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RS Energy Group Canada - Privacy Policy

Updated: April 2019

Privacy Policy

We know that you care how information about you and your employees and/or clients is used and shared by RS Energy Group (“RSEG”), and we are committed to being transparent about our practices for collecting, using and handling personal information. This Privacy Policy sets forth our policy and practices with respect to the gathering, use, and sharing of personal information we obtain from you through our website at www.rseg.com (“Website”) or that you otherwise provide to us.

This Privacy Policy describes the types of personal information we obtain from you, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of the information. This Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

Consent

BY SUBMITTING PERSONAL INFORMATION TO RSEG, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY APPLICABLE LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting the RSEG Privacy Officer as indicated in Section 11. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

DEFINED TERMS

As used in this Privacy Policy and in addition to the other terms defined in this Privacy Policy, the following terms have the indicated meanings — “Visitor” means a person, other than a Registered User, who accesses that portion of the Website that is accessible without entering a username and password; “Registered User” means a person who has registered on behalf of his or her self (and the company that he or she represents where applicable) in order to access and use content provided only to Registered Users via the Website; “we,” “us,” “our” and “RSEG” means RS Energy Group Canada, Inc., RS Energy Group, Inc., RS Energy Group UK, Ltd, our parent company and any other affiliates that we control or which are under the same common control as us; “you” and “your” means a Visitor or a Registered User, as applicable; “personal information” means any data or information about an identifiable individual, and may include without limitation items such as name, age, sex, marital status, home address and telephone number and personal e-mail address; and “User Information” means individually or collectively, the Registration Information, the Tracking Information, Cookie data, and any other information you provide to us via the Website.

INDEX OF TOPICS

Click on one of the links below to jump to the listed section:

1. Where does RSEG collect information from?

We may collect your personal information from the following sources:

Personal information you give to us:

  • When you contact us (for example by phone, email or letter); and
  • When you use our services, including through the Website.

Personal information we obtain based on your use of our Website or from third parties as described in Sections 2 and 3, such as:

  • Information based on the assessment of analytical information based on your use of our services, including through the Website

You have the option of not providing personal information as described in Section 5. Any personal information that is optional will be clearly marked at the point of collection.

2. What information does RSEG collect and how do we use it?

RSEG collects and uses the following types of personal information:

  • Subscription information, including first name and email address, and occasionally additional information such as name, addresses and telephone numbers;
  • Details of how you use our Website and when and where you have accessed it from;
  • Details of how you interact with us on social media;
  • Details of when any contact between us and you (including voice recordings of telephone calls and copies of written communications such as emails or letters);
  • Details of which RSEG products you have purchased;
  • Any consents which you have given us in relation to the collection, processing and handling of your information;
  • Details of your use of services offered by RSEG; and

Further details about certain types of information we collect and how we use it are set out below:

A. Registration Information. In order to request information via the Website, you may first be required to register and submit to us contact information and certain other information about you (and, where applicable, the company or clients that you represent) (collectively, “Registration Information”). We may use the Registration Information to communicate to you with respect to marketing activities, including advising you of: (i) new and modified services offered by RSEG; (ii) offers made available by RSEG and other businesses; and (iii) other commercial information that we believe will interest you.

B. Tracking Information. When you access the Website, we capture, record and retain general data about your use of the Website including, without limitation, your domain name, your Internet protocol (IP) address, the name and location of the web page from which you entered the Website, the locations you visit within the Website and the amount of time you spend on each page of the Website, (collectively, “Tracking Information”). We use Tracking Information to help administer, update and enhance the Website.

C. Cookies. “Cookies” are pieces of data sent from a Web server to a Web browser that enable a Web server to identify users that visit a website hosted by the server. We use Cookies to identify Visitors and Registered Users on the Website so that we can provide you more customized information and services. The Website uses JavaScript, Google and cookies (such as DART cookies) as well as service providers (such as LeadLander) to help us analyze how Visitors and Registered Users use the Website. At your discretion, you may configure your Web browser not to accept cookies from our Website. However, if you do not accept cookies from our Website, you may lose access to the Website or experience decreased performance of the Website.

D. Login Identification/Passwords. To access certain areas of our Website, RSEG may require you to provide us with a login identification and a password, which we will use to verify your identity and for our internal use in maintaining your Registered User account.

E. Other Information. As a Visitor or Registered User, you may choose to send us a question via e-mail or other electronic means. We will use this information to communicate with you and to enhance the Website to better meet your needs.

F. Aggregate Data. In addition to any other uses described in this Privacy Policy, you agree that we may extract and use information from your Registration Information for the purpose of creating Aggregate Data (as defined in the next sentence). “Aggregate Data” means: a set of Registration Information comprised of any number of Registered Users in an aggregated form only, that does not specifically identify any individual Registered Users and that is not intended to disclose any information that is personally identifiable to an individual Registered User. You agree to allow us, for any internal purposes, to use, develop, analyze, exploit, combine, and extract Aggregate Data, and to disclose and publish Aggregate Data to any third party through any means.

3. Does RSEG share your Registration Information?

Information about our customers is an important part of our business, and RSEG will never share or sell your information to external companies or third parties for their own marketing purposes.

In the usual course of our business, we may use other third party organizations to support the essential delivery of RSEG’s products and services. These organizations process your personal information on our behalf. We may share your personal information with such third party organizations for these reasons:

  • assisting in verifying your identity;
  • assessing risks;
  • understanding your requirements;
  • developing, testing, researching and improving our products and services;
  • marketing products, services and RSEG events/news that we believe may be appropriate and relevant to you [may include sharing general information with a relevant third party involved in RSEG co-hosted/co-sponsored events/guest speakers at RSEG events];
  • legal and regulatory compliance; and
  • improving customer service.

Certain services are provided by third party organizations who collect and use personal information in order to provide those services to you. These third party organizations have a separate responsibility to protect your personal information and will keep you informed about how your personal information will be used. Your personal information will only be shared with third party organizations when required (for example for legal obligations or regulatory requirement or in respect of the products and/or services you request as an RSEG client). When we share your information with our approved third party providers, our contractual relationship with them prevents them from using your information for any other purpose outside of our instructions to them. They may use their own third party data processors, but are always required to meet the same legal requirements as RSEG does. These types of third party organizations provide services such as:

  • Marketing automation tools used as a lead for various email campaigns such as Pardot;
  • Website analytics or tracking user activity on our Website, such as LeadLander;
  • Customer Satisfaction Surveys utilizing Qualtrics;
  • Video hosting including analytics for user activity regarding videos viewed on our Website and time, such as Wistia;
  • Contact data bases used for email campaigns such as Zoominfo;
  • Canadian Revenue Agency, Auditors and US Regulatory Agency (where required or permitted by applicable law.

We share Registration Information only with RSEG affiliates and as described below:

A. Complementary Service Providers. We may work with third party service providers that we do not control (“Service Providers”) in order to expand the information, we are able to offer you on the Website and to enhance your Website experience and to better understand how clients utilize RSEG solutions and what our customers find most relevant and important. In some cases, you may not be aware that Service Providers are involved. You consent to us sharing your Registration Information with Service Providers in relation to their services so long as their policies regarding use of your Registration Information are consistent with and as restrictive as this RSEG Privacy Policy. If you expressly choose to use a Service Provider’s services offered through the Website, then you authorize us to disclose your Registration Information to that Service Provider in accordance with the terms of your express agreement. Participating in website forms such as RSEG blog subscription or RSEG Contact request form, and any other engagement with RSEG’s website assumes your authorization for us to disclose your Registration Information to that Service Provider in accordance with the terms of your express agreement.

B. Agents and service providers. We engage other entities and individuals to assist us with providing the Website and related services, which may include by way of example and not limitation (i) the collection, storage, processing and management of your Registration Information; and (ii) the correction of technical problems with the Website. These entities and individuals will only have access to your Registration Information to the extent necessary to perform their obligations to us.

C. LeadLander. One of the third parties we use to collect and track user statistics and trends related to our Website and services is Upland Software, Inc. through its LeadLander product offering ("LeadLander"). LeadLander's privacy policy and information about how the LeadLander services operate and use data from our Website and services is available at: https://uplandsoftware.com/privacy/. As part of your use of our Website we will install Cookies onto your computer on behalf of LeadLander. You acknowledge and accept the placement of such Cookies which will collect data about your use of our Website and services and other sites and services which utilize LeadLander's services.

D. Qualtrics. Another third party we use to perform and track user’s experience on the website is Qualtrics, LLC. Qualtrics will only have access to the responses that you provide on various customer satisfaction and loyalty surveys regarding your interactions and experience with RSEG.

E. Marketing and Promotional Offers. We may use your personal information to tell you about relevant products offered by us. This is what we mean when we talk about ‘marketing’. We can only use your personal information to send you marketing messages if we either have your consent or a ‘legitimate interest’. A legitimate interest is when we have a business reason to use your information for marketing purposes (which will not unfairly go against your rights and freedoms). In other words, we will not market to you based on legitimate interest if you have told us that you do not want to receive such marketing or are registered on a preference services list.

We may use your Registration Information, and we have a legitimate interest, to:

  • Communicate with you and send you marketing messages about RSEG’s products and services, including (i) new and modified services and features offered by us; and (ii) special offers made available by us (collectively, the “Unsolicited Marketing Offers”);
  • Contact you via telephone to welcome you to RSEG; and
  • Send you marketing messages by email or via social media about products offered by RSEG which are similar to those you have already purchased (if you have provided us with an email address).

We may share your Registration Information and responses to questionnaires and surveys with other businesses who offer products and services that are complementary to our services. If you do not want us to share your Registration Information with other businesses and if you do not want to receive Unsolicited Marketing Offers, then you should contact us in accordance with Section 11 below and request to “opt out” from receiving Unsolicited Marketing Offers. Upon receipt and processing of an opt out request, we will not share your Registration Information with other businesses and will not send you further Unsolicited Marketing Offers.

We will ask your explicit consent to send you any other marketing messages.

You can withdraw your consent or ask us to stop sending you any marketing messages at any time. If you want to do so, please contact us in accordance with Section 11.

F. Business Transfers. We may be involved in the sale or transfer of some or all of our business, including as part of a reorganization. As part of that sale or transfer, we may disclose your Registration Information to the acquiring organization but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.

G. Law Enforcement, Legal Disclosure and Protection of the Website and others. We will release your Registration Information when we believe release is appropriate (i) to comply with laws or regulations; (ii) in response to judicial process, including to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information; (iii) for the enforcement of any agreement we may have with you; or (iv) for the protection of rights, property, or safety of RSEG or others.

H. With your consent. Other than as set out above, you will receive a notice when your Registration Information might be sent to third parties, and you will have an opportunity to “opt out” by contacting us in accordance with Section 11 below and requesting to “opt out” from having your Registration Information sent to third parties. Upon receipt and processing of an opt out request, we will not share your Registration Information with third parties. If you do not “opt out”, then you will have consented to our sharing your Registration Information with third parties.

4. For Users within the European Economic Area (“EEA”) - How the law protects you?

Your privacy is protected by law, which says that we can use your personal information only if we have a proper reason to do so. This includes sharing it outside of RSEG as described in Section 3. The reasons why we may process your personal information are:

  • To fulfil a request by you for us to send you news, information or promotional materials;
  • When it is our legal duty;
  • When it is our legitimate interest; or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information, but this must not unfairly go against your rights or freedoms. If we rely on our legitimate interest, we will tell you what that is. The following table provides a summary of how we use your personal information, our reasons for processing it and our legitimate interests for the processing (where applicable):

What We Use Your Personal Information For Our Reason(s) for Processing Our Legitimate Interests (where applicable)
-to manage our relationship with you
  • - fulfilling obligations
  • - Our legal duty
  • - Your consent
-keeping our records up to date
  • -to communicate with you about your membership with RSEG or products you have purchased
  • - to develop and carry out marketing activities
  • -to conduct analysis and research activities to improve and develop our products and services
- our legitimate interest
  • -working out which of our products and services may interest you and telling you about them
  • - defining audiences to market RSEG products to
  • -seeking your consent when we need it to contact you
  • -being efficient about how we fulfil our legal and contractual duties
-to provide you with products/services we can offer when requested
  • -fulfilling contracts
  • -our legal duty
  • -our legitimate interests
  • -being efficient about how we fulfil our legal and contractual duties
  • -complying with laws and regulations that apply to us
-to manage risk for RSEG and our reader group members or customers -to comply with laws and regulations that apply to us
  • -our legal duty
  • -our legitimate interests
- complying with laws and regulations that apply to us - being efficient about how we fulfil our legal and contractual duties
-to exercise our rights as set out in our agreements or contracts - fulfilling contracts

5. What are your rights regarding your personal information?

  • If your personal information has been processed on the basis of your consent, you may withdraw your consent at any time.
  • You can request to access your personal information.
  • You can request to rectify your personal information if it is in accurate, incomplete or out of date.
  • You can request the erasure of your personal information (i) if your personal information if no longer necessary for the purpose for which it was collected and processed, (ii) you have withdrawn your consent on the processing based exclusively on such consent, (iii) you objected to the processing, (iv) the personal information processing was unlawful, (v) the personal information must be erased to comply with a legal obligation applicable to RSEG.
  • You always have the option to not share any of your personal information with us. If you choose this option, it may delay or prevent us from meeting our obligations. It may also mean that we cannot provide you with a product or service which you have purchased from us, or you may be limited in the activities and features we can provide you for which such personal information is necessary. We will notify you if your choice not to give personal information to us would result in a delay or prevent us from meeting our obligations.
  • You have the right to object to the processing of your personal information by us, including for marketing purposes.

6. Risks where Service Providers are located in foreign jurisdictions

Use of your personal information by service providers as provided in this Privacy Policy may result in your personal information being transferred across international borders. It may be transferred to countries that have a different level of data protection laws that the one existing in the county from where you submitted your personal information. RSEG takes appropriate measures to maintain the security of your personal information both during transit and at the receiving location by implementing contractual clauses in accordance with applicable law. In addition, please review the information below that is specific to our users located within each of North America and the EEA:

A. Users within North America. Your personal information or your employees’ and/or clients’ personal information may be subject to access by law enforcement or regulatory authorities in foreign jurisdictions according to the applicable laws of such other jurisdictions. We expect and assume that you will have provided notice to and/or obtained consent from your employees and/or clients (where required by law) with respect to any sharing of your employees’ and/or clients’ personal information on our Website. You are responsible to provide your employees and/or clients with such notice (and/or to obtain such consent from your employees and/or clients) as may be required under applicable privacy and other laws, and by using our Website and providing such employees’ and/or clients’ personal information with us, you expressly represent to us and agree that you have provided such notice or have obtained such consent.

B. Users within the EEA. Data protection law holds all countries in the EEA to the same high standards. If we transfer your information outside of the EEA, we will make sure that it is protected to these standards. RSEG will only send your personal information to countries outside of the EEA to:

  • follow your instructions;
  • comply with a legal duty; or
  • work with other third party organizations we use to help provide RSEG services to you.

We will always use one or more of these safeguards:

  • Transfer personal information only to a non-EEA country with privacy laws that give the same protections as in the EEA;
  • Put in place a contract with the recipient that means they must protect personal information to the same standards as in the EEA; or
  • Transfer personal information to organizations that subscribes to the Privacy Shield. This a framework that sets privacy standards for exchanges of personal information for commercial purposes sent between the US and EU countries.

7. What security measures are taken regarding the Website and personal information?

RSEG has taken precautions to protect the Website data and information under our control from misuse, loss, or alteration. Our security measures include appropriate technical and organizational measures to protect the confidentiality and security of your Registration Information. Unfortunately, no system or measures can ensure complete security and you should also take steps to protect your information and transmissions. You must decide what security measures are appropriate for you; however, common examples are keeping your login identification and password secure and making sure you completely log out when you have finished using the Registered User section of the Website. You should also understand that any time you share personal information, it could be accessed by a third party, such as hackers. As such, you should take care to ensure that you have considered this possibility when sharing personal information.

8. How do you access and correct your information?

You can access your Registration Information by contacting us in accordance with Section 11 below. If you believe there are factual errors in such information, you may contact us in accordance with Section 11 and specify the alleged errors. We will make reasonable efforts to verify and correct any factual errors within a reasonable amount of time. Where we are not able to make the change you request, we will annotate our records to reflect the fact that you requested the change and the reason why the change was not made.

9. What if our Privacy Policy changes?

We will post all changes to our Privacy Policy on our Website so you may always become aware of what information we collect, use and disclose. If at any point we decide to use or disclose your Registration Information in a manner different from that stated at the time it was collected, we will notify you by way of an e-mail or a notice posted on the Website. Your use of the Website after such a notice is posted is deemed to be acceptance of the revised Privacy Policy.

This Privacy Policy was last updated in February 2019.

10. How long can we store your User Information?

We may store your User Information as long as reasonably necessary for our business and legal purposes, including for as long as your account is active, for the duration of the contract with you or as needed to provide you with the services you requested, to answer questions, resolve problems or provide improved and new services, and as otherwise provided in this Privacy Policy. We may also retain your User Information in accordance with our internal retention procedures as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements, or as otherwise authorized or permitted under applicable law.

11. How do you contact us or the relevant Privacy Commissioner or Supervisory Authority?

You may contact us with questions regarding this Privacy Policy or our information collection or processing practices at privacy@rseg.com or in writing at:

Suite 1400, 585 8th Avenue SW
Calgary, Alberta, Canada T2P 1G1
Attention: Privacy Officer

You are informed that you can also lodge a complaint with the privacy commissioner or supervisory authority of the province or country where you are located if you have any concerns about our information collection or processing practices. In the United Kingdom, the applicable supervisory authority is the Information Commissioner’s Office.

12. What is RSEG’s responsibility for links to other websites?

The Website may contain links to other websites not owned or controlled by us. We are not responsible for the privacy practices, content, products or services offered through such other websites.