OUR COMMITMENT TO YOUR PRIVACY
XPV Water Partners (“XPV”, “We”, or “us”) recognizes the importance of privacy and sensitivity of personal information and is committed to the protection of privacy for those who provide personal information to us. XPV will ensure the accuracy, confidentiality and security of your personal information, as well as follow legal requirements to allow you to request access to and correction of your personal information.
This privacy policy explains XPV’s policies and procedures regarding the collection, use, disclosure and retention of personally identifiable information received from visitors to our website (www.xpvwaterpartners.com) (the “Website”) and registered users to our Website. Please note: this Privacy policy will be updated from time to time; as a result, a revised Privacy policy will be posted to notify our visitors and users of changes.
If you are a user or visitor in the European Economic Area, the EU General Data Protection Regulation (“GDPR”) may apply to the processing of your information. The GDPR places obligations on us as a “data controller” and grants you specific rights in respect of the use and handling of your personal information. Both personal information and personal data have the same meaning in the context of this privacy policy.
PERSONAL INFORMATION
What is Personal Information?
Personal Information is any information that can be used to identify or contact a specific individual, such as name, address, phone number, email address or billing information.
Consent to collect personal information
Your personal information, such as your name, phone number, email, address and billing information, is not automatically collected by XPV when using the Website.
Your personal information is only obtained if you consent to provide it in conjunction with a request for information regarding XPV’s products and services, including when registering as a user with our Website. We do not sell your personal information to third parties for any reason.
By submitting your personal information to XPV, you acknowledge and agree that we may collect, use and disclose your personal information in accordance with this Privacy Policy. You may withdraw your consent at any time by contacting XPV in the manner set out below.
Should we wish to use your information for any other purpose not previously stated, we will first obtain your consent.
Types of personal information collected
With your consent, we may collect the following personal information:
- first and last name, email address, phone number, or address;
- Billing information;
- Company name and address
Purposes for collecting, using and disclosing personal information
We may use and/or disclose your personal information for the following reasons:
- to contact you and respond to inquiries and requests for XPV’s services;
- to contact you about XPV’s Website;
- to notify you about changes to XPV’s Website;
- to evaluate products or services XPV could offer to you;
- to monitor or improve use of XPV’s Website;
- for marketing purposes and to inform those interested in our products about events, products, services or other items of interest;
- to customize advertising and content viewed on the XPV Website;
- to provide special offers to you from XPV and/or its affiliates;
- to provide promotional material on behalf of XPV;
- to communicate with you regarding the provision of any services by XPV; or
- to register the Website visitor for an extranet account, process orders for brochures and other written materials or respond to a visitor’s request.
Retention
We will retain your personal information for the period of time that is required by law. When your personal information is no longer required, it will be destroyed or anonymized.
Withdrawing consent
You can withdraw your consent for XPV to use your personal information for one or more of the above purposes by sending an email to
or by calling [•], or toll-free [•]. By withdrawing your consent you acknowledge that XPV may not be able to provide further information to you.
Third-party disclosure
XPV will not collect, use or disclose to a third party your personal information without your explicit consent except:
- Where the third party is necessary to allow us to provide products or services to you, such as shipping or direct mail organizations;
- Where we are required or permitted to do so by law (such as to comply with court orders, warrants or subpoena, or requests by law enforcement agencies to enforce our Website terms and condition of use); or
- Where otherwise required by law.
In such cases where your personal information is provided to third parties for the purposes noted above, our agreements require the third parties to keep personal information secure and confidential and that the information may only be used in connection with providing services to XPV.
Security measures
We are committed to protecting the security of your personal information. We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use your personal information and have clearly defined internal policies and practices. We apply security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.
Your personal information is stored on our database servers located in Canada or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Policy. We have implemented technological measures to prevent individuals from accessing personal information without authorization. Data centres are designed to be physically secure and protected from unauthorized access by unauthorized persons.
Although we will make reasonable efforts to protect personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems.
LINKING TO WEBSITES
From time to time, XPV's Website may also reference or contain links to other websites. We do not endorse any other non-XPV websites and accept no responsibility for the quality, content, nature or reliability of the sites accessible from our Website or sites that may link to XPV website. When leaving XPV's Website, you should be aware that XPV's terms and policies, including this Privacy Policy, no longer govern your online activities; we do not have any control over non-XPV websites. Please ensure to always review the applicable terms and policies, including privacy and data-gathering practices of the linked site prior to using any other site or providing any personal information to a third party.
ADDITIONAL RIGHTS OF EU DATA SUBJECTS
If you are an EU data subject under the GDPR, without limitation, you have the following additional rights in respect of your information:
- You are entitled to ask us to port your Personal Information (i.e., to transfer it in a structured, commonly used, and machine-readable format to you), to erase it, or restrict its processing;
- You have the right to object to some processing of Personal Information that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing;
- You may withdraw any consent we have requested and/or that you have provided in respect of the processing or handling of your Personal Information; and
- If you have unresolved concerns regarding the use or handling of your Personal Information you have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
There are limitations on these rights in certain circumstances, for example (and without limitation):
- If we can demonstrate that we have a legal requirement to process your personal information, then in some instances we may retain data even if you withdraw consent; and
- If we require your personal information to comply with legal or contractual obligations, and if without such data we will not be able to manage our contractual relationship with you, or meet any obligations placed on us, then provision of such data is mandatory.
HOW TO CONTACT US
If you have questions or concerns about this Privacy Policy, wish to have access to your personal information or want to correct, update or delete any personal information, please send an email to [•] or call [•] or toll-free at [•], or write to us at:
XPV Water Partners
40 University Ave
Suite 801, Toronto, Ontario
[M5J 1T1]
Last updated: February 2019
