Privacy Policy

1. OBJECTIVE AND SCOPE

6893449 CANADA INC., Dunsky Energy + Climate Advisors (“DUNSKY”) is committed to maintaining the accuracy, security, and privacy of your Personal Information in accordance with applicable Canadian privacy laws. This Privacy Policy is a statement of principles and guidelines concerning the protection of your Personal Information. It aims to help you understand the type of information collected, used, retained, disclosed, destroyed by us and the security measures DUNSKY has in place to protect your Personal Information.

2. YOUR CONSENT

BY VISITING OR USING DUNSKY’S WEBSITE (THE “SITE”), OR BY OTHERWISE COMMUNICATING WITH US, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY (THE “POLICY”) AND YOU CONSENT TO THE COLLECTION, USE, DISCLOSURE, RETENTION, AND DISPOSAL OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE TERMS DESCRIBED IN THE POLICY.

You understand that certain features of our Site or our services may no longer be accessible or may be restricted as a result of your refusal or withdrawal of consent to this Policy.

DUNSKY does not collect Personal Information from persons under the age of 14 without the express and verified consent of the person having parental authority.

3. DUNSKY’S RESPONSIBILITY

DUNSKY is responsible for the protection of Personal Information in its possession, whether it is held by DUNSKY or by a third party, and regardless of its form (written, graphic, sound, visual, computerized, or other). As such, DUNSKY shall take appropriate security measures to protect such information in a manner proportionate to its sensitivity and in compliance with applicable law.

4. THE INFORMATION WE COLLECT

What is Personal Information?

Canadian privacy laws define Personal Information broadly as information that allows a natural person to be directly or indirectly identified – other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.

What Personal Information Do We Collect?

By visiting or using the Site or otherwise communicating with us, we may collect certain Personal Information, including:

your first and last name;
contact information such as address, email address, or telephone number;
and possibly other information gathered from you in surveys or stakeholder consultations that you may participate in as part of DUNSKY’s studies, in a marketing campaign, or as part of our human resources recruitment processes such as your resume.

In any case, whenever we ask you for any Personal Information that can be used to identify you as an individual, we will provide an explanation upon request as to why we gather the information, how we gather it, how we store it, and how we plan on treating and using it.

We will only gather this information if you specifically agree to ‘opt-in’, i.e. you explicitly give us your consent to collect this information from you. We will not gather any Personal Information from you unless you specifically agree to provide it to us.

5. ACCURACY OF PERSONAL INFORMATION

DUNSKY is committed to keeping your Personal Information accurate, complete, and up-to-date. If your information changes, please notify us immediately so that we can make the necessary changes.

6. ACCESSIBILITY AND CORRECTION

You have the right to access, verify, or amend the Personal Information we have collected about you. If you wish to access or obtain a copy of your Personal Information, or if you wish us to amend any of the Personal Information we hold about you that is inaccurate, you may do so by sending us a written request. You may also inquire as to how the information is used, ensure that it is accurate and complete, and update it if necessary, to the extent permitted by law.

If access to your Personal Information is denied, DUNSKY will notify you in writing, give reasons for the denial, and inform you of the recourses open to you. If access is granted, DUNSKY will give you a reasonable opportunity to review your Personal Information. Your Personal Information will be provided to you in an understandable form within a reasonable time, generally within 20 days. DUNSKY may extend such 20-day period by up to an additional 10 days if meeting the time limit would unreasonably interfere with the activities of DUNSKY or the time required to undertake any consultations necessary to respond to your request would make the time limit impracticable to meet. You will be able to challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.

7. DESTRUCTION OR ANONYMIZATION

We will only gather and store Personal Information for the purpose stated during the gathering process. If the purposes for which the information was collected have been fulfilled, we will safely erase and destroy it to ensure your privacy. We may anonymize the information as permitted by law in order to use it for serious and legitimate purposes, subject to a retention period stipulated by law.

8. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

DUNKSY is committed to only asking for information where there is a clear and necessary need for that information and adequately explained to you.

DUNSKY limits the collection, use, and disclosure of your Personal Information, both in the amount and type of Personal Information, to that which is necessary to fulfill the purposes identified. We will identify the purposes for which your Personal Information is collected at or before the time your Personal Information is collected.

DUNSKY may collect, use, and disclose your Personal Information for the following purposes:

to establish and maintain commercial relations with clients, suppliers, partners, financial institutions, and affiliates;
to provide ongoing services;
administer accounts;
make and receive payments;
fulfill contractual obligations;
to understand and respond to website visitors, clients, and potential clients needs and preferences, including to communicate with website visitors, clients, and potential clients;
to conduct surveys, stakeholder consultations, research, and statistical analysis;
to distribute our newsletters, promotional information, and other material to registrants who have voluntarily enrolled on our emailing list;
to develop, enhance, market, sell, provide, and inform you of DUNSKY’s services;
to update and verify our databases and information provided by third parties;
to develop and manage our databases;
to recruit permanent or temporary employees, interns, or external experts at DUNSKY;
to cooperate with regulatory authorities;
to comply with, any legal or regulatory requirements or provisions.

9. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

Your Personal Information is accessible to our officers and employees who must access it to make the use provided for in this Policy and with which they must comply, or, to third parties in order for them to perform contract for services, business, or restricted mandate on behalf of DUNSKY.

We will not sell, lease, or rent your Personal Information or our client list. We collect Personal Information only with your consent for the purpose(s) for which you have given consent.

We keep your Personal Information, questions, and transactions with us and treat them as confidential; and we employ the appropriate security safeguards.

However, from time to time, DUNSKY may disclose your Personal Information to:

service providers, including an organization or individual retained by DUNSKY to perform functions on its behalf, such as marketing, data processing, document management, and office services;
service providers providing offsite servers to store information;
any other third party or parties, where we are permitted or required by applicable law, regulation, or by the rules of professional conduct governing the legal profession.

Any disclosure of your Personal Information to third parties will be done pursuant to agreements setting out the requirements for use, safeguarding, retention, and disposal of such information, or as required by law.

To that extent, Personal Information may be accessed or retained by third parties located outside Quebec as stated in section 10.

10. WHERE DO WE STORE YOUR PERSONAL INFORMATION?

Your Personal Information is stored in secured locations and on servers of third parties with whom DUNSKY contracts for such storage purposes. That service provider may in turn store data, including your Personal Information, on servers located in Canada and in the U.S.A.

DUNSKY retains your Personal Information only for as long as is necessary in order to fulfill the purposes identified within this Privacy Policy, or for as long as may be required to comply with applicable laws.

11. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

To help protect the confidentiality and security of your Personal Information, DUNSKY employs administrative and technological safeguards appropriate to the sensitivity of your Personal Information.

DUNSKY applies strict security measures to protect your Personal Information against any unauthorized access, use, disclosure, modification, loss, theft, or any other breach of security. The information collected is protected by computer security measures that are reasonable in light of its sensitivity.

Physical and physical security measures include:

controlled-access offices and locked filing cabinets;
restricting access to your Personal Information to a selected group of people;
written contractual obligations with third parties who require access to your Personal Information, requiring them to protect, through security measures, the confidentiality and security of your Personal Information and to use it only for the purposes of the contract, mandate, or service they are performing.

Computer security measures include:

password-protection systems;
secure data networks protected by industry-standard firewalls;
restricted access to our data processing and storage rooms;
regular review of our security practices;
regular updating of our technology.

12. WITHDRAWAL OF CONSENT

You may modify or withdraw your consent to the collection, use, and disclosure of your Personal Information at any time by sending written notice to the person responsible for access and protection of Personal Information at DUNSKY (the “PrivacyOfficer”).

You understand that certain functionalities may no longer be accessible or may be restricted following the withdrawal of your consent to this Policy.

13. COOKIES

When an individual visitor accesses the DUNSKY website, we may use a browser feature called a ‘cookie’ to collect information such as:

the type of Internet browser and operating system the visitor uses;
the domain name of the website from which the visitor came;
date and duration of the visit;
number of visits;
average time spent on our website;
pages viewed, and number of cookies accumulated.

A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor directly, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by sending us correspondence from the website or by registering for an event), we will not know who the individual visitors are. In addition to the identified purposes described in our Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website, and to facilitate usage by a visitor. Visitors can accept, reject or modify the use of cookies when visiting our website. They can also reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.

Cookies Used on our Website

Cookie Type	Essential?	Purpose	Duration
_ga _gid _gat _utma _utmb _utmc _utmt _utmz	No	These cookies enable to store information such as the time you visit the website, whether you have visited before, and the website you visited prior to visiting our website.	How long a Google Analytics cookie remains on your computer or device depends on what it is and what it is used for. Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years. In addition to managing your cookie preferences at the beginning of your session, you can delete Google Analytics cookies and other cookies at any time by clearing your browser cache.
pll_language	Yes	To store user language settings	1 year

Detailed list of site-wide cookies, their uses and duration.

14. ONLINE COMMUNICATIONS

In order to provide our website visitors with a service or information, visitors may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, participating in an event, and participating in surveys. If you are known to DUNSKY as a registered user of an online service, we may combine and store Personal Information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.

15. RECRUITMENT

Our website contains links to a third-party website, JazzHR, which allows DUNSKY to collect applications for positions that we are looking to fill. Applicants are asked to provide Personal Information, such as their name, email address, phone number, and other relevant information for the purposes of the recruitment process, which allows us to communicate with the candidates and perform the recruitment process.

16. EMAIL COMMUNICATIONS

Occasionally, if you already agree and gave DUNSKY your consent to receive our email communications, we may send marketing or promotional email communications to you with information that may be useful, including information about DUNSKY’s services. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional emails from DUNSKY.

17. EXTERNAL LINKS

Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third-party websites may have different privacy policies and practices than DUNSKY, and DUNSKY has no responsibility for such third-party websites. Access to any other website from or to the Site is at your own risk. DUNSKY makes no representations about the privacy practices, content, or accuracy of information found on such third-party websites. Any reference to third-party websites is subject to the terms of use of those sites.

18. HOW TO OBTAIN FURTHER INFORMATION REGARDING THIS POLICY OR FILE A COMPLAINT

Any person concerned by Personal Information collected, used, communicated, or retained by us may file a complaint with the Privacy Officer. Complaints must indicate the nature of the facts complained of, the date on which the incident occurred, and the expectations regarding the outcome of the complaint. The Privacy Officer shall acknowledge receipt of the complaint and process it within a maximum of twenty (20) days.

DUNSKY investigates all privacy complaints and takes appropriate steps to resolve them. For further information about how we handle Personal Information, please contact the Privacy Officer at:

Marie-Noel Ouellet
Director, Operations and Privacy Officer
Dunsky Energy + Climate Advisors
50 Ste-Catherine West, Suite 420, Montreal, QC H2X 3V4
Tel: (514) 504-9030
Email: info@dunsky.com

19. CHANGES TO OUR PRIVACY POLICY

DUNSKY reserves the right to modify or supplement this Policy at any time by notifying its users on this page and/or by sending a notice to the persons concerned through any contact information at our disposal.

Changes to this Privacy Policy will be noted here at dunsky.com so that you can be fully informed about our privacy policies and practices. It is recommended that you consult this page regularly, referring to the date of the last modification. If the modifications affect the initial consent, DUNSKY will obtain a new consent, if necessary.

Revised on: May 13, 2024