Privacy Policy

WEBSITE TERMS OF USE

PRIVACY NOTICE PURSUANT TO ART. 13 OF THE GENERAL DATA PROTECTION REGULATION

For purposes of GDPR, the Controller is:

GHGSat Inc.

3981 Boul. St-Laurent, Suite 500

Montreal, Quebec

Canada, H2W 1Y5

privacy@ghgsat.com

Purpose for Processing

GHGSat Inc. collects and processes your personal data, as the data subject, for the purpose of communicating with you regarding the business of GHGSat Inc., its subsidiaries, or affiliates.

Legal Basis for Processing

The legal basis for processing the personal data of the data subject is a) the data subject’s consent; b) it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; c) it is necessary for compliance with a legal obligation to which the Controller is subject.

Third Party Data Processing

We may process the information to third parties for the purpose set out above. Some third party recipients of data may reside outside the European Union. In the event that the recipient country does not ensure a level of data protection equivalent to that of the European Union, the company undertakes to take all appropriate guarantees, either on the basis of an adequacy decision such as that for the Privacy Shield, or, in the absence of such a decision, on the basis of appropriate guarantees, in particular those drawn up on the model of standard contractual clauses made public by the European Commission a copy of which may be requested at privacy@ghgsat.com.

Data Retention

Storage retention period of your data depends and is determined by corporate policies, government regulatory requirements, and other factors like the need for data storage space.

Privacy Rights

If you are located within the European Union or another country that has adopted GDPR, the following applies:

1. You have the right to access, modify, rectify, limit and/or delete any personal data as well as a right of opposition, if necessary, subject to legitimate and imperative reasons, to the processing of these data. If you wish to exercise your rights, you can contact privacy@ghgsat.com.

2. You also have the right to lodge a complaint with a supervisory authority.

3. For data processing based on your consent, you have the right to withdraw your consent to the processing of your data at any time. The withdrawal does not affect the lawfulness of processing based on your consent before its withdrawal.

If you would like to withdraw your consent please contact privacy@ghgsat.com.

4. You have the right to object to the processing of your personal data at any time on grounds relating to your particular situation. We ask you to provide the reasons and legitimate interest to back up your objection. In case of a legal objection, we shall no longer process your personal data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. We shall inform you on the grounds of our decisions.

Legal Obligation

You are obliged to provide your personal data based on government regulatory requirements for personal screening of visitors, and various other requirements. If you fail to provide your personal data, you may be denied the ability to do business with GHGSat Inc., or access to our facility.

Automated Processing

The processing of your personal data may be automatically processed or “screened” as necessary for entering into, or performance of, a contract between the data subject and a data Controller.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020

This California Privacy Notice (this “notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to GHGSat Inc.’s and its subsidiaries’ (“Company” “us” “we” our”) other privacy policies or notices.

To aid in readability, in some places we have abbreviated or summarized CCPA terms or language. Terms defined in the CCPA that are used in this notice shall have the same meaning as in the CCPA.

For more information on this notice or your California privacy rights email us at privacy@ghgsat.com or, write to us at: 3981 Boul. St-Laurent, Suite 500, Montreal, Quebec, Canada, H2W 1Y5.

PERSONAL INFORMATION WE COLLECT

We have collected the following categories of personal information from Consumers within the last twelve (12) months:

Identifiers

This may include but is not limited to: a real name, postal address, Internet Protocol address, email address, social security number, driver's license number, passport number, or other similar identifiers.

We collect this information directly from the Consumer for the purpose of responding to direct requests for information, recruiting, training, and conveying product specifications.

Personal Records

This may include, but is not limited to: signature, telephone number, education, employment, employment history, credit card number, or any other financial information or medical information.

We collect this information directly from the Consumer for the purpose of responding to direct requests for information, recruiting, training, and conveying product specifications.

Internet Usage Information

This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.

We collect this information directly from the Consumer for the purpose of tracking website traffic volume per page.

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as personal information and we reserve the right to convert, or permit others to convert, your personal information into deidentified data or aggregate consumer information.

Subject to restrictions and obligations of the CCPA, our vendors may also use your personal information for some or all of the above listed business purposes. Our vendors may themselves engage service providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an additional business purpose for which we are providing you notice.

SHARING PERSONAL INFORMATION

We may share personal information with third parties for a business purpose. In the last twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Identifiers

Personal Records

Customer Account Details / Commercial Information

Internet Usage Information

Geolocation Data

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.

Service providers.

Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the last twelve (12) months, we have not sold any personal information.

CALIFORNIA PRIVACY RIGHTS

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification process. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected personal information.

If we cannot comply with a request, we will explain the reasons in our response. We will use personal information provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or clearly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Additionally, you have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining. Once we receive and confirm your request, we will disclose to you:

The categories of PI we have collected about you.

The categories of sources from which we collected your PI.

The business or commercial purposes for our collecting or selling your PI.

The categories of third parties to whom we have shared your PI.

The specific pieces of PI we have collected about you.

A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.

A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred.

If we sold your PI, we will explain:

The categories of your PI we have sold.

The categories of third parties to which we sold PI, by categories of PI sold for each third party.

Deletion Request Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your personal information that we did not collect directly from you.

Do Not Sell

We do not sell your personal information as such is defined under the CCPA, and until such time as we change this policy by updating this notice, will treat personal information collected under that policy as subject to a do not sell request.

Ours and Other’s Rights

Notwithstanding anything to the contrary, we may collect, use and disclose your personal information as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

Changes to Our Privacy Notice

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will notify you through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our privacy policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: privacy@ghgsat.com

Postal Address: 3981 Boul. St-Laurent, Montreal, Quebec, Canada, H4M 2S9