Privacy Policy

What does this policy apply to?

This privacy policy (the “Policy”) applies to all Personal Information that we collect or that you provide to us through the EVLO Energy Storage inc. (“EVLO”, “we”, “us”, “our”) website www.evloenergie.com (the “Website”). The practices described in this Policy do not apply to other websites that you may consult or use, including those accessed through hyperlinks on our Website. In such cases, the information collected or transmitted is then subject to the privacy policy of those external websites.

What is “Personal Information”?

For the purposes of this Policy, “Personal Information” means any information relating to a natural person which enables that person to be identified, directly or indirectly. Information that is required by law to be made public, or information concerning the exercise of a function within a company (such as name, title, function, email address and business telephone number) is generally excluded from this definition.

What Personal Information do we collect?

The Personal Information we collect is the following:

• Name
• First name
• Email address
• Any other Personal Information you may provide, for example, via the form on the “Contact us” page.

We also collect information about you through the interactivity established between your device (computer, tablet, or phone) and our Website. For more information, see “What do we use cookies for?”

How is your Personal Information collected?

Directly to you

We generally collect your Personal Information with your consent, except in the case of users within the European Union as set out in the section “Additional information for users within the European Union”, and unless applicable law provides an exception to this principle (for example, to comply with our legal obligations, where necessary to establish, exercise or defend a legal claim or legal proceeding).

Your Personal Information is collected by various means, including:

• The “Download Spec Sheet” form
• The form in the “Contact us” section.

Refusal of collection

If you wish, you have the right to refuse the collection, use, and disclosure of your Personal Information. However, you should note that if you choose not to provide us with your Personal Information, this may prevent you, for example, from using the Website, since such Personal Information is essential to the provision of the requested services.

What do we use your Personal Information for?

For limited and specific purposes

In general, the Personal Information collected is used for the following Purposes:

• Respond to requests and questions you may submit on the Website, and more generally, manage our relations with Website users,
• Operate and improve our Website,
• Improve your overall experience when visiting the Website, and tailor content and advertising to your interests,
• Carry out commercial prospecting in order to send you offers, news, or any other related information concerning the products and services we offer in the field of energy storage,
• Communicate information about changes to the Website,
• Maintain a secure environment,
• Comply with the legal and regulatory obligations applicable to us,
• Manage any potential or actual disputes with you or third parties,

(collectively, the “Purposes”).

To send you Messages

If you have consented to receive such information, EVLO may send you newsletters, electronic messages such as emails or text messages, news and/or other written communications (the “Messages”) about EVLO, its products and/or services. You may choose not to receive Messages in the manner indicated in the “Contact us” section or through the unsubscribe link included in our Messages. However, EVLO may continue to send you Messages to inform you of available updates or critical technical issues related to the Website.

Use for secondary purposes

Depending on the circumstances, EVLO may also aggregate and anonymize the Personal Information you have provided, in order to create statistical data that EVLO may use to improve the Website, examine user interests, or train machine learning algorithms. EVLO may also share this information with its third-party partners. This statistical data does not include any Personal Information.

What do we use cookies for?

When you browse the Website, cookies and web beacons may be deposited on your device (computer, tablet, or phone). A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet, or other device when you use your browser to visit an online service. Other tracking technologies, such as tracking pixels, may be used for similar purposes. For the purposes of this Policy, all such tracking technologies are collectively referred to as “Cookie(s)”. They enable us to collect or memorize certain information when you browse our Website. Only the issuer of the cookie file is able to read this file.

Strictly necessary cookies

These Cookies are necessary for the operation of the Website and cannot be deactivated in our systems. Strictly necessary Cookies are essential to ensure proper working order of the basic functions the Website may provide. They also enable a user to navigate from one page to another without losing previous actions from the same session.

Non-essential Cookies

If you have consented to their use, EVLO and/or its third-party partners may also use the following non-essential Cookies in connection with the Website and Messages:

• Functionality cookies. These Cookies enable the Website to provide enhanced functionality and personalization of your browsing experience. If you have consented to their use, Functionality Cookies remember your preferences and the choices you make, including your username, region, and language.
• Analytical cookies. We may use analytical Cookies to better understand Website traffic patterns, to help us measure and improve the effectiveness of the Website and Messages, and to determine whether Messages have been opened and links clicked. These Cookies are used for statistical purposes only. All information collected by these Cookies is aggregated and anonymous. To decline tracking by Google Analytics, consult this module: https://tools.google.com/dlpage/gaoptout?hl=en. You may also decline the use of Analytical Cookies by following the instructions below.

How to manage Cookies

With the exception of strictly necessary Cookies, we will only place Cookies on your devices with your consent, and these Cookies will be retained for a maximum period of thirteen (13) months from the time they are placed on your devices. After this period, your consent will be required again. Cookies can be managed and/or blocked via your browser’s cookie settings. However, if you block Cookies, you may be unable to use all the features of the Website and Messages. For more information on how to manage and/or disable non-essential Cookies, please visit https://allaboutcookies.org/how-to-manage-cookies/.

With whom do we share your Personal Information?

Your Personal Information will not be sold or otherwise marketed without your prior consent. However, in processing your Personal Information, we may share it with the following entities and in the following situations.

Our employees

Your Personal Information is processed by EVLO employees. We ensure that only authorized persons within EVLO have access to your Personal Information when necessary for the purposes of managing our commercial relationship or our legal obligations.

Our strategic partners

EVLO may share your Personal Information with its partners to the extent that such disclosure is required for the Purposes. In addition, EVLO may share your Personal Information with the following entities:

• Hydro-Québec and our affiliates,
• Our service providers, external service suppliers, agents, and co-contractors, insofar as they assist us carry out the Purposes defined in this Policy. For example, the hosting service for your Personal Information is operated by an external IT provider,
• Third parties who may collect your Personal Information on our Website by means of Cookies, subject to your prior express consent where required by applicable law or regulation.

When required by applicable laws

EVLO may also share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with the law, (ii) comply with an order of a competent judicial authority, regardless of jurisdiction, (iii) comply with any legal action served on EVLO, (iv) protect and defend the rights or property of EVLO, (v) enforce or verify your compliance with any agreements you have entered into with EVLO, (vi) prevent fraud or other illegal activity perpetrated through the Website, or (vii) act under exigent circumstances to protect the personal safety of users of the Website from the general public.

For company transfers

We may share your Personal Information without your authorization when our operations require it (for example, in the event of a merger, acquisition, bankruptcy, or sale of assets). In any such cases, we may also share some or all of your Personal Information with the relevant third party (or its advisors) as part of a due diligence process.

For other purposes with your consent

Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific cases where additional conditions apply and, in such cases, we will clearly indicate that specific third parties are processing your Personal Information.

How long do we keep Personal Information?

Personal Information will only be stored for as long as is necessary for the Purposes set out in this Policy and to comply with our legal and regulatory obligations. After this period, the Personal Information we hold will be destroyed or anonymized, in accordance with the retention schedule we have adopted and applicable legislation.

In determining the appropriate retention period for your Personal Information, we consider the amount, nature and sensitivity of the Personal Information involved, the potential risk of harm resulting from unauthorized use or disclosure of your Personal Information, the Purposes for which we process your Personal Information and the possibility of achieving those Purposes by other means, as well as any applicable legal, tax or regulatory requirements. To find out more about how long we retain Personal Information, please contact us using the details provided in the “Contact us” section.

Is your Personal Information transmitted outside your territory of residence?

The Personal Information we collect is stored in secure systems hosted on servers that may be located outside your territory or residence, including outside the province of Quebec. We may also retain the services of agents and service providers who may be located outside your home territory. However, we strive to protect Personal Information in our control or custody, including Personal Information entrusted to an agent or service provider, whether they are located in Canada, the United States or other jurisdictions or countries. In particular, we strive to limit their access to Personal Information to that which is necessary to perform the tasks entrusted to them. Please be aware that we also strive to put in place contractual agreements with our suppliers to ensure an adequate level of protection for Personal Information. This may include the implementation of robust and effective security measures. If you have any further questions on this subject, please do not hesitate to contact us.

How do we protect the confidentiality of your Personal Information?

Personal Information Management Program

To protect your Personal Information, we have implemented policies, practices and procedures relating to the management of the Personal Information we store. These internal policies and procedures govern the collection, use, disclosure, retention, and destruction of Personal Information, as well as the handling of complaints, information security and data governance at EVLO. They also provide the framework for the implementation of privacy impact assessments, where required, as well as the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer. The collection of your Personal Information through our Website complies with the requirements of this program.

With necessary and appropriate safety measures

All Personal Information we collect is kept confidential in accordance with applicable privacy and data protection laws in the jurisdictions where we do business. We follow the generally accepted industry standards, and so Personal Information in our possession is accessible only to authorized persons who will consult such Personal Information only when necessary for the performance of their duties. We take reasonable administrative, technical, and physical measures to protect your Personal Information and to minimize the risks of loss, confidentiality breaches, theft and unauthorized access, use, modification, and destruction. In addition, we use the following measures:

• Restricted access to our physical offices and Personal Information,
• SSL (Secure Sockets Layer) protocol,
• Encrypted communications,
• ISO 27001-certified web host,
• Network monitoring software,
• Computer backups,
• Login and passwords,

Children’s privacy

The Website is not intended for persons under the age of 13. EVLO does not knowingly process Personal Information from children under the age of 13 unless a parent or legal guardian has consented. If you believe that Personal Information has been collected from children under the age of 13 without your prior consent, you may contact EVLO as described in the “Contact us” section.

Policy updates

This Policy may be modified, updated, revised, or supplemented from time to time by EVLO, at its discretion. The date of the update indicates when it was last modified. It is therefore necessary to consult the latest version of this Policy to be aware of any changes. If substantial changes are made to the Policy, you will be notified when you access the Website. The Policy and any related agreements will be posted on our Website. EVLO asks its users to review the revised Policy before continuing to use its Policy. Your use of the EVLO Website constitutes your acceptance of any changes to the Policy.

Your rights

According to legislation concerning protection of Personal Information, you have certain rights, such as the following:

• Protection of the confidentiality of your Personal Information,
• Access to your Personal Information,
• Rectification of your Personal Information if it proves to be incomplete, inaccurate or equivocal, or if its collection, communication or storage is not authorized by law,
• Deindexing or reindexing your Personal Information,
• Portability of your Personal Information,
• Deletion of your Personal Information,
• Removal of your email address from our mailing list,
• Withdrawal of your consent, if applicable. However, we would like to inform you that anonymous information, which does not directly or indirectly allow us to know who you are, may be retained even if you withdraw your consent.

You also have the right to lodge a complaint with the competent authority at any time if you believe that EVLO is not processing your Personal Information in accordance with this Policy or applicable laws.

EVLO does not discriminate against its users based on their exercise of any of their rights under applicable law.

EVLO has established procedures for receiving complaints and inquiries regarding its policies and practices for managing Personal Information. We will inform individuals who make inquiries or lodge complaints of the existence of the relevant proceedings. EVLO will investigate all complaints. If a complaint is found to be justified, we will take appropriate action, including, if necessary, amending our policies and practices.

For all inquiries, please see the “Contact us” section.

Contact us

Please do not hesitate to contact us if you have any questions, information requests, comments, or complaints about your Personal Information. To do so, please contact our Privacy Officer by email at the following address:

Energy Storage EVLO inc.

Data Privacy Officer

 plaintesrp@evloenergie.com

Pavillon Archimède, 1804, Blvd. Lionel-Boulet

Varennes (Québec) J3X 1S1

Canada

Additional information for users within the European Union

The following table indicates the Purposes for which we process your Personal Information and, for each of them, the legal grounds that legitimizes the processing in question under European law. Depending on the circumstances, we may use different legal grounds to process the same Personal Information for different Purposes.

We process your Personal Information for the following Purposes and on the following legal grounds