data and its use in accordance with the Policy. During this period, we undertake to take physical and technical measures to ensure the security of the data and your Personal Information (see section 9).

At the end of the retention period or in the event of withdrawal of your consent to the collection of data, we will ensure that we either:

Destroy all data collected regarding your Personal Information irreversibly; or
To anonymize the data collected regarding your Personal Information so that they no longer allow you to be irreversibly identified.

Any destruction of data is done securely in order to maintain the security of your Personal Information.

9. Data security

To the best of our knowledge, we undertake to implement reasonable security measures to ensure the protection of the Personal Information that we manage. The security measures in place are adapted to the sensitivity of the information so that sensitive Information is subject to a higher degree of security. Access to the data is limited to those persons necessary for its collection, use and communication.

10. Right of access and withdrawal of consent

At any time, you have the right to access the Personal Information we hold about you and to request a copy of such information, subject to the exceptions provided for in any applicable law. You may also ask us what Personal Information we collect about you, who has access to it and how long we retain it.

You also have the right to request the correction or rectification of any Personal Information we hold if it is inaccurate, incomplete, or ambiguous.

Subject to legal restrictions and subject to compliance with this Policy, you may withdraw your consent to the use, collection or disclosure of Personal Information collected.

For all such requests, we ask that you contact the Privacy Officer in writing (see section 15).

11. Sensitive information

Except in exceptional circumstances, we do not collect Sensitive Information as part of our activities. If we are required to do so, we will ensure that we obtain your express consent in accordance with applicable laws and regulations.

12. Complaints

Any person who wishes to make a complaint regarding the application of this Policy or regarding the protection of their Personal Information may do so by contacting the Personal Information Protection Officer in writing (see section 15).

We ask that you provide your name, contact details and a description of the subject and reasons for the complaint so that we can address the situation as quickly as possible.

Any complaint received will be treated confidentially by the Privacy Officer.

Following the analysis and processing of the complaint, we undertake to send you a reasoned and written response, determining whether we have failed to comply with this Policy or any other legislation or regulation in force regarding the protection of Personal Information.

If you are not satisfied with the handling of your complaint or the response provided, you may file a complaint with the Commission d’accès à l’information du Québec or any other personal information protection oversight organization.

13. Disclaimer

As stated in this Policy, we are committed to using all reasonable means to ensure the security and confidentiality of your Personal Information according to technology standards. Despite these protections and given a constantly changing technological environment, we are never safe from a security breach, hacking, virus, theft, misuse of our systems or alteration of Personal Information.

By your consent (see section 3), you also agree that we cannot be held responsible for any security breach indicated above. You also declare to waive any claim in this regard, except in the case of gross negligence or willful misconduct on our part. Accordingly, you agree to release us, as well as our directors, administrators, employees, related persons, and business partners from any liability for any damage of any nature whatsoever, whether direct or indirect, in connection with your Personal Information.

14. Terms of use

This Policy is distinct from the terms of use governing our website. The terms of use contain provisions and obligations regarding your use of our website. These conditions indicate in particular the applicable law as well as the exclusive jurisdiction in the event of a dispute. These conditions of use have the same effect as if they had been reproduced in full in this Policy.

15. Personal information protection officer

This Policy has been approved by our Privacy Officer.

For any questions, comments or complaints regarding this Policy or the handling of complaints, please contact the Privacy Officer using the following contact information:

Michael Lecomte

2925 rue Cartier

Saint-Hyacinthe (Quebec) J2S 1L4

mlecomte@lecomte.ca

16. Entry into force and amendments

This Policy is published on our website and is also disseminated by any means appropriate to reach the persons concerned.

Any changes to this Policy will be notified to you of the adjustments made. In particular, you will be notified if the collection, processing, or disclosure of your Personal Information is modified.

Version and change table:

Version	Effective on	Changes since last version
1.0	Semptember 22, 2003	S.O.

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