Confidentiality Policy

As part of our activities, Altitude Aerospace collects, uses, and processes personal information to fulfill its mission as an employer and provider of engineering services. We recognize the importance of respecting privacy and protecting the personal information we have access to. Altitude Aerospace is committed to complying with all applicable personal information protection laws and regulations. This policy outlines how Altitude
Aerospace collects, uses, retains, and destroys the personal information you provide when you are employed by the company, use our website, our services, or interact with our company.

By providing us with personal information, you agree to its processing in accordance with this policy, and you authorize Altitude Aerospace, its partners, and service providers (where applicable) to process your personal information for the purposes described below.

2. Scope

This policy applies to the protection of all personal information held by Altitude Aerospace.

Anyone with access to personal information in the context of their role must comply with this policy.

3. Definitions

In this policy, the following terms mean:

• Anonymization: The process of modifying personal information so that the identification, directly or indirectly, of the individuals concerned is no
  longer possible at any time and in an irreversible way.
• Retention: secure storage of personal information for the required duration. 
• Lifecycle: refers to all stages of processing personal information: collection, use, disclosure, retention, and destruction. 
• Destruction: deletion, elimination, or permanent erasure of personal information. 
• Personal Information Incident: refers to unauthorized access, use, or disclosure of personal information or any accidental or intentional loss,
  alteration, or any other compromise to its protection.
• Data Subject: the natural person to whom the personal information relates.

• Personal Information: any information that relates to an individual and allows them to be identified directly or indirectly, including: names, first names, mailing and email addresses, phone numbers, credit card numbers, social insurance or security numbers, date of birth, etc. It must: 

Reveal something to someone; Be related to a natural person; Be capable of distinguishing that person from another or identifying their nature.

4. Effective date

This policy applies as of September 1, 2023

5. Guiding principles

Respect for privacy and the protection of personal information are essential to us, which is why, through this policy, we aim to protect it in accordance with applicable laws.

To ensure this protection, Altitude Aerospace commits to collecting, processing, and sharing identifiable information only when the individual has consented to it, unless permitted or required by law.

Work contact details, such as name, title, position, mailing and email addresses, and work phone numbers related to a person’s role within an organization, as well as publicly available information as defined by law, are generally not subject to these guiding principles.

• Collection and use

At Altitude Aerospace, we collect only the personal information necessary for our operations.

At the time of collection, and later upon request, we inform data subjects of the purposes for which their data is being collected and of their right to withdraw consent to its use or disclosure.

A data subject who provides personal information is presumed to consent to its use and disclosure for the stated purposes.

Altitude Aerospace uses personal information only for the purposes for which it was collected or when otherwise permitted by law.

Work contact details, such as name, title, position, mailing and email addresses, and work phone numbers related to a person’s role within an organization, as well as publicly available information as defined by law, are generally not subject to these guiding principles.

• Disclosure

Subject to legal exceptions, Altitude Aerospace may not disclose personal information without the data subject’s consent.

• Retention

Altitude Aerospace takes all reasonable steps to ensure the personal information we hold is accurate, current, and complete for the purposes for which it was collected.

Personal information is retained only for the duration necessary for the purposes for which it was collected.

• Destruction and anonymization

Collected personal information is destroyed according to the deadlines in the Personal Information Destruction and Anonymization Schedule.

6. Rights of data subjects

As a data subject, you may request access to the personal information we hold about you. In some cases, a written request may be required. Subject to applicable laws, data subjects have the following rights:

• To know what personal information Altitude holds and obtain a copy. Altitude reserves the right to provide this copy in either electronic or paper format;
• To request that incomplete or inaccurate information be corrected;
• To request deletion of personal information under certain circumstances;
• To withdraw consent for the use and disclosure of personal information.

All requests are processed according to our procedures (Access Request and Complaint Handling Procedure and/or Personal Information Deletion Request Procedure).

7. Use of cookies

We use cookies to enhance your browsing experience and better understand how you use our website. Cookies are small files stored on your computer when you visit our website. They contain information such as display language and browsing behavior. This data is used for statistical purposes and to enable certain features and facilitate navigation. Information collected by cookies is always kept confidential. You may disable or block cookies by adjusting your browser settings.

8. Personal information security

Altitude Aerospace implements reasonable security measures to ensure the confidentiality, integrity, and availability of personal information that is collected, used, disclosed, retained, or destroyed.

These measures take into account the sensitivity of the information, its purpose, volume, location, and format.

9. Personal information incidents

All personal information incidents are handled according to our personal information incident management procedure.

In accordance with the law, Altitude Aerospace maintains a confidentiality incident register.

If an incident poses a serious risk of harm to data subjects, Altitude will promptly notify them and inform the Commission d’accès à l’information du Québec (CAI).

10. Mandatory registers

In compliance with the law, Altitude Aerospace maintains an up-to-date register of personal information.

11. Roles and responsibilities

The protection of personal information held by Altitude Aerospace relies on the commitment of all individuals who handle such information, particularly employees and suppliers, to:

• Act with care, integrate the principles of this policy, and comply with defined procedures;
• Obtain valid consent when collecting personal information;
• Access only the personal information necessary for their duties;
• Securely store files containing personal information so that only authorized persons have access;
• Refrain from disclosing personal information encountered in the course of duties unless authorized to do so;
• Not retain any personal information on any medium after employment or contract ends, and maintain confidentiality;
• Destroy personal information according to the destruction schedule and applicable procedures;
• Report any breach, personal information incident, or irregularity that could compromise the security, integrity, or confidentiality of personal information to the data protection officer.

The data protection officer:

• Ensures compliance with and implementation of the law;
• Is responsible for applying and enforcing this policy and related procedures;
• Supports teams in protecting personal information;
• Supervises coordination in the event of a personal information incident;
• Maintains and updates the incident register;
• Receives and handles written requests from data subjects.

12. Complaint and handling

Any complaint regarding Altitude Aerospace’s privacy practices or compliance with legal requirements must be addressed to the Privacy Officer, who will handle it within a maximum of 90 days:

Data protection officer: Nancy Venneman

Email address: nvenneman@altitudeaero.com

Mailing address: Nancy Venneman

333 Boulevard Decarie, suite 250,

H4N 3M9, Montreal, Qc, Canada

13. Review

This policy will be reviewed annually or as needed to ensure its relevance and effectiveness. Employees will be informed of any significant changes.