PRIVACY POLICY

THERON EV INC. (“Theron” or “We”) is strongly committed to protecting your privacy and complying with your choices. Both personal and non-personal information collected is safeguarded according to the highest privacy and data protection standards. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and the Act Respecting the Protection of Personal Information in the Private Sector.

This page explains and informs you of the policies regarding the collection, use, migration and disclosure of personal information when you use Theron website https://www.theron-ev.com/ (the “Website”) and when you use our vehicles, when you use our platform, when you make purchases, register an account on our Website, fill out applications or forms, make inquiries or contact us (the “Services”).In order to improve the Website and our Services, we will use your personal information when you interact with us, when we communicate with you and when you register and interact with our services. By using the Website and our Services, you agree to the collection and use of your personal information in accordance with this Policy.

Notre engagement

1. Your information will not be rented or sold to any third party.
2. We use state-of-the-art security measures to protect your information from unauthorized users.
3. We give you the possibility to control the information that you shared with us.

1.   Notice

We will inform you when information that personally identifies you ("personal information") is asked for and you will have the choice to provide it or not. Generally, this information is requested when you use our Website and our Services and/or purchase our products, subscribe to products updates, newsletters or other online services.

2. Usage

We use your personal information for the following purposes:

- To provide and maintain our Website, including to monitor the usage of our Website and our Services ;

To manage your account, including your registration as a user of the Website. The personal information you provide can give you access to different functionalities of the Website that are available to you as a registered user;

For the performance of a contract, for example, the development, compliance and undertaking of a purchase contract for the products, items or services you have purchased or of any other contract with us trough our Website;

- To contact you, by email, social media accounts, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;

- For statistical purposes and user details;

- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

- For business transfers: We may use your personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our our assets, whether as a going concern or as part of bankruptcy liquidation, or similar proceeding, in which your personal information held by us is among the assets transferred;

- For payments and invoicing, to send it to our financial service providers described in Section 11 when you purchase our product or require maintenance and repairs. We need to collect certain information to organize the delivery of your vehicle and coordinate maintenance and support operations if you experience issues with your vehicle. We will never store your payment information in a database or on our own servers. This information is only recorded and collected by our financial service providers, when applicable;

- When you use a Theron vehicle, it's possible that we collect information about the vehicle and its geographical location to enhance the vehicle's performance and customer experience. Our vehicles may be connected, and data could be gathered when you use them, enabling Theron to provide appropriate and timely support for the vehicles and to undertake research and development initiatives. Theron may be legally obligated to share this data with authorities and law enforcement, particularly to assist you in case of emergencies. Location data may be accessible when necessary, such as in the event of an accident, assistance calls, or with your consent.

- When you apply for a job posting ;

- To alert you of Website upgrades,
updates, discounts or other services from Theron;

- For Online Customer Support, if you use the free email support  (support@theron-ev.com, info@theron-ev.com or privacy@theron-ev.com) to help you use the Website and the Services, our team may need to use your personal information;

- Preventing and Combating Fraud, as we are actively combat credit card fraud trough our financial Third Party Services providers. To do so, our team may need to use some of your personal information;

- For other purposes,
such as data analysis, research and development activities and internal business purposes, planning purposes, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, Services, marketing and your experience.

We collect your email when you register to our Website in order to send you informational communications about newsletters, notifications or emails about our products or services, such as their purpose and the best use you can make of them.

We may also collect your name, phone number, addresses, language, currency, payment information, operating system information, document searched and country information for a better experience with Theron products/Services. Certain information you submit to us is not considered personal information under this Privacy Policy and is collected and used in accordance with the applicable Website Terms and conditions.

We also collect your phone number in order to contact you in case these emails bounce back because of a typo in your email address and if we cannot figure out what the correct email address is.

We also contact the phone number that is provided if we suspect that the cardholder’s credit card information has been compromised, i.e used in a fraudulent way.

3. Consent

By using the Website and our Services, you agree to the collection and use of your personal information in accordance with this Policy. When you provide your personal information, you consent that it can be used for the above purposes and that Theron is an authorized holder of such information. If you choose not to register or provide personal information, you might still be able to use our Website, but you will not be able to receive additional services, gain access to the Website or access certain areas that require registration. When you activate your account, you are providing your consent to occasionally receive information from us. In each communication from us you will have the opportunity to unsubscribe from further communications; alternatively, you may contact us to express your choices at the address provided at the bottom of this page.

It is important to note that our Website is not intended for people under the age of 14.

4. Access to your information

You are entitled to review the personal information you have provided us and ensure that it is accurate and current at all times. In the event that you request to know what personal information is processed by us, we will provide you with the following information free of charge: the purposes of the processing; categories of personal information processed; recipient(s) of the personal information; the length of time the personal information will be retained; your privacy rights and information on data transfers. These requests will be made by sending a request to the personal information protection officer at privacy@theron-ev.com. The data subject has the right to obtain from the controller confirmation as to whether or not personal information concerning him or her is being processed and, if so, access to the personal information. The controller provides a copy of the personal information being processed. As a customer, you have access to your personal information via our Website (once logged into your customer account).

5. Security of information

Theron is strongly committed to protecting your information and ensuring that your choices are honored. We have taken strong security measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. All sensitive data is stored to the highest safety standards, behind firewalls on secure servers with restricted access, 24 hours a day, 7 days a week.

We have implemented (1) liability insurance; (2) automated backup mechanisms; (3) disaster recovery services; (4) continuous monitoring of our services and automated alert mechanisms; (5) rigorous management of access rights; (6) regular testing, reporting and internal auditing of systems security; and (7) frequent upgrades of all our IT environments and systems.

Please note that your personal information may be stored on servers located in a country other than where you reside. Where possible, Theron makes efforts to host personal information in Quebec. In certain cases, we host personal information in the United States and elsewhere in Canada, including through our use of Amazon Web Services. We also use third party service providers in other countries, and they may process your data in those countries. Those countries may not have the same data protection laws as the country in which you initially provided that information, or of your nationality. Before transferring personal information to third parties, we take commercially reasonable measures to ensure that adequate safeguards are in place, such as by entering into agreements with such third parties that incorporate standard contractual clauses or other legally acceptable transfer mechanism.

6. Retention of information

We retain information as long as it is necessary to provide the services requested by you, resolve disputes and enforce our agreements, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted whichever comes first. An account can be deleted at any time by contacting privacy@theron-ev.com.  

Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms and Conditions, and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Provided you do not delete your account, we may also retain and use certain personal information for a reasonable period of time, including to pursue legitimate business interests, resolve disputes, conduct audits, comply with legal obligations, or enforce our Terms and Conditions.

7. Users’ Rights

You have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

a) Right of access to personal information
You have the right to access your personal information, obtain a copy of the personal information being processed by Theron and obtain information about Theron's internal personal information processing. In the event that you request to know what personal information is processed by us, we will provide you with the following information free of charge: the purposes of the processing; categories of personal information processed; the categories of persons who have access to your personal information; recipient(s) of the personal information; the length of time the personal information will be retained; your privacy rights and information on data transfers. These requests will be made by sending a request to privacy@theron-ev.com. You have the right to obtain from us confirmation of whether or not your personal information is being processed and, if so, access to your personal information. The controller provides a copy of the personal information being processed. As a customer, you have access to your personal information via our platform (once logged in on your account).

b) Right to portability of personal information
You have the right to receive your personal information in a structured, commonly used and machine-readable format. Such a request will be made by sending an email with your relevant details to privacy@theron-ev.com.

c) Right to rectify
You have the right to, if necessary, have your personal information amended or deleted or restricted. These requests will be made by sending a request to privacy@theron-ev.com with all relevant details.

Please note that we may rectify, reconstruct or delete incomplete or inaccurate information at any time at our own discretion. You have the right to obtain from the us, without unreasonable delay, the rectification of inaccurate personal information. In view of the purposes of the processing, you have the right to complete incomplete personal information, including by providing an additional declaration. As a customer, you can change your personal information directly from our platform. In case of any issues with changing your personal information from our platform, please contact our technical support at privacy@theron-ev.com.

d) Right to be forgotten and right to oppose
You may withdraw your consent to the processing of your personal information at any time. In this case, if there is no overriding legitimate interest in continuing to process your personal information (e.g. to comply with our legal obligations, resolve disputes, enforce our agreements, etc.) and the personal information is no longer necessary for the purpose originally pursued, we will delete your personal information. Such withdrawal of consent will be made by sending an email to  privacy@theron-ev.com with your relevant details.

Moreover, you have the right to obtain from us the erasure of your personal information without unreasonable delay and we undertake to erase your personal information within a reasonable period.  As a customer, all of your user data is deleted within a reasonably delay following the cancellation of your account.

e) Right to the restriction of processing 
You may request us to restrict the processing of your personal information if any of the following conditions apply:  (a) you contest the accuracy of your personal information, for a period of time allowing us to verify the accuracy of your personal information; (b) the processing of your personal information is unlawful and you object to the deletion of your personal information and instead requires the restriction of the use of your personal information; (c) We no longer needs your personal information for the purposes of the processing, but your personal information are still necessary for you for the establishment, exercise or defence of legal claims; and (d) You have objected to the processing pursuant paragraph d) during the verification as to whether the legitimate grounds pursued by Theron override those of you. These requests will be made by sending a request to privacy@theron-ev.com.

f) Right to be informed of an automated decision and to object to it
In the event that our Website makes decisions exclusively by automated means, you have the right to (i) be informed, (ii) request additional information about the automated decision making, and (iii) submit comments to the personal information protection officer at privacy@theron-ev.com.

g) Right to opt-out
You can ask us to not send marketing communications and not to use your personal information when we carry out profiling for direct marketing purposes. You can opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails or by sending us an email to privacy@theron-ev.com. Transactional account messages will be unaffected if you opt-out from marketing communications.

8. What we do with the Information you share

By providing your personal information, you agree that it may be shared with third parties as necessary to provide you with the best possible service. Inside the company, data is stored to the highest safety standards behind firewalls on secure servers with restricted access, 24 hours a day, 7 days a week.

We may on occasion require the help of other companies to provide limited services on our behalf. We will only provide such companies with the information required for them to perform these services; these service providers are bound by strict privacy policies and are prohibited from using your information for any other purpose.

In very rare instances Theron may disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Theron; (b) protect and defend the rights or property of Theron; and (c) act in urgent circumstances to protect the personal safety of users of Theron, its websites, or the public.

9. Does Theron uses cookies?

A cookie is a small file placed on a device's hard drive for record-keeping purposes by a web server. Our Website may use cookies to recognize you on subsequent uses of the site and/or to record your browsing data for several purposes, including: (i) identifying you when you log in to our site, (ii) offering content, including advertisements, relevant to your interest, on our site or on third party sites, (iii) improving the quality and navigation of the Website and/or use of our Services, (iv) creating new features and services, (v) conducting traffic and statistical analysis. In particular, we use the following cookies in accordance with our applicable Terms and Conditions:

- Cookies to manage user authentication;
- Cookies to enable audience measurement and statistics on the site;
- Cookies to improve your browsing experience, such as remembering if you clicked on the pop-up window so that it does not appear next time;
- Cookies to track your preferences.

You may block, delete or disable some or all cookies by changing your cookie preferences in your browser settings or directly on the pop-up window that will appear when using the Website. However, please note that if you choose to configure your browser in this manner, some areas of our site and/or Services may not function properly.

10. Does Theron privacy policy apply to linked websites?

Our Privacy Policy applies solely to information collected on our Website and from our Services.

The Website may contains links to web sites of third parties. Theron is not responsible for the actions of these third parties, including their privacy practices and any content posted on their web sites. We encourage you to review their privacy policies to learn more about what, why and how they collect and use personal information. Theron adheres to industry recognized standards to secure any personal information in our possession, and to secure it from unauthorized access and tampering.

However, as is true with all online actions, it is possible that third parties may unlawfully intercept transmissions of personal information, or other users of our services may misuse or abuse your personal information that they may collect from Website.

Theron can use third-party advertising companies to serve our ads on our website. These third-party advertising companies may employ cookie and 1x1 pixel. gifs or web beacons to measure and improve the effectiveness of ads for their clients. To do so, these companies may use anonymous information about your visits to our website and other websites but will not collect any information which can personally identify you or can be linked to you. This information can also be used for online preference marketing purposes.If you want to prevent a third-party advertiser from collecting data, currently you may either visit each ad network's web site individually and opt out or visit the NAI gateway opt-out site to opt-out of all network advertising cookies. Click here for the NAI gateway opt-out site.

11. Third Party Services

In order to provide you with the best possible service, to facilitate our service offering or to help us analyze how our Website is used, we may retain the services of certain third parties. Here are the categories of recipients to whom we may share your information, as well as examples of third-party service providers we may use :

Marketing Services:

- MetaPlatforms, Inc.;
- Google LLC;
- LinkedIn, Inc.;
- Nordet &Co.;
- YouTube;
- X;

IT Services:

- MicrosoftCorporation;
- MicrosoftAzure;
- Odoo;

Data Services:

- Google Maps;
- Amazon Web Services;

Customer Support Services:

- Odoo;

Financial Services and E-commerce activities:

- Stripe;
- Paypal;
- Etc.

These third parties have access to your personal information only to perform these tasks on our behalf and are required not to disclose or use it for any other purpose. We encourage you to review their privacy policies to learn more about what, why and how they collect and use personal information.

12. Legal notice

This privacy statement has been prepared in compliance with the legal obligations set out in applicable Québec and Canadian laws on the protection of personal information, in particular the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Act Respecting the Protection of Personal Information in the Private Sector.

The following person has been designated as personal information protection officer, as required by the laws in force on the protection of private data:

Name: Justine Viviers
Function : Commercial director
E-mail: justine.viviers@theron-ev.com

13. Privacy Incidents

In the event that Theron is subject to a security incident that could result in serious harm to you, including unauthorized access, use or disclosure of personal information, loss of personal information, or any other breach of privacy, we will notify you and the Commission d'accès à l'information as soon as possible.

14. Changes to this policy

If we make changes to our Privacy Policy, we will post these changes here so that you are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use your information in a manner different from that stated at the time it was collected, we will notify you by email.

15. Questions or comments

If you have questions or comments about this privacy policy, please email us or write us at:

THERON EV INC.
1250 av. de la Station
Shawinigan, Québec
G9N 8K9
Privacy@theron-ev.com
For more information about how to contact Theron please visit our contact page.

September 09, 2023