This Privacy Code applies only to Imperial 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 Code, “personal information” means information about an identifiable individual; it does not include the personal information of an employee of an organization when used for business communications information about our business customers is not covered.
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, Imperial Energy collects personal information directly from you. If third parties hold information Imperial Energy requires, we will do our best 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 include contract terms, financial information and other information for the purpose of market analysis and strategic planning. This information may also include information related to our media and public relations activities or related to our interactions with financial and other analysts and 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 Personal Information
Imperial Energy collects personal information to allow us to manage and develop our business and operations, including:
- · Establishing, 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 Imperial Energy or carefully selected third parties 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.
Limiting Use, Disclosure and Retention
Unless the customer authorizes us to release it, or said release is required or permitted by law, we will not disclose Personal Information to third parties. In particular, we will never sell, lease or trade Personal Information to third parties without the customer’s consent. However, in order to better provide customers with our products and services, we may share Personal Information with other Imperial Energy businesses or suppliers who perform services on our behalf and with whom contracts have been signed that obligate that third party to adhere to our privacy policies and practices. We provide information on our dealings with customers to credit reporting agencies, credit bureaus and financial institutions. We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
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 Code. 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. For example, when you accept our products or services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time. 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 Code or separately), we will endeavor to 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.
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 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 Code 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 Code.
Safeguarding Personal Information
Imperial 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 Imperial Energy holds about you is accurate and current. Imperial 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, Imperial 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 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. We may charge you a fee to access your personal information; but we will advise you of any fee in advance. If you need help in preparing your request, please contact the office of our Privacy Officer. Imperial 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. Imperial Energy will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
You can Imperial any questions or concerns about this Privacy Code to Imperial Energy’s Privacy Officer. Imperial 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 Imperial Energy’s Privacy Code, change or withdraw your consent or make a complaint under this Privacy Code, you can contact us:
c/o Compliance Department
1200-251 Consumers Rd.
North York ON M2J4R3
This Privacy Code does not create or confer on any individual or on Imperial Energy any rights, or impose on Imperial Energy any obligations beyond any rights conferred or obligations imposed by Canadian privacy legislation.
Last Amended: May 2, 2014