Privacy Policy

This notice reflects LRL's Privacy Policy, effective September 28, 2026.  |  Privacy Officer: Harlyn Porter, IT Manager (Privacy Officer), privacy@ledroadwaylighting.com

LED Roadway Lighting Ltd. and its division Liveable Cities (together, "LRL") design and manufacture LED streetlights, lighting controls and smart city sensors. This notice explains what personal information LRL collects, why, who it is shared with, how long it is kept, how it is protected, and the rights you have. It applies to ledroadwaylighting.com and liveablecities.com, and to the personal information LRL handles in the course of its business.

In short: LRL collects personal information only for a stated purpose and uses it only for that purpose. Video and data from devices we install for our customers belong to those customers, and LRL handles it only on their instructions. You can ask to see, correct or delete your information at any time by contacting our Privacy Officer.

What We Collect and Why

Customers and business contacts

Contact details, order records and warranty claims. We use them to fulfil orders, handle warranty claims and provide customer service.

Our websites

When you contact us through a form, we collect what you provide, such as your name, email address and phone number, and the details of your request for product information, a demo or a quote. If you subscribe to our newsletter or marketing email, we collect your email address and a record of your consent. With your consent, analytics tools also collect information about how you use our websites, including your IP address and browsing behaviour. We use this information to respond to your enquiry, to send marketing only to people who have agreed to it, and to improve how our websites work.

Cameras at our premises

We record camera footage at LRL premises to deter criminal activity and to protect our people and property.

Devices we install for our customers

Our connected devices collect data for the customers that operate them. That is explained in the next section.

Legal requirements

We also use personal information where the law requires it.

Devices We Install for Our Customers

LRL installs streetlight controllers, luminaires, environmental and traffic sensors, and SLX-VIDEO cameras for customers such as municipalities and utilities. The data these devices produce belongs to the customer.

  • Lighting controllers and luminaires report energy use, faults, dimming and the location of each light. This is information about the lighting network, not about people.
  • Environmental and traffic sensors report measurements such as air quality, particulates, noise levels, vehicle counts and speed. They do not record individuals. Our noise sensors measure sound levels only and do not record audio.
  • SLX-VIDEO cameras capture video and images of roads, sidewalks and other public areas. We treat all of this video and imagery as personal information, because a person or vehicle can often be identified even when a face or licence plate cannot be seen.

Who decides. For devices installed for a customer, the customer decides what the devices are for, where they are placed, and when video is viewed or retrieved. The customer is responsible for the information, and LRL handles it only on the customer's documented instructions under a written agreement. LRL does not use customer data for its own purposes. Customers can also apply privacy masks to block out private property such as homes, yards or windows.

Signage and notice. Telling the public that cameras are in use is the customer's responsibility, through its own signage or privacy notice.

By default, video stays on the device. An SLX-VIDEO camera records to its own storage and analyzes video on the device. Video leaves the device only when the customer chooses to view or retrieve it.

Questions about footage of you. If you want to know about video of yourself recorded by one of these cameras, contact the organization that operates the cameras, or contact our Privacy Officer, who will pass your request to that customer. The customer decides how to answer, and LRL supports it.

Cookies and Similar Technologies

Our websites use cookies and similar technologies. Some are needed for the site to work. Analytics and marketing technologies measure how the site is used and help us show relevant content, and they do not load until you consent.

Consent on ledroadwaylighting.com and liveablecities.com is managed by Complianz. The consent banner lets you accept all, deny all, or choose by category, and you can change or withdraw your choice at any time. Your choice is stored in the website's own database, not sent to a third party.

Each site's Cookie Policy lists the technologies in use, by name, category, cookie name and duration. It is generated from a regular scan of the site, so it shows what is actually in use:

Marketing Email

We send marketing email only to people who have agreed to receive it, as required by Canada's Anti-Spam Legislation (CASL). Every marketing email has a single-click unsubscribe link, and we process unsubscribe requests within 10 business days. If your only connection with us is an enquiry, we may send you marketing email for up to 6 months after it, and after that only if you have agreed. When you unsubscribe, we keep your email address and the date on a do-not-email list so that you are not emailed again. We use email open and click tracking to see how well our marketing emails perform.

Who We Share It With

We use service providers to help run our websites, marketing, analytics and other services, including:

  • Local Fresh, Inc.: website hosting, maintenance, backups and form handling
  • Google LLC: website analytics (Google Analytics)
  • Mailchimp: distribution of marketing email to mailing-list subscribers
  • Microsoft Corporation: email and business systems (Microsoft 365, Azure)

They handle personal information only on our behalf and on our instructions. Each is bound by a written agreement that requires it to:

  • use personal information only for the purposes we authorize
  • keep it secure
  • not retain, share or use it for any other purpose
  • tell us without delay of any breach or attempted breach of confidentiality, and of any security incident affecting personal information
  • let us verify that it is meeting these requirements
  • return or securely destroy the information when the work ends

Some technologies on our websites, such as embedded maps and video (Google Maps, YouTube), fonts, and social media content, are provided by third parties that handle your information under their own privacy policies. They are listed in each site's Cookie Policy and load only with your consent.

AI tools

LRL staff may use approved enterprise AI tools in their work. Personal information may be processed by those tools only for the purpose it was collected for, under an enterprise data processing agreement, and it is never used to train third-party AI models.

How Long We Keep It

Website enquiry and contact form submissions 12 months after the last contact, unless the enquiry becomes a customer relationship
Marketing contacts Only while we have valid consent, and deleted 12 months after the last contact unless the enquiry becomes a customer relationship
Records of marketing consent As long as we rely on the consent, and 3 years after the last message sent under it
Unsubscribe requests Kept on our do-not-email list so you are not emailed again
Customer and order records 7 years, for business record and tax purposes
Website analytics (Google Analytics) 14 months
Video from devices installed for customers Set by each customer, up to 31 days in normal use. Video on a device's own storage is overwritten as the storage fills
Camera footage at LRL premises Up to 14 days, longer only for an active investigation or legal proceeding
Privacy requests and complaints 24 months after the request or complaint is closed
Records of privacy incidents At least 24 months

How We Protect It

We protect personal information wherever we hold it, with security controls suited to how sensitive it is. Access is limited to people who need it for their work. Staff who handle customer video must complete the privacy training that customer requires before they are given access.

Our Privacy Officer is accountable for privacy across LRL, including this notice, privacy impact assessments before new systems or uses of personal information, and handling requests and complaints. The Privacy Officer is also the person in charge of the protection of personal information under Quebec's privacy law.

If something goes wrong

We record every privacy incident. If an incident creates a real risk of significant harm to you, we notify you and the Office of the Privacy Commissioner of Canada as soon as feasible, along with any organization that may be able to reduce the harm. If you are in Quebec and an incident presents a risk of serious injury, we promptly notify you and the Commission d'accès à l'information du Québec. Where the information belongs to one of our customers, we notify that customer, and the customer decides on any notice to you and to its regulator.

Where Your Information Is Stored

Some of our service providers, including analytics, customer relationship management, email marketing and hosting providers, are located outside Canada, including in the United States. Our websites are hosted by our web provider in the United States, and data from our connected devices is processed in Microsoft Azure's Canada Central region. Information stored outside your province or country may be subject to the laws of that place. We require our service providers to protect personal information to the standard Canadian privacy law requires.

If you are in Quebec, your information may be communicated outside Quebec, including to another Canadian province. Before that happens, we assess the privacy risks and put a written agreement in place.

Our devices operate in over 60 countries. Where data from a deployment outside Canada is sent to our infrastructure in Canada, Canadian privacy law applies to it, and the data-protection law of the country where it was collected may also apply.

Your Rights

You can:

  • ask to see the personal information we hold about you
  • ask us to correct information that is inaccurate or incomplete
  • ask us to delete your information where we no longer need it for a legal or legitimate business purpose
  • withdraw your consent, subject to legal and contractual obligations

If you are in Quebec, you can also ask to receive computerized personal information you gave us in a structured, commonly used format; be told when we make a decision about you based only on automated processing, and on request learn the information, reasons and main factors behind it; and ask us to stop disseminating your information or to de-index a link attached to your name where the dissemination breaks the law or a court order, or seriously harms your reputation or privacy.

If you are in the United Kingdom or the European Union, you have rights under the GDPR, including access, rectification, erasure, restriction and objection. Where your information comes from a device we operate for a customer, we handle your request together with that customer.

How to Make a Request or Complaint

Contact our Privacy Officer using the details below. We acknowledge a request within 5 business days and reply in writing within 30 calendar days. Access is free. If we charge a reasonable fee for transcribing, copying or sending information, we tell you the approximate amount first. If we refuse a request, we tell you in writing why, which law we are relying on, and what you can do next.

Complaints

You can complain to our Privacy Officer about how we handle personal information. We acknowledge a complaint within 5 business days, investigate it, and reply in writing within 30 calendar days with the outcome and any corrective action taken.

If you are not satisfied, you can contact the Office of the Privacy Commissioner of Canada. If you are in Quebec, you can also contact the Commission d'accès à l'information du Québec.

Changes to This Notice

We review this notice at least once a year, and update it before or at the same time as any material change in how we handle personal information, such as a new product line, a new way of collecting personal information, or a new service provider.

Contact Us

Privacy Officer
Harlyn Porter, IT Manager (Privacy Officer)
LED Roadway Lighting Ltd.
84 Chain Lake Drive, Suite 403, Halifax, Nova Scotia B3S 1A2, Canada
Email: privacy@ledroadwaylighting.com (Liveable Cities enquiries: privacy@liveablecities.com)
Telephone: +1-902-667-1228 ext. 206