Commercial Privacy Policy

Purpose

Nauticol Energy Ltd. and its affiliates are committed to protecting personal information provided by vendors, suppliers, contractors, website visitors and other individuals (collectively, “Business Contacts“).

This policy applies to Nauticol Energy Ltd. and any affiliate of Nauticol Energy Ltd. that collects, uses and discloses personal information in Canada (collectively, “Nauticol“).

The purpose of this policy is to outline the practices that Nauticol follows in protecting and managing personal information collected, used and disclosed by Nauticol in relation to its business.

Definition of Personal Information

Personal information means information about an identifiable individual such as an individual’s home contact information, email, phone number and financial information.  Personal information does not include information that is publicly available, such as information in a telephone directory, or business contact information (information that would appear on a business card). 

Collection, Use and Disclosure of Personal Information

In relation to Business Contacts, Nauticol collects personal information necessary to the business relationship, including information needed:

  • to establish and maintain relationships and communicate with Business Contacts;
  • to establish and maintain a commercial relationship;
  • to develop, enhance, market, promote or provide products and services;
  • to manage and develop Nauticol’s business operations;
  • to provide customer service;
  • to notify Business Contacts of potential jobs;
  • in relation to a business transaction; and
  • for any other purpose identified in a privacy consent form or statement.

Such personal information may include a Business Contact’s:

  • company and individual names,
  • website,
  • phone number,
  • email,
  • workplace and home contact information, and
  • any additional marketing information

In some cases, Nauticol may require Business Contacts to demonstrate individual consent obtained for the collection, use and disclosure of personal information provided to Nauticol.

Nauticol will use and disclose personal information only for the purposes for which the information was collected, except as authorized by law.  Nauticol will notify and, if required, obtain consent for use and disclosure of personal information which falls outside the purposes for which the information was originally collected.

Nauticol discloses a limited amount of personal employee information to certain third-party service providers located within Canada, including PCL Construction which is engaged in the construction of a project for Nauticol, and who is managing the sub-contractors on that project. Nauticol requires that such service providers maintain privacy protections that are equivalent or substantially similar to those outlined in this policy.

Nauticol stores personal information on its computer system.  Access to personal information stored on such system is limited to individuals on a need-to-know basis.  The system engages technological safeguards to protect the personal information stored on its system.

Protection of Personal Information

Nauticol will make every reasonable effort to ensure that personal information is accurate and complete.  If you are aware of an error in personal information about you, please let us know and Nauticol will correct it on request whenever possible.  In some cases, Nauticol may ask for a written request for correction.

Nauticol protects personal information in a manner appropriate for the sensitivity of the information and will make every reasonable effort to prevent loss, misuse, disclosure, copying, modification, disposal or destruction of personal information or any unauthorized access to personal information.  Nauticol will retain personal information only for as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.  When destruction is appropriate, Nauticol will employ appropriate measures to destroy personal information, including shredding paper records and permanently deleting electronic records.

Access to Records

Employees and former employees of Nauticol may access their own personal information in Nauticol’s custody or control, except in specific circumstances.  For example, privacy law prohibits access to information that may contain personal information about another individual or confidential business information.  If refusing a request in whole or in part, Nauticol will provide the reasons for the refusal.  In some cases where exceptions to access apply, Nauticol may withhold that information and provide the remainder of the record.

Individuals may make a request for access to their personal information by writing to Nauticol’s Privacy Officer, Marc Adler. Sufficient information must be provided in the access request to allow Nauticol to identify the information being sought.

Nauticol will endeavour to respond to an individual’s request for information within 30 days of receiving the written request and will indicate whether the individual is entitled to access the information. If access is refused, Nauticol will provide reasons for the refusal, the name of the person who can answer questions about the request and advise of the right to have the decision reviewed by the applicable Privacy Commissioner.

Questions

Any questions about this policy or the collection, use and disclosure of personal information by Nauticol should be directed to Nauticol’s Privacy Officer:

Marc Adler, Chief Legal Officer
Email: madler@nauticolenergy.com
Office (Direct): 587-393-7727