Privacy Policy
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1. PURPOSE OF THE POLICY
Definition. In this Policy, "personal information" means any information collected by Ultium CAM, Limited Partnership ("we", "us" and "our") that, alone or in combination with other information, directly or indirectly identifies an individual ("you", "your" and "yours"), but does not include business contact information. Business contact information" is information concerning a person's position within a company, such as their first name, last name, title, position, as well as their work address, e-mail address and telephone number.
Legislative framework. In accordance with the Act respecting the protection of personal information in the private sector (R.R.S.Q., c. P-39.1) (the "Private Sector Act"), as amended by the Act to modernize legislative provisions respecting the protection of personal information (Bill 25), we implement policies and practices to govern our governance and operations with respect to the protection of personal information, including this Policy. This Policy and any amended version of it are subject to the legislation applicable in the province of Quebec.
Policy objectives. The main purpose of this Policy is to provide you with information, in plain language, relating to :
- the means we use to collect your personal information;
- the categories of personal information we may collect and the purposes for which we collect it;
- how we may use your personal information and the categories of third parties to whom we may disclose your personal information;
- the rights you enjoy with respect to your personal information held by us, namely the right to access your personal information,
the right to rectify your personal information in certain circumstances and the right to withdraw your consent to the use and disclosure of your personal information; - the various security measures we have put in place to protect the confidentiality of your personal information;
- how your personal information is stored, destroyed and/or anonymized; and
- how you can contact us to address your questions, share your comments or, if applicable, make a complaint in connection with this Policy or, more generally, our processing of your personal information.
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2. THE INFORMATION GATHERED AND THE MEANS
List of means. We may collect your personal information in the following ways:
- Automatically when you visit our website, which is accessible via the following hyperlink: https://ultiumcam.net/ (the“Site”), in particular through the use of cookies and other similar technologies (collectively, “Cookies”);
- When you provide us with personal information through the Site;
- When you communicate with our authorized representatives (face-to-face communications, videoconferences, e-mail, instant messaging, telephone calls, faxes, etc.);
Personal information collected automatically
- 3. PURPOSES FOR COLLECTING INFORMATION
Purposes for collecting personal information Purposes" are the reasons why we need to collect your personal information.
We may collect personal information about you for the following purposes:
We may collect personal information about you for the following purposes:
- Identify you so that we can interact with you properly;
- Process any request or question you send us, including communicating with you in connection with the processing of such request or question;
- Process your job application, whether unsolicited or in response to a job offer;
- Communicate with you insofar as we wish to follow up on your application, obtain further information in connection with your application and/or inform you of any decision we have taken in connection with your application;
- To enable us to perform our obligations and exercise our rights as your employer or in any other capacity;
- Allow you to access the Site;
- Identify the technology you use when accessing the Site (such as operating system and browser) in order to assess compatibility and improve overall accessibility;
- Identify the websites from which you access the Site in order to evaluate the number of referrals obtained;
- Identify the country from which you wish to access the Site in order to check whether access can be granted in accordance with the applicable legislation.
Consent prior to use for other purposes. Subject to the exceptions set out in the Privacy Act, we will obtain your consent before using your personal information for any purpose other than those listed above.
Authorization to collect personal information for identification or location purposes. In connection with the use of certain Digital Markers (see summary table attached as an appendix to this Policy), we may collect personal information using technology that includes features that allow us to identify and locate you. The functions that allow us to collect your personal information for identification and location purposes are deactivated by default and are not collected by the Company.
- 4. TO WHOM WE COMMUNICATE YOUR PERSONAL INFORMATION
Access to and disclosure of personal information. We may provide access to, or disclose, personal information about you to the following persons or entities:
- a. To employees and representatives of our organization and entities of the same corporate group (GM and POSCO) who require access to such personal information in the pursuit of one or more of the purposes listed in section 3 above;
- b. To our external service providers and agents who require access to this personal information in order to perform their obligations arising from a service contract or mandate entered into with us (e.g. web hosting or cloud computing service providers) under the terms of which the relevant external service provider or agent is required to take appropriate measures to :
- (i) protect the confidentiality of personal information;
- (ii) ensure that the personal information communicated is used only for the purpose of fulfilling its obligations under the terms of the service contract or mandate;
- (iii) ensure that the personal information communicated is not retained after the termination of the service contract or mandate;
- (iv) promptly notify us of any breach or attempted breach by any person of any obligation relating to the confidentiality of personal information disclosed; and
- (v) allow us to verify the confidentiality of the personal information provided;
- c. To your previous and current employers and any institutions you may have attended, in order to verify the truthfulness, accuracy and completeness of any information provided as part of your application submitted to us, as well as to obtain additional information from these entities, where applicable;
- d. To any other person or entity, where required or permitted by applicable law, or with your prior consent.
We may disclose your personal information to persons or entities in the above categories who are located outside the province of Quebec. In such cases, we will conduct a privacy impact assessment in accordance with the Privacy Act prior to any such disclosure. We will only disclose your personal information if the privacy impact assessment demonstrates that the person or entity in question is able to provide adequate protection of your personal information in accordance with generally accepted privacy principles, among others.
- 5. MEANS OF PROTECTING PERSONAL INFORMATION
Security measures. We have adopted and implemented physical, technological and administrative security measures to protect your personal information and reduce the risk of unauthorized and/or illegal access, use, disclosure and destruction. The following is a brief description of these security measures:
- Selection process for employees and partners. We follow a process that takes into account our obligations to protect personal information when recruiting new employees who will be called upon to handle personal information, or when entering into a service contract or mandate involving the disclosure of personal information to a third party;
- Confidentiality undertakings and internal guidelines. All our employees who may have access to your personal information are required to sign an undertaking of confidentiality and to comply with internal directives on the protection of personal information;
- Training. We make every effort to ensure that all our employees who may have access to personal information receive training in privacy, protection of personal information and cybersecurity;
- Access management and retention. We ensure that your personal information is accessible only to those of our employees and authorized representatives who need to have access to it in order to perform their duties related to the pursuit of one or more of the purposes identified in section 3 of this Policy. To this end, we have put in place mechanisms to manage access to personal information, including the granting of separate access rights based on the employee's position and the ongoing logging of access. In addition, we store your personal information on the secure servers of our web hosting service providers;
- Retention Schedule. We have established a retention schedule to ensure that your personal information is not retained beyond the time required to fulfill the purposes described in section 3 of this Policy. Subject to any obligations we may have under applicable law, your personal information will be securely destroyed within a reasonable period of time following the fulfillment of the purposes described above;
- Secure destruction processes. We have established processes for the secure destruction of personal information whose retention period has expired;
- Management of confidentiality incidents. In the event of a privacy incident that presents a risk of serious harm to you, we will take the necessary steps to notify you, in accordance with the Privacy Act. The assessment of the risk of serious harm to you is based on criteria such as the sensitivity of the personal information concerned by the confidentiality incident, the apprehended consequences of its use and the likelihood that it will be used for harmful purposes;
- Complaint handling process. We have developed and adopted a complaint handling process specific to the treatment of personal information within our organization. If you would like to leard more, please contact us as indicated in section 8 of this Policy; and
We reassess the above-mentioned safety measures on a regular basis. Risk. No organization can validly claim to be immune to the risk of a confidentiality incident involving personal information. Despite our best efforts to ensure the protection of your personal information, we are unable to provide you with a guarantee that your personal information is protected from the risk of a confidentiality incident. If you have reason to believe that the protection of your personal information has been compromised, please contact us as indicated in section 8 of this Policy.
- 6. USER RIGHTS
Right of access
Right of rectification
Right of withdrawal
Procedure
- 7. COMPLAINTS PROCESS
Right to file a complaint. If you are dissatisfied with our organization's handling of your personal information, you may file a complaint with our Privacy Officer, whose contact information is set out in section 8 of this Policy.
Complaints to the Commission d'accès à l'information du Québec. The Commission d'accès à l'information du Québec is an administrative body whose duties include overseeing the application of the Privacy Act. If you feel that we are not respecting our obligations under the Private Act, you can submit a written complaint to the Commission d'accès à l'information du Québec. To do so, you can consult the Commission d'accès à l'information du Québec complaint form.
- 8. RESOURCE PERSON
To exercise any of your rights, ask questions, make comments or lodge a complaint with respect to this Policy or our processing of your personal information, please contact our Privacy Officer at the following address: Hassan Chaudry
Privacy Officer
Ultium CAM L.P.
7305 boulevard Bécancour, Bécancour, G9H5G6
Telephone number: 1-450-830-4392
E-mail address: ultiumcam_compliance@ultiumcam.net- 9. POLICY UPDATE
Amendment process. The date of adoption and the date of the last update of this Policy are indicated in the header on the first page. This Policy may be amended from time to time to take into account changes in applicable legislation and in the policies and practices governing our governance and operations with respect to the protection of personal information, among other things. In order to modify this Policy, we will post a notice of modification on the section of the Site dedicated to this Policy and notices of modification. If we have your e-mail address, we will use it to send you the notice of change. The content of the notice of modification will come into effect at the end of the fifteenth (15th) day following the date of its publication on the Site, subject to reasons justifying a shorter delay.