Our Privacy Policy

Policy

Activo Inc./Activo I&R (“Activo”) is committed to maintaining the accuracy, confidentiality, security, and privacy of its customers, employees, contractors, partners and other stakeholders’ personal information consistent with legislative requirements, specifically the relevant sections of the Federal Personal Information Protection and Electronic Documents Act (PIPEDA), Alberta PIPA, BC PIPA, and Quebec’s Law 25. This policy applies to personal information Activo handles and to that handled by our service providers on our behalf. Activo has a designated Privacy Officer responsible for our privacy program and ensuring compliance with all applicable privacy laws. Activo will maintain written policies and procedures, employee training, complaint handling procedures, and vendor/contractual safeguards to enforce this policy. The identity and contact details of the Privacy Officer will be made available, as required.

Scope

This policy applies to customers, employees, contractors, applicants, vendors, partners, and other third parties, and covers personal information handled in the course of Activo’s business operations, services and digital platforms.

What Information Activo Collects

Activo will only collect information reasonably required for business and operational purposes, including:

• Employment history, qualifications, references, background checks
• Contact and emergency contact details
• Payroll, banking, and benefits information
• Training and performance-related information
• Security and IT system information

For customers, vendors, partners and other third parties, Activo may collect information pertaining to identity, contact information, account credentials, purchase history, support records, billing and service- related data, technical information related to service delivery and other information necessary for the stated purposes.

This information will be collected directly from you or from authorized sources (e.g. references you provide) and Activo will limit collection to what is necessary for the stated purposes, as required by privacy laws.

Why Activo Collects It

Activo uses your information to:

• Hire and onboard you
• Pay you and provide you with benefits
• Ensure workplace safety and security
• Manage performance and training
• Meet legal and regulatory requirements

For customers, vendors, partners and other third parties, Activo uses the information for account setup, service delivery, billing, customer support, quality assurance, compliance, fraud/security monitoring, and service improvements.

Activo communicates the purposes of collection and limits subsequent use to those purposes unless consent is obtained, or the law permits otherwise.

Consent and Notice

The application of the Activo Policy is as follows:

• Specify the elements of valid consent for collecting, using or disclosing personal information.
• Permit federal works, undertakings, and businesses to collect, use and disclose personal information without the knowledge or consent of the individual to establish, manage or terminate employment relationships; and
• Provide a framework for organizations to notify individuals proactively about disclosures of their personal information made in certain circumstances to government institutions.
• Alberta PIPA and BC PIPA specifically allow employee information to be collected without consent when it is reasonable for managing the employment relationship.
• For Quebec employees, Activo will follow consent obligations relative to Law 25.

The Policy does not impose an obligation to obtain consent to collect, use or disclose employee personal information to the extent that the applicable provincial legislation does not require consent.

Limiting Collection, Use, Disclosure and Retention

Activo minimizes the personal information collected and uses it only for identification purposes or as required/permitted by law. Activo retains personal information only as long as necessary for those purposes, legal/accounting requirements, or legitimate business needs, after which it securely deletes, anonymizes, or disposes of it in accordance with applicable legislation and privacy laws. Activo does not sell your personal information.

Accuracy

Activo keeps personal information accurate, complete, and up to date as needed for the purposes for which it is used and provides mechanisms for you to update your information. To maintain accurate and up-to-date personnel records, employees can notify the HR/Payroll Department of any changes to personal information.

How Activo Protects Your Information

Activo applies administrative, technical and physical safeguards appropriate to the sensitivity of the information – including encryption, complex passwords, monitoring, MFA, secure systems, limited access and staff training – to keep your information safe.

Electronic Monitoring

Activo may use electronic and IT monitoring systems (access logs, security cameras) for workplace safety, security and operational purposes. Electronic monitoring is conducted only when necessary, proportionately, and limited to legitimate business needs, including safety, security, and operational requirements, and in line with applicable privacy laws.

Cross-Border Transfers

Activo may transfer personal information to service providers (including outside your province) who process it on our behalf. Activo requires contractual measures to ensure a comparable level of protection and restrict use to our documented purposes. In Quebec, if necessary, before Activo communicates personal information outside of Quebec, Activo conducts a privacy impact assessment that considers the sensitivity, purposes, safeguards, and legal framework of the destination.

Your Privacy Rights

You have the right to:

• Request access to the personal information Activo holds about you
• Ask for the correction of inaccurate information
• Learn how your information is used
• In Quebec, request data portability as permitted by privacy laws

You will receive a response within the timelines set by applicable privacy law.

Third-Party Services

Activo is not responsible for the privacy practices of third-party websites or services that may be linked from Activo systems.

Breach Response and Notification

Activo maintains an incident response plan and promptly assesses privacy incidents. Where required, Activo will notify affected individuals and relevant privacy regulator(s) and keep records of breaches.

Feedback Process

If you have any questions, requests or complaints, you may contact Activo’s Privacy Officer at [email protected]. In addition, you may contact us at (905) 752-1900 or by postal mail at Activo Inc., 90 Gough Road, Unit 1, Markham, ON L3R5V5. Whichever way you elect to contact us, we may ask that you confirm and verify your identity. If your question, request or complaint remains unresolved, you may contact the applicable provincial privacy regulator.

Review

This policy will be reviewed annually to reflect Activo’s current practices and legislative requirements.