Last modified: June 24, 2020
Open Regenerative Technologies Inc. doing business as Open Technologies and our affiliates and subsidiaries (“Company” or “we” or “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes how we collect, use, disclose, and protect the information that we collect from participants in benchmarking programs that use GRID (“Program”) and users of the website (“Participant” or “you”), describes the types of information we may collect from you or that you may provide when you visit the GRID website (our “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use the information collected in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the information we collect from you is adequate, relevant, not excessive, and used for limited purposes.
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
The information that we collect under the Program is non-personal information, and is limited to Building Contact Information (defined below) and Building Information (defined below). This information cannot be used to identify, contact or locate a single person.
This policy applies to information we collect, use, or disclose about Participants and Website users:
- as part of the Program;
- on our Website; and
- in email, text, and other electronic messages between you and the Company.
INFORMATION WE COLLECT
We collect specific information about each building contact and each building that is participating in the Program, including but not limited to:
- Business Contact information from each building contact, including their first and last name, phone number, email address, company name, position, title and the relationship between the building contact and the building. (“Business Contact Information”)
- Building Information for each building participating in our Program, including property type, gross floor area, irrigated area, site energy use intensity, source energy use intensity, water use intensity, greenhouse gas emissions, greenhouse gas emission intensity, and energy star score. (“Building Information”)
- Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
- Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
HOW WE COLLECT INFORMATION
We use different methods to collect Information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
- ENERGY STAR Portfolio Manager, for example, a building manager approves the transmission of specific information from their ENERGY STAR Portfolio Manager account. Once approved, the information is transferred directly to the Company.
- Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, tags, pixels, and other tracking technologies.
HOW WE USE YOUR INFORMATION
We use Information that we collect about you or that you provide to us, including any Business Contact information and Building Information, to build graphical and statistical representations of energy use by different buildings participating in the Program. We build statistical models that allow us to isolate building variables and see their effect on energy use.
DISCLOSURE OF YOUR INFORMATION
We may disclose elements of a Participant’s Building Information as part of an aggregate data set. These aggregate data sets could include visualizations that illustrate the effect of a building’s size, age or type on its energy use. The Building Information displayed in these aggregate data sets, will not identify and individual building and will not be linked to other pieces of Information stored for the Program.
- To our subsidiaries.
- To partner organizations including:
- Natural Resources Canada;
- B.C. Hydro;
- Metro Vancouver;
- University of British Columbia;
- City of Vancouver;
- City of Burnaby;
- City of North Vancouver;
- City of Surrey;
- City of Richmond;
- City of Victoria;
- District of Saanich;
- Township of Langley; and
- City of Calgary
(collectively, “Partner Organizations”)
The entities included as Partner Organizations is subject to change without notice.
CONSENT TO PUBLIC DISCLOSURE OF BUILDING INFORMATION
Each Participant in the Program will have the option to consent to the public disclosure of Building Information including, but not limited, to the name of your building and its address, which will be visible and connected to all other property data for such building on a public disclosure map and within program reports and materials.
You may revoke your consent to public disclosure at any time by writing to your program manager. Upon a reasonable amount of time from revoking your consent to public disclosure, the Company will remove your property name and address from the visible dataset as well as any identifying links to your Building Information. Your Building Information will be visible only within the aggregate datasets and data visualizations noted above.
We may also disclose your Business Contact and Building Information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
CREATION AND DISCLOSURE OF ADDITIONAL DATA PRODUCTS
We may use any of the data we collect from you to create additional data and analytics products (“Additional Products”) These Additional Products will not contain business contact information or any other information that could identify individuals or individual buildings. We may disclose, transfer or sell these Additional Products to third parties or use them for any other purpose.
We store all Information collected as part of the Program on servers located in Canada. We may transfer Business Contact Information and Building Information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep this Information confidential, use it only for the purposes for which we disclose it to them, and to process this Information with the same standards set out in this policy.
The security of your Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all the Information you provide to us behind firewalls on our encrypted servers.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Information, we cannot guarantee the security of Information transmitted to us. Any transmission of Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or any email service.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
ACCESSING AND CORRECTING YOUR BUSINESS CONTACT AND BUILDING INFORMATION
It is important that the Business Contact and Building Information we hold about you is accurate and current. Please keep us informed if this information changes.
If you want to review, verify, correct, or withdraw consent to the use of your Business Contact and Building Information, you may send your program manager an email to request access to, correct, or delete any personal information that you have provided. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why subject to any legal or regulatory restrictions.
We will provide access to your Information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- information protected by solicitor-client privilege;
- information that is part of a formal dispute resolution process;
- information that is about another person that would reveal their personal information or confidential commercial information; and
- information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact us at firstname.lastname@example.org.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We have procedures in place to receive and respond to complaints or inquiries about our handling of information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy, please contact our Product Manager using the contact information listed above.