Last updated: September 29, 2022
ABOUT THIS POLICY
WHAT IS PERSONAL INFORMATION?
For the purposes of this policy, personal information means any information about an individual that can identify that person, either directly or indirectly, individually or in combination with other information. Generally, personal information does not include your name or business contact information, such as your job title, professional designation, or office address.
WHAT PERSONAL INFORMATION DO WE COLLECT?
Some of the personal information we collect as part of our activities and service delivery includes:
your contact information, such as your name, email address, and phone number
data pertaining to your fleet (if applicable), such as size of the fleet, including the number of electric vehicles in the fleet, and the region where you operate
marketing information and your communication preferences, as well as your comments and survey responses
any other personal information you provide to us
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Right from you
Generally, we obtain the personal information we need right from you; for example, when you use our services or when you contact us.
With your consent
Generally, we will obtain the personal information we need right from you, with your consent, subject to the exceptions provided for under applicable legislation. For example, Cleo may need to proceed without your consent when, for fraud detection or prevention purposes, seeking your consent would defeat the purpose.
Refusing and withdrawing your consent
You have the right to opt out of the collection, use and disclosure of your personal information. Similarly, subject to reasonable notice and applicable legal or contractual restrictions, you can contact us at any time to withdraw your consent to the use of your personal information that is in our possession or control. You must be aware, however, that if you decide not to provide your personal information, that choice may prevent you from accessing certain features of the website. We also must inform you that some anonymous information, that does not enable us to know who you are, can be retained even if you withdraw your consent.
WHY DO WE USE YOUR PERSONAL INFORMATION?
For specific and limited purposes
Generally, we use your personal information to:
establish and manage our relationship with you
provide and maintain the requested products and services, including access to the website
reply to your requests for information and assistance
improve the user-friendliness of our website, its content, and your customer experience
any other purpose authorized or required in accordance with applicable legislation or regulations
any other purpose for which you have given your consent
(collectively, the “purposes”).
The information collected this way will be used solely for the purposes set out in this policy.
For messaging purposes
If you have consented to receive such information, Cleo can send you newsletters and electronic messages (the “messages”) regarding Cleo services or products and third-party products or services. You can express your desire to not receive messages as described later in the Contact Us section or by following the instructions in the messages. However, Cleo may continue to send you messages to inform you of possible upgrades to or critical technical issues with the website.
For secondary purposes
Cleo can also aggregate and de-identify the personal information you have provided in order to create statistical data for improving the website and training the machine-learning algorithms. Cleo may also share that information with its partners. These statistical data do not include personal information.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Cleo does not rent or sell any of your personal information to third parties and will not share it with third parties without your consent, unless required by law or necessary for the purposes set out below.
With our employees
As part of their job, our employees may need access to your personal information; for example, when you contact us or request technical support. That access is limited to what they need in performing their duties.
With our strategic partners
Cleo may share your personal information with its partners to the extent that such disclosure is required for the purposes. Cleo may use third parties to facilitate its operations, such as growth-oriented analytical and product management service providers or hosting service providers. As part of these activities, Cleo’s service providers can access and use your personal information for a limited period of time. When Cleo uses third parties to handle any personal information, it establishes reasonable contractual and technical safeguards to ensure that all the personal information handled by those third parties is kept strictly confidential. Please note that those third parties may be in different legal jurisdiction than you, in which case appropriate action will be taken by Cleo as outlined below in the section Is your personal information transmitted outside Québec?
Where required by the applicable legislation
We may also share your personal information if required by law or if we believe in good faith that such action is necessary to (i) comply with the law; (ii) comply with the order from a competent judicial authority in any jurisdiction; (iii) comply with legal proceedings served on Cleo; (iv) protect and defend Cleo’s rights or property; (v) enforce or verify your compliance with any agreement you have with Cleo, if applicable; (vi) prevent fraud or other illegal activity perpetrated through the website; and (vii) take action in urgent circumstances to protect the personal safety of users of our website or the general public.
During a business transfer
We may share your personal information without your consent when our operations require it (e.g., in the event of a merger, acquisition, bankruptcy, or sale of assets). This type of event may also result in some or all of your personal information being shared with the relevant third party (or their advisors) as part of due diligence.
For other purposes, with your consent
Where you have expressly consented, your personal information may be shared with other third parties. For example, additional conditions may apply and, in these specific cases, we make it clear that specific third parties process your personal information.
THIRD-PARTY SERVICES AND PLATFORMS
Link to third-party platforms
We may include links on our website to third-party sites or services that we do not control, for example, if you use an integrated feature of Google or social media (LinkedIn, Facebook, etc.). These third parties can share some information about you with us. Your activities on our website can be posted on social media platforms. Please read the privacy policies of those sites, applications or platforms that may collect personal information, in order to understand their privacy policies and practices. This policy applies only to personal information processed by or on behalf of Cleo.
A cookie is a small text file stored in a reserved location on your computer, mobile device, tablet, or other device when you use an online service with a browser. Other tracking technologies, such as web beacons and tracking pixels, can be used for similar purposes. In this policy, all of these tracking technologies are collectively referred to as “cookies” or “cookie files”. Any personal information collected using cookies by or on behalf of Cleo is handled with the same level of confidentiality as any other personal information held by Cleo.
Strictly necessary cookies
These cookies are required to run the website and cannot be turned off in our systems. Strictly necessary cookies must be there in order for our website to provide basic functions including, presumably, connection. In particular, they enable a user to move from one page to the next without erasing their previous actions in the same session.
If you have consented to their use, Cleo or its third-party partners, or both, can also use non-essential cookies associated with the website and messages:
Functionality cookies (also known as “preference cookies”: These cookies are not essential to the delivery of our services, but they enable customization and improvement of the user experience. For example, if you have consented to their use, these cookies will store your communication and language preferences.
Analytical cookies: The use of analytical cookies enables us to better understand website traffic patterns and helps us to measure and improve the effectiveness of the website and messages, as well as to determine whether these messages were opened and whether the links they contain were used. These cookies are used for statistical purposes only. All the information they collect is aggregated and anonymous. To decline to be tracked by Google Analytics, read this module: https://tools.google.com/dlpage/gaoptout?hl=en. You can also opt out of analytical cookies by following the instructions below.
Advertising cookies: If you consent to it, third parties, including Google Display Network, LinkedIn Insight Tag, can also place advertising cookies on our website. This enables them to know what in our website content consulted interests you and to customize the ads on our website (or outside of it) accordingly. If applicable, you can turn off the cookies of companies participating in the Digital Advertising Alliance’s AdChoices program.
Social network cookies: Our site may also use sharing cookies, which enable us to add features to our website for sharing content on social medial such as Facebook and LinkedIn. Using the share buttons will install a cookie for connecting the content consulted on our website to your user account on those media.
How to manage cookies
With the exception of strictly necessary cookies, cookies will only be placed on your devices if you consent to it, and those cookies will be kept for a maximum period of eighteen (18) months from the time they are placed on your devices. At the end of that period, your consent will again be required.
Cookies can be managed or turned off using the cookie settings in your browser. To the extent that their policies are applicable, you can also manage social network cookies by reading the policies of the following social media:
However, if you opt out of cookies, you will likely not be able to use all the features of the website and messages. For more information on how to manage or turn off non-essential cookies, please visit https://www.allaboutcookies.org and https://optout.aboutads.info/?c=2&lang=EN.
HOW DO WE ADVERTISE ONLINE?
Using cookies or mobile ad IDs
Based on the preferences you have expressed on your mobile devices, Cleo and its advertising partners can also use your mobile advertising ID to target and measure the effectiveness of their advertising campaigns. In iOS, this identifier is called “IDFA” (ID for Advertising); in Android (Google Play), this identifier is called “AAID” (Android Advertising ID). You can access and reset your mobile ad ID or limit its use through the settings on your mobile devices’ operating system.
Under no circumstances will Cleo authorize advertising directed at children when it has actual knowledge that the user is under the age of 13. For more information about Cleo’s advertising practices, please contact Cleo as indicated in the Contact Us section.
For more information about how targeted advertising works, you can read the Network Advertising Initiative education page (“NAI”). You can also opt out of some of these services by visiting the Digital Advertising Alliance opt-out portal.
Do Not Track signal
Some browsers may send websites a Do Not Track (“DNT”) signal to indicate that the user does not want their activity tracked. There is currently no universally accepted standard for how to interpret these signals, although work is underway to establish consensus. Therefore, we do not respond to the DNT signal.
HOW LONG DO WE KEEP PERSONAL INFORMATION?
IS YOUR PERSONAL INFORMATION TRANSMITTED OUTSIDE QUÉBEC?
The personal information we collect is stored in secure systems hosted on servers that may be located outside your province, territory, state, or country of residence, including in Canada and the United States. We may also retain the services of agents and service providers that may be located outside Québec. However, we strive to protect the personal information in our care, including personal information entrusted to an agent or service provider. In particular, we strive to limit their access to what is necessary for performing the duties assigned to them. Please note that we also strive to put contractual agreements in place with these agents and service providers to ensure the confidentiality and security of your personal information. This may include the implementation of robust, effective security measures. If you have further questions about this, do not hesitate to contact us.
HOW DO WE PROTECT THE CONFIDENTIALITY OF YOUR PERSONAL INFORMATION?
Necessary and appropriate security measures
We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the personal information in our possession. We do this by adhering to the generally accepted standards in our industry. Thus, the personal information in our possession is made available only to the people authorized to access it, who consult it when it is necessary to perform their duties. The following is a list of some of the physical, technical and administrative safeguards put in place and maintained to minimize the risk of incidents:
Secure Sockets Layer (SSL) protocol
ISO 27001-certified platform
network monitoring software
username and password
If you think your personal information has been compromised, we encourage you to contact us.
WHAT ARE YOUR RIGHTS?
Under the applicable privacy legislation, you have certain rights, including the following:
protection and confidentiality of your personal information
access to your personal information
correction of your personal information if it is incomplete, inaccurate or vague, as applicable, or if the collection, disclosure or retention of your personal information is not authorized by law
de-indexing of your personal information
data portability, in other words, the right to receive, in a structured, commonly used, and machine-readable format, a copy of all personal information that Cleo holds about you
removal of your email address from our newsletter mailing list by submitting a request through the Contact Us page of our website, using the form provided for this purpose
withdrawal of your consent to the disclosure or use of your personal information, if applicable
To exercise any of these rights (to the extent applicable), please follow the instructions in the Contact Us section.
UPDATES TO THE POLICY
The policy may be amended, revised, updated or supplemented from time to time by Cleo, at its discretion, to reflect changes in its practices or for other operational, legal or regulatory reasons. The date of the policy update indicates when it was last modified. It is necessary to refer to the most recent version of the policy for the most recent changes. If there are significant changes to the policy, either you will be notified when you visit our website or you will receive a link to the new version of the policy. The policy and any associated documents, if applicable, will be posted on our website. By browsing Cleo’s website, you accept the changes made to the policy, if applicable.
If you would like to receive more information about our privacy practices, send a comment, file a complaint, or exercise any of the rights available to you in accordance with applicable legislation, or if you have any questions, please contact a member of our team by filling out the form on the Contact Us page of our website or contact the person responsible for privacy by email at email@example.com or by mail at:
Édifice Jean-Lesage, 20e étage
75, boul. René-Lévesque O.
Montréal, Québec H2Z 1A4