Privacy policy

Date last updated: 05/01/2026 | Effective date: 05/01/2026

Introduction

At NOWA inc. (hereinafter “NOWA”, “we” or “our”), we attach great importance to protecting the personal information entrusted to us. This Privacy Policy (hereinafter the “Policy”) explains, in clear and accessible terms, how we collect, use, disclose, retain and protect personal information in connection with our products and services, including our PRESENCE platform, our web portal, our mobile application and our customer support services.

This Policy applies to any individual whose personal information is collected by NOWA, whether visitors to our website, Customers of our products, subscribers to the PRESENCE service, users of our management portal, or any other person in a relationship with NOWA.

NOWA is subject to the Act respecting the protection of personal information in the private sector (Québec) (commonly referred to as “Law 25”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). Depending on the context, NOWA may also be subject to the General Data Protection Regulation (European Union, “GDPR”) and the California Consumer Privacy Act (California, “CCPA”).

1. Definitions

“Personal information” means any information that relates to a natural person and allows that person to be identified, directly or indirectly.

“Sensitive information” means personal information that, in particular due to its medical, biometric or otherwise intimate nature, or to the context of its use or disclosure, gives rise to a high reasonable expectation of privacy.

“PRESENCE Service” means the recurring subscription service offered by NOWA that enables remote monitoring and management of installed systems.

“Customer” means any natural or legal person who has purchased a NOWA product or subscribed to a NOWA service.

“Processor” means any company or person processing personal information on behalf of NOWA, in accordance with its instructions.

2. Identity of the controller and contact details

The party responsible for the processing of personal information is: NOWA inc.

8467, Albert-Louis-Van Houtte avenue
Montreal (Quebec) H1Z 4J2 Canada
Telephone: 450-445-0700
Website: www.nowa360.com

The Privacy Officer (PO) is:

Jean-Hugues LaBrèque, President and Chief Executive Officer
8467, Albert-Louis-Van Houtte avenue, Montréal (Quebec) H1Z 4J2 Canada
Email: conformite@nowa360.com
Telephone: 450-445-0700

For any question, complaint or request relating to the protection of your personal information, you may contact our Privacy Officer directly using the contact details above.

3. Personal information we collect

Depending on your interaction with NOWA, we may collect the following categories of personal information.

3.1 When you visit our website

  • Browsing data: IP address, browser type, pages viewed, visit duration, referral source
  • Cookies and similar technologies: see our Cookie Policy

3.2 When you request a quote or make contact

  • Contact details: last name, first name, email address, telephone number, postal address
  • Type of status: owner, building manager, member of a co-ownership syndicate, etc.
  • Information about your project: description of the need, building characteristics, context

3.3 When you purchase a product

  • Billing and delivery details
  • Payment information (processed by our payment provider; NOWA does not store credit card numbers)
  • Transaction history

3.4 When you subscribe to the PRESENCE service

  • Contact details of the Customer and of emergency contacts
  • Information about the building and the configuration of the installed system
  • Real-time sensor data: valve status, leak detections, event logs
  • Technical data about the equipment (versions, models, unique identifiers)

ABOUT PRESENCE SERVICE DATA: The data collected by the PRESENCE service is primarily technical and operational. However, the history of this data may indirectly reveal certain lifestyle habits (for example, prolonged absences or water-use routines). NOWA uses this data exclusively to provide the service and does not carry out any commercial profiling based on this information. You may at any time request clarification from the Privacy Officer.

3.5 When you use the management portal or the mobile application

  • User account credentials (username, encrypted password)
  • Usage preferences and personal settings
  • Connection history and access logs
  • Communications with technical support

3.6 When you request technical support

  • Contact details of the requester
  • Description of the issue and history of interventions
  • Technical data required for diagnosis

3.7 When you sign up for the newsletter

  • Email address
  • Communication preferences

3.8 When you apply for a partnership (installer, reseller)

  • Contact details of the company and the contact person
  • Professional information (licences, certifications, Québec business number (NEQ) or equivalent)
  • Commercial data (geographic area, experience, references)

4. Purposes of collection

We collect and use your personal information solely for the following purposes:

4.1 Provide our products and services

  • Activate, configure and operate NOWA products and the PRESENCE service
  • Process your orders, deliveries and invoicing
  • Enable the monitoring of connected equipment
  • Send alerts, notifications and service reports

4.2 Provide technical support

  • Diagnose and resolve technical problems
  • Perform preventive and corrective maintenance
  • Maintain a history of interventions

4.3 Manage the contractual relationship

  • Manage user accounts and portal access
  • Maintain communication with our Customers and partners
  • Meet our contractual obligations

4.4 Improve our products and services

  • Analyze the use of our platforms (in an aggregated and anonymized manner where possible)
  • Identify improvement opportunities
  • Develop new features

4.5 Communicate with you

  • Keep you informed of our products, services and updates
  • Send newsletters (subject to your consent)
  • Invite you to events

4.6 Meet our legal obligations

  • Respond to requests from competent authorities where required by law
  • Retain information required by tax and commercial laws
  • Prevent and detect fraud

5. Legal bases for processing

In accordance with applicable requirements (in particular the GDPR for individuals located in the European Union), the processing of your personal information relies on the following legal bases depending on the context:

  • Your consent, for marketing communications and certain optional processing
  • The performance of a contract to which you are a party (purchase, PRESENCE subscription, support services)
  • A legal obligation to which NOWA is subject
  • NOWA’s legitimate interest, to the extent that your rights and freedoms do not prevail (for example, for the security of our platforms, fraud prevention, and the improvement of our services)

6. Consent

Where the law requires your consent for the collection or use of your personal information, we obtain it in a clear, free and informed manner. Depending on the context:

  • Consent may be given expressly (by checking a box, signing a document, or responding to an explicit request)
  • It may be given implicitly in certain situations (for example, by using a service after having been informed of the purposes)
  • It may be withdrawn at any time, as easily as it was given, by contacting our Privacy Officer

For sensitive information, we obtain express, separate and specific consent.

For minors under the age of fourteen (14), consent is given by the holder of parental authority or by the guardian.

The withdrawal of consent does not affect the lawfulness of processing carried out before that withdrawal.

7. With whom we share your information

Your personal information may be disclosed, to the extent necessary to fulfill the purposes described, to the following recipients:

7.1 NOWA employees and authorized representatives

Our employees have access only to the personal information strictly necessary to perform their duties. They are bound by confidentiality obligations.

7.2 Processors and service providers

We use processors for services such as cloud hosting, payment processing, the sending of notifications, and analytics. These processors are contractually bound by strict confidentiality and security obligations, and may only use your information for the agreed purposes.

7.3 Certified installers and NOWA resellers

As part of providing our services, certain information may be disclosed to our certified installers and, in some cases, to resellers authorized to operate the PRESENCE service for their own Customers (see our PRESENCE reseller licensing terms). This disclosure is limited to the information strictly necessary for installation, maintenance or the provision of the service. These partners are bound by contractual commitments to protect personal information.

7.4 PREVCAN partners and insurers

Where you are referred by a partner insurer as part of the PREVCAN ecosystem, certain information relating to your prevention efforts may be shared between NOWA, the referring insurer and the installer involved, to the extent strictly necessary to support your project.

7.5 Professional advisors

Our legal, accounting or other professional advisors may have access to certain information where necessary for the performance of their mandate.

7.6 Competent authorities

We may disclose personal information to competent authorities where required or permitted by law, in particular in response to a court order, an investigation or a legal obligation.

7.7 In the event of a corporate transaction

In connection with a sale, merger, acquisition or reorganization involving NOWA, your personal information could be transferred to the acquiring entity, subject to compliance with applicable laws and the commitments of this Policy.

8. Transfers outside Québec and international transfers

Some of our processors, service providers or partners may be located outside Québec, in particular in Canada, the United States or other jurisdictions. In all cases, NOWA carries out a prior assessment of protection factors in accordance with Law 25 and applies appropriate measures to ensure equivalent protection:

  • Assessment of the sensitivity of the information transferred
  • Assessment of the legal regime of the destination jurisdiction
  • Implementation of contractual clauses imposing adequate protection standards
  • Periodic audits and controls of processors

For individuals located in the European Union, transfers of data to Canada benefit from the European Commission’s adequacy decision. For transfers to other jurisdictions, NOWA uses the mechanisms provided for by the GDPR (standard contractual clauses, binding corporate rules, etc.).

9. Retention periods

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal retention obligations. By way of indication:

Data category Indicative retention period
Browsing data and cookies Maximum 13 months after the last interaction
Quote requests with no follow-up 24 months following the last interaction
Customer data and order history Duration of the contractual relationship + 7 years (tax obligations)
PRESENCE sensor data Duration of the subscription + 24 months for support and warranty purposes
Portal user accounts Duration of the subscription + 12 months in the event of inactivity
Communications with technical support 5 years for quality and improvement purposes
Newsletter list Until unsubscription

Upon expiry of these periods, the personal information is securely destroyed or anonymized.

10. Security of personal information

NOWA implements technical and organizational security measures appropriate to the sensitivity of the personal information processed, in order to protect it against unauthorized access, loss, destruction, misuse, alteration or unauthorized disclosure. These measures include, in particular:

  • Encryption of data in transit and at rest for sensitive data
  • Access controls based on the principle of least privilege
  • Enhanced authentication for administrative access
  • Regular backups and continuity plans
  • Continuous monitoring of systems to detect anomalies
  • Staff awareness and training
  • Periodic security audits
  • Strict contractual commitments from processors

11. Your rights

Subject to the exceptions provided for by law, you have the following rights regarding your personal information:

11.1 Right of access

You have the right to obtain confirmation that NOWA holds personal information about you and to access it.

11.2 Right of rectification

You have the right to request the correction of information that is inaccurate, incomplete or equivocal.

11.3 Right to withdraw consent

Where processing is based on your consent, you may withdraw it at any time, which does not affect processing carried out before the withdrawal.

11.4 Right to portability

Since September 2024, you have the right to receive, in a structured, commonly used technological format, the personal information you have provided to us, and to request that it be communicated to another organization.

11.5 Right to erasure (limited)

In certain situations provided for by law (for example, where the purpose has been fulfilled or consent has been withdrawn), you may request the deletion of your personal information.

11.6 Right to object to automated processing

Where a decision concerning you is made solely on the basis of automated processing, you have the right to be informed and to submit your observations.

11.7 Procedure for exercising your rights

To exercise any of these rights, contact our Privacy Officer by email (conformite@nowa360.com), by telephone (450-445-0700) or by postal mail. We will process your request within thirty (30) days of receiving it. Exercising these rights is free of charge, unless the request is manifestly abusive or repetitive, in which case reasonable fees may be charged.

11.8 Recourse

If you believe that your rights are not being respected, you may file a complaint with the Commission d’accès à l’information du Québec or the Office of the Privacy Commissioner of Canada. Individuals located in the European Union may also file a complaint with the supervisory authority of their country.

12. Cookies and similar technologies

Our sites and applications use cookies and similar technologies to ensure their operation, analyze usage and improve your experience. For more details on the types of cookies used and how to manage your preferences, please consult our Cookie Policy, available on our website.

13. Marketing communications

We may send you marketing communications (newsletters, offers, event invitations) subject to your prior consent where required by law. You may unsubscribe at any time by clicking the unsubscribe link included in each communication or by contacting our Privacy Officer. In accordance with Canada’s Anti-Spam Legislation (CASL), these communications clearly identify their sender and allow easy unsubscription.

14. Special protection of minors

NOWA does not target minors directly and does not knowingly collect personal information concerning minors without the prior consent of the holder of parental authority, where such consent is required. If you are a parent or guardian and become aware that information about a minor has been collected without your consent, you may contact our Privacy Officer to request its deletion.

15. Notifications in the event of a confidentiality incident

NOWA maintains a register of confidentiality incidents and has implemented an internal procedure to manage such incidents. In the event of an incident involving a risk of serious harm to you, NOWA:

  • Takes the required measures without delay to limit the risks
  • Notifies the Commission d’accès à l’information du Québec within the prescribed timeframes
  • Notifies you as promptly as possible, unless doing so could hinder an investigation or the communication is impossible
  • Documents the incident and the measures taken

16. Privacy impact assessments

In accordance with Law 25, NOWA conducts a privacy impact assessment (PIA) for any project involving the acquisition, development or redesign of an information system that involves the collection or processing of personal information. This approach makes it possible to identify risks and to put appropriate protection measures in place from the design stage of projects.

17. Jurisdiction-specific rights

17.1 For individuals located in the European Union (GDPR)

If you are located in the European Union, you have additional rights under the GDPR, in particular the right to object to processing and the right to restriction of processing. To exercise these rights, contact our Privacy Officer.

17.2 For California residents (CCPA/CPRA)

If you are a California resident, you have specific rights under the CCPA and the CPRA, in particular:

  • The right to know what personal information is collected, used, disclosed or sold
  • The right to delete personal information
  • The right to correct inaccurate personal information
  • The right to opt out of the sale or sharing of personal information (NOWA confirms that it does not sell or share personal information)
  • The right to limit the use and disclosure of sensitive personal information
  • The right to non-discrimination for exercising your rights

To exercise these rights, contact our Privacy Officer.

18. Changes to this Policy

NOWA may amend this Policy to reflect changes in its practices, its services or applicable legal requirements. The most recent version is published on our platforms together with its update date. In the event of a substantial change, we will inform you by email (if you are a Customer or a newsletter subscriber) or by a visible notice on our website, at least thirty (30) days before the changes take effect, where possible.

19. Governing law and jurisdiction

This Policy is governed by the laws of the Province of Québec and the applicable federal laws of Canada. Any dispute relating to its interpretation or application falls under the jurisdiction of the courts of the judicial district of Montréal, subject to the rights applicable in your jurisdiction of residence.

20. Questions and contact details

For any question concerning this Policy or to exercise your rights, you may contact our Privacy Officer:

Jean-Hugues LaBrèque
Privacy Officer
NOWA inc.
8467, Albert-Louis-Van Houtte avenue
Montreal (Quebec) H1Z 4J2 Canada
Email: conformite@nowa360.com
Telephone: 450-445-0700