Summitt Privacy Statement
At Summitt Energy, your privacy is important to us. We are committed to maintaining the confidentiality, security and accuracy of your personal information. This Privacy Statement (the “Privacy Statement”) describes the information that Summitt Energy collects, how we use it and to whom that information may be disclosed.
This Privacy Statement covers the activities of the subsidiaries of Summitt Energy Inc. (collectively “Summitt Energy”).
In particular, this Privacy Statement applies to any personal information Summitt Energy receives, from all individuals, unless the personal information is dealt with in Summitt Energy’s policies that deal with the personal information of employees.
This Privacy Statement applies only to Summitt Energy’s activities that are subject to the provisions of Canada’s federal and provincial privacy legislation, including, where applicable, the federal Personal Information Protection and Electronic Documents Act.
What is Personal Information?
For the purposes of this Privacy Statement, “personal information” means information about an identifiable individual. This does not include the name, title, business address or telephone number of an employee of an organization when used for business communications information about our business customers is not covered by this Privacy Statement.
The Personal Information We Collect
We collect and maintain different types of personal information about individuals with whom we interact. This includes:
- Contact and identification information, such as name, address, telephone number and e-mail address;
- Product and service related information;
- Credit and financial information such as billing and credit history or payment history;
- Customer relationship information, such as customer service requests; and
- Business relationship information.
As a general rule, Summitt Energy collects personal information directly from you. If third parties hold information that Summitt Energy requires, we will endeavor to ensure the information has been collected with your consent.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may also include information related to our interactions with financial and other advisors.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
The Purposes for Collecting Your Information
Summitt Energy collects personal information to allow us to manage and develop our business and operations, including:
- Establishing, maintaining, managing and terminating business relations with you;
- Reviewing the products and services that we provide to you;
- Reviewing the products and services that we obtain from you;
- Informing you of our products and services other than those that you have specifically requested,
- Informing you of products and services Summitt Energy may wish to offer you;
- Protecting us against error, fraud, theft and damage to our goods and property;
- Enabling us to comply with applicable law or regulatory requirements; and
- Any other reasonable purpose to which you consent.
When we collect your personal information, the purpose(s) for collecting the information will be communicated before or at the time of collection.
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Limiting Use, Disclosure and Retention
We use and disclose your personal information when, for example:
- It is for purposes described in this Privacy Statement;
- We are required by law to do so;
- The information is publicly available; or
- It is required for any additional purposes that may be described at the time we advise you of the use of your personal information (which consent may be express, deemed or implied as explained below).
Your personal information may be disclosed when, for example, it is:
- Permitted or required by applicable law or regulatory requirements;
- Part of Summitt Energy’s regular reporting activities to other Summitt Energy subsidiaries in and outside of Canada;
- To protect the rights and property of Summitt Energy;
- During emergency situations or where necessary to protect the safety of a person or group of persons;
- Personal information that is already available to the public;
- To employees, contractors, consultants and other parties (including other members of Summitt Energy) who require the information to assist us to establish, maintain and manage our business relationship with you, including, for example, third parties that provide services to us or on our behalf or third parties that collaborate with Summitt Energy in the provision of services to you;
- To another party, in the event of a change in ownership of all or a part of Summitt Energy through some form of merger, purchase, sale, lease or amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Statement
It is important to us that we collect, use or disclose your personal information where we have your consent to do so or as provided in this Privacy Statement. Depending on the sensitivity of the personal information, your consent may be express, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.
Typically, we will seek your consent at the time that we collect the personal information. In some circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Statement or separately), we will advise you of that purpose before such use or disclosure.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
Consent may be withdrawn or changed, subject to legal or regulatory requirements. Where required, Summitt Energy will advise you of any implications of withdrawing or changing consent. If you wish to withdraw consent, where consent is needed, you may contact Summitt Energy using one of the methods listed in the “Contacting Us” section, below.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Chief Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may limit our ability to provide products or services to, or acquire products or services from, you.
We assume, unless you advise us otherwise, that by receiving a copy of this Privacy Statement or by continuing to deal with us, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Statement.
Safeguarding Personal Information
Summitt Energy will endeavor to safeguard personal information using methods that are appropriate to the sensitivity of the information.
Accuracy of Personal Information
It is important that the personal information Summitt Energy holds about you is accurate and current. Summitt Energy requires you to keep us informed of changes to any personal information.
Retaining Personal Information
Except as otherwise permitted or required by applicable law or regulatory requirements, Summitt Energy will endeavor to retain your personal information only for as long as is necessary to fulfill the purposes for which the personal information was collected.
Accessing Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Chief Privacy Officer using the contact information set out below. Please note that any such communications must be in writing.
When making an access request, we require specific information from you to confirm your identity and right to access, as well as to search for, and provide you with, the personal information that we hold about you.
Summitt Energy may not be able to provide you with access to your personal information, where such refusal is permitted or required by applicable law or regulatory requirements. Summitt Energy will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
You can direct any questions or concerns about this Privacy Statement to Summitt Energy’s Chief Privacy Officer. Summitt Energy will maintain procedures to receive and investigate complaints and complainants will be advised of the results of any such investigation.
To get more information about Summitt Energy’s Privacy Statement, change or withdraw your consent or make a complaint under this Privacy Statement, you can contact us:
Email address: [email protected]
Chief Privacy Officer:
100 Milverton Drive
Revision to this Privacy Statement
Summitt Energy may from time to time make changes to this Privacy Statement to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with personal information. We will post any revised version of this Privacy Statement on our website. Any changes to this Privacy Statement will be effective from the time they are posted, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, unless you consent to that change. This Privacy Statement was last updated on May 1, 2015.
This Privacy Statement does not create or confer on any individual or on Summitt Energy any rights, or impose on Summitt Energy any obligations beyond any rights conferred or obligations imposed by Canadian privacy legislation.
Last Reviewed: January 1, 2018