Privacy Policy — SOGHU
Société de gestion des huiles usagées (SOGHU)
Effective date: [TO COMPLETE] Last updated: [TO COMPLETE]
⚠️ DRAFT — DO NOT PUBLISH AS IS Starting point drafted per the Commission d’accès à l’information guide Rédiger une politique de confidentialité (Dec. 2023). Every
[TO CONFIRM]marker must be validated internally. Legal review recommended before publication.This is the English counterpart of
SOGHU_politique_confidentialite_ebauche.md. Under the Charter of the French Language, the French version must be available and at least equivalent. The two must be updated together — divergence between them is itself a compliance risk.
Who we are
Société de gestion des huiles usagées (SOGHU) is [legal status to confirm: non-profit? accredited organization?], with its head office at [full address].
We recover and recycle used oil, used antifreeze, oil and antifreeze containers, used filters and aerosol containers across Quebec.
This policy explains how we collect and use your personal information when you use our website, soghu.com. It is separate from our terms of use and from our personal information governance policy.
1. How we collect your personal information
We collect personal information through the following technological means:
- registration forms (drop-off point, collector, processor, membership) and annual renewal forms;
- the OneWindow online remittance (RE) form, for members;
- the Contact page form and emails sent to soghu@soghu.ca;
- the drop-off point locator search field (“Where are you located?”);
- contest and promotion entry forms we run from time to time;
- cookies on our website;
- [TO CONFIRM: newsletter? member account area? anything else?]
Third parties that collect information on our behalf
- OneWindow [TO CONFIRM: exact vendor, role, hosting location] — processing member remittances;
- Google (Google Analytics, Google Maps) — audience measurement and display of drop-off point maps;
- YouTube (Google) — playback of videos embedded in our pages;
- [Website host] [TO CONFIRM];
- [Newsletter provider, if any] [TO CONFIRM].
Technologies that identify, locate or profile you
Our site uses technologies capable of identifying or locating you:
- Google Analytics: measuring traffic to our site (pages visited, referral source, device used);
- Google Maps: displaying drop-off points near the location you enter;
- YouTube, Facebook, LinkedIn: cookies set by these platforms when embedded content loads.
These functions are off by default. They activate only if you consent through our cookie banner. You can change your preferences at any time via [link/button name to confirm].
2. What we collect, and why
| Category | Examples | Why |
|---|---|---|
| Identifying information | Name, job title, company name, mailing address, email address, phone number | Process your registration as a drop-off point, collector, processor or member; contact you about your file; list your location in our public directories |
| Technical or digital information | IP address, browser and device type, connection date and time, pages visited | Operate and secure the site; measure traffic in order to improve it |
| Location information | City, postal code or address you enter in the locator | Show you the nearest drop-off points |
| Financial information | [TO CONFIRM: banking details, business numbers, volumes declared through OneWindow] | Process remittances and payments under the program |
| Contest information | [TO CONFIRM] | Administer the contest and contact winners |
We do not collect health information or biometric information.
Declining certain collection
- You can refuse non-essential cookies and still use the site normally. Only embedded content (maps, videos) will not display until you consent.
- You can reach us by phone at 1-877-987-6448 instead of using the online forms.
- Some information is required to register as a drop-off point, collector, processor or member. Without it, we cannot process your request. [TO CONFIRM: exactly which fields]
3. Who has access to your personal information
Internally
Only those who need it to do their jobs:
- [TO CONFIRM: operations team? member services? accounting? communications?]
Externally
We share certain information with:
| Recipient | Information | Why | Outside Quebec? |
|---|---|---|---|
| Technical and browsing information | Audience measurement, map display | Yes — United States | |
| [OneWindow / vendor] | [TO CONFIRM] | Remittance processing | [TO CONFIRM] |
| [Host] | [TO CONFIRM] | Website hosting | [TO CONFIRM] |
| RECYC-QUÉBEC / MELCCFP | [TO CONFIRM — regulatory reporting obligations] | Legal obligations | No |
Public directories: if you register as a drop-off point, collector or processor, your location’s name, address, phone number and hours are published on our site so the public can find you. [TO CONFIRM: is this clearly stated at the point of registration?]
Some of our providers may process your information outside Quebec, including in the United States. Before any such transfer, we conduct a privacy impact assessment as required by law. [TO CONFIRM: have these assessments been done?]
4. How we protect it
We protect your personal information through [TO COMPLETE — a few concrete examples only; do not detail security measures to the point of creating risk]:
- technological measures: [e.g. encryption in transit, firewalls, access controls];
- administrative measures: [e.g. information security policy, staff training];
- physical measures: [e.g. locked premises and cabinets].
5. How long we keep it
[TO COMPLETE — SOGHU should have a retention schedule. State at minimum the general retention periods by category, and that information is destroyed or anonymized once those periods and any legal obligations have run.]
6. Your rights
You have the right to:
- access the personal information we hold about you;
- have it corrected if it is inaccurate, incomplete or ambiguous;
- withdraw your consent to collection through cookies, at any time, via [preferences link];
- request that we stop disseminating your information or de-index it, in the cases provided by law;
- receive your information in a structured, commonly used technological format (portability), in the cases provided by law;
- file a complaint with us under the process set out in our governance policy, and then with the Commission d’accès à l’information if our response does not satisfy you.
We respond to requests within 30 days of receiving them.
7. Contact us
Privacy Officer
Responsable de la protection des renseignements personnels
La Société de gestion des huiles usagées (SOGHU)
303 – 8005 boul. du Quartier
Brossard (Québec)
J4Y 0N5
Email: soghu@soghu.ca
Phone: 1-877- 987-6448
For any question about this policy, or to exercise your rights, please contact us at the address above.
Commission d’accès à l’information du Québec
cai.gouv.qc.ca | 1-888-528-7741
8. Changes
We update this policy when our practices change. The last updated date appears at the top of this page. We invite you to check back from time to time.
[Do not reinstate the current wording under which continued use of the site constitutes acceptance — that is not valid consent under section 14.]