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Privacy Policy

Date of last revision March 31st, 2021

WHAT IS THE SCOPE OF THIS PRIVACY POLICY?

This Privacy Policy applies whenever you access any of our services, products, websites or their content (including mobile applications) as a non-employee.  This Privacy Policy describes, for example:
  • What personal information we collect and how we collect it
  • The purposes for which your personal information is processed 
  • How you can access and/or update your personal information
  • How your personal information is stored and protected 
  • How we use third party service providers in the processing of your personal information
  • Ways to contact us with your questions about this Privacy Policy or any concerns you have about how we process your personal information 
This Privacy Policy does not cover business communications or information about our business customers, except to the extent such communications or information are required to be addressed in this Privacy Policy by applicable law and regulations.   By using our services, products, content, or websites, you agree that GFL may collect, use share and disclose (“process”) your personal information according to this Privacy Policy.

WHAT PERSONAL INFORMATION IS COLLECTED?

Information that we, or our third party service providers on our behalf, may collect about you includes:
  • Personal or identifying information such as your name, physical address, telephone number, email address, date of birth and social insurance number (note: in general, you may access our websites without providing this type of information). 
  • Information regarding services and products we market or provide to you.
  • Transactional, credit and financial information, for example banking or payment card numbers and expiration dates, and information about your credit, billing, and payment history.
  • Contact and correspondence content such as your requests for customer service, and other information regarding our customer relationship.
  • Biometric information such as photographs and video images that are collected by the cameras on our service trucks and voice recordings of conversations with our client service team.
  • Digital or technical information as described below, including information such as which webpages you visit as well as the frequency and duration of your visits, which web browser you use, computer access points and mobile devices, referring website information, and your Internet Protocol (“IP”) address.  Device-specific information (ex. device model, operating system, etc.) and device-event information (ex. crashes, hardware settings, etc.) may also be tracked. Digital information may sometimes be personally identifying; other times, it may be aggregated or anonymized.
  • Location information, such as your address, zip/postal code, and other information about your location.
  • Social media information, such as information that you post or provide when interacting with our social media accounts or pages.
  • Information regarding your choices and preferences.
  • Other information you provide. 
To the extent your consent is required by applicable law and regulations in order for us to collect your personal information, your consent to such collection will be obtained.  As required by applicable law and regulations depending on the situation, we may seek consent at the time we collect your personal information, or after collection but prior to using or sharing your personal information, or after collection but prior to using or sharing of your personal information for a purpose different than that which was initially communicated. Your consent may be obtained in one of these ways:
  • Express. This means orally, electronically, or in writing, you specifically provide your consent.
  • Implied. This means your consent can reasonably be inferred from your actions or inaction. An example is when you accept our services or products, at which time we are entitled to assume you consent to your personal information collection (and subsequent use, sharing, and storage) related to your acceptance and use of such services or products (or for purpose/s otherwise identified at such time).  By continuing your business relationship with us, we assume your consent to the collection, use, sharing, and storage of your personal information as described in this Privacy Policy.
  • Deemed. This means we are entitled to assume your consent has been given.  For example, if you do not opt-out of consent when offered to do so, your consent will be deemed provided.
We may combine different types of information collected about you.  We may also collect, use, share, or store your information without your knowledge or consent when we are permitted or required to do so by applicable law and regulations.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

Your information may be collected in several different ways, such as:
  • Directly from you. For example,
    • You may provide your contact information by telephone or email as part of a customer service request or account registration.  
    • When you use or access our websites, automated tools, including our chatbot functionality, or digital applications may collect your information. 
    • Our trucks are equipped with cameras which collect photo and video information.
  • Automatically from you. We, and our third-party service providers and partners, may collect your information through automated technology, including tracking technologies that collect information in connection with your use of our services, products, websites or mobile applications. Third parties may collect personal information about your online activities over time and across different websites when you use our websites and mobile applications.  The information collected may include the following:
    • Usage data, such as URLs of webpages you visit, time spent and interactions with our webpages, search terms and results, and whether you open our electronic communications. Our analytics partners may use technologies to analyze your usage data and share this information with us.
    • Identifiers and device information, such as IP address, operating system, browser, browser language, device type, device manufacturer, name and location of your internet service provider.
    • Our marketing partners may use embeds, plug-ins, and other search engine optimization tools to record your real-time use of our websites, including mouse movements, clicks, scrolls, and keystrokes, and share this information with us.
    • Location data, including general and precise geolocation data. 
  • From Other Sources. We may also collect information about you from other sources including our payment processing providers, credit reporting agencies, third party social media services, and from publicly available databases. 

WHY DO WE PROCESS YOUR PERSONAL INFORMATION?

We process your personal information to:
  • Establish, organize, and manage our business relationship with you.
  • Review and tailor the services and products we offer and/or provide to you.
  • Analyze the delivery and your use of our services and/or products. 
  • Ascertain the effectiveness of our marketing of services or products.  
  • Customize services and products that we offer through our websites.
  • Determine the best use of website content as well as service and product offerings.
  • Allow our third party service providers, such as marketing partners, analytics firms, and payment processing vendors, to process, analyze or store your information (please note that providing information to us is your consent for us to transfer it to our third party service providers across international boundaries).
  • Protect us from error, fraud, or theft.
  • Enable us to comply with applicable law and regulations.
  • Assess your credit or financial standing.
  • Undertake and analyze the effectiveness of market research.
  • Tailor and direct marketing and advertising material to you.
  • Track, register, measure, and analyze use of our services, products, websites, and mobile applications.
  • Diagnose problems with our server or troubleshoot our website functionality
  • Evaluate and improve the content of our websites services, products, websites, and mobile applications.
  • Protect and enforce our Terms of Use or our rights, which may include debt collection.
  • Protect the safety of people or property.
  • Defend ourselves against claims or allegations.
  • Facilitate the diligence process in a sale, merger, acquisition, or financing. 
  • Comply with obligations (including to disclose or transfer your information) related to the sale of, or other transaction involving, our assets or business.
  • Enable other purposes described in this Privacy Policy. 
  • Enable other purposes to which you consent at or before providing your information as required by applicable law and regulations.
When a third party collects your information on our behalf, or when we share your information with a third party to obtain data processing/analytics services, we will take commercially reasonable measures to attempt to ensure such information is used or shared for the purposes described in this Policy and in connection with provision of the respective services. Your information which we have collected may also be shared with and/or used by a third party upon your express consent.  We will not sell or license your personal identifying information to third party advertisers. If you are applying for employment with us, we will collect certain personal information from you as part of the application process including your name, address, email address, and any information provided on your cover letter, resume or through the assessment and interview process.  This information may be provided by you to us through our online chatbot functionality or our applicant portal.  We use this information only for the purpose of assessing your suitability for employment and corresponding with you regarding your application.

HOW IS YOUR PERSONAL INFORMATION STORED AND PROTECTED?

Your information (including information collected by third parties which they share with us) will be stored and protected by us in accordance with applicable law and regulations.  Our security practices are designed to mitigate the impact of attacks from any access point to our systems where your information is stored; however we do not warrant or guarantee that a breach will not occur.   We will use reasonable efforts to store your information only for as long as necessary to fulfill the purposes for which it was collected, however we may store some of your information for longer as permitted or required by applicable law and regulations (such as tax or legal requirements).     Please note that your personal information is processed at our operating offices and in any other places where the parties involved in the processing are located. This means that your personal information may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may differ from those of the jurisdiction in which you reside.    Information collected by our Internet service providers (including your IP address) may be stored on such providers’ server logs for extended periods of time.  For information about the policies of our hosting platform, please visit https://wpengine.com/legal/.   We may use third parties to store information which we collect, in which case, we will take commercially reasonable measures to require that our third party service providers only use or share your information for the purposes described in this Policy and in connection with provision of the storage services.   Please note some data may be stored on your device locally via the use of “cookies” (see above) or data caches.

HOW AND WHY WILL WE CONTACT YOU?

We may contact you by mail, e-mail, or phone in order to better manage the business relationship we have with you, for example to:
  • Communicate about our service and product offerings
  • Request your response to marketing surveys
  • Correspond about billing and payments
  • Notify you of a data breach, if you have a legal right to receive such notice
  • Respond to or investigate any request or concern that you contact us about, for example to communicate results of a complaint investigation, to follow-up on a customer service issue, etc.

HOW AND WHY WILL THIS PRIVACY POLICY BE UPDATED?

We may make changes to this Privacy Policy as needed within our business operations, for example:
  • To reflect changes in industry best practices or our legal or regulatory obligations
  • To reflect changes in how we treat information you provided to us 
  • To reflect changes in our business or corporate structure, for example in the case of a merger or sale of all or a part of our business
If we revise our Privacy Policy, we will post the revised version on our websites, so that the websites will always reflect the most up to date version of our Privacy Policy. Any changes to our Privacy Policy will be effective from the time they are posted to our websites; except for any change in why we process your personal information that will only be valid upon your consent to such change to the extent such consent is required by applicable law and regulations. 

HOW TO CONTACT US IN REGARDS TO YOUR INFORMATION OR THIS PRIVACY POLICY?

We have appointed a Privacy Officer who is responsible for ensuring GFL’s compliance with applicable personal information protection laws and regulations. Our Privacy Officer can be reached at: GFL Environmental Inc. 100 New Park Place Suite #500 Vaughan, ON L4K0H9 Canada   You may wish to contact us in regards to this Privacy Policy, for example to:
  • Ask questions about our practices regarding third party service providers we use
  • Change or withdraw your consent, subject to legal or contractual restrictions and reasonable notice (which may limit our ability to have a business relationship with you)
  • Inform us of changes or corrections to your information
  • Ask to see the information we store about you so that you may review or verify it
  • Obtain a copy of any personal information we collected from you
  • Communicate concerns about this Privacy Policy
  • Ask for assistance in preparing your request for access to your information
When contacting us in regards to this Privacy Policy or your information, please do so in writing.  Please note that we may require specific information in order to confirm your identity or right to access the information requested, or to search for and provide what you have requested.  We will let you know in advance if we will plan to charge you a fee for accessing your information.  If our refusal to your request to access your information is permitted or required by applicable law and regulations, we will inform you of such, subject to any legal or regulatory restrictions.

OUR USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

We and our third-party partners may use cookies and similar tracking technologies, such as web beacons, pixels, and tags, to collect, use, disclose, and otherwise process certain information when you use our services, products, websites, or mobile applications. Our website does not respond to do not track signals. We use third-party analytics tools, such as Google Analytics, to collect and analyze information about activities on our website and mobile applications. For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, please refer to www.google.com/policies/privacy/partners/. We also use a third-party tool called Microsoft Clarity to better understand how individuals use and interact with our websites   through behavioral metrics, heatmaps, and session replay. Microsoft Clarity uses cookies and other tracking technologies to collect information on our users’ behavior and their devices, such as how much time users spend on pages and which links they choose to click. For more information on Microsoft Clarity, including how Microsoft may use your information to provide its advertising to you, please refer to https://privacy.microsoft.com/en-us/privacystatement.

THIRD-PARTY WEBSITES

Our websites may also contain links to websites which we do not own or manage, and which are not governed by this Privacy Policy.  Even if accessed via the links on our websites, we do not accept responsibility for any third party websites, including the content of and third party compliance with the privacy policies which govern those third party websites.

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