Last modified January 1, 2014
This Policy outlines how we at Pulse Energy collect, use and disclose the Personal Information of our users (“you”, “your”, “user” or “users”). We may amend this Policy from time to time, and any changes will be posted on the Website (and/or sent to the email address specified in your account) and will apply to activities and information on a going forward basis. You are encouraged to review this Policy on an ongoing basis to make sure that you understand how any Personal Information you provide to us will be used.
Scope of this Policy
We partner with utility companies (each, a “Utility”) to promote energy efficiency to their customers. Users of the Website may include Utility customers, Utility personnel or visitors to the Website who are neither customers nor personnel of a Utility.
BY USING THE WEBSITE OR SUBMITTING PERSONAL INFORMATION THROUGH THE WEBSITE, YOU AGREE TO THE TERMS OF THIS POLICY AND YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION ACCORDING TO THIS POLICY. YOUR PERSONAL INFORMATION MAY BE PROCESSED BY US OR ON OUR BEHALF IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL IN AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.
What is Personal Information?
“Personal Information” is any information or combination of information that identifies a discrete individual, or by which a discrete individual’s identity could be deduced and includes the individual’s name and personal contact information, but does not include business contact information.
Information We Collect and How We Use It
Personal Information – We may collect such Personal Information as your name, personal contact information (such a mailing or email address), résumé/CV and Utility account and billing information, and may use this Personal Information for the following purposes:
- Communicating with you concerning our products and Services;
- Responding to questions or requests you submit;
- Providing and improving our Services to you, including Services we provide to you in conjunction with your Utility;
- Analyzing and optimizing the Website;
- Meeting legal and regulatory requirements;
- Establishing, managing and terminating the employment relationship with our employees; and
- Notifying you about changes to our Services and sending you offerings of new products and services.
Non-Personal Information – Cookies, Beacons and Tracking
When you access or use the Website or view promotional e-mails that we send you, we (or a third party provider) may use “ cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons, to track what you view and interact with. Pulse Energy treats information collected by cookies and similar technologies as non-Personal Information.
A “cookie” is a small bit of record-keeping information that is sent to your computer. The cookies that we use do not include Personal Information and may be used to: (a) help you navigate around the Website, (b) monitor how many people are using the Website, and (c) store your preferences and track trends.
Most browsers are initially set up to accept cookies, but you can disable cookies or set your browser to indicate when a cookie is being sent. However, disabling cookies may affect your ability to access the Website.
To improve our site, we also use Google Analytics and have implemented a tracking code to support Display Advertising. We will not facilitate the merging of personally-identifiable information with non-personally identifiable information previously collected from Display Advertising features that is based on the DoubleClick cookie unless we have robust notice of, and the user’s prior affirmative (i.e., opt-in) consent to, that merger. Using the Ads Settings, users can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.
Pulse Energy’s servers may log non-Personal Information about your use of the Website, such as: (a) your search activity, pages viewed, the date and time of activity; and (b) any information provided by your computer or mobile device in connection with your use of the Website, such as your browser type, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs.
Trusted Partners and Contractors
Pulse Energy may use and disclose to its affiliated companies, contractors or other trusted businesses or persons the collected non-Personal Information for the purpose of auditing, researching and analyzing usage of the Website, ensuring the technical functionality of the Website and further developing the Website and other Pulse Energy products.
Your Choices for Personal Information Collection and Use
We only collect Personal Information that you provide to us, either directly, when using certain features of the Website (such as registering with us, signing up to receive newsletters etc.) or from your Utility or third parties that provide services for us in connection with the Website or Services. Unless you otherwise inform us, by providing us with your Personal Information you consent to our collection of your Personal Information and our use and disclosure of your Personal Information in accordance with this Policy.
We will not collect or use Personal Information for purposes other than those described in this Policy unless we have obtained your prior consent. If we propose to use Personal Information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of your Personal Information for those other purposes.
You can decline to submit Personal Information or withdraw your consent (such as by unsubscribing to our newsletters) at any time, in which case Pulse Energy may not be able to provide all or some of the Services to you.
We only disclose Personal Information to other entitles (e.g., Utilities) outside of Pulse Energy in the following limited circumstances:
- We have your consent (we require opt-in consent for the sharing of any sensitive Personal Information) – you acknowledge that Pulse Energy does not control or have responsibility for the manner in which such third parties use or further disclose your Personal Information;
- To our subsidiaries and affiliated companies;
- To third party businesses or persons for the purpose of processing Personal Information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures;
- We disclose certain Personal Information to Google Analytics to help us analyze the use of the Website;
- We have a good faith belief that access, use or disclosure of Personal Information is reasonably necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Service; (b) satisfy any applicable law, regulation, legal process or enforceable governmental request, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of, Pulse Energy, its users or the public;
- As required or permitted by law; or
Third Party Privacy Policies
Pulse Energy may make available links through the careers portal, advertisements, hyperlinks or otherwise enable you to access third party products or services from the Website. While using such products or services, you are using products or services that are not affiliated with or controlled by us. Pulse Energy is not responsible for those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. Providing links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies. You recognize and agree that Pulse Energy is not liable for a third party’s use of your Personal Information and you should review the privacy policies of these third parties.
We follow generally accepted industry standards to protect the Personal Information submitted to us against unauthorized access or disclosure.
We restrict access to Personal Information to Pulse Energy employees, contractors and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.
We will make reasonable efforts to ensure that Personal Information in our control is accurate and complete.
We will retain Personal Information only as long as necessary to fulfil the purposes stated above, as required for legal or business purposes or as required or permitted by law, including any contractual obligations to our Utility customers. Subsequently, we will destroy, erase, or make anonymous such information. However, we will retain for at least one year Personal Information that has been used to make a decision about a client, customer or employee. When we delete Personal Information, it will be deleted from the active database, but may remain in our archives.
Accessing and Updating Personal Information
You may request access and/or corrections to your Personal Information. We will make good faith efforts to provide you with access to your Personal Information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required or permitted to be retained by law or for legitimate business purposes.
If we reject your request for a correction, we will make a notation of such request and rejection on your file or Personal Information. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or would jeopardize the privacy of others.
Enforcement & Questions
Pulse Energy regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or Pulse Energy’s treatment of Personal Information by contacting our privacy officer at firstname.lastname@example.org, or by writing to us at: c/o Pulse Energy Inc., Attention: Privacy Officer, 600 – 576 Seymour Street, Vancouver, British Columbia, Canada, V6B 3K1.
When we receive formal written complaints at this address, it is Pulse Energy’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities to resolve any complaints that cannot be resolved between Pulse Energy and an individual. If you are located in British Columbia, Canada, you may also contact the Office of the Information and Privacy Commissioner of British Columbia at P.O. Box 9038, Stn. Prov. Govt., Victoria, British Columbia, V8W 9A4, tel. (250) 387-5629, fax (250) 387-1696.