Privacy Policy

EchoPoint Solutions Inc. and its affiliates are committed to keeping the Personal Information we collect accurate, confidential, secure and private. This Privacy Policy has been designed to inform emp loyees, contractors, agents, customers of the Local Distribution Companies that we serve, and individual members of the public, of both our commitment to and recognition of our obligation to meet the terms of applicable privacy laws, including, the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA) and the Municipal Freedom of Information and Protection of Privacy Act (Ontario).

Contents

This Privacy Policy describes the principles EchoPoint Solutions Inc. will use to protect the privacy of Personal Information of customers and other individuals in its possession or control. It addre sses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines the individuals' rights in respect of this information. For the purposes of this Privacy Policy, "Personal Information" means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.

In this Privacy Policy, "EchoPoint", "we", "us", or "our" means EchoPoint Solutions Inc., "LDC" refers to Local Distribution Company and "customer", "you", and "your" means the individual who is a c ustomer, prospective customer, LDC customer, vendor or other individual member of the public whose Personal Information is in our possession or control.

By requesting service from EchoPoint, visiting or using our Website, or otherwise providing us with your Personal Information, you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time. The terms in this Privacy Policy may be changed from time to time, so you should review it here periodically for any updates or changes.

Personal Information Protection Principles

Accountability
EchoPoint is accountable for the protection of all Personal Information within the organization's possession or control, including any Personal Information that has been transferred to a third party for processing purposes. EchoPoint may engage employees, contractors or other companies, including third parties to perform services for EchoPoint that involve access to Personal Information. EchoPoint shall use contractual or other means to provide a comparable level of protection of this information while the information is being processed by such third parties.

Rick Pontini, President, EchoPoint Solutions Inc., Chief Privacy Officer, is accountable for EchoPoint Solutions Inc. compliance with this Privacy Policy. He may be contacted at: 13360 Sylvestre Dr Te cumseh, ON N8N 2L9, 519.739.2010

Identifying Purposes
EchoPoint will identify itself as a third party to the LDC customers that we serve, inform the customer the purposes for which it collects Personal Information at or before the time the information is collected, such as when a customer applies for participation in conservation programs offered by us. If EchoPoint needs to refer the customer to a Third Party for completion of requested services, EchoPoint will seek customer consent for approval prior to releasing customer information to third party contractors. If a customer refuses permission for EchoPoint to use Personal information or transfer personal information to Third Party contractors, it may prevent us from providing some services since we require a minimum amount of Personal Information to enroll/complete customer requests. All Personal Information EchoPoint Solutions collects from customers and other individuals (as applicable) is collected, at a minimum for the following purposes:

  • To identify or contact customers, respond to customer inquiries and otherwise maintain business relations with customers;
  • To deliver and maintain conservation programs;
  • To promote conservation programs offered by the Ontario Power Authority and the LDC's that we serve;
  • To provide customers with information about energy conservation programs and incentives;
  • To request customer participation in surveys, contests or events;
  • To notify customers about events, training opportunities, causes or programs sponsored by the Ontario Power Authority or the LDC's that we serve;
  • To provide individuals with information they have requested on Conservation programs.

Consent, Limiting Use, Disclosure and Retention
EchoPoint will obtain customer consent before, or when, it collects, uses or discloses Personal Information. Consent may be obtained directly from the customers, LDC's or from a third party that has obtained consent to disclose Personal Information to EchoPoint. For example, if the customer has signed a separate contract with a contractor, EchoPoint may obtain Personal Information from the contractor. Consent may also be given by an authorized representative such as a legal guardian or person with power of attorney. EchoPoint will not use or disclose Personal Information for purposes other than those for which it was collected except with consent or as permitted or required by law or regulatory authorities.

EchoPoint will collect, use or disclose Personal Information without prior consent, only in limited circumstances as permitted or required by law or regulatory authorities. Subject to certain legal and contractual restrictions and reasonable notice, customers can refuse or withdraw consent to the collection, use or disclosure of Personal Information at any time. However, refusal to provide such consent, or withdrawal of such consent, may prevent us from providing customers with some services since we require a minimum amount of Personal Information about the customers to provide conservation information and programs. EchoPoint will explain the implications of such withdrawal or refusal to provide such consent at time of refusal or withdrawal of consent. Under certain exceptional circumstances, EchoPoint may have a legal duty or right to collect, use or disclose your Personal Information without customer knowledge or consent.

In accordance with applicable laws, EchoPoint will not disclose any consumer information (which may include Personal Information) to any of its affiliates without the consumer's consent except where consumer information is required to be disclosed:

  • for billing or market operation purposes;
  • for law enforcement purposes; or
  • for the purpose of complying with a legal requirement.

EchoPoint will retain Personal Information only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. We will establish retention periods for up to 1 year, after which the Personal Information in such accounts will be returned to respective LDC's. EchoPoint will not trade, rent or sell Personal Information.

Limiting Collection
EchoPoint shall limit the amount and type of Personal Information it collects to that which is necessary for the purposes identified, and shall collect such information by fair and lawful means. The types of Personal Information that EchoPoint usually collects from individual customers include:

  • Customer name and address (mailing and service address) and other contact information (i.e. home and work telephone numbers and e-mail addresses);
  • Customer transactions with LDC customers (i.e. account number and account class);
  • Identifying information (i.e. customer account number);
  • Information we receive from customers through promotions and correspondence or communications with us;
  • Depending on the circumstances, we may collect some or all of the Personal Information listed above from individual customers.

Accuracy
EchoPoint maintains procedures to ensure all Personal Information we collect and use is kept as accurate, complete and up-to-date as necessary for the purpose for which it is to be used. However, we rely on the Local Distributions Company's to disclose all material information to us and to inform us of any errors or changes in such information.

Safeguards
In fulfilling its responsibilities with respect to the confidentiality of Personal Information, EchoPoint employs a number of safeguards, appropriate to the sensitivity of the specific information, to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, such as locked filing cabinets, restricted access to offices, limiting access on a "need to know" basis, use of passwords and encryption. Procedures for implementing these measures have been communicated to all employees and relevant third parties to ensure compliance.

Openness
EchoPoint will from time to time review and revise its Privacy Policy. EchoPoint will make changes to its Privacy Policy available to its customers by such means as EchoPoint's website and customer agreements

Individual Access
Upon request and with satisfactory proof of the customer's identity, any customer that has requested service from EchoPoint may obtain information regarding the type, use and disclosure, of his, or her, Personal Information that EchoPoint has in its possession or control. Any customer may request that his, or her, Personal Information be amended for purposes of accuracy and completeness. Echopoint may require the customer to provide such request in writing.

Challenging Compliance
Should you have any questions or concerns, please contact us at privacymatters@echopointsolutions.com