This Policy covers the activities of the subsidiaries of SFE Energy, Inc. (collectively “SFE Energy” “, “us”, “we”, or “our”)
This Policy applies to your use of all of the websites and on-line services owned or operated by SFE Energy and any other website that we may own or operate currently or in the future (collectively, the “Sites”). Unless we say otherwise, all references to the Sites in this Policy include all such sites.
This Policy covers personal information collected on the Sites and any personal information-collected and through our on-line services.
What is Personal Information?
For the purposes of the Policy, “personal information” means information about an identified or identifiable individual. This does not include the name, title, business address or telephone number of an employee of an organization when used for business communications.
The Policy does not cover information about our business customers.
What Personal Information Does SFE Energy Collect?
We collect and maintain different types of personal information about individuals with whom we interact. This information includes:
- Contact and identification information, such as name, address, telephone number, e-mail address, and date of birth, ;
- 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, SFE Energy collects personal information directly from you. If third parties hold information that SFE Energy requires, we will endeavor 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 also include information related to our interactions with financial and other advisors.
Where permitted and/or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
Why Does SFE Energy Collect Personal Information?
SFE 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;
- Obtaining credit approval;
- Informing you of our products and services other than those that you have specifically requested;
- Informing you of products and services SFE Energy or carefully selected third parties may wish to offer you;
- Responding to your comments or requests for information;
- 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.
Cookies and Web Beacons
Limiting Use, Disclosure and Retention
We use and disclose your personal information when, for example:
- It is for purposes described in the Policy;
- We are required by law to do so;
- The information is publicly available; or
- It is required for any additional purposes that may be described at the time we advise you of the use of your personal information (which consent may be express, deemed or implied as explained below).
We use and disclose your personal information when, for example:
- Permitted or required by applicable law or regulatory requirements;
- Part of SFE Energy’s regular reporting activities to other SFE Energy subsidiaries in and outside of the United States;
- To protect the rights and property of SFE Energy;
- During emergency situations or where necessary to protect the safety of a person or group of persons;
- Personal information that is already available to the public;
- To employees, contractors, consultants and other parties (including other members of SFE Energy) who require the information to assist us to establish, maintain and manage our business relationship with you, including, for example, third parties that provide services to us or on our behalf or third parties that collaborate with SFE Energy in the provision of services to you;
- To another party, in the event of a change in ownership of all or a part of SFE Energy through some form of merger, purchase, sale, lease or amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them to use or disclose your personal information in a manner consistent with the use and disclosure provisions of the Policy.
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 Policy. 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. 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 Policy or separately), we will 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.
Consent may be withdrawn or changed, subject to legal or regulatory requirements. Where required, SFE Energy will advise you of any implications of withdrawing or changing consent. If you wish to withdraw consent, where consent is needed, you may contact SFE Energy using one of the methods listed in the “Contacting Us” section, below.
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 Chief 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 Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your personal information as explained in this Policy.
How is My Personal Information Safeguarded?
SFE Energy´s commitment to the privacy of your information includes maintaining the security of our information. We use physical, electronic, and procedural safeguards to help prevent unauthorized access to or use of personally identifiable customer information. Your information is stored on secure servers that we strive to protect in controlled facilities. We require our employees and data processors to respect the confidentiality of any personally identifiable information held by SFE Energy. Please be advised that, unfortunately, no data can be guaranteed to be 100% secure, so we cannot give an absolute assurance that the information you provide to us will be secure at all times. SFE Energy cannot be held responsible for actions arising from unauthorized access to your personally identifiable information. SFE Energy will retain personally identifiable information for a time period consistent with the duration of our business relationship and with applicable laws and financial reporting requirements. Disposal of personally identifiable information will be made as permitted by applicable law and in a manner intended to protect the privacy of such information.
Accuracy of Personal Information
It is important that the personal information SFE Energy holds about you is accurate and current. SFE 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, SFE 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 would like to review, verify or correct your personal information, please contact our Chief 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.
SFE 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. SFE Energy will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
You can direct any questions or concerns about this Policy to SFE Energy’s Chief Privacy Officer. SFE Energy will maintain procedures to receive and investigate complaints and complainants will be advised of the results of any such investigation.
As a service and possible reference to you, SFE Energy may provide you with links to other web sites on the Internet. These links are provided for your convenience and, in no way, constitute an endorsement from SFE Energy. These sites maintain their own privacy policies that may differ from SFE Energy’s privacy policies, so when accessing other web sites, please read that specific sites privacy and security policies. SFE Energy is not responsible for the content of or privacy practices employed by other sites.
Privacy of Children
We understand that children need special safeguards and privacy protection. We realize that they may not understand all the provisions of our Policy or be able to make thoughtful decisions about the choices that are made available to our adult users. We strongly urge all parents to participate in their children’s use of the Internet and any online services, and to teach their children about protecting their personal information while online.
The Sites are not directed to children. We do not sell products or services for purchase by children. We will not knowingly collect personal information from children.
Your California Privacy Rights
If you are a California resident, you may request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us in writing at the section below.
By Email: [email protected]
Chief Privacy Officer: PO BOX 967 Buffalo, NY 14240-0967
SFE Energy may from time to time make changes to the Policy to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with personal information. We will post any revised version of the Policy on our website. Any changes to the Policy will be effective from the time they are posted, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, unless you consent to that change. The Policy was last updated on March 1, 2016.
The Policy does not create or confer on any individual or on SFE Energy any rights, or impose on SFE Energy any obligations beyond any rights conferred or obligations imposed by Legislation.
Last Reviewed: January 1, 2018