Introduction
This Privacy Policy (the “Policy”) describes the practices of Roulez Électrique Inc. (“Roulez Électrique” or “we”) regarding the collection, use, disclosure, retention, and protection of personal information in connection with the Application and the Program.
Capitalized words and expressions that are not otherwise defined in this Policy have the meaning assigned to them in the Club Roulez Électrique Program Participation Agreement (the “Agreement”).
This Policy applies when you interact with Roulez Électrique, including when you visit or use our website or the Application, create or use your Club Roulez Électrique Account, register or connect an Eligible Charging Station, participate in the Program, complete a form, contact our support team, or provide us with information or documents. Certain activities or specific relationships may be governed by separate notices, consents, or policies that will be provided to you when applicable.
By accepting this Policy or by providing us with personal information after having had the opportunity to review it, you consent to the collection, use, disclosure, and retention of your personal information in accordance with this Policy, subject to the choices available to you, the consents you provide, and the requirements of applicable laws.
Plain-Language Summary
This section summarizes the main elements of the Policy. It does not replace the detailed provisions below.
- We collect only the personal information that is reasonably necessary to create and manage your Club Roulez Électrique Account, administer your participation in the Program, connect an Eligible Charging Station, receive and process Charging Data, award Roulez Électrique Points, and, where the applicable conditions are met, enable the creation, verification, transfer, or monetization of Carbon Credits.
- We use your personal information only for the purposes set out in this Policy, including to administer the Program, ensure its proper operation, prevent Double Counting, meet our legal and regulatory obligations, protect Participants, and improve our services.
- We disclose your personal information only to authorized Program Partners when reasonably necessary for the operation of the Program, the operation of the Application, verifications, audits, payments, or the creation, verification, transfer, or monetization of Carbon Credits, or when permitted or required by law.
- We apply appropriate security measures to protect your personal information against loss, unauthorized use, unauthorized access, disclosure, alteration, or destruction.
- You remain in control of your personal information. Subject to applicable laws, you may request access to your personal information, correction of your information, withdrawal of certain consents, and the exercise of the other rights described in this Policy.
- Withdrawing certain consents or deleting certain information may, however, limit or make it impossible for you to participate in the Program when that information is necessary for its operation or for compliance with our legal or regulatory obligations.
- Decisions regarding ineligibility or suspension may rely on automated processing, but you may request an explanation and human review where required by law.
1. Our Commitments
The protection of personal information is an important value for Roulez Électrique. We are committed to:
- collecting only the personal information reasonably necessary for the operation of the Application and the Program;
- using this information only for the purposes described in this Policy or as otherwise authorized or required by law;
- limiting access to personal information to individuals who reasonably need it in the performance of their duties;
- disclosing personal information only to authorized Program Partners or other persons when necessary, authorized, or required by law;
- implementing security measures appropriate to the sensitivity of the personal information;
- retaining personal information only for the period necessary for the intended purposes or as required by law;
- allowing Participants to exercise the rights granted to them under applicable laws.
2. Person Responsible for the Protection of Personal Information
You may contact our person responsible for the protection of personal information:
By email: [email protected].
By mail:
Roulez Électrique
519 rue des Volontaires, Trois-Rivières, Québec G9A 2E7
Attention: Person Responsible for the Protection of Personal Information.
Role. The responsible person receives requests for access, correction, withdrawal of consent, complaints, privacy questions, and reports of potential incidents.
3. Personal Information We Collect
Depending on your participation in the Program, the features of the Application you use, and how your Eligible Charging Station is connected, we may collect the following categories of personal information.
| Category | Examples | Primary purposes |
|---|---|---|
| Application and security | IP address, device, logs, events, cookies, preferences, errors. | Security, fraud prevention, improvement, statistics, support. |
| Authorization | Proof of ownership, lease, mandate, invoice, charging station photo, proof of installation or authorization. | Confirm the right to register the charging station and share the data. |
| Charging station and site | Make, model, serial number, identifiers, service address, territory, connection status. | Verify eligibility, prevent duplicate registration, determine calculation factors. |
| Account | Name, email, telephone, address, language, preferences, login credentials. | Create and manage the account, communicate with you, provide support. |
| Consents and evidence | Accepted versions of the Agreement, Policy and Terms, date and time of acceptance, IP address, session identifiers, expressed choices. | Document consents, demonstrate formation of the Agreement, administer granted authorizations, respond to a dispute or audit. |
| Payment and tax information | Payment method, payment identifier, billing address, required tax information. | Pay rewards, maintain records, comply with tax obligations. |
| Charging | kWh, date, time, duration, power, status, errors, diagnostics, session history. | Calculate rewards, aggregate credits, conduct audits, produce reports. |
| Support | Messages, attachments, service notes, request records. | Answer questions, resolve issues, document decisions. |
4. Sources of Personal Information
- You, when you create an account, register a charging station, provide supporting documentation, or contact support.
When you authorize the connection of a charging station or an account with a manufacturer, the information is transmitted in accordance with the authorizations you grant to the manufacturer concerned. Roulez Électrique receives only the information necessary for the operation of the Program.
- Roulez Électrique, authorized Program Partners, installers, brokers, aggregators, auditors, verifiers, registries, or data providers, when necessary for the Program.
- Other reward or credit systems, solely to verify eligibility, duplicate registration, or competing claims.
- Technical and payment service providers, for security, payments, and administration.
5. Purposes of Collection, Use, and Disclosure
We collect, use, and disclose personal information only for purposes necessary to administer the Program, operate the Application, comply with our legal and regulatory obligations, and for the other purposes described below.
Administration:
- create and manage your Club Roulez Électrique Account;
- administer your participation in the Program;
- provide the Application;
- make payments or provide compensation resulting from the conversion of Points.
Operations:
- connect an Eligible Charging Station;
- receive, process, and retain Charging Data;
- ensure the proper operation of the Application.
Program:
- verify your eligibility;
- award Roulez Électrique Points;
- enable the creation, verification, transfer, or monetization of Carbon Credits;
- make payments or provide compensation.
Integrity:
- prevent fraud;
- prevent Double Counting;
- detect anomalies;
- prevent errors, abuse, and incidents;
- conduct verifications and audits.
Support:
- respond to your requests;
- provide support and improve the Application;
- send administrative communications;
- send promotional communications, with your consent where required.
Compliance:
- comply with our legal obligations;
- protect our rights;
- resolve disputes.
6. Consent
Separate consent. Where required, we request your consent separately, clearly, and specifically, including for connecting the charging station, sharing data with authorized Program Partners, verifying registration with third parties, and using data for credits.
Withdrawal. You may withdraw your consent for the future by contacting us or through available settings. Withdrawal may make participation in the Program, calculation of rewards, or creation of credits impossible.
Limits on withdrawal. Withdrawal does not prevent the retention or limited use of information where necessary to comply with the law, complete audits, correct payments, defend rights, prevent fraud, or manage credits already declared.
7. Disclosure of Personal Information
| Recipients | Information and purposes |
|---|---|
| Roulez Électrique and authorized Program Partners | Program administration, support, reward calculation, credit coordination, customer communications. |
| Charging station manufacturers, platforms, and operators | API connection, serial number validation, reading charging sessions, diagnostics, charging station status. |
| Brokers, aggregators, buyers, auditors, verifiers, registries, and authorities | Creation, validation, audit, transfer, sale, or declaration of credits and environmental attributes. |
| Other reward or credit programs | Limited verification of duplicate registration, participation period, registration status, or competing claims. |
| Cloud, analytics, security, and support providers | Hosting, processing, monitoring, logging, improvement, customer service. |
| Payment and tax service providers | Payments, fraud prevention, tax compliance, and accounting records. |
| Professional advisors, insurers, authorities, or courts | Advice, protection of rights, legal compliance, investigations, litigation, or reporting obligations. |
| Business transaction | Sale, merger, financing, reorganization, or transfer of assets, with appropriate safeguards. |
8. Transfers Outside Québec
Processing. Certain service providers or authorized Program Partners may process personal information outside Québec when necessary for the operation of the Program or the Application.
Before disclosing personal information outside Québec, we take the measures required by applicable laws to ensure that it receives adequate protection.
When Charging Data is obtained through an API, it is collected from the servers of the manufacturer of the Eligible Charging Station, which may be located in countries or territories selected by that manufacturer. As part of this collection, Roulez Électrique accesses the data made available by the manufacturer in accordance with the applicable authorizations, but does not disclose personal information to the manufacturer’s servers solely as a result of this API-based collection.
Transparency. The primary processing territories are Québec and Canada.
9. Security Measures
We apply administrative, technical, and physical measures appropriate to the sensitivity of personal information in order to protect it against loss, theft, unauthorized access, use, disclosure, alteration, or destruction.
10. Retention and Destruction
We retain personal information only for the period necessary for the purposes described in this Policy or to comply with applicable legal, regulatory, contractual, or operational requirements.
When that period ends, personal information is destroyed or anonymized in accordance with applicable laws and our internal practices.
11. Decisions Based Exclusively on Automated Processing
We may use automated processing to support certain Program activities, including verifying the eligibility of certain Charging Data, detecting anomalies, preventing Double Counting, or calculating Roulez Électrique Points.
Where a decision based exclusively on automated processing has an effect on you in circumstances provided for by law, you will be informed and may exercise the rights granted to you under applicable laws.
12. Your Rights
You may request, among other things:
- access to your personal information;
- correction of inaccurate, incomplete, or ambiguous information;
- withdrawal of consent;
- portability where provided by law;
- information regarding a decision based exclusively on automated processing;
- or file a complaint with the competent authority if you are dissatisfied with our response.
To exercise any of these rights, please contact the person responsible for the protection of personal information.
13. Minors
The Program is intended for persons who have the legal capacity to enter into the Agreement. If we learn that we have collected personal information about a person who does not have such capacity without the authorization required by law, we will take reasonable steps to delete that information or otherwise regularize the situation.
14. Cookies and Similar Technologies
Cookies. The Application and website may use cookies, device identifiers, and similar technologies for authentication, security, preferences, performance analysis, and improvement.
Marketing. We will use your contact information for marketing communications only in accordance with the choices, consents, or exceptions permitted by law. You may unsubscribe from marketing communications; administrative communications related to the Program may continue.
15. Changes to the Policy
We may amend this Policy to reflect changes in our practices, the Program, the Application, or legal requirements.
The effective date of the applicable version appears at the beginning of the Policy.
Where required by applicable laws, we will notify you of material changes before they take effect.