Glacier RIG Ltd. Terms and Policies

Personal Information Protection

At Glacier RIG Ltd., we are committed to providing our clients (subscribers, enrollees, registrants, clients, members, readers and users) with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.

While we have always respected our clients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information in accordance with both British Columbia’s Personal Information Protection Act (PIPA), and the EU’s General Data Protection Regulation (GDPR). PIPA, which came into effect on January 1, 2004, and sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information. GDPR, which came into effect May 25th, 2018, serves to protect the privacy and use of personally identifiable information of EU data subjects specifically. Glacier RIG Ltd. seeks to apply the most protective and otherwise beneficial privacy policies to all of our clients.

We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA and GDPR, outlines the principles and practices we will follow in protecting clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, copies of, and correction of, their personal information.

This Personal Information Protection Policy applies to Glacier RIG Ltd. and its subsidiaries and affiliated companies.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Glacier RIG Ltd.

Collection

Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

Examples of why we collect client information:

1. To verify identity
2. To identify client preferences
3. To understand the needs of our clients
4. To open and manage an account or subscription
5. To deliver requested products and services
6. To process a purchase transaction
7. To provide informational services
8. To enroll the client in a program
9. To send out information about Glacier RIG Ltd.’s products and services
10. To ensure a high standard of service to our clients
11. To meet regulatory requirements

Public Information

In the event of a client voluntarily providing his or her personal information to be shown in the public domain on Glacier RIG Ltd. or any of its affiliated sites, the client will have the necessary control to modify or remove their public information at their discretion.

Examples of public personal information include resumes, specialist profiles, author profiles, speaker profiles, etc.

Consent

1. We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2. Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
3. Consent may also be implied where a client is given notice and an opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client does not opt-out in accordance with the Canadian Anti-Spam Legislation (CASL) of July 1, 2014, and the General Data Protection Regulation (GDPR) of May 25, 2018.
4. Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Glacier RIG Ltd. to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.
5. We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
   • When the collection, use or disclosure of personal information is permitted or required by law
   • In an emergency that threatens an individual’s life, health, or personal security
   • When the personal information is available from a public source (e.g., a telephone directory or web site)
   • When we require legal advice from a lawyer
   • For the purposes of collecting a debt
   • To protect ourselves from fraud
   • To investigate an anticipated breach of an agreement or a contravention of law
6. We will not sell client lists or personal information to other parties unless we have consent to do so.

Retention

1. If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
2. We will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Accuracy

1. We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
2. Clients may request correction to their personal information in order to ensure its accuracy and completeness. To update personal information, you may make a request in writing by providing sufficient detail to identify the personal information and the correction being sought. Requests for modification to personal information can be sent in writing to support@glacierrig.com.
3. If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the client’s correction request in the file. We may require proof to support the request for modification (e.g. identification, proof of address, credit card or bank account such as in the case of refunds).

Security

1. We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
2. The following security measures will be followed to ensure that client personal information is appropriately protected:
   • Encryption
   • Firewalls
   • Restricting employee access to personal information as appropriate
   • The opportunity for clients to update account password at will
3. We use appropriate security measures when destroying client’s personal information such as: shredding documents, deleting electronically stored information.
4. We continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Access

1. Clients have a right to access their personal information, subject to limited exceptions as found in PIPA and GDPR, including items such as solicitor-client privilege, disclosure that would reveal personal information about another individual, health and safety concerns, etc.
2. To access personal information you may make a request in writing by providing sufficient detail to identify the personal information being sought to the Data Privacy Officer at support@glacierrig.com.
3. Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed, if applicable.
4. We will make the requested information available within 30 business days or provide written notice of an extension where additional time is required to fulfill the request.
5. A minimal and reasonable fee may be charged for providing access to personal information in certain circumstances in accordance with PIPA and GDPR regulations. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.
6. If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.

Questions and Complaints: The Role of the Data Privacy Officer (DPO) or designated individual

1. The Data Privacy Officer or designated individual is responsible for ensuring Glacier RIG Ltd.’s compliance with our data privacy and protection polices in accordance with the latest versions of the Personal Information Protection Act (PIPA) and General Data Protection Regulation (GDPR) regulations.
2. Clients should direct any complaints, concerns or questions regarding Glacier RIG Ltd.’s compliance in writing to the Data Privacy Officer.