Privacy Policy
Last Update: June 1, 2023
The following describes how information collected will be used.
Mailing list – Individuals subscribing to the mailing list will receive quarterly communications. The mailing list is hosted on servers in the United States. The mailing list may be shared with vehicle manufacturers participating in this program. The mailing list will not be sold to third parties. An individual can unsubscribe from the mailing list at any time.
Contact information – Companies and individuals with EV battery(ies) for collection will need to provide their contact information for the purpose of communication and collection of the EV battery. Vehicle manufacturers participating in the program may have access to this information for the purpose of monitoring the program’s progress. This information can’t be removed from the records on file as its pertinent to the transactions occurring to perform the service.
Battery information – Battery information provided by companies and individuals will be used for the purpose of arranging the EV battery collection. Battery information includes but is not limited to dimensions, weight, disposition, information on damage, defects, and thermal events, photographs, serial numbers, product numbers, identification numbers, vehicle make, vehicle model, and vehicle year. This information becomes the property of the service provider and may be used for performing the service, for training, and sharing publicly. Vehicle manufacturers participating in the program may have access to the information.
Quantity of EV batteries collected – Vehicle manufacturers may report the quantity of EV batteries collected to provincial representatives of the respective Ministries of Environment or similar Ministry responsible for the management of EV batteries at end of their vehicle life. Contact information is not included in this reporting. The battery disposition (end-of-life vs. damaged-defective) is included in this reporting.
ACCEPTANCE AND ENFORCEMENT
Call2Recycle Canada, Inc. (collectively “Call2Recycle” or “we”) is providing this privacy policy (“Privacy Policy”) to inform you (“User” or “you”) of our policies and procedures regarding the collection, use and disclosure of personal data and information that we receive from Users who use the EV Battery Recovery program website managed by Call2Recycle (the “Services”) and participate in Call2Recycle’s programs.
Be sure to check this page periodically for the most current version of the Privacy Policy. We reserve the right at any time, in our sole discretion and without liability, to update or modify the Privacy Policy without notice, and your continued access or use of the Services will mean that you accept the updated or modified Privacy Policy. If we change it, we will update the “Last Updated Date” at the top of the Privacy Policy. By continuing to access the Services, you are indicating that you agree to be bound by the revised Privacy Policy. If the revised Privacy Policy is not acceptable to you, please do not use the Services.
INFORMATION COLLECTION AND USE
We collect information when you use the Services or provide it to us directly, which information can be divided into the following general categories:
Non-Personal Information: When you access our Services, certain non-personal information is automatically collected, such as your IP address, device identifier, operating system, URL to our Service, times of your visits, language, device location data, and your use of our Services. Some other Non-Personal Information is also collected manually when you fill out an EV Battery collection request via our website, such as information and/or photograph(s) of the EV batteries being collected, the city in which the requestor does business, the quantity of EV batteries collected, the state of health (end-of-life vs. damaged-defective) of the EV batteries, the vehicle make, model, and year from which battery was from (when available), the destination of batteries by battery holder, and the certificates of recycling by battery (when available). We will not combine Non-Personal Information with any Personal Information that we collect directly from you (if applicable). We use Non-Personal Information to review our traffic, to observe how Users use our Services, to monitor and analyze the use of the Services, to monitor and analyze statistics, to obtain an accurate representation for technical administration, to increase the functionality and usability of our Services, to better tailor our Services to the needs of Users, and to run our programs and business activities. This type of information will not allow you to be personally identified.
Personal Information: We collect Personal Information that you voluntarily upload or provide to us by using the Services or by subscribing to the EV Battery Recovery program newsletter, such as your name, business email address, business telephone number, or corporate mailing address, as applicable.
The purpose of collecting Personal Information is to:
- Provide, maintain, perform and improve the Services and our programs;
- Evaluate applications for eligibility to the Services and our programs and contact you accordingly;
- To communicate with you, if you have chosen to receive the EV Battery Recovery program newsletter, regarding our services; you may withdraw your consent to receive such communications at any time; note that our email list may be supplied to vehicle manufacturers for the purpose of continuing Call2Recycle’s Services and programs if Call2Recycle is no longer a supplier to the industry. Such mailing list is not to be shared with any third party other than Call2Recycle, the vehicle manufacturers, or a new service provider;
- To perform internal operations, including, for example, to prevent fraud and abuse of our Services and programs, to troubleshoot software and operational problems, to perform data analysis, testing and research, and to monitor and analyze usage and activity trends;
We expressly acknowledge that we will not use your Personal Information for any other purpose without your consent. We will only collect Personal Information to the extent necessary for the purposes identified above. We may use Personal Information that has been de-identified for study or research or for the production of statistics.
The Personal Information may be collected for the benefit of vehicle manufacturers and transport providers. In addition, Personal Information may be used and disclosed as Call2Recycle may deem reasonably necessary to the aforementioned third parties enforce the terms of use of the Services or to protect the rights, property or safety of any person or entity, or as required by law, in particular, in response to a request from government authorities.
RIGHT TO REVIEW INFORMATION
You have the right to access and rectify the Personal Information we collect about you. If you wish to review this information, please send a written request to privacy@call2recycle.ca.
WITHDRAWAL OF CONSENT
You may at any time decide to no longer consent to the collection of your Personal Information by sending a written request to privacy@call2recycle.ca or request to correct or delete your Personal Information. Upon receiving notice of your withdrawal of consent, we will stop using your Personal Information within a reasonable period of time. Please note that in certain circumstances, we may refuse a request to delete your Personal Information, such as when the Personal Information is required for compliance with the law, with a contractual agreement between the parties, or in connection with claims. You acknowledge and agree that we may not be able to provide you the Services if you withdraw your consent.
SHARING INFORMATION
We do not sell, rent or disclose to third parties the information we collect and store. You can expect us to share information collected with other parties in the following ways:
- Call2Recycle, Inc.: We operate the EV Battery Recovery program, while Call2Recycle, Inc., based in Atlanta, GA, United States, owns the software platform that provides the logistics services we offer. As such, the information collected and stored via our portal is shared with Call2Recycle, Inc. to process the EV battery collection requests and deliver the Services. Call2Recycle, Inc. is required to have the same level of privacy protection as we do. Therefore, we expect your information to be treated with the same level of care that we employ.
- Affiliated Service Providers: We have agreements with various affiliated service providers to facilitate the provision of our Services and programs, under which we may share the information we have collected. All affiliated service providers we use are required to have the same level of privacy protection as we do. Therefore, we expect your information to be treated with the same level of care that we employ.
- Statistical Analysis: We may share Non-Personal Information and information that has been aggregated anonymously with third parties, including, but not limited to, statistical, machine learning, or marketing purposes. No Personal Information will be shared in this manner.
- Transactions: Transactions occur as part of or during negotiations of a merger, sale of company assets, any financing or acquisition, or in any other situation in which Personal Information may be disclosed or transferred as one of our business assets. However, in no event will these transactions allow your information to be used for any purpose other than the purpose for which you have given us your consent.
DATA SECURITY
Our data security policy is available here. Security measures have been put in place with respect to the Services and our programs to protect the loss, misuse and alteration of the information under our control. Please note, however, that no data security measures can be guaranteed to be completely effective. Therefore, we cannot certify or guarantee the security of Personal Information or other information. You transmit Personal Information to us at your own risk.
CONFIDENTIALITY INCIDENTS AND INCIDENT RESPONSE PLAN
In accordance with applicable law, Call2Recycle has implemented a policy for handling confidentiality incidents and an incident response plan, which are available here.
DATA RETENTION
We will retain the Non-Personal Information and Personal Information collected in connection with our Services for the time needed to perform the Services and run our programs, and/or as long as may be requested by law, regulations, governmental orders or decrees, and/or as may be required by principles of good governance, whichever is longer. When the Non-Personal Information and Personal Information collected is no longer needed, it will be safely destroyed and/or anonymized and no copies will be kept.
EXTERNAL LINKS
We are not responsible for the privacy practices of other sites you may click on while using our Services and encourage you to read their privacy statements.
INTERNATIONAL TRANSFER
The EV Battery Recovery program that we operate on behalf of vehicle manufacturers is destined to users located in Canada. Note that our logistics services, through the software platform we use (owned by Call2Recycle, Inc.), operate both in Canada and in the United States. Please be advised that the information we collect, including Personal Information, will be transferred to, processed, stored and used in the United States and/or Canada, and will be protected in accordance with generally accepted privacy principles. By using the Service or providing any information to us, you consent to the transfer, processing, use, sharing, disclosure and storage of your information, including Personal Information, to the United States and/or Canada as set forth in this Privacy Policy.
CONTACT US – PRIVACY OFFICER
Michael Partab, Chief Financial Officer acts as Privacy Officer and is responsible for ensuring compliance and implementation of applicable laws. You can contact him at the contact information listed below:
100 Sheppard Ave East, Suite 800, Toronto ON M2N 6N5
The Privacy Officer is responsible for, among others:
- Approving governance policies and practices regarding the protection of personal information that the organization must establish and implement;
- Participating in the conduct of Privacy Impact Assessments (“PIAs”) involving certain information systems or electronic service delivery systems and suggest measures to ensure the protection of personal information processed in connection with such systems;
- Recording any communication (without consent) to another organization or public body that may reduce the risk of injury resulting from a confidentiality incident and advising the organization in the assessment of the risk of injury resulting from a confidentiality incident;
- Receiving and responding to access and rectification requests, requests related to data portability and data processing, the right to be forgotten, and complaints regarding the protection of personal information.
COMPLAINT PROCESS
If you have any complaint regarding the protection of personal information by Call2Recycle, please send it to our Privacy Officer, who will review and address the complaint within 30 days following its receipt, and will respond to you to inform you how the complaint was resolved. If you are not satisfied with the resolution provided by the Privacy Officer, you may exercise your rights under applicable privacy laws.
RIGHT TO BE FORGOTTEN
If the dissemination of your Personal Information (i) contravenes the law or a court order, or (ii) otherwise causes serious injury to your reputation or privacy, you can ask our Privacy Officer in writing that Call2Recycle restrict from disseminating your Personal Information or have hyperlinks associated with your name and that provide access to Personal Information, de-indexed (i.e. “delisted” from search results). Our Privacy Officer will respond to the request in writing within 30 days of its receipt, unless the Commission d’accès à l’information or other competent body extends the time limit within which we must provide our response.
ELIGIBILITY
The Services are not intended for persons under the age of 18. Vehicle manufacturers, dismantlers or other organizations who let employees or other representatives under the age of 18 access our platform and use our Services hereby warrant that such individuals under the age of 18 are duly authorized by law to use the Services, and Call2Recycle declines any responsibility in connection therewith. If Call2Recycle becomes aware that Personal Information about unauthorized individuals under the age of 18 has been inadvertently collected, Call2Recycle will promptly delete such information