Privacy and Personal Information Protection Policy
1. Context
The Act respecting the Protection of Personal Information in the Private Sector governs the collection, use and disclosure of personal information in a manner that recognizes the privacy rights of individuals in the province of Quebec.
As a group of companies offering car rental services, the Sauvageau Group is required to preserve the privileged and confidential nature of the information we receive when dealing with our customers and employees.
The Sauvageau Group member companies are the following:
– Location Sauvageau inc.
– Location Jean Légaré ltée
– Location Kiroule inc.
– 14057881 Canada inc.
To provide you with quality services, we require access to some information about you. We ensure that our employees handle this information with the necessary care and discretion, in compliance with the applicable legal and regulatory requirements.
The purpose of this Privacy and Confidentiality Policy is to ensure the protection of personal information and to govern the manner in which the Sauvageau Group collects, uses, communicates, holds and destroys such information or otherwise handles it. In addition, it is intended to inform all interested party of the manner in which the Sauvageau Group processes their personal information. It also addresses the processing of personal information collected by the Sauvageau Group through technological means.
By providing us with your personal information, you consent to its processing in accordance with this Policy.
2. Scope and definitions
This policy applies to the Sauvageau Group, which includes its officers, employees, consultants, partners, as well as anyone who otherwise provides services on behalf of the Sauvageau Group. It also applies to the Sauvageau Group website and all websites controlled and maintained by the Sauvageau Group.
It applies to all types of personal information handled by the Sauvageau Group, whether it be information relating to its potential or current customers, consultants, employees, members or any other person (such as visitors of its websites or others).
For the purposes of this Policy, personal information means any information which relates to a natural person and which allows that person to be identified, or which, individually or in combination with other information, allows that person to be identified. For example, this could be an individual’s name, address, email, phone number, gender, banking information, health information, ethnic origin, language, etc.
Sensitive personal information means information for which there is a high level of reasonable expectation of privacy, e.g. health information, banking information, biometric information, sexual orientation, ethnic origin, political views, religious or philosophical beliefs, etc.
Generally, a person’s professional or business contact details are not considered personal information, e.g. the name, title, address, email or telephone number of a person at their workplace. More specifically and for greater certainty, under the Act respecting the Protection of Personal Information in the Private Sector of Quebec, sections 3 (Collection, use and communication), 4 (Retention and destruction of personal information), and 6 (Data security) of this Policy do not apply to information about a person relating to the performance of duties within an enterprise, such as their name, title, duties, as well as their workplace address, email and telephone number.
3. Collection, use and communication
In the context of its business, the Sauvageau Group may collect various types of information for various purposes. The types of information collected by the Sauvageau Group, their use (or intended purpose) and the means by which the information is collected are set out in Schedule A attached hereto.
The Sauvageau Group will also inform the persons concerned, at the time of collecting such information, of any other information collected, the purposes for which such information is collected, and the means of collection, in addition to other information to be provided as required by law.
The Sauvageau Group adheres to the following general principles relating to the collection, use, and disclosure of personal information:
Consent :
• Generally, the Sauvageau Group collects personal information directly from the person concerned and with their consent unless an exception is provided by law. Consent may be obtained implicitly in certain situations, for instance, when the person elects to provide their personal information after being informed by this Policy of the use and disclosure for the purposes outlined herein (see Schedule A for more details). Thus, this Policy and the information it contains may be consulted by the person concerned at the time personal information is collected.
• The Sauvageau Group must also obtain the consent of the person concerned before collecting their personal information from third parties, communicating it to third parties, or using it for secondary purposes. However, the Sauvageau Group may act without consent in certain situations provided for by law and under the conditions it sets forth. The main situations in which the Sauvageau Group may act without consent are outlined in this Policy.
• By providing us with personal information through our website, by phone, by email, in person or by any other means, you consent to the collection, use and disclosure of your personal information in accordance with this Policy.
Collection :
• In all cases, the Sauvageau Group only collects information if it has a valid reason to do so. Collection will be limited to that which is necessary information to achieve the intended purpose for which it is collected.
• Please note that the services and programs of the Sauvageau Group are not intended for minors, and generally, the Sauvageau Group does not intentionally collect personal information concerning minors (in such cases, information cannot be collected from them without the consent of the person having parental authority or of the tutor, unless collecting this information is clearly for the minor’s benefit).
• Collection from third parties. The Sauvageau Group may collect personal information from third parties. Unless an exception is provided by law, the Sauvageau Group will seek the consent of the person concerned before collecting such person’s personal information from a third party. If such information is not collected directly from the person, but instead from another organization, the person concerned may request information on the source of such collected information from the Sauvageau Group.
In certain situations, the Sauvageau Group may also collect personal information from third parties, without the consent of the person concerned, if the Sauvageau Group has a serious and legitimate reason for doing so and if: (a) the information is collected in the interest of the person concerned and cannot be collected from such person in due time, or (b) this collection is necessary to ensure the accuracy of the information.
Retention and use :
• The Sauvageau Group ensures that the information it holds is up to date, complete, and accurate at the time it is used to make a decision in relation to the person it concerns. It is important that you let us know of any changes to your personal information so that we may update our records accordingly. Any such updates can be sent to the privacy officer.
• The Sauvageau Group may only use a person’s personal information for the purposes outlined herein or for any other purposes provided at the time of collection. If the Sauvageau Group wishes to use this information for another purpose, a new consent must be obtained from the person concerned, which will need to be expressly obtained if it concerns sensitive personal information. However, in certain cases provided by law, the Sauvageau Group may use the information for other purposes without the consent of the person concerned, e.g:
• when it is used for purposes consistent with the purposes for which it was collected;
• when it is clearly used for the benefit of such person;
• when necessary for the purpose of preventing or detecting fraud or of assessing and improving protection and security measures;
• when its use is necessary for the purpose of providing or delivering a product or providing a service requested by the person concerned; or
• when its use is necessary for study, research or statistical production purposes and it is depersonalized;.
• Limited access The Sauvageau Group has implemented measures to limit access to personal information only to those employees and persons within its organization who are authorized to access such information and who need it for the performance of their duties. The Sauvageau Group will request consent from the person concerned before granting access to any other person.
Communication :
• Generally, and unless an exception is outlined in this Policy or otherwise provided by law, the Sauvageau Group will obtain consent from the person concerned before communicating such person’s information to third parties. In addition, when consent is required and concerns sensitive information, the Sauvageau Group will be required to obtain express consent before it is communicated.
• Thus, personal information may be communicated to third parties without the consent of the person concerned in certain situations, including, without limitation, the following:
• The Sauvageau Group may communicate personal information to a public body (such as the government) which, through a representative, collects such information in the exercise of its functions or the implementation of a program under its management.
• Personal information may be provided to its service providers to whom it is necessary to communicate the information, and this, without the person’s consent. Service providers include insurers, subcontractors, or IT and cloud service providers of the Sauvageau Group. In such cases, the Sauvageau Group is required to have written contracts in place with such service providers specifying the measures they must take to protect the confidentiality of the personal information communicated, that the information is to be used only as part of the contract’s performance, and that they may not retain this information following the contract’s expiration. In addition, these contracts need to provide that such service providers must notify the privacy officer of the Sauvageau Group (identified in this Policy) of any violation or attempted violation of any obligation concerning the confidentiality of the information communicated and must allow this person to conduct any verification relating to confidentiality requirements.
• If necessary for the purposes of concluding a commercial transaction and subject to the conditions provided by law, the Sauvageau Group may also communicate personal information, without the consent of the person concerned, to the other party to such transaction.
• Communication outside Quebec: It is possible that personal information held by the Sauvageau Group will be communicated to partners or third parties located outside Quebec and be subject to the laws of such jurisdiction, for instance, when the Sauvageau Group uses cloud service providers whose server(s) are located outside Quebec or when the Sauvageau Group deals with subcontractors located outside of the province.
• Should we be required to disclose personal information to third parties under this Policy, including to consultants, service providers or others, we will take reasonable steps to ensure compliance with this Policy, whether such third parties are located within Canada or abroad.
• Our privacy policies and practices require that a written agreement be entered into with such service provider to comply with this Policy and its obligations to maintain the confidentiality and security of the personal information entrusted to it.
Additional information on the technologies used:
• For the purposes of our business, we operate a website. The personal information we collect on our websites is collected, among other things, to respond to your request, for instance, when you provide your name, email address, and address in the form provided for this purpose in the “Contact Us” section of the website.
• Use of cookies: Cookies are small data files sent to a visitor’s computer by their web browser when they visit a website. They can serve several purposes. Cookies allow websites to store certain information about you to facilitate your access to and browsing within our websites. Cookies can only be read by the website transmitting them to your computer.
• Websites controlled by the Sauvageau Group use cookies, in particular:
• To remember visitors’ settings and preferences, like language selection, and to enable tracking of a visitor’s current session.
• For statistical purposes to understand the behaviour of visitors, the content viewed, and to enable website improvement.
• Websites controlled by the Sauvageau Group use the following types of cookies:
• Session cookies: These are temporary cookies held in memory for the duration of the website visit only.
• Persistent cookies: These are held on the computer until they expire and are retrieved the next time the website is visited.
• Some cookies may be disabled by default, and visitors may choose whether to enable these functions when visiting the websites of the Sauvageau Group. However, if you choose to reject cookies, some pages or sections of our website may not be properly displayed, or some features may not be available.
• The use of cookies may also be activated or deactivated by changing preferences within the used browser’s settings.
• Please note that the use of cookies is limited to your identification as a user and does not identify you by name or address.
• It should be noted that this Policy does not apply to third-party websites which may be accessed through links displayed on our website. We are not responsible for third-party websites, their content or their access. As a result, any personal information you transmit through these websites is subject to the privacy policies of those websites. It is your responsibility to review such policies to ensure that your personal information is protected.
• Other technological means used: The Sauvageau Group also collects personal information through other technological means, such as web forms integrated within a website under the control of the Sauvageau Group (e.g. its contact form, membership form, newsletter and seminar registration form), online surveys on its platforms and applications, as well as other platforms and form tools (e.g. Microsoft Forms). If the Sauvageau Group collects personal information through a technological product or service which includes privacy settings, the Sauvageau Group will ensure that these settings provide the highest level of privacy by default (cookies excluded).
4. Retention and destruction of personal information
Unless applicable laws or regulations require a minimum retention period, the Sauvageau Group will only retain personal information for as long as necessary to achieve the purposes for which it was collected and to comply with our legal and regulatory obligations.
At the end of the retention period or when the personal information is no longer needed, the Sauvageau Group will ensure that it is destroyed. Destruction of personal information will be carried out by the Sauvageau Group in a secure manner to ensure its protection.
This section may be supplemented by any policy or procedure adopted by the Sauvageau Group relating to the retention and destruction of personal information, as applicable. For more information, please contact the privacy officer of the Sauvageau Group (identified in this Policy).
5. Responsibilities of the Sauvageau Group
As per applicable laws, the Sauvageau Group is responsible for protecting the personal information in its possession or control.
To protect collected personal information, the Sauvageau Group has designated a privacy officer. They are responsible for ensuring compliance with applicable legislation concerning the protection of personal information. The privacy officer must approve the governance policies and practices relating to the protection of personal information. More specifically, this person is responsible for implementing this Policy and ensuring that it is known, understood and applied. In the event of such the privacy officer’s absence or inability to act, the president of the Sauvageau Group will assume the duties of the privacy officer.
The employees and partners of the Sauvageau Group who have access to personal information or are otherwise involved in its management must ensure its protection and comply with this Policy, as well as all implemented guidelines.
The roles and responsibilities of the employees of the Sauvageau Group throughout the life cycle of personal information may be further defined by any other relevant policy of the Sauvageau Group, as applicable.
To protect your personal information, the Sauvageau Group has implemented various policies, practices and procedures relating to the management of personal information we hold. These internal policies and procedures govern the collection, use, communication, retention and destruction of personal information, as well as the handling of complaints and information security. They also establish a framework for conducting privacy impact assessments, as well as preventing and dealing with potential privacy incidents.
The Sauvageau Group also ensures that its staff undergo the necessary training and awareness activities required to ensure the protection of personal information.
7. Privacy Impact Assessment (PIA)
A PIA is a preventive measure aimed at improving the protection of personal information and preserving the privacy of natural persons. This exercise involves the consideration of various factors likely to have a positive or negative impact on the privacy of the persons concerned. The performance of a PIA serves to evidence that the Sauvageau Group has complied with all of its obligations and that all measures have been taken to protect this information in an efficient manner.
The Sauvageau Group conducts PIAs in the following situations:
• Before undertaking a project to acquire, develop or overhaul an information system or electronic service delivery system involving personal information; and
• Before communicating personal information outside Quebec.
As part of the performance of a PIA, the Sauvageau Group considers, in particular, the sensitivity of the information, the purposes for which it is to be used, its quantity, distribution and storage medium, as well as the measures proposed to protect such personal information.
8. Data Security
Given the confidential nature of the information it holds, the Sauvageau Group takes reasonable security measures necessary to ensure the protection of personal information collected, used, communicated, stored or destroyed, in accordance with applicable legislation. The security measures in place reflect the purpose, quantity, distribution, storage medium and sensitivity of the information. Thus, this implies that information that can be qualified as sensitive (see definition in section 2 above) will require more stringent security measures and require a higher level of protection. The Sauvageau Group has taken the necessary administrative, technical and physical measures to limit the risk of incidents. In particular, and in line with the above statement relating to the limited access to personal information, the Sauvageau Group must put in place the necessary measures to limit access to its information systems so that only employees who need access to the personal information be allowed to access it.
9. Privacy incidents
Any privacy incident involving personal information held by the Sauvageau Group must be handled.
In accordance with the Act, the Sauvageau Group must maintain a register of privacy incidents.
If the incident presents a risk of serious injury for the persons concerned, the Sauvageau Group will promptly notify them as well as the Commission d’accès à l’information.
10. Rights of access, rectification and consent withdrawal
Subject to applicable laws and regulations, a person wishing to exercise their rights of access, rectification or withdrawal of consent, must submit a written request to the privacy officer of the Sauvageau Group, at the email address provided in section 12 below.
Subject to certain legal restrictions, persons concerned may require access to and rectification of their personal information held by the Sauvageau Group if it is inaccurate, incomplete or equivocal. They may also require the termination of the dissemination of personal information concerning them or that any hyperlink attached to their name allowing access to this information by technological means be deindexed, when the dissemination of this information violates the law or a court order. They may do the same, or require that the hyperlink allowing access to this information be reindexed, when certain conditions provided for by law are met.
The privacy officer of the Sauvageau Group must reply in writing to such requests within 30 days of their receipt. Any refusal must be substantiated and include the law provision on which it is founded. The privacy officer must assist the applicant in understanding the refusal if necessary.
Subject to applicable legal and contractual restrictions, persons concerned may withdraw their consent to the communication or use of the information collected.
They may also ask the Sauvageau Group what personal information is collected from them, the categories of people within the Sauvageau Group who have access to it and how long it will be kept.
11. Complaint handling process
Receipt
Any person wishing to make a complaint concerning the application of this Policy or, more generally, the protection of their personal information by the Sauvageau Group, must do so in writing to the privacy officer of the Sauvageau Group, at the email provided in section 12 below.
The complainant will be required to provide their name, contact information, including a telephone number, as well as the nature and reasons of their complaint, in sufficient detail to allow the complaint to be assessed by the Sauvageau Group. If the complaint is not sufficiently precise, the privacy officer may request any additional information they deem necessary to assess the complaint.
Processing
The Sauvageau Group undertakes to handle all complaints in a confidential manner.
Within 30 days following receipt of the complaint or following receipt of all additional information deemed necessary and required by the privacy officer of the Sauvageau Group for its processing, the latter must assess it and provide a substantiated written response by email to the complainant. The purpose of this assessment will be to determine whether the handling of personal information by the Sauvageau Group complies with this Policy, any other policies and practices in place within the organization and applicable laws or regulations.
If the complaint cannot be processed within this period, the complainant must be informed of the grounds justifying the extension, the progress of the processing of the complaint and the timeframe reasonably necessary to provide a definitive response.
The Sauvageau Group must keep a separate file for each complaint it receives. Each file will contain the complaint, the analysis and documentation supporting its assessment, as well as the response sent to the complainant.
The complainant may also possible file a complaint with the Commission d’accès à l’information du Québec or any other privacy supervisory body responsible for the application of the applicable law.
However, the Sauvageau Group encourages all interested persons to first contact its privacy officer and wait for the completion of the handling process by the Sauvageau Group.
12. Approval
The Policy is approved by the privacy officers of the Sauvageau Group, whose contact details are as follows:
Privacy officers:
| Company | Privacy officer | |
|---|---|---|
| Location Sauvageau inc. | Jean Raphaël Higgins Gosselin | jeanraphael.higginsgosselin@sauvageau.qc.ca |
| Location Jean Légaré Ltée | Mehdi Harriz | mharriz@locationlegare.com |
| Location Kiroule inc. | Jacques Champagne | j.champagne@locationkiroule.com |
| 14057881 Canada inc. | Jean Raphaël Higgins Gosselin | jeanraphael.higginsgosselin@sauvageau.qc.ca |
For any request, question or comment related to this policy, please contact the privacy officer by email.
13. Sanctions
All staff members of the Sauvageau Group are required to comply with this Policy as well as any other document, guideline, procedure or policy deriving from this Policy. Staff members failing to comply with this policy will be subject to disciplinary measures up to and including dismissal. Consultants, suppliers and business partners who fail to comply with this Policy are subject to contractual measures and penalties up to and including contract termination. Additional training and awareness activities may also be provided, as applicable.
14. Publishing and Amendment
This Policy is published on the website of the Sauvageau Group, as well as on all other websites controlled and kept by the Sauvageau Group, to which this Policy applies, and this with respect to any personal information collected. This Policy is also disseminated by any appropriate means to reach the persons concerned.
The Sauvageau Group must also do the same for any amendment to this Policy, which will also be required to be subject to a notice informing the persons concerned. The Sauvageau Group reserves the right to amend or supplement this Policy at any time, including, without limitation, to comply with new requirements or for updating purposes.
*Note: Please note that the use of the masculine gender is intended to lighten this policy and make it easier to read.
Tableau des versions et des changements :
| Version | En vigueur le | Changements depuis la dernière version |
|---|---|---|
| 1.0 | October 21, 2024 | N.A. – First version |
| 2.0 |
Schedule A
The following consists in a non-exhaustive list of the types of information which may be collected by the Sauvageau Group, their use, or intended purpose, and the means by which the information is collected. This includes, without limitation, the following.
Please note that most of the personal information managed by the Sauvageau Group concerns customers, employees or job applicants. As it relates to other categories of persons set out in the table below, the information provided is, in most cases, of a professional or business nature (see section 2 regarding employees). It should be noted that in most cases, the Sauvageau Group also collects the professional title/duties of persons, the organization’s name and/or address (see section 2 regarding employees).
| Relationship with the Sauvageau Group | Type of personal information | End of collection/uses | Means of collection |
| Clients | a. Full name, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person |
| b. Personal address, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| c. Phone number, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| d. Email, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| e. Driver’s license information, including photos you have provided or images for verification purposes, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| f. Insurance information, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| g. Vehicle rental information, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| h. Location of rental and return, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| i. Rental dates, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| j. Rental type and vehicle preference, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| k. Purchased auxiliary products, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| l. Billing information, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| m. Fees, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| n. Payments, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| o. Credit card information, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| p. Information relating to accidents involving vehicles belonging to the Sauvageau Group, including third parties such as persons involved, witnesses and police reports, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| q. Information about a health problem for which the Sauvageau Group can provide driver assistance devices or which are related to injury claims, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| r. Contact details for emergency contacts, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| s. Any preferences or special requirements the undersigned may have, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| t. Personal information communicated for the purposes of developing and maintaining a business relationship or shared voluntarily by individuals, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| u. Where applicable, closed-circuit television video recordings and photographs of you in public areas of our rental locations, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| v. Fuel Data: The Sauvageau Group uses this information to facilitate the recording and billing of fuel costs, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| w. Odometer data: The Sauvageau Group uses this information to facilitate the billing of mileage expenses (if applicable) and to help it manage its fleet of vehicles, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| x. Vehicle performance and diagnostic data: The Sauvageau Group uses this information to help it define vehicle maintenance needs and manage its vehicle fleet, | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| y. Vehicle location data | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| z. Any other information necessary for the purposes of complying with our legal, regulatory or contractual obligations. | Vehicle rental agreement and compliance with our legal, regulatory or contractual obligations | Form on the website, by phone or in person | |
| Relationship with the Sauvageau Group | Type of personal information | End of collection/uses | Means of collection |
| Employees | a. Full name, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person |
| b. Personal address, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| c. Phone number, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| d. Email address, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| e. Driver’s license information, including photos you have provided or images for verification purposes, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| f. Social insurance number, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| g. Date of birth, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| h. Compensation data, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| i. Information on education and professional experience as well as curriculum vitae, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| j. Criminal record information, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| k. Credit file information, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| l. Banking information for payroll, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| n. Any special preferences or requirements the undersigned may have, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| o. Personal information communicated for the purposes of developing and maintaining a business relationship or shared voluntarily by individuals, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| p. Where applicable, closed-circuit television video recordings and photographs of you in public areas of our rental locations, | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person | |
| q. Any other information necessary for the purposes of complying with our legal, regulatory or contractual obligations. | Employee records and compliance with our legal, regulatory or contractual obligations | By email, by phone or in person |