Privacy Policy

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 1.0   INTRODUCTION

The Guelph Hydro Inc. group of companies, which are comprised of Guelph Hydro Inc., Guelph Hydro Electric Systems Inc., and Envida Community Energy Inc. (collectively, "Guelph Hydro Group", "Us", "Our" or "We") is concerned about privacy matters and wants you to be familiar with how We collect, use and disclose your personal information. As used in this privacy policy (the "Privacy Policy"), "personal information" means any information about an identifiable individual.

This Privacy Policy explains Our commitment to and recognition of Our obligation to meet the spirit and terms of applicable privacy laws and regulations including, but not limited to, the Personal Information Protection and Electronic Documents Act (Canada) and the Municipal Freedom of Information and Protection of Privacy Act (Ontario). Further, this Privacy Policy explains Our information practices and the choices you can make about the collection and use of your personal information.

This Privacy Policy is incorporated into and forms part of the terms of use of any website operated or provided by Guelph Hydro Group (collectively, "GHG Websites" and each is a "GHG Website")  

By accepting service from Us, using a GHG Website, or otherwise providing Us with your personal information, you are accepting the practices described in this Privacy Policy, as they may be amended by Us from time to time. The terms in this Privacy Policy may be changed from time to time so you should review it for changes periodically on the main GHG Website at www.guelphhydroinc.com  

2.0  WE ARE ACCOUNTABLE TO YOU

Guelph Hydro Group is responsible for all personal information within its possession or control, including any personal information that is transferred to third parties for legal, regulatory, processing, storage or other purposes. We have employees who are accountable for compliance with these privacy and security principles. Our privacy officer is responsible for Our compliance and commitment to this Privacy Policy. We require a comparable level of protection from Our third party relations.

3.0  WE LET YOU KNOW WHY WE COLLECT AND USE YOUR PERSONAL INFORMATION

Guelph Hydro Group identifies the purpose for which your personal information is collected and will be used or disclosed. If that purpose is not listed below, We will do this before or at the time the information is actually being collected. All personal information collected by Us from customers and other individuals (as applicable) is collected, at a minimum, for the following purposes:

• to identify or contact customers, respond to customer inquiries and otherwise maintain business relations with customers;
• to deliver and maintain electricity services;
• to bill and collect payment;
• to establish credit worthiness;
• to establish and administer for pre-authorized, equal billing or other payment plans;
• to administer and manage Our business operations;
• for legal, regulatory and electricity market operation requirements;
• to help prevent or investigate fraud, theft of power or other breaches of the law;
• to provide customers with information about Our services, the electricity industry, rates and energy conservation;
• to request customer participation in surveys or contests;
• to notify customers about events, causes or programs sponsored by Guelph Hydro Group;
• to perform statistical analyses of user behaviour and characteristics, in order to measure interest in and use of the various sections of a GHG Website so as to improve design, navigation and experience of such GHG Website; and
• to prepare Our financial records.

We may monitor and/or record any telephone conversation with you for quality assurance and training purposes.

4.0   WE WILL OBTAIN YOUR CONSENT TO COLLECT, USE AND/OR DISCLOSE YOUR PERSONAL INFORMATION

Guelph Hydro Group will obtain your consent before, or when, it collects, uses and/or discloses your personal information. Guelph Hydro Group 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 law or regulatory authorities. Your consent to the collection, use and/or disclosure of your personal information may be either express or implied, depending on the circumstances, the purposes for which such personal information is being collected and the sensitivity of the information. 

Consent may be given by an authorized representative such as a legal guardian or person with power of attorney. Consent may also be obtained directly from you or from a third party that has obtained your consent to disclose your personal information to Guelph Hydro Group. For example, if you sign a separate contract with a third party for hydro services (a "retail provider"), Guelph Hydro Group may obtain your personal information from such retail provider and Guelph Hydro Group may provide your billing and consumption information to them.

By accepting service from Us, using the GHG Website, or otherwise providing Us with your personal information, you will be deemed to consent to Our use of your personal information for the purposes outlined above. Otherwise, Guelph Hydro Group will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your personal information. You can change your consent preferences at any time by contacting Guelph Hydro Group (please refer to the "How to contact Us" section below), where Our employees can help direct your call to the appropriate department within Guelph Hydro Group.

5.0  WE LIMIT COLLECTION OF YOUR PERSONAL INFORMATION

Guelph Hydro Group collects only the information required to provide Our services to you. Guelph Hydro Group will collect personal information only by clear, fair and lawful means. We will not, as a condition of supplying you with a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the specified, legitimate purpose.

The types of personal information that Guelph Hydro Group usually collects from individual customers include: Customer name and address (mailing and service address) and other contact information; facts about historic and current consumption of power for your home or business; customer transactions with Guelph Hydro Group (i.e. account number, account balances, payment history, and account activity); general financial information (i.e. credit card number, credit and reference information); identifying information (e.x. date of birth, driver's license number, passport number, and/or social insurance number); medical information to be used in case of planned power outages; financial institution information requested for pre-authorized payments; and information We receive from you through your correspondence or communications with Us. Depending on the circumstances, We may collect some or all of the foregoing personal information listed above from you.

6.0  WE LIMIT DISCLOSURE, USE AND/OR RETENTION OF YOUR PERSONAL INFORMATION

Because of the structure of the electricity sector in Ontario, it may be necessary to share your billing and consumption information with third party billing and settlement agencies, such as where you have signed a separate contract with a retail provider. Your personal and other information may also be shared or disclosed to other agencies or organizations as required or permitted by law or regulatory authorities. Our billing, settlement and regulatory relationships with third parties are governed by Our license and regulatory codes that are established by the Ontario Energy Board. Under certain exceptional circumstances, We may have a legal duty or right to disclose personal information without your knowledge or consent.

Under certain exceptional circumstances, Guelph Hydro Group may have a legal duty or right to collect, use or disclose your personal information without your knowledge or consent. In accordance with applicable laws, each of the Guelph Hydro Group entities will not disclose any consumer information (which may include personal information) to any of its respective affiliates without your written consent except where consumer information is required to be disclosed: (i) for billing or market operation purposes; (ii) for law enforcement purposes; or (iii) for the purpose of complying with a legal requirement.

Guelph Hydro Group does not disclose personal information to any organization or person for any reason except as set out in this Privacy Policy and for the following purposes: (i) We may use service providers located outside of Ontario, and, if applicable, your personal information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those jurisdictions; (ii) in the unlikely event of a proposed sale of Guelph Hydro Group's business or assets (or a part thereof), or a merger or amalgamation of Guelph Hydro Group with another company, We may disclose your personal information to third parties such as prospective purchasers of Guelph Hydro Group's shares, business or assets, and to their lawyers, accountants, financial advisors, agents and other representatives as necessary for the purposes of such transaction and upon completion of such a transaction, your information will be one of the transferred assets; and/or (iii) where We otherwise have your explicit consent.

You are deemed to consent to disclosure of your personal information for those purposes. If your personal information is shared with third parties, those third parties are bound by appropriate agreements with Guelph Hydro Group to secure and protect the confidentiality of your personal information.

Guelph Hydro Group will retain your personal information only for so long as is necessary to fulfill the purpose for which it was collected and to meet Our legal and contractual obligations. We will employ explicit retention periods for closed accounts, after which the personal information is destroyed or made anonymous.

7.0  WE KEEP YOUR PERSONAL INFORMATION UP TO DATE AND ACCURATE

In order to ensure the reliable delivery of hydro service and the correct billing for such service, all personal information will be kept accurate, complete and up to date.

You may request access to the personal information We have on record in order to review and amend the information, as appropriate. To access your personal information, refer to the "How to contact Us" section below.

8.0  THE SECURITY OF YOUR PERSONAL INFORMATION IS A PRIORITY FOR GUELPH HYDRO GROUP

We take steps to safeguard your personal information, regardless of the format in which it is held, including, but not limited to: (i) physical security measures such as restricted access facilities and locked filing cabinets; (ii) electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers; (iii) organizational processes such as limiting access to your personal information to a selected group of individuals; and (iv) contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information.

It is important for you to protect against unauthorized access to your password and your computer. Be sure to sign off when you have finished using any shared computer.

9.0  WE ARE OPEN ABOUT OUR PRIVACY AND SECURITY POLICY

We are committed to providing you with understandable and easily available information about Our policy and practices related to management of your personal information. This policy and any related information is available at all times on the GHG Websites or on request. To contact Us, refer to the "How to contact Us" section below.

10.0   WE PROVIDE ACCESS TO YOUR PERSONAL INFORMATION STORED BY GUELPH HYDRO GROUP

You can request access to your personal information stored by each of the Guelph Hydro Group entities. To contact Us, refer to the "How to contact Us" section below. Upon receiving such a request, the applicable Guelph Hydro Group entity will: (i) obtain satisfactory proof to confirm your identity; (ii) inform you about what type of personal information it has on record or in its control, how such information is used and to whom the information may have been disclosed; (iii) provide you with access to your information so you can review and verify the accuracy and completeness and request changes to the information; and (iv) make any necessary updates to your personal information.

11.0   WE RESPOND TO YOUR QUESTIONS, CONCERNS AND COMPLAINTS ABOUT PRIVACY

Guelph Hydro Group responds in a timely manner to your questions, concerns and complaints about the privacy of your personal information and Our privacy policies and procedures.

12.0   PRIVACY AND GHG WEBSITES

We receive and store certain types of information whenever you interact with Us online. For example, like many websites, We obtain certain types of information when your web browser accesses GHG Websites.

Guelph Hydro Group employs software programs that monitor network traffic. These programs record the Internet Protocol ("IP") addresses of computers, mobile and other devices that visit GHG Websites. They also may record the date and time of visits, the pages viewed, and the browsers and operating systems used by visitors. We do not attempt to link this information to the identities of individual users, unless an attempt to damage the GHG Websites has been detected.

Portions of GHG Websites use statistical tools that may be operated by third party providers (collectively, the "Analytical Tools"). The Analytical Tools may use "cookies" and/or web beacons. A cookie is a small piece of information that a website transfers to the hard drive of a visitor's computer for record-keeping purposes. A cookie is used to help a website distinguish a user's browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing that website. Cookies do not contain information that identifies you personally. A web beacon, also known as a "clear GIF" (a common format for image files), is an invisible file located on web pages that you visit. They are often used in combination with a cookie to track navigation of a website. If you visit a page on a GHG Website that contains a web beacon, it communicates with your computer to determine, among other things, whether you have been to that page before or viewed a particular advertisement.

The information generated by the cookies and/or web beacons about your use of the GHG Websites (including your IP address) will be transmitted to and stored on servers located outside of Ontario including, but not limited to, the United States, by the applicable third party provider of an Analytical Tool. This information will be used for the purpose of evaluating your use of GHG Websites, compiling reports on the activities of a GHG Website and providing other services relating to the activity of GHG Websites and Internet usage. The third party providers of Analytical Tools may also transfer this information to other third parties where they are required to do so by law, or where such third parties process the information on their behalf. By using a GHG Website, you consent to the processing of data about you by third party providers of Analytical Tools in the manner and for the purposes set out above.

The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer. Because cookies allow you to take advantage of some of essential features of the GHG Websites, We recommend you leave them turned on.

13.0   WHAT ABOUT LINKS TO OTHER WEBSITES?

GHG Websites have links to third party websites that Guelph Hydro Group does not own or maintain. Links to other websites or other resources which are not created or controlled by Guelph Hydro Group ("Linked Sites") are intended for convenience only. Linked Sites are wholly independent from Guelph Hydro Group, therefore Guelph Hydro Group has no control over any products, services, materials, or other information contained in or available through these third party websites. We make no representations or warranties about the privacy practices of those websites. Therefore, access to any third party websites through GHG Websites, regardless of whether the third party website is a Linked Site or not, is entirely at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive devices, programs.

14.0   HOW TO CONTACT US

You may contact Us:

• by calling Us at 519.822.3010 (customer inquiries) or 519.822.3017 (administration);
• by faxing Us at 519.822.0960;
• by emailing Us at info@guelphhydro.com - Attention: Privacy Officer
• by mailing Us at Guelph Hydro Inc., 395 Southgate Drive, Guelph, ON, N1G 4Y1.

If your questions, concerns and complaints have not been resolved to your satisfaction or if you have further questions, you can contact us by mail: Guelph Hydro Inc., 395 Southgate Drive, Guelph, ON, N1G 4Y1, Attention: Privacy Officer.