Canada Privacy Policy

1. What Is Personal Information?

This Privacy Policy applies to any personal information we collect or receive about you, from you or any other source. “Personal Information” as used in this Privacy Policy refers to any information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual and that is recorded in any form, as further defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial legislation, including Quebec’s Act respecting the protection of personal information in the private sector, British Columbia’s Personal Information Protection Act and Alberta’s Personal Information Protection Act (collectively “Applicable Privacy Legislation”). See section 3 for a list of personal information.

Personal Information does not include information that has been anonymized in accordance with applicable law or information that is otherwise excluded from the definition of personal information under Applicable Privacy Legislation.

2. Personal Information We Collect and Why

We limit our collection of Personal Information to what is reasonably necessary for the purposes identified in this Privacy Policy and as otherwise permitted by law. The purposes for which we collect Personal Information include:

Contacting You. To contact or otherwise communicate with you, including providing customer service, responding to your inquiries or complaints, and providing you with information about our products and services.

Products, Services and Customer Support. To provide the products and services you request, service accounts, fulfill orders, and process transactions and returns (as applicable).

Maintain and Improve Our Services. To provide, improve, administer, and manage our Sites and services. For example, we use this information to analyze the use and delivery of our services, such as determining whether containers have been overfilled or damaged.

Marketing and Advertising. To market and advertise our products and services to you, to inform you about our products or services that we believe will be of interest to you or to provide you with our newsletter. We may contact you by email, post, or telephone, or through other communication channels

Protect Our Company and Interests. For legal, safety, and security purposes; including to protect our rights, property and safety; and those of our employees, customers, and the public, including our Internet service providers, from fraud and other crimes, and to detect and prevent fraud.

Business Operations. To help with our operations such as troubleshooting, operational support, data analysis, surveys, testing, audits, assessments, events management, and research and development.

The Personal Information WM collects directly from you depends on how you use our Sites and services and whether you are performing work for WM through a third-party employer. WM generally collects Personal Information when you request a service, browse a Site or interact with us directly, as deemed necessary for the purposes defined in this Privacy Policy. The Personal Information we may collect about you includes:

A. Personal Identifiers

• Name

• Address

• Email Address

• Telephone Number

• Account Identifiers

• Government-Issued Identifiers

• Driver’s License Number

• Social Insurance Number

Personal identifiers are typically collected when you access certain areas of the WM Sites that require registration for certain services, or if you require more information about those services or send us questions, comments, suggestions or complaints. We may use personal identifiers to contact or otherwise communicate with you, including providing customer service, responding to your inquiries or complaints, and providing you with information about our products and services.

B. Payment Information

• Payment Card Information

• Bank Account Information

• Transaction Information

• Billing Information

If you decide to purchase our products or services, our third-party services providers may need to collect certain additional information, like your credit or debit card number and expiration date, bank routing information and account number.

C. Commercial Information

• Products and Services Purchased

• Account Activity

• Service History

• Marketing Preferences

If you use our services, we may collect information about products and services considered or purchased, primary usage, amount of product ordered, reseller/promo code, auto-delivery selection, transaction history or tendencies, and marketing preferences.

D. Professional and Employment Information

• Resumes

• Qualifications

• References

• Job Title

• Employer Details

If you are engaged to perform work for WM through a third party, we may collect certain information from your employer or from the party that has engaged you as required to perform the services.

E. Device and Technical Information

• IP Address

• Browser Type

• Device Model

• Operating System

• Unique Device Identifiers

• Usage Logs

• Website Interactions

• Mobile Network Information

When you connect to our services using a custom application (apps), we may collect device-specific information through our website or other technologies such as your device model, operating system, unique device identifiers, and mobile network information. We may associate your unique device identifier or phone number with information that you may have used to register for certain services or purchase products. Server logs that are maintained by us or by our third-party service providers may contain information about the services that you have used, and your device-specific information. We may also maintain digital communication logs that track information like your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, and SMS routing information. We may use your device’s IP address or MAC address to track device-event information such as crashes, pages visited, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, broad geographical information, and navigation patterns.

F. Communications Information

• Emails

• Customer Support Correspondence

• Chat Communications

• Call Recordings

• SMS Communications

In certain cases, we may collect additional information such as information you provide through your communications with us or customer support, including call recordings when you contact us through our customer support center and the nature of an inquiry or other information shared.

G. Images, Audio and Video Recordings

We may collect photographs, audio recordings and video recordings, including through:

• Facility Security Systems

• Vehicle Cameras

• Service Delivery Verification Systems

• Customer Service Calls

• Operational Safety Programs

Please be aware that we use cameras capable of recording video in certain locations, including on certain devices, vehicles or containers, to protect our rights, property and safety and those of our employees, customers and the public and in order to look for ways to improve our customers’ experiences. For example, these cameras may capture images of bins that may be damaged or overloaded or that have contamination and WM may then recommend solutions. The purpose of these cameras is not to identify bystanders and when possible, we will be using blurring technology. Where this is applicable, signs will be posted to indicate that cameras are in use. We may also use tools to collect audio, electronic, visual, or similar information such as photographs and images and call/video recordings (e.g., of customer support calls) for similar purposes, including for quality control, employee training and/or for compliance or to fulfill a legal function or obligations and to enforce our terms of services with you.

H. Website and Tracking Information

• Cookies

• Analytics Information

• Advertising Interactions

• Session Replay Data

• Navigation Information

• Website Usage Information

We may collect and store information (including Personal Information) locally on your device through our website or other technologies such as browser web storage (including HTML5), application data caches, cookies or other similar technologies. A cookie is a text file that is placed on your hard disk by a web page server. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. The term “cookie” also includes other similar technologies that store or access information on the user’s device. Certain services may include a unique application number in connection with the installation of apps. This number and information, including, without limitation, operating system type and app version number may be sent to our service providers when you install, update or uninstall apps. We may also collect and process information about your general geographic location, such as your postal code, IP address, your browser type, pages you view, links you click, the length of time you visit or use the service, browsing paths and digital interactions with our site or apps, interaction with websites, apps & ads, and how you use the service. For more information on our use of cookies, visit the Cookies section below.

I. Other Information You Share With Us

In certain cases, the provision of your Personal Information is not required by a statutory or contractual obligation. However, where applicable, the provision of your Personal Information will be necessary to enter into a contract or other arrangement with us or to receive our services and products as requested by you.

3. How We Collect Personal Information

We collect Personal Information from or about you in connection with the products and services that we provide to you, and some of this information may be collected directly from you or automatically from your interactionswith us. When you have been engaged through a third party, it is possible that this third party may communicate your Personal Information to us as required to perform the services.

Directly From You

We collect Personal Information directly from you when you:

• Register for an account

• Purchase products or services

• Request information

• Participate in promotions

• Communicate with us

• Sign up to receive communications from us

• Visit our social media pages

• Contact us directly (via phone, email, etc.) or engage with us through an available chat feature on a site

• Interact with us in person (e.g. visit one of our physical locations, engage with us at an in-person event, etc.)

• Otherwise interact with us

Automatically

We collect Personal Information automatically through online technologies including:

• Cookies

• Web beacons

• Pixels

• Analytics Technologies

• Session Replay Tools

• Similar Technologies

You may manage cookie preferences using browser settings or cookie preference tools available on our websites. In certain jurisdictions, the use of non-essential cookies requires opt-in consent. In these cases, non-essential cookies will be turned off by default and you will need to opt-in for cookies to be fully functional.

From Third Parties

We collect Personal Information from third parties, including:

• Affiliates, subsidiaries and their employees

• Service providers (including companies that support our business, such as waste vendors, business vendors including HR employment-related vendors, payment processors, information technology vendors, financial institutions)

• Business partners

• Cities, municipalities, provincial and other governmental entities and agencies to which we provide services

• Social media platforms

• Analytics providers, including online advertising networks

• Third party websites, including those that allow you to integrate your third-party account data with us

• Publicly available sources, where permitted by law

4. Automated Processing and Artificial Intelligence

We may use automated technologies, analytics tools, machine learning systems, artificial intelligence technologies, or similar technologies to support our operations, including:

• Improving Customer Experience

• Website Functionality

• Cybersecurity and Fraud Prevention

• Analytics and Business Improvement

• Customer Support

• Operational Efficiencies

Where required by applicable law, individuals may request information regarding decisions based exclusively on automated processing, including the Personal Information used and the principal factors leading to the decision.

5. Cookies

We use both first- and third-party cookies. First-party cookies are set by WM, and third-party cookies are cookies set from a domain different to our domain.

We do not control third party websites and are not responsible for their privacy statements. Please refer to any third party’s privacy policy for information on what information they collect, how they use it, and how long it is stored. If you want to block all cookies, you may be able to do so by activating the settings in your browser(s). However, if you use your browser settings to block all cookies (including those strictly necessary for our website to function) then you may not be able to access all or parts of our website.

We use cookies and similar technologies for capturing usage Information (collectively “Tracking Technologies”) for the following purposes:

• Essential. We may use cookies or other Tracking Technologies that we consider ‎are strictly necessary to allow you to use and access our Sites, including cookies ‎required to prevent fraudulent activity and improve security.‎ These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you, which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. Some of these cookies do not collect Personal Information. We also use other first-party cookies to collect certain measurement data that are necessary to help us manage our business activities and that do not collect your Personal Information. You can set your browser to block or alert you about these cookies, but some parts of the site may not work properly.

• Performance Related. We may use cookies or other Tracking Technologies that are useful ‎in order to assess the performance of our web services, including as part of our analytic ‎practices or otherwise to improve the content, products or services offered through our web services.‎ These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the site

• Functional Cookies. We may use cookies that collect information about your choices on our Site you are visiting and enable the Site to provide enhanced functionality and personalization such as your choice of language or region. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

• Advertising Related. We may use Tracking Technologies to deliver content relevant to your ‎interests on our Sites and third-party sites based on how you interact with our content. ‎These cookies are used by third parties to build a profile of your interests and show you relevant adverts on other sites. This includes using Tracking Technologies to understand the usefulness to you of the ‎content that has been delivered to you.‎ They are generally based on uniquely identifying your browser and internet device.

• Session Replay Cookies. We may use cookies, which may be provided by our service providers, for purposes of session replay. These cookies record your interactions with our Sites, including mouse movements, text, and other information, associated with your visit to our Sites. This information is used to help us improve our website and better provide you with information you are interested in when you visit our website. They may be set by us or by third-party providers whose services we have added to our pages. This information is used to help us improve our Sites and better provide you with information you are interested in when you visit our Sites.

• Social Media. We may use certain social media cookies, pixels or other Tracking Technologies that are set by a range of social media services that we have added to the Sites to enable you to share our content with your friends and networks on those platforms. They are capable of tracking your browser across other websites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.

6. How We Share Personal Information

We do not sell Personal Information for monetary consideration.

We may disclose Personal Information:

• Within the WM corporate group

• To service providers

• To comply with legal obligations

• To protect rights, property and safety

• During business transactions

• With your consent or at your direction

• As otherwise permitted by law

At times WM may use the services of independent companies to provide certain services to you, including, without limitation, to entities affiliated to WM, website hosting services, payment processing, product promotions, order processing and shipping services, companies assisting us in conducting business (including waste vendors and governmental entities), information technology vendors and visitor surveys. WM may share your Personal Information with these service providers as appropriate under our business models, including to assist us in carrying out the purposes described in this Privacy Policy, or otherwise disclosed to you, it being understood that they will only be permitted to use the information as part of the performance of their work for us or when the disclosure of the information is required by law and that such third parties will have appropriate privacy standards in place. Other than our service providers, we do not share Personal Information with non-related third parties without your consent, except to the extent necessary to complete your request for products and services offered through the WM Sites.

WM may also use or disclose your Personal Information as is necessary to: (a) comply with a subpoena or court order; (b) cooperate with law enforcement or other government agencies; (c) establish or exercise our legal rights; (d) protect the property or safety of our company and employees, contractors, vendors, suppliers, the public and customers; (e) assert or defend against legal claims; (f) help with internal and external investigations; (g) to complete a business transaction or in the context of a prospective transaction, such as a transfer of assets or shares or merger, in accordance with applicable legal requirements, or (g) as otherwise required by law or permitted by law. We may disclose your information in connection with the sale or merger of a WM company or any transaction that involves the sale or assignment of some or all of our assets.

Service Provider Requirements

We require service providers to protect Personal Information and process it only for authorized purposes. Depending on the circumstances, safeguards may include contractual protections, confidentiality obligations, security reviews and audit rights.

8. International and Cross-Border Transfers

Personal Information may be processed, stored or accessed outside your province or territory of residence, including outside Canada (and outside of Québec, for Québec residents).

When Personal Information is transferred outside Canada, it may be subject to the laws of the foreign jurisdiction. Courts, regulators, governments and law enforcement authorities in those jurisdictions may have access to the information under lawful authority. By providing us with Personal Information, you understand and expressly agree that we may transfer it outside of Canada/ Québec to, for example, the United States of America and/or India. If you do not agree to the transfer of your Personal Information outside of Canada or outside of Québec (for Québec residents), do not provide us with Personal Information.

We implement contractual, technical and organizational safeguards designed to protect Personal Information during cross-border transfers, including by ensuring that your Personal Information will receive adequate protection in the receiving jurisdiction.

9. Security Safeguards

WM has implemented reasonable physical, electronic, and procedural security measures to assist with safeguarding your Personal Information in our possession, and to help protect against unauthorized access and disclosure. Only our authorized personnel and those of our service providers who perform legitimate business functions for WM are authorized to access your Personal Information.

We maintain policies and practices which ensure the protection of your Personal Information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your Personal Information, including:

• Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limit their access to such information on a “need-to-know” basis

• If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, antivirus software and similar measures

• A designated Privacy Officer to monitor WM’s compliance with applicable data protection laws

• Employee privacy and data security training

• Procedures for receiving, investigating and responding to complaints or inquiries regarding WM’s information handling practices, including any security incidents involving Personal Information

• Framework governing the retention and destruction of Personal Information, as more fully described above in the Retention section of this Privacy Policy

• Contractual protections and other measures to ensure that service providers with whom we share Personal Information maintain adequate privacy protections and standards. For example, we generally require our service providers to limit their use and retention of Personal Information to what is necessary to provide their services and to notify us in case of any actual or suspected security incident. We also try to monitor and audit their compliance with these requirements in various ways (e.g., on-site inspections (if feasible), surveys and interviews, proof of certification).

• We maintain procedures for detecting, investigating, documenting and responding to privacy and security incidents involving Personal Information.

Please be aware that despite our efforts, no measures can guarantee security. WM cannot promise, and you should not expect, that your Personal Information, personal searches, and other communications will always remain secure. You should take care with regard to how you handle and disclose your Personal Information or any username or password that you are required to use to access services on our Sites.

10. Retention

We retain Personal Information only as long as reasonably necessary to fulfill identified purposes, meet legal obligations, resolve disputes, or protect legitimate business interests.

When Personal Information is used to make a decision about you, we will retain that information for at least one (1) year, as required by Applicable Privacy Laws.

When Personal Information is no longer required, it will be securely deleted, destroyed or anonymized in accordance with applicable law and company policies.

11. Children’s Privacy

WM’s Sites are general audience Sites. WM’s Site content is not designed for or directed toward children who are under the age of 14. We do not knowingly collect Personal Information from children or minors. If WM becomes aware that a child under the age of 14 has provided us with Personal Information without parental consent, that information will be deleted from our systems. If you have questions about Personal Information that may have been submitted by your child, please contact us as indicated in the Contact Us section below.

12. Your Privacy Rights

You may request access to your Personal Information and request a correction to it if you believe it is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws.

Depending on the law applicable in the jurisdiction where you reside and subject to legal or contractual restrictions, you may also be entitled to:

• Request information on automated processing of your Personal Information. You can obtain information on the Personal Information used to render the decision (and request that this information be correct) and the reasons, principal factors and parameters that led to the decision.

• Request, in certain circumstances, that we cease disseminating your Personal Information or to de-index any hyperlink that allows access to that Personal Information by technological means, if such dissemination contravenes ‎applicable law or a court order.

• Obtain a copy of the Personal Information we collected from you in a structured technological format and that this ‎information be communicated to any person or organization as directed by you.‎

• Obtain additional information about data processing, including the Personal Information collected and how it is processed by WM.

To exercise one of your rights, please contact us as indicated in the Contact Us section below. We will respond within the timelines required by applicable law. We may require you to verify your identity before processing your request.

13. Changes to this Privacy Policy

WM may update this Privacy Policy from time to time, and you should take the time to review it each time that you visit one of our Sites. The Privacy Policy is current as of the date which appears at the top of this page. By using one of our Sites or providing us with Personal Information after we update this Privacy Policy, you agree to this Privacy Policy as revised. If the changes we make are significant, we will provide a more prominent notice and obtain consent when required by applicable laws. If you do not agree to the changes in our Privacy Policy, it is your responsibility to stop using our Sites. It is your obligation to ensure that you read, understand and agree to the latest version of the Privacy Policy.