Website Privacy Policy

This Policy governs how Orennia Inc. (“the Company”) handles “Personal Information”, which means any information, recorded in any form, about an identifiable individual, including but not limited to name, age, salary, address, performance details, references, health information, opinions and images.

The Company is responsible for Personal Information that is in its custody or under its control and it is committed to compliance with applicable Privacy Laws. This Policy integrates the principles guiding and reflected in Privacy Laws and details the Company’s requirements on the collection, storage, use, retention, access to, disclosure, correction and safeguarding of Personal Information.

It is our policy that the Personal Information we process in the course of conducting our business will be handled in compliance with the requirements of the applicable privacy legislation in Canada, which may include the Personal Information Protection Act (Alberta), the Personal Information Protection and Electronics Documents Act (Canada) and other applicable privacy legislation within each jurisdiction in which we operate.

The Company does not sell, share or distribute your personal information, except as described in this Policy or at the time of collection, or as permitted or required by applicable laws.

Please read this Policy carefully to understand our policies and practices for collecting, using, disclosing, and storing data. By engaging with our website and otherwise providing your Personal Information to us in the course of using our services, you accept and consent to the practices described in this Policy. This Policy may change from time to time. Your continued engagement with our website and with the Company after any such revisions indicates that you accept and consent to them. We ask that you please check this Policy periodically for updates. If you do not agree to terms and conditions of this Policy, you should discontinue your use of our website immediately.

0.1 Interpretation of this Policy

This Policy does not create or confer upon any individual any rights, or impose upon the Company any rights or obligations, outside of, or in addition to, any rights or obligations imposed by Privacy Laws. Should there be, in a specific case, any inconsistency between this Policy and the Privacy Laws, the Privacy Laws shall govern in respect of any such inconsistency.

0.2 Collection, Use and Disclosure of Personal Information

Unless outlined in this Policy or as otherwise permitted by applicable law, no Personal Information is collected without first obtaining your express or implied consent. The Company may collect Personal Information of clients and customers in the course of the Company’s service delivery or a third party’s engagement with the Company, and through use of the Company’s website. The Company may also collect limited Personal Information from individuals who make requests to the Company for information or if you otherwise provide Personal Information to us. Personal Information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

The Personal Information collected by the Company may be used and disclosed for its business purposes including to administer our website and business; enable your use of the services available on our website; send you email notifications that you have specifically requested; send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter); send you marketing communications relating to our business which we think may be of interest to you, where you have specifically agreed to this, by email or similar technology, you can inform us at any time if you no longer require marketing communications by emailing us at marketing@orennia.com).

This Policy applies to any activity that involves the collection, use or disclosure of Personal Information by or on behalf of the Company from customers, clients, suppliers, Contractors, consultants and employees.

This Policy does not apply to information that is not considered Personal Information, including Business Contact Information if the collection, use or disclosure is for the purpose of enabling the individual to be contacted in relation to the individual’s business responsibilities, and for no other purpose.

The Company will retain Personal Information only for as long as it reasonably requires the Personal Information for legal or business purposes described above, and in accordance with the Company’s record retention schedule, unless Company is required to retain Personal Information longer by applicable law or regulation, by administrative needs, by legal process, or to exercise or defend legal claims.

0.3 Processing of Personal Information Outside Canada and Service Providers

Unless otherwise permitted or required by Privacy Laws, when Personal Information is transferred outside Canada, including the countries in which the collection, use, disclosure or storage is occurring or may occur, the purpose for which the processing outside Canada has been authorized, and the way in which written information about the contractors privacy policies and practices can be accessed, if applicable. When Personal Information is transferred outside of Canada, the Personal Information may be accessible to law enforcement or other authorities in such countries.

The Company transfers the Personal Information of employees, clients and customers outside of Canada to storage on servers located in the U.S.

The Company also uses service providers and contractors that may be located outside of Canada or that may transfer your personal information outside of Canada. The Company uses third party service providers for business and operational purposes. Please contact the Company’s Privacy Officer for further details at privacy@orennia.com.

0.4 Automatically Obtained Information

Our servers collect and store information such as the IP address from which you access our websites, your browser type, the date and time you accessed the site, the internet address of the website that you came from, and cookie information as further described below.

0.5 Cookies

A cookie is a file that is written to your hard drive when you access a website. We use cookies to improve user experience, personalize your access to content of our websites to your interests, ensure data security and understand general traffic patterns. This information may be used to guide enhancements in site structure. It may also be used to evaluate the effectiveness of a program or publication.

From time to time, the Company uses Google Remarketing, Facebook, LinkedIn, Bing and others as determined by the Company to advertise its programming on other websites using cookies.

The Company tracks its website usage via Google Analytics and HubSpot to help inform its programming and marketing activities. Information collected via these vendors includes, but is not limited to, data to track frequency of visits, pages visited, web browser used, and city of web visitor.

0.6 External Links

Our website includes links to other organizations’ websites solely for information and convenience. Other websites are governed by privacy policies and practices that may differ significantly from those of the Company. We strongly recommend that you review the privacy policies and practices with respect to collection, use and disclosure of personal information of all linked websites before submitting any personal information. We are not responsible for the content or the privacy practices of other websites.

0.7 Security

The security of your Personal Information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse and unauthorized access, use, alteration or disclosure.

We caution that, while we endeavor to secure your Personal Information, no network, system or server is 100% secure.

0.8 Managing Personal Information and Privacy Officer

Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used. You are responsible for notifying the Company of any changes to your Personal Information that has been collected by the Company.

Requests for access to or correction of your Personal Information or to withdraw your consent, or any questions or concerns that you may have about the treatment of your Personal Information, should be directed to the Company’s Privacy Officer at privacy@orennia.com.

0.9 Changes to the Website Privacy Policy

The Company may make changes to this Policy from time to time to reflect changes in its legal or regulatory obligations or the manner in which it deals with Personal Information.

January 2025