Privacy Policy

Welcome to Relion. We hope that you enjoy and appreciate using our “Services”, which include (i) visiting our website at https://www.relioncharging.com, including all subpages and subdomains, present and future (the “Website”); and (ii) using our online “Platform”, which provides our users (each a “User”) with access to our end-to-end EV charging infrastructure O&M online solution.

This Privacy Policy (the “Policy”) covers personal information collected from you or about you when (1) you visit our Website; or (2) you have created an account to use the Platform. 

Relion takes your privacy and the security of personal information very seriously. We are providing this Policy to tell you about who we are, what personal information we collect from you and about you, and what we do with your personal information, all while you use the Services or otherwise interact with us. The Policy also explains your rights under the law, and how you can contact both us and the necessary authorities to enforce those rights. We ask that you please read it carefully.

Here are the key elements of this Policy so that you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your personal information. By submitting any personal information to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy. 

Before we get started on the details, here are a few terms and phrases we think you should know as you read this Policy.

“Data Protection Laws” refers to the laws that are designed to protect your personal information and privacy in the place where you live. Relion is committed to adhering to all applicable Data Protection Laws. The Data Protection Laws include: 

1. “PIPEDA” (the Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada outside Quebec; 
2. Quebec’s Act Respecting the Protection of Personal Information in the Private Sector, as amended by Law 25 (the “Quebec Private Sector Act”), which applies to our activities in Quebec;
3. The California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act which applies to our activities in the United States in certain circumstances; 
4. State privacy laws in the United States, including, but not limited to, those in force in California, Colorado, Connecticut and Virginia; and
5. Any other applicable data protection law. 

Under PIPEDA, Relion “collects, uses and discloses” your personal information. Under the Quebec Private Sector Act, Relion “collects, holds, uses or communicates to third persons” your personal information. Those phrases (or their variations) may be used interchangeably in this Policy. 

“Personal information” – this is information that we collect from you or about you and which is defined in PIPEDA as “information about an identifiable individual.” Under the Quebec Private Sector Act, it is defined as “any information which relates to a natural person and allows that person to be identified either directly or indirectly.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and/or numbers) that gets attached to you.

12989981 Canada Inc., d.b.a. Relion (“Relion”) is a Canadian corporation located in Montreal, Quebec, Canada at the address listed below. Where this Policy refers to “Relion”, it may refer to Relion and/or its affiliates, and their respective shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to Relion. In this Policy, any individual that has created an account to access the Platform shall be referred to as a “User” and any Website visitor, User or other individual for whom we hold personal information may be referred to as “you”.

Under PIPEDA, Relion is an “organization”; under the Quebec Private Sector Act, Relion is an “enterprise”; and under CCPA, Relion is a “business”.

If you want to ask us anything about what’s in this Policy, or anything else privacy- or data-related, or if you wish to exercise any of your available privacy rights, you can contact:

Relion Privacy Officer

Jesse White
[email protected]
Address: 2200 Stanley Street, Montréal Québec H3A 1R6, Canada
Phone Number: (343) 451-6949‬‬‬‬‬‬‬‬

You have the following rights regarding your personal information held by Relion, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting any prices or fees charged by Relion, if any, in connection with our Services. However, please note that exercising certain of these rights may affect your ability to use some or all of the Services.

• The right to withdraw your consent for Relion to use your personal information at any time;
• The right to have your personal information erased from Relion’s records;
• The right to have any hyperlink from Relion (or the Website or the Platform) that is attached to your name removed;
• The right to access your personal information and any relevant information around its collection, use, and disclosure; 
• The right to have a copy of your personal information given to you in an easy-to-read format so that you can transfer it to another organization;
• The right to have your personal information corrected or updated if you believe it is inaccurate or out of date;
• The right to opt out of marketing communications we send you, at any time;
• The right to know whether Relion sells or shares your personal information (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications; 
• The right to demand that Relion not sell your personal information. Please note that Relion does not sell your personal information;
• The right to restrict the use of your personal information if it is inaccurate or if our collection, use or disclosure of it is against the law; and 
• The right to refuse any marketing or advertising targeted at you by Relion. 

If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above or refer to the relevant sections further in this Policy. 

Please note that if you request erasure of your personal information, we shall do it to the extent feasible. However, Relion reserves the right to retain some of your personal information for a reasonable period of time in order to satisfy certain legal obligations or to satisfy its obligations under a legal procedure of any sort. 

Relion limits the amount of personal information we collect to only what is necessary and appropriate for the identified purposes. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.

In the table below, please find all the personal information we may collect from you directly, and what we use it for. Under PIPEDA and the Quebec Private Sector Act, the legal basis for our collection and use of this personal information is your informed consent and by submitting this personal information, you acknowledge having granted this consent to Relion. 

Sometimes we get personal information about you from third parties, or the third party collects it on our behalf and uses it. This table explains the details about this personal information – what it is, where it came from and what we or the third party does with it. Under PIPEDA and the Quebec Private Sector Act, the legal basis for our collection, use and disclosure of this personal information is your informed consent, and by submitting such personal information to third parties, you agree that you have granted such consent. None of this data comes from publicly available sources. 

To the extent that analytics identifiers are generated by or collected from third parties, these may be considered personal information collected from third parties, and you can find details about that further below in this Policy.

We do not collect any of what the Data Protection Laws consider sensitive personal information from you, unless you voluntarily submit it to us, which we encourage you not to do. 

We only share some of your personal information with the third parties identified in the table below in this section, along with what they do with it. Each type of third party identified below is under a contractual obligation not to (1) transfer or sell your personal information; or (2) use your personal information for any purpose, other than the purpose identified in the table below.

We will share personal information with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; or (2) we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person; or (3) we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Services infrastructure or the Services generally). 

We may also share personal information: (1) to joint ventures or other organizations under common control with Relion (in which case we will require such entities to honour this Policy); (2) if Relion merges with another entity, or is subject to a reorganization (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).

We will never share your personal information with other third parties, except under these circumstances or as otherwise permitted under applicable Data Protection Laws. We do not sell or rent your personal information to any third party for direct marketing purposes or any other purpose. 

Additionally, please note that all categories of personal information described in the table above are shared with our service providers that provide the technical infrastructure for the Website or the Platform, including our website hosting service provider WPEngine, Inc., and our platform content service provider, Amazon Web Services. These companies store the personal information and maintain its availability to you and to us, including for record-keeping purposes. These companies are equally under a contractual obligation not to (1) transfer or sell your personal information; or (2) use your personal information for any purpose, other than that identified in this paragraph.

Relion automatically collects certain information using the “Third-Party Analytics Programs” listed below to help us understand more about our Users and Website visitors, but none of this information identifies you personally, except via an alphanumeric string. For example, each time you visit the Website or the Platform, we automatically collect (as applicable) your IP address, browser and computer or device type, access times, the web page from which you came, the web page(s) or content you access, and other related information. We use information collected for the specific purposes detailed below, in order to better understand your needs and the needs of Users and Website visitors in the aggregate. 

We manage our own mailing list with the assistance of certain third-party email service providers (the “Email Service Providers”) to send out our newsletter, to schedule meetings and to email Users regarding the Services, their account and updates to the Platform. Personal information is transferred to the Email Service Providers in order for the emails to be sent out properly. The Email Service Providers do not use your personal information for any other purpose and will not transfer or sell your personal information to any other third party. 

You may unsubscribe from Relion’s mailing list at any time by following the link at the bottom of Relion emails. Other types of emails, such as emails related to the Platform and your account, will not have an opt-out option, as they are necessary for your use of the Services. 

Relion’s email practices are designed to be strictly compliant with anti-spam laws, including, but not limited to, the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23) and the American CAN-SPAM Act of 2003. If you believe you have received email in violation of these laws, please contact our Privacy Officer using the contact information further up in this Policy.

Relion is continuously evaluating and modifying our use of various advertising networks, which may change from time to time. In this section you will find the advertising network that Relion currently uses and instructions for opting out of advertising from such network. You may also opt out or decline such advertising by refusing or deleting the appropriate cookie, as described further in this Policy. We will always update this Policy if we use additional advertising networks.  

Generally, these ad networks work by delivering you advertisements that will be of particular interest to you when you use their websites, apps, or services, based on your browsing and activity history interacting with the Website and the Platform. Certain advertising networks use your email address that you submit to us to match your profile in order to better target the advertising to your preferences, called email retargeting. 

The table below identifies the advertising network that we currently use, as well as links and instructions on opting out. By visiting the Website or using our Services, you consent to our advertising to you in this manner, understanding that you can opt out any time, or refuse or delete the cookie (as described below), which will prevent such advertising.

We also use HubSpot for inbound marketing purposes in connection with the advertising networks detailed in the table above, which you can read about in more detail here. Note that the type of online advertising facilitated by inbound marketing will only apply to you if you accept all non-necessary cookies, as detailed in the next section.  

Relion uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website and the Platform. Cookies are small text files placed on your computer or device when you visit a website, in order to track the use of the site and to improve the user experience by storing certain data on your computer. By using the Services, you agree to their use, but only if you explicitly consent to such use, according to the cookie banner presented to you when you visit the Website or the Platform. By default, all non-necessary cookies are turned off when you first visit the Website or the Platform; you can use our cookie management tool to accept or decline other categories of cookies. 

Specifically, we use cookies and related technologies for the following functions:

• to facilitate online advertising, as described above in this Policy;
• to provide general internal and user analytics and to conduct research to improve the content of the Platform and the quality of the Services using the Third-Party Analytics Programs, as described above in this Policy; 
• for authentication purposes and to enable key functionalities of the Platform; 
• to enable your logging-in to the Platform; 
• to track information about emails you receive (for example, whether you opened an email or clicked on any links in it) and to track performance of our email campaigns; and
• to assist in identifying possible fraudulent activities.

Your browser or device can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s or device’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:

• Google Chrome
• Mozilla Firefox
• Microsoft Edge
• Opera
• Apple Safari
• iOS
• Android

Please note that deleting or blocking certain cookies may reduce your user experience on the Website or Platform. Furthermore, deleting certain cookies may prevent certain functions from working at all. 

We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal information which are necessary for each specific purpose are collected, used and disclosed by us. These procedures prevent your personal information from being lost or used or accessed in any unauthorised way. Examples of such procedures include restricted access to offices, training of personnel, using passwords and well-defined internal policies and information technology practices.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws require us to do so, and within the time frame required by the applicable Data Protection Law.

Relion uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal information) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Relion uses WP Engine and Amazon Web Services for hosting the Services and the Platform data, including personal information.

All information, including personal information, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for internet data transfer and transactions. You can use your browser to check Relion’s valid SSL security certificates on the Website and the Platform.

In addition to the measures to protect your personal information described in the previous section, we have drafted and implemented certain internal procedures and policies regarding personal information, including the following:

1. A framework for the keeping and destruction of personal information, including where we may keep anonymized data;
2. Defining and describing the roles and responsibilities of the members of Relion personnel throughout the life cycle of personal information; 
3. A process for dealing with individual complaints and requests for personal information and exercising of individuals’ rights under Data Protection Laws; and
4. A management and IT policy and procedure for addressing potential data breach incidents involving personal information in the custody of Relion. 

For our Quebec Website visitors and Users, we endeavour to keep your personal information in Quebec. However, it is possible that certain of our third-party service providers may be in other provinces or countries where your personal information could be transferred. When this happens, we do the following to safeguard your personal information:

1. We will perform what the Quebec Private Sector Act calls an “Assessment of the privacy-related factors” (what is generally called a “Privacy Impact Assessment,” or “PIA”) prior to the personal information leaving Quebec. If the PIA does not meet our standards and the standards required by the Quebec Private Sector Act, we will not transfer your personal information to such a service provider; and
2. If the PIA allows us to transfer the personal information to such a service provider outside Quebec, we will sign what is generally called a “Data Processing Agreement,” or DPA, or conclude other contractual provisions with the service provider, which protects the personal information transferred to them and limits their use of it to what we have contracted with them to do. The DPA or other contractual provisions will adhere to the requirements of the Quebec Private Sector Act. 

Furthermore, any time we are considering sending your personal information outside Quebec to a third party who is not a service provider, we will perform a PIA. If the PIA does not meet our standards and the standards required by the Quebec Private Sector Act, we will not transfer your personal information to such third party. 

If you are in Canada, outside of Quebec, and you are not satisfied with the response received or the actions taken by our Privacy Officer, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website. In Quebec, you can make a complaint to the Commission d’accès à l’information du Québec with information found on their website. 

Your personal information will only be kept for as long as is necessary for the purpose needed for that processing. For example, we will only retain your Account Information for as long as you remain a User. Once you delete your account, we will delete your personal information shortly thereafter.  

Notwithstanding the foregoing, we may have to keep your personal information for a longer period of time in order to satisfy our requirements under any applicable law. 

In some cases, where permitted by the Data Protection Laws, we may keep personal information that has been anonymized for our legitimate business purposes. 

Relion does not use any automated decision-making processes on its Website or on the Platform. 

We do not knowingly collect any personal information from a child under the age of 16. If we become aware that we have inadvertently received personal information from a person under the age of 16 through the Website or the Platform, we will delete such information from our records.

The date at the top of this page indicates when this Policy was last updated. Because Data Protection Laws are constantly evolving, every now and then we will have to update this Policy. You can always find the most updated version at this URL, and we will always post a notice on the Website and the Platform if we make significant changes to the Policy and use reasonable efforts to contact you if we have your contact information, for example, if you are a User.

Thanks for reading! Please keep your personal information safe; we promise to do the same. 

(© under license) – 12989981 Canada Inc., d.b.a. “Relion”.