Privacy Policy

1. Introduction

Electronic Products Recycling Association (“EPRA”, “our“, “we” or “us“) recognizes the importance of protecting the Personal Information (as defined in section 2) that you provide to us. Accordingly, we have established this Privacy Policy that describes how we protect, collect, use, communicate, keep and destroy Personal Information, whether or not collected by technological means.

As we are a national organization, this Privacy Policy is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and the regulations there under (“PIPEDA”) as well as the applicable provincial privacy legislation and regulations, including, the Personal Information Protection Act (Alberta), the Personal Information Protection Act (British Columbia), and An Act respecting the protection of personal information in the private sector (Québec). Accordingly, this Privacy Policy applies to all EPRA affiliated websites (collectively the “Websites”).

Please note that our Privacy Policy is subject to revision. The privacy statement published below is our most current policy and is date stamped at the bottom of the page.

BY PROVIDING PERSONAL INFORMATION TO EPRA OR ITS SUPPLIERS, THROUGH OUR WEBSITES, BY TELEPHONE, BY E-MAIL, IN PERSON OR BY ANY OTHER MEANS, YOU CONSENT TO THE COLLECTION, USE AND COMMUNICATION, KEEPING AND DESTRUCTION OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

2. Personal Information

For the purposes of the present document, Personal Information is any information related to a natural person that allows, directly or indirectly, that person to be identified (“Personal Information”). Personal information collected by EPRA may include such information as your IP address, geographic location, computer operating system, and browser type. Specific Personal Information, such as your name, phone number, postal address, or e-mail address, is not automatically gathered.

3. Consent

EPRA will not collect, use, or disclose Personal Information without your consent unless it is authorized or required to do so by applicable legislation.

Please note that you have the right to refuse to provide us with Personal Information. You also have the right, subject to reasonable notice and applicable legal restrictions, to withdraw your consent to the use of Personal Information already collected by contacting our Privacy Officer at the contact information provided in section 15. Please note that a refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide our services or information to you.

IMPORTANT: If you provide us with Personal Information about other individuals, you declare that you have the authority to do so and, where applicable, that you have obtained the necessary consent, and you acknowledge that such information may be used in accordance with this Privacy Policy.

4. Collection and Use

Without limiting the generality of the foregoing, EPRA will collect and use Personal Information for the purposes identified at the time the information is collected, subject to compliance of the applicable legislation. Collection will be limited to what is necessary for the purposes identified. The following is a non-exhaustive list of the information EPRA may collect about any person visiting our Websites or contacting us by e-mail.

4.1 Websites Users or Interaction with Us by E-Mail

When you browse our Websites or interact with us via e-mail, we may collect information about you as described below, some of which is collected automatically:

  • Connection data, which may include your IP address, the pages you visit on the Websites, the date and time of your visit to the Websites, the address of the web page you visited before using the Websites, the URL that directed you to our Websites, your browser type and settings, information about your device (such as brand, model and operating system), information about your browser configuration, language preferences, unique login information and cookies. Usage data and analyses, which may include the frequency of connection, the functions you use, the duration and timing of use, as well as the different types of activities undertaken by users, and demographic information we may request from you. This information is collected to improve the functionality of the site and enhance your browsing experience.
  • If you make and inquiry or would like to obtain additional information about our services, use our functions, register for an event, webinar or contest, or download certain content, we may ask you to provide us with your contact details, such as your first and last name, phone number, postal address and e-mail address as well as certain information about your needs or preferences that you choose to provide.
  • Technical support questions, general comments you choose to provide.
  • Any other Personal Information provided.

This information is collected to help us learn more about your needs, preferences, and interactions with our Websites and the services offered, to perform statistical, market and performance research to help us evaluate our Websites and our services, estimate our audience size, measure our performance and improve the experiences and services we offer. It is not associated with a specific individual unless you make an inquiry, request a service or voluntarily provide Personal Information.

4.2 Surveys, Events, and Marketing Information

If you choose to participate in our surveys, contests, events, requests for information, we may collect information about you in connection with the survey, contest, request for information or event including, without limitation, your name, e-mail address, phone number; and general information about you that you choose to provide.

4.2.1 Phone Calls

If you contact us by phone, we may record the call and ask you to provide us with contact information, such as your name, address, phone number and e-mail address.

4.2.2 Offices Visits

If you visit our offices, you may be asked to register as a visitor and provide your name, e-mail address, phone number, as well as the time and date of your arrival.

4.3 Communication

EPRA retains Personal Information only as long as necessary for the fulfillment of those purposes. EPRA limits the communication and disclosure of your Personal Information to
purposes other than those mentioned above, but note the following clarifications and exceptions:

4.3.1 Application of the Law

We may share your Personal Information to respond to law enforcement requests, court orders or other legal process or if we believe that such disclosure is necessary to investigate, prevent or respond to illegal activities, fraud, physical threats or as required by any other applicable law or regulation and to the extent necessary to protect EPRA’s property, interests, and rights.

4.3.2 Archive Service

We may share your Personal Information with a company engaged in the business of keeping documents for their general informational value.

4.3.3 Our Employees and Authorized Service Providers

Authorized Personnel may have access to your Personal Information in order to assist us in providing services to you. Employees access and use such Personal Information in accordance with our instructions, only if they need to know such information, and under strict confidentiality and security obligations. Please be assured that our employees manage such information with the utmost discretion and rigor and comply with this Policy and applicable legal and regulatory requirements.

When you provide Personal Information to EPRA, you grant us the right to share your Personal Information with authorized service providers acceptable to us who will use this information to help us respond to your requests and perform services. Please note that we will only share the Personal Information necessary to these third-party service providers, solely for the purpose of providing the services to you, and that we will ensure that these authorized service providers agree to keep the Personal Information confidential and secure.

Service providers retain the information they need to perform the functions for which they have been appointed and we do not authorize these third parties to use or disclose your Personal information for their own marketing or other purposes.

4.3.4 Explicit Consent

EPRA may also communicate your Personal Information if you expressly request or consent to such disclosure.

5. Your Personal Information and Third-Party Websites

Our Websites may contain links to independent third-party Websites. These third party Websites (“Third-Party Websites“), whose links are provided solely for your convenience, are not under our control and may be governed by their own privacy policies. EPRA does not warrant and is not responsible for the collection, use, keeping or disclosure of your Personal Information by such Third-Party Websites. EPRA assumes no responsibility for your use of such Third-Party Websites or your access to Third-Party Websites through our Website. By using our Websites, or by accessing Third-Party Websites through our Websites, you release EPRA from any and all liability for the actions, practices and omissions of such third parties.

6. Transfer of Personal Information Abroad (applicable to Québec)

The Personal Information collected from the province of Québec through EPRA’s Websites is currently located in Ontario. However, in the future, we may engage third-party service providers to process, manage and host Personal Information on our behalf that may be located outside the province of Ontario. As a result, some of your Personal Information may be transferred to another province or country and may be subject to the laws of that province or country.

However, we will ensure to protect the Personal Information in our custody, including Personal Information entrusted to a service provider. Our policies and practices regarding the protection of Personal Information require that a written undertaking be signed by this service provider to respect its obligation to preserve the confidentiality and security of the Personal Information entrusted to it. This includes, but is not limited to, implementing robust and effective security measures, as well as prohibiting the disclosure, transfer, or use of your Personal Information to others in accordance with the applicable privacy legislation in the province of Québec.

7. Protection of Personal Information

We take appropriate measures to ensure the confidentiality of Personal Information and to protect such Personal Information against loss, as well as unauthorized access, disclosure, copying, use or modification, considering the sensitivity of the information and the purposes for which it is to be used.

EPRA uses commercially reasonable and appropriate physical, electronic, and managerial procedures and generally accepted industry standards to safeguard and secure the Personal Information we collect.

In addition, the Personal Information we hold is therefore only accessible to persons who are entitled to know about it and who consult it only when necessary for the performance of their duties.

To this end, we ensure to restrict access to our offices and computer equipment, train our personnel and require from our agents and suppliers of goods and services with access to Personal Information to sign confidentiality agreements and implement equivalent security measures.

Please note, however, that since no mechanism offers maximum security, using the Internet to transmit, create or host Personal Information always involves a certain amount of risk.

If you believe that your Personal Information has been compromised, we invite you to contact our Privacy Officer at the contact information appearing in section 15 of this Policy.

8. Minors

EPRA is in compliance with the requirements of PIPEDA and with the guidelines issued by the Office of the Privacy Commissioner of Canada (OPC).

EPRA does not knowingly collect Personal Information from persons under the age of 18.

EPRA’s Websites are not intentionally designed for or directed at a minor under 14 years of age. If a minor under the age of 14 wishes to use our Websites, our Apps our services or otherwise contact us, the collection of Personal Information from that minor shall not be made without the consent of the person having parental authority or the tutor. If we become aware that we have unintentionally collected Personal Information from persons under the age of 14 without the consent of the person having parental authority or the tutor, we will ensure that such information is deleted from our records as soon as possible. If you are the person having parental authority or the tutor of a minor under the age of 14 and you are aware that your minor child has provided us with Personal Information, we invite you to contact our Privacy Officer at the contact information appearing in section 15 of this Policy so that we may take the necessary action.

9. Keeping Period

EPRA will host and keep your Personal Information for as long as necessary to fulfill the purposes set out in this Policy and to ensure compliance with our legal and regulatory obligations. You may at any time withdraw or change your consent to our use of your Personal Information, or request that we permanently delete it, subject to conditions imposed by law.

If you wish to learn more about how long we keep your Personal Information, we invite you to contact our Privacy Officer, whose contact information appears in section 15 of this Privacy Policy.

10. Access, Rectification, Updating of Personal Information and Withdrawal of
Consent

You have the right to access and obtain copies of your Personal Information. You also have the right to update, rectify and correct any Personal Information that you believe is inaccurate or incomplete. You also have the right to demand that we cease disseminating Personal Information about you, or that we deindex any hyperlink attached to your name allowing access to such Personal Information by any technological means, when its dissemination contravenes the applicable legislation or a court order. You may do the same, or demand that the hyperlink providing access to Personal Information be reindexed, when certain conditions provided for in the Act are met.

To do so, please submit a written request to the Privacy Officer at the address indicated in section 15, who will reply in writing within 30 days of the date of receipt of any such request.

If you wish to obtain copies of your Personal Information, we may charge you a nominal fee, which will be disclosed to you in advance, simply to cover the cost of transcription, reproduction and/or transmission.

Subject to legal and contractual restrictions, if any, you may at any time withdraw your consent to the use or communication of Personal Information collected about you.

11. Electronic Communications (E-Mails)

Your e-mail address may be used to send you electronic communications from time to time. At any time, you may ask us to stop sending you electronic communications by contacting the Privacy Officer at the contact information appearing in section 15 of this Policy or by using the “unsubscribe” instructions appearing at the bottom of these communications, if applicable.

12. Cookies and other Tracking Technologies on our Website, through our Services
and in E-Mail Communications.

We use common information collection tools, such as usage data collection tools, cookies, and similar technologies to automatically collect information that may contain Personal Information from your computer or mobile device when you browse our Websites or interact with e-mails we have sent to you.

By accessing and browsing our Websites, you consent to the use of cookies in accordance with the terms of this Policy and the Website’s Terms of Use. You can control and manage cookies in several ways. Please be aware that deleting or blocking cookies may have a negative impact on your user experience and some parts of our Websites may no longer be fully accessible. Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, which are often found in your browser’s “Tools” or “Preferences” menu.

13. Modifications

EPRA reserves the right to make changes to this Privacy Policy at any time. Such changes will be posted on the Websites and will be effective immediately upon posting. We will take reasonable steps, if necessary, to notify you of any significant changes.

You may contact our Privacy Officer at the address or phone numbers listed in section 15 to obtain an up-to-date copy of the Privacy Policy.

14. Complaints Handling Process (applicable to Québec)

14.1 Reception

Any complaint regarding the application of this Privacy Policy must be made in writing to the EPRA’s Privacy Officer at the e-mail address indicated in section 15.

The complaint must contain the complainant’s name, contact information, including a phone number, as well as the subject and reasons for the complaint in sufficient detail to enable EPRA to assess the complaint. The Privacy Officer may request any additional information he or she deems necessary to assess the complaint.

14.2 Treatment

Please note that EPRA undertakes to treat all complaints received confidentially. Once the complaint has been received, along with any additional information deemed necessary and requested by the Privacy Officer, EPRA will have thirty (30) days to analyze it. At the end of its analysis, the Privacy Officer will provide the complainant with a written response explaining why the complaint was accepted or rejected.

EPRA undertakes to make every reasonable effort to process each complaint within thirty (30) days. However, in the event that a complaint cannot be processed within this timeframe, the complainant will be informed of the reasons for the extension, the status of the complaint and the reasonable time required to provide a definitive response.

A separate file will be created for each complaint received, where applicable. The file should contain the complaint, the analysis and documentation supporting its evaluation, as well as the response sent to the person who initiated the complaint.

You may also file a complaint in writing to the Commission d’accès à l’information – Direction de la surveillance at the following address: 900-2045, rue Stanley, Montréal, Québec, H3A 2V4 or by e-mail at cai.communications@cai.gouv.qc.ca. However, we invite all interested parties to first contact the Privacy Officer, and to wait until EPRA has completed the complaint process.

15. Questions, Comments and Privacy Officer

EPRA is responsible for Personal Information in its custody or control and has designated an individual who is accountable for compliance with this Policy and applicable legislation about Personal Information.

Should you have any questions, concerns or complaints regarding this Privacy Policy of the personal information that EPRA has about you, please contact our Privacy Officer, Annie Holmes, Chief Financial Officer and Vice-President, Operations, at privacy@epra.ca.

This Privacy Policy was last updated on February 28, 2024.