Privacy Policy

POWER PARTNER GROUP INC.

Privacy Policy

Effective Date: June 5, 2026

About This Privacy Policy

Power Partner Group Inc., operating publicly as Power Partner (“we”, “us”, “our”), is a corporation incorporated under the laws of Ontario, Canada. We operate the website PowerPartner.ca (the “Site”). Power Partner coordinates and manages residential EV charger installations and related electrical service upgrades (the “Services”), which are performed by independent licensed electrical contractors who obtain and hold all required Electrical Safety Authority (ESA) permits. We also operate an F&I dealership channel through which automotive dealerships offer our installation packages to their customers at the point of vehicle purchase.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information, and your rights in relation to that information. It applies to all interactions with Power Partner, including:

  • Customers who engage Power Partner directly through the Site or by referral
  • Customers whose information is provided to Power Partner by an automotive dealership in connection with the purchase of an installation package as part of an F&I (Finance & Insurance) product offering
  • Users of our customer-facing tools, including the panel verification tool
  • Visitors to the Site

This Privacy Policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada’s Anti-Spam Legislation (CASL). It applies in addition to any specific consent obtained at the point of collection.

1. Information We Collect

We collect personal information that you provide directly, information collected automatically, and information provided to us by third parties on your behalf (specifically automotive dealerships when you purchase an installation package through their F&I program).

1.1 Information You Provide Directly

  • Contact details: name, email address, phone number, mailing address
  • Property details and photos: images or descriptions of electrical panels, garage layouts, charger locations, and any other photos you upload to help us and our contractors assess and quote installation work
  • Transactional information: invoices and billing details where applicable
  • Communications: messages, recordings, notes from phone calls, emails, and any other content you submit

1.2 Information Provided by Automotive Dealerships (F&I Channel)

When you purchase an EV charger installation package through an automotive dealership’s F&I program, the dealership will collect your contact information, vehicle details, and selected installation package, and will transmit this information to Power Partner so that we can coordinate the installation. By agreeing to purchase an installation package through the dealership’s F&I program, you consent to the dealership sharing this information with Power Partner for the purpose of completing the installation.

1.3 Information from Utility Providers (Green Button Data)

To verify that your existing electrical service has sufficient capacity to support an EV charger installation, our panel verification tool may ask you to provide a Green Button XML file obtained from your utility provider (e.g., Hydro One, Alectra, Toronto Hydro). This file contains your residential electricity consumption data, typically covering up to 12 months of historical usage. We collect this data only with your express consent and use it solely for the purpose of performing a load calculation to validate installation feasibility.

Green Button XML files contain sensitive personal information. Section 4 of this Policy describes how this file is handled and how we limit its distribution.

1.4 Information Collected Automatically

  • Technical data: IP address, browser type, operating system, device identifiers, and pages visited
  • Cookies and similar technologies used for analytics and functionality (see Section 8)

2. How We Use Your Information

We use personal information for the following purposes:

  • To coordinate your installation, including site assessment, contractor scheduling, ESA permits (obtained by the licensed contractor), and inspection
  • To verify that your existing electrical service has sufficient capacity for the installation you have purchased (panel verification)
  • To communicate with you about your inquiry, appointments, transactions, site assessment findings, and service updates (transactional/operational communications)
  • To process billing and to issue invoicing to participating dealerships in the F&I channel
  • To send marketing and promotional communications, only if you have opted in (we will obtain separate consent for commercial emails or SMS in compliance with CASL)
  • To improve our Services, perform analytics, keep records for business, legal, and tax purposes, and prevent fraud or abuse
  • To respond to requests, complaints, or legal process
  • To meet regulatory obligations under the Ontario Electrical Safety Code, including cooperating with the Electrical Safety Authority (ESA) in connection with installation permits held by the licensed contractor and inspections, where required

3. Legal Basis & Consent

By using our Site, purchasing an installation package (directly or through a dealership’s F&I program), and providing personal information, you consent to the collection, use, and disclosure described in this Policy.

Where you are providing the Green Button XML file or other utility data, you are providing express consent for Power Partner to receive and process this information for the specific purpose of validating your installation. You may withdraw this consent at any time, though doing so may prevent us from completing your installation.

For marketing electronic messages (email or SMS) we will obtain express opt-in consent in compliance with CASL before sending promotional messages. You may withdraw marketing consent at any time (see Section 11).

4. Who We Share Your Information With

We share personal information only as necessary to provide the Services.

4.1 Electrical Contractors (Subcontractors)

To perform installations, we engage independent licensed electrical contractors. These contractors receive the following information about you for the specific purpose of completing your installation: your name, address, phone number, property and panel details, site assessment findings, and (where applicable) the results of the load calculation performed on your utility data. We do not transmit your raw Green Button XML file to contractors; contractors receive only the load calculation result needed to complete the work.

Subcontractors are independent businesses, not employees of Power Partner Group Inc. They are bound by contractual terms requiring them to: use your information solely for the purpose of completing your installation; maintain confidentiality of your personal information; ensure any employees or helpers with access to your information are bound by equivalent confidentiality obligations; permanently delete your personal information from their systems within thirty (30) days of installation completion, except where retention is required by the subcontractor’s own regulatory obligations under the Ontario Electrical Safety Code (limited to the ESA permit number, the inspection pass date, and the electrical line schematic); and not retain your information beyond what is necessary for installation and regulatory record-keeping.

Once your information has been transmitted to a subcontractor, our ability to control how the subcontractor stores or retains that information is limited, though our contractual terms require the deletion described above and permit us to verify it.

4.2 Automotive Dealerships (F&I Channel)

In the F&I channel, Power Partner shares limited information with the originating dealership (such as confirmation of installation completion, final pricing including any adders, and warranty information) as necessary to complete the F&I transaction and any financing amendments.

4.3 Service Providers

We share information with service providers that perform functions on our behalf. Current and planned service providers include:

  • GoHighLevel (GHL) — CRM, contact management, marketing automation, form processing
  • Google Cloud Storage (Toronto, Canada) — secure storage of Green Button XML files and other technical assets
  • Zoho Mail — business email infrastructure
  • Resend — transactional email delivery
  • QuickBooks — accounting

4.4 Green Button XML File — Handling and Limited Distribution

Because the Green Button XML file contains sensitive electricity consumption data, we handle it under the following controls:

  • Collection and storage: You upload the file through our panel verification tool. The file is stored in Google Cloud Storage (Toronto, Canada), which is our system of record for this data.
  • Use: Power Partner performs a load calculation from the file to validate installation feasibility.
  • Limited distribution: We do not forward your raw Green Button XML file to subcontractors or by email. Subcontractors receive only the load calculation result, not the underlying file.
  • Retention: Power Partner does not retain the Green Button XML file beyond the retention period set out in Section 6.

4.5 Legal or Governmental Authorities

We may disclose personal information where required by law, court order, regulatory requirement, or to protect rights and safety. This includes disclosures to the Electrical Safety Authority (ESA) in connection with installation permits and inspections.

4.6 Business Partners or Successors

In the event of a sale, merger, or reorganization of Power Partner Group Inc., your information may be transferred to a successor business. We will provide notice to affected individuals where required by law.

5. Cross-Border Transfer and Storage

Some of our service providers host or process data outside Canada:

  • Zoho Mail: India-headquartered, servers potentially in multiple international jurisdictions
  • Resend: United States
  • GoHighLevel: United States

Your Green Button XML file and the load calculation derived from it are stored in Canada (Google Cloud Storage, Toronto). By using our Services and providing personal information, you consent to the transfer and storage of your other data on servers outside Canada. We take reasonable steps to ensure that third-party providers use appropriate protections and are bound by contractual confidentiality obligations.

6. How Long We Keep Your Information

We retain personal information only as long as needed for the purposes described in this Policy:

  • Leads / prospective customer records (no transaction): 2 years from last contact
  • Kick-out or cancelled records (assessment did not proceed to installation): site assessment data, photos, and any utility data deleted within 30 days of the kick-out or cancellation, except minimal records required for legal, tax, or fraud-prevention purposes
  • Client and transactional records (invoices, payments, tax records): 7 years
  • Green Button XML files: Retained no longer than 90 days after installation completion in Power Partner’s controlled systems, at which point they are deleted from these systems
  • Site assessment records (photos, measurements, notes) for completed installations: 7 years
  • Marketing consent records: maintained as long as you remain an active subscriber, plus 3 years following unsubscription
  • Privacy breach records: 24 months following the breach, as required by PIPEDA

7. Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information, including:

  • Access controls limiting personal information access to authorized personnel
  • Encryption in transit (HTTPS) for our Site and customer-facing tools
  • Secure storage of sensitive files (Google Cloud Storage with access controls)
  • Limiting distribution of sensitive utility data by processing load calculations in-house and sharing only the result
  • Contractual confidentiality requirements with all subcontractors and service providers

No internet transmission or electronic storage is 100% secure. If we become aware of a data breach that creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by PIPEDA.

8. Cookies & Tracking Technologies

We use cookies and similar technologies to operate the Site, analyze usage, and personalize content. You can manage cookie preferences through your browser settings. Refusing cookies may limit some functionality.

9. Children

Our Services are directed to adults. Because purchasing an installation package requires legal authority to authorize permanent electrical work at a property, our Services are not intended for anyone under the age of 18, and we do not knowingly collect personal information from anyone under 18.

10. Your Rights

If you are in Canada, you have the following rights regarding your personal information under PIPEDA:

  • Access: request a copy of personal information we hold about you
  • Correction: request correction of inaccurate or incomplete information
  • Deletion / erasure: request deletion of your personal information, subject to our retention obligations
  • Withdraw consent: withdraw consent for marketing communications, panel verification data collection, or other processing where consent is the basis for collection
  • Complain: to our designated Privacy Officer (Section 13), or directly to the Office of the Privacy Commissioner of Canada

We will respond to access and rectification requests within 30 days of receipt.

11. Marketing & CASL Compliance

We will send commercial electronic messages (email or SMS) only where we have obtained your express consent. All marketing messages will include an unsubscribe link or clear instructions to opt out. You may withdraw consent at any time by using the unsubscribe link in any marketing email, contacting us at [email protected], or replying STOP to any SMS marketing message.

12. Third-Party Links and Tools

Our Site, customer-facing tools, and the panel verification tool may contain links to third-party websites. We are not responsible for the privacy practices or content of third-party sites.

13. Contact Us

If you have questions, requests, or concerns about privacy, or to exercise any rights under this Policy, contact our designated Privacy Officer:

Privacy Officer: Spencer Smirle, President
Power Partner Group Inc.
Email: [email protected]
Website: PowerPartner.ca

If you prefer to make a formal complaint to an oversight authority, you may contact the Office of the Privacy Commissioner of Canada:
www.priv.gc.ca — 1-800-282-1376

14. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted on the Site with a new effective date, and we will notify customers with active installations in progress via email of any changes that affect their data.

End of Privacy Policy. Effective June 5, 2026 — DRAFT, subject to legal review.