Privacy policy

1. Background

Orange Traffic is a Quebec-based for-profit corporation that processes personal information in the course of its operations. Orange Traffic is a leading provider of high-quality ISO 9001 and CSA-certified traffic signal products, specializing in design, production and distribution.

The purpose of this policy is to ensure the protection of personal information and to govern the manner in which Orange Traffic collects, uses, communicates, retains and destroys it. Furthermore, it aims to inform all interested parties of the way in which Orange Traffic handles their personal information. Additionally, it addresses the handling of personal information collected by Orange Traffic through technological means.

2. Application and Interpretation

This policy applies to all of Orange Traffic’s management, employees, consultants, and anyone else working on its behalf. It also applies to the Orange Traffic website and all websites managed by the company.

The policy covers all personal information handled by Orange Traffic, including that belonging to its employees, members, and website visitors.

This policy defines “personal information” as any data about an individual, whether it directly identifies them or not. Examples include one’s complete name, home address, email, telephone number, and so on.

“Sensitive personal information” is data that individuals rightfully expect to remain confidential, such as their medical history, date of birth, social security number, and financial details.

Typically, an individual’s professional or business contact information (such as their name, job title, work address, work email address or work telephone number) is not considered personal information. In Quebec, the Act Respecting the Protection of Personal Information in the Private Sector, effective as of September 22, 2023, exempts certain information from the provisions of sections 3 (collection, use, communication), 4 (retention and destruction) and 6 (data security). This applies to an individual’s personal data related to their role within an organization, such as their name, job title, responsibilities, as well as their work address, email address and phone number.

The aforementioned sections do not apply to information that is publicly available by law as of the policy’s effective date.

3. Collection, Use and Communication

Most of the services we provide, including website access, require us to collect a minimal amount of data.

For current or potential business partners, we collect only essential information about the people we interact with, such as their names, positions and contact details.

When applying for a position at Orange Traffic, you may submit your application via our website, by email or otherwise, and share information such as your first and last name, telephone number, email address and resume.

Orange Traffic ensures transparency by disclosing all relevant information about the collected data, its intended use, and the collection methods. We are committed to complying with all legal requirements.

Orange Traffic adheres to the following principles when handling personal information:

Consent: :

• Orange Traffic typically collects personal information directly from the individual concerned and with their consent, unless a legal exception applies. Therefore, this policy and the information it contains will be accessible to the person concerned at the time their personal information is collected.
• Generally speaking, Orange Traffic must obtain permission from the individual before acquiring their personal data from external sources, sharing it with third parties, or using it for any other purpose. However, there are exceptions where Orange Traffic is allowed to act without obtaining prior authorization, provided certain legal conditions are met. This policy outlines when Orange Traffic can operate without seeking consent.

Collection: :

• Orange Traffic gathers data solely when required to achieve a particular objective. Furthermore, the data acquired will be restricted to what is essential to meet that objective.
• Please note that Orange Traffic services are not intended for use by minors.

Holding and use: :

• Orange Traffic is very careful to ensure that the data they use to make decisions about individuals is up-to-date and accurate.
• Orange Traffic may only use an individual’s personal information for the purposes stated herein or any other purposes disclosed at the time of collection. If Orange Traffic wishes to use the information for any other purpose, they must first obtain explicit consent from the individual concerned, particularly if the data is considered sensitive personal information. However, in specific instances mandated by law, Orange Traffic may use personal information for secondary purposes without the explicit consent of the individual. These circumstances include:
  • When it is evidently in the individual’s best interest;
  • To prevent or detect fraud; or
  • To evaluate and enhance security and safety measures.
• Restricted access. Orange Traffic implements measures to limit access to personal information to only those employees and individuals within the organization who have a legitimate need to know the information and for whom the information is essential for the performance of their duties. Before providing access to anyone else, Orange Traffic will first obtain consent from the affected individual.

Communication: :

• Orange Traffic generally requires consent before disclosing personal information to external third parties, unless an exception is specified in this policy or mandated by law. Additionally, when disclosing sensitive personal information, Orange Traffic obtains explicit consent from the person involved before sharing.
• Disclosure outside Quebec: Personal information held by Orange Traffic may be disclosed outside Quebec, for example, when Orange Traffic uses cloud service providers whose servers are located outside Quebec or when it deals with subcontractors located outside the province.

Additional information on the technologies used: :

• Use of cookies
  Cookies are files that a website sends to a visitor’s browser, which stores them on their device. These cookies have various functions.

Orange Traffic’s website uses cookies, specifically:

• To remember visitors’ settings and preferences, such as language choices, and to monitor their current session.
• To analyze visitors’ behaviour and content for statistical purposes, with the goal of enhancing the website.

Orange Traffic’s website uses the following types of cookies:

• Session cookies: These are temporary cookies that are stored only for the duration of one’s visit to the website.
• Persistent cookies: These remain on one’s device until they expire and are retrieved the next time the site is visited.

Other technologies used

Orange Traffic also collects personal information through technological means, such as a Web form integrated into its website.

If Orange Traffic collects personal information through a tech product or service that has privacy settings, they must ensure that these settings offer the highest level of protection by default, excluding cookies.

4. Retention and Destruction of Personal Information

Orange Traffic will only keep personal information for as long as necessary for the purposes for which it was collected, unless a minimum retention period is required by law or regulation.

Employee data, including salaries and benefits, will be retained for seven years after the end of employment.

Job applicant resumes are kept for six months before being destroyed.

Data retention periods are set out in a “Data Retention Schedule”, which specifies the retention period for each type of data.

Once the retention period has expired or the personal information is no longer needed, Orange Traffic will either:

1. destroy it, or
2. render it anonymous (meaning it can no longer definitively identify the individual and no longer allows for a connection to be made between the individual and the personal information). Once anonymous, the data could be used for important and legitimate purposes.

Orange Traffic must ensure the safe and secure destruction of information to protect it. This will be done in line with our internal security procedures, including “Mesures de surveillance” and “Politique de conservation et destruction des renseignements personnels”.

This section may be supplemented by any policies or procedures adopted by Orange Traffic regarding the retention and destruction of personal information, if any. For more information, please contact Orange Traffic’s Privacy Officer, identified in this policy in Section 9.

5. Responsibilities of Orange Traffic

In general, Orange Traffic is responsible for protecting the personal information in its possession.

Orange Traffic’s designated Privacy Officer is its Human Resources Director, as per Section 9. Their primary responsibility is to ensure adherence to relevant privacy laws and regulations. This includes approving all policies and procedures related to the management of personal information. Additionally, they must ensure that this policy is understood and implemented throughout the company.

In the event of the Privacy Officer’s absence or incapacity, Orange Traffic’s Accounting Technician will take on the role of Privacy Officer.

All Orange Traffic employees who handle or oversee personal information are responsible for protecting it and adhering to this privacy policy.

Orange Traffic’s internal security guidelines govern the cybersecurity responsibilities of employees throughout the lifecycle of personal information.

6. Data Security

Orange Traffic has implemented and maintains appropriate security measures to protect the personal information under its control. These measures are tailored to the nature of the information, including its purpose, volume, distribution, medium and level of sensitivity. As a result, information that is considered sensitive (as defined in Section 2) will receive enhanced security measures and heightened protection.

Orange Traffic must implement the necessary measures to restrict access to its information systems, ensuring that only employees with a legitimate need to use them are granted access. This aligns with the earlier discussion on limiting access to personal information.

7. Rights of Access, Rectification and Withdrawal of Consent

To exercise their rights of access, rectification or consent withdrawal, the individual concerned must submit a written request to the Orange Traffic Privacy Officer, whose email address is provided in section 9.

Under specific legal conditions, individuals have the right to obtain and review the personal data that Orange Traffic stores about them. They can also request corrections to incomplete, inaccurate, or unclear information. Moreover, they can demand that the dissemination of their personal information be halted or that any hyperlink leading to such information be removed from search engine results if it violates laws or court orders. They may also require that the link providing access to this information be re-indexed when specific legal conditions are met.

Orange Traffic’s Privacy Officer must respond in writing to such requests within 30 days of receipt. If a denial is issued, it must include a detailed explanation of the legal basis for the decision, along with information on any potential legal remedies available and the deadline for taking action. If necessary, the Privacy Officer must assist the applicant in understanding the refusal.

Provided that legal and contractual constraints are met, individuals have the right to revoke their consent for the communication or use of their personal information.

They may also ask Orange Traffic what personal information is collected from them, which Orange Traffic employees have access to it and how long it is kept.

Portability of personal information

To ensure the portability of your personal information, you may submit a request to the Privacy Officer, as identified in Section 9. They will provide you with the necessary form to initiate this process. The data will then be provided in a structured, commonly used and easily readable format, as required by Law 25.

8. Complaints Handling Process

Reception

Any person wishing to file a complaint regarding the application of this policy or, more generally, the protection of their personal information by Orange Traffic, must do so in writing and send it to the person responsible for protecting personal information at Orange Traffic, at the email address indicated in the following section.

The person will be asked to provide their name and contact information, including a telephone number, as well as the subject and rationale for the complaint. The complaint must be detailed enough for Orange Traffic to assess it. If the complaint is not clear enough, the Privacy Officer may request any additional information they deem necessary to evaluate the complaint.

Treatment

Orange Traffic commits to treating all complaints confidentially.

Within 30 days following receipt of the complaint, or following receipt of all additional information deemed necessary and required by Orange Traffic’s Privacy Officer in order to process the complaint, the latter shall evaluate the complaint and formulate a reasoned written response by email to the complainant. This evaluation will determine whether Orange Traffic adheres to this policy, any other policies and practices within the organization, and applicable laws or regulations regarding the handling of personal information.

If the complaint cannot be processed within this period, Orange Traffic must inform the complainant of the reason for the delay, progress so far, and the expected timeframe for completing the investigation.

Orange Traffic must keep a separate file for each complaint received. The file should contain the complaint, the analysis, supporting documents, and the reply sent to the complainant.

9. Endorsement

This policy is approved by Orange Traffic’s Privacy Officer, whose contact information is provided below:

For any questions, comments or requests regarding this policy, please contact the designated person by email.

10. Publication and Modifications

This policy is published on the Orange Traffic website. This policy is also disseminated by any means likely to reach the people concerned.

We retain the authority to update this policy at any time. The latest version of the policy can always be found on our website. Furthermore, your use of our platform may be subject to additional terms and conditions outlined in our user agreement.

Last update: September 5, 2024