UAP Inc. (“UAP”) has made it its mission to be the Canadian leader in the sale, distribution and marketing of automotive parts and accessories for cars and heavy vehicles. To carry out this mission, UAP relies on a team of motivated and competent employees evolving in a dynamic environment.
Over the years, UAP has not only become known for the excellence of its products and its dynamic approach to its business markets, but also for its commitment to offering its customers high-quality services and top-notch advice.
To live up to this commitment, UAP attaches great importance to the protection of the Personal Information provided to it by its customers in the scope of its commercial activities, including when they are consulting its web sites, or using its on-line services.
SCOPE AND APPLICATION
This policy has been drawn up to meet the requirements of the relevant provisions of the statutes that govern the protection of Personal Information and privacy.
More specifically, this policy focuses on the provisions that were adopted to govern the collecting, holding, use, communication and destruction of Personal Information in the private sector. The rules that were introduced were designed to establish a balance between the rights pertaining to the protection of privacy of individuals with regard to their Personal Information, and UAP’s needs to collect, use or communicate such information in connection with its business activities.
For the application of this policy, “Personal Information” means any information which relates to a natural person and allows that person to be identified.
To ensure compliance with this policy, UAP makes every effort to require that its employees, representatives or agents conduct themselves in a responsible manner with respect to the protection of Personal Information. To this end, it provides them with the appropriate information sessions, or sensitization.
At UAP, the protection and confidentiality of Personal Information that it holds is controlled at every stage of the management of this information: the collecting, holding, use, communication and destruction thereof.
At each phase of the management of the Personal Information that UAP holds, it makes sure that it gets consent from the person concerned. This consent must be manifest, free, enlightened and given for specific purposes, and is valid only for the length of time necessary to achieve the purpose for which it was requested. In this respect, UAP prefers that consent from the person concerned be given in writing.
Only the employees, representatives or agents whose functions at UAP require the use of Personal Information are authorized to collect such information on UAP’s behalf.
In general, this information should be collected from the person concerned, and only with his or her consent. It may however be collected from a third party, provided the consent of the person concerned was obtained, or where it is authorized by law.
UAP may only collect Personal Information which is necessary to carry out its functions, to achieve specified ends, or to fulfill its mission.
The person who provides the information must be informed of the foregoing, how the information will be used, the category of persons who will have access to it, where it will be held, and his or her right to access or correct it.
UAP applies strict security rules and makes every reasonable commercial effort to ensure the confidentiality of the Personal Information it holds on its customers and the protection thereof against loss, unauthorized access, unauthorized use, duplication or alteration. UAP must ensure that these means are reasonable, given in particular, the sensitive nature of such Personal Information, the ultimate aim of its use, its quantity, breakdown and medium.
Furthermore, UAP ensures that the Personal Information contained on paper is kept under lock and key, and under the responsibility of a specified individual. As for Personal Information contained on a computing medium, this is kept in a manner that ensures the effective and secure control thereof, and a limited access thereto.
Access to the Personal Information will be restricted to UAP’s employees, representatives and agents who may only use such Personal Information in the performance of their duties.
The use of the Personal Information held by UAP is limited to the purposes for which it was collected.
UAP must ensure that the Personal Information it holds is current and accurate when it is used.
UAP undertakes not to communicate the Personal Information that it holds to third parties without first obtaining the consent of the person concerned, or where authorized by law.
UAP undertakes at all times not to sell, transfer or lease Personal Information in its possession to third parties.
Where disclosure of information is authorized or permitted, UAP ensures that the confidentiality of the Personal Information is protected.
In particular, e-mail must not be used to communicate a message or documents containing Personal Information without the consent of the person concerned, unless appropriate measures have been taken to ensure the communication is secure and confidential.
Where Personal Information held by UAP is no longer necessary for the purposes for which it was collected, UAP ensures that any document containing Personal Information, regardless of the medium, is destroyed using a process that ensures the confidentiality of the information it contains.
UAP undertakes to inform any person who so requests that it holds information about such person, what use is made thereof, and that it has been disclosed to third parties, where applicable. UAP must, at all times, permit the person concerned to obtain access to, and consult the Personal Information about him or her.
The person concerned may also dispute the accuracy of the Personal Information about him or her in UAP’s possession, and make the appropriate corrections thereto, in accordance with the law.
To make a request for access to Personal Information, or request that such Information be corrected or updated, the person concerned should contact UAP’s Director Administration in writing at the following address: 7025 Ontario Street East, Montreal, Quebec, H1N 2B3. The latter must respond to the person concerned within thirty (30) days of the receipt of the request.
All employees, representatives and agents of UAP handling Personal Information shall take all appropriate measures to ensure the strict compliance with this Policy, as well as with the requirements relating to the protection of Personal Information, and this, at all times.
In case of doubt regarding the application of this Policy, any employee, representative or agent of UAP must consult UAP’s Director Administration before taking any action whatsoever which could have the effect of collecting, holding, using, communicating or destroying Personal Information in breach of the present Policy or the law.
Any observed or anticipated breach of the provisions of this Policy or of the law which could detrimentally affect the confidentiality of Personal Information held by UAP must be reported without delay to UAP’s Director Administration.
7025 Ontario Street East, Montreal, Quebec, H1N 2B3
SUMMARY – TEN PRINCIPLES ON THE PROTECTION OF PERSONAL INFORMATION
- Reasons for collection – UAP must determine, and inform the person concerned, why the Personal Information is being collected, as well as the terms and conditions surrounding its use.
- Consent – so that the Personal Information can be collected, used or communicated, the person concerned must be informed thereof and agree thereto except where otherwise required or authorized by law.
- Restriction on collecting – UAP is only entitled to collect Personal Information that is necessary to carry out its functions, to achieve specified ends that it indicated and to fulfill its mission.
- Restriction on holding, using and communicating – the Personal Information held by UAP can only be held, used or communicated to achieve the purposes for which it was collected unless the person concerned has consented to another use or the law requires or authorizes it. The Personal Information can only be kept for the length of time necessary to achieve the purposes for which it was collected.
- Accuracy – UAP ensures that the Personal Information it collects and holds is current and accurate when it is used.
- Security measure – UAP must implement security measures to protect the Personal Information it holds against any loss, theft, communication, duplication, unauthorized use or modification. UAP must ensure that these measures are reasonable given, in particular, the information’s sensitive nature, the ultimate aim of its use, its quantity, breakdown and medium.
- Transparency – UAP must provide its customer base with information regarding the standards and methods that it uses to collect, hold, use, communicate and destroy personal Information.
- Accessibility – Where the person concerned submits a written request, UAP must notify him or her of the existence of the Personal Information about him or her that it holds, how it uses the information, and the fact that it is communicated to third parties, where applicable. UAP must allow the person concerned to access the information and to contest its accuracy or its completeness.
- Resolution of complaints and request regarding the protection of Personal Information – any concerned person may send written questions, requests or complaints to UAP’s Director Administration at the following address: 7025 Ontario Street East, Montreal, Quebec, H1N 2B3.
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