GHGSat, with its registered office at 1130 Sherbrooke St W, 15th floor Montreal, Quebec Canada, H3A 2M8, may collect personal information in compliance with applicable privacy laws including the Act Respecting the Protection of Personal Information in the Private Sector CQLR c P-39.1 (“the Act”). For purposes of GDPR, GHGSat is the Controller.

2. Why do we collect your Personal Information?

We collect the personal information indicated below for the following purposes: communicating with you regarding the business of GHGSat Inc., its subsidiaries, or affiliates.

3. What information does GHGSat collect?

We may where relevant, collect, use, store, disclose and transfer different kinds of Personal Information about you which we have grouped together as follows:

4. How we collect your Personal Information?

We collect Personal Information about you from the following sources:

1. From you. You may give us your Personal Information by corresponding with us, including by mail, telephone and email or via a contact form or otherwise on the Website or a message on social media, by interacting with us as part of your job or through an interview process, by visiting the Website and/or by using Services.
2. Third parties or publicly available sources. We may receive Personal Information about you from various third parties and public sources including:
   o tradeshows and conferences from which you engaged with us on products and services, if you ask for details of your complaint, query or feedback to be passed to us for investigation or resolution.
   • Business Contact Data from your employer or another member of your organisation.
   • Technical Data from analytics providers such as Google.
   • Identity Data, Contact Data, and Preference Data from third parties, such as fraud prevention agencies who may gather information from publicly available sources including voting registers or from social media.
   • Identity Data, Contact Data, and Preference Data from sales intelligence and lead generation platforms such as Apollo.io, which compile business contact information from publicly available sources and their own databases.
3. Automated technologies or interactions. Subject to your consent, if you interact with our Website or social media pages, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies. Please see section on Cookies Policy for further details.

You may also be asked to provide Personal Information on our Website or when you otherwise use our Services or interact with us. Personal Information can be gathered when you fill out and send feedback forms or send emails to GHGSat, or when you register for our newsletters and/or publication list and/or when you communicate with us by means of the “Contact Us” tool.

5. How is your Personal Information used?

We have set out below a description of all the ways we process your Personal Information, and which of the “legal bases” we rely on to do so (we are required by the Act and certain other privacy laws, including the United Kingdom General Data Protection Regulation (“UK GDPR”), to always have a permitted reason or justification (called a “lawful basis”) for processing your Personal Information. In certain jurisdictions, including Canada, our main legal basis is your consent (which may be express or implied depending on the circumstances), except if a consent exception applies.

6. How is your Personal Information disclosed?

We generally do not share Personal Information with any third parties, other than as necessary for third parties to perform services on behalf of GHGSat. However, we may share personal information with third parties with your consent or where required or permitted by applicable law. The categories of third parties with whom we share Personal Information may include the following:

Note that the above listed third parties are obligated to maintain the confidentiality of Personal Information (unless, for example, they have a legal obligation to share it pursuant to the Act or other legislation) and are required to maintain appropriate security measures to protect Personal Information.

We may also share your Personal Information with other entities in our group of companies as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for our general business purposes, for authorisations/approvals with relevant decision makers, to enable other entities to provide support for our business tasks such as responding to queries, for system maintenance support and hosting of data and to provide legal and audit services.

We also reserve the right to share, assign, or transfer your Personal Information to any of our subsidiaries or other affiliates or to any successor in interest to our business by merger, sale of assets, reorganization, operation of law or otherwise.

Additionally, if you provide GHGSat with content for publishing or feedback, we may publish your username, name and/or location.

7. Transferring Personal Information to other jurisdictions

GHGSat and some of our third-party suppliers may transfer or process your Personal Information outside of your home jurisdiction to a location in the world that may not have privacy laws which meet the same standards as your local laws. To help ensure that your Personal Information receives an adequate level of protection, we have put in place the following measures to ensure that your Personal Information is treated by those third parties in a way that is consistent with and which respects our commonly adopted internal practices on data protection:

1. Where required, agreements/additional contractual clauses with the relevant counterparty as approved in accordance with the relevant data protection law to protect the Personal Information transferred outside your home jurisdiction; or
2. We have ensured that an exemption/derogation from the usual restrictions is in place.

If you require further information about these protective measures, please contact us using the contact details at the end of this Webpage.

8. How long do we retain Personal Information?

GHGSat will only retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider several factors, including the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Cookies and analytical Services

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. GHGSat uses OneTrust, a consent management platform, to enable you to manage your cookie preferences directly on our Websites. Through the OneTrust cookie banner and preference center, you can review the categories of cookies we use, accept or reject non-essential cookies, and update your preferences at any time. If you disable or refuse cookies, please note that some parts of our Websites may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

10. Do Not Track

GHGSat implemented a cookie “door” to ensure your cookie preferences and any preferences entered through our applications are honoured, and thus we do not sell or share your personal information derived from cookies or applications for cross context behavioural advertising without your consent.

11. Other websites

GHGSat’s Website may contain links to other websites on the Internet that are owned and operated by third parties. The privacy practices of those websites linked to GHGSat’s Website and /or Services are not covered by this Privacy Notice, and GHGSat is not responsible for the privacy policies of those websites. If you provide any information to such third parties, different rules regarding the collection and use of your Personal Information may apply. We strongly suggest you review such third party’s privacy policies before providing any data to them. These other websites may use their own cookies to use, collect data or solicit your Personal Information. Additionally, other companies which place advertising on the Website may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these entities directly if you have any questions about their collection and use.

12. Data Governance

GHGSat takes appropriate measures to protect information from unauthorized access, collection, use, disclosure, copying, modification or disposal. While GHGSat puts in place reasonable measures to protect information, we cannot guarantee at all times the security of such information. No method of transmitting or storing data is completely secure, particularly with regard to Internet applications. We recommend that you do not use unsecure channels to communicate Personal Information or confidential information to us.

GHGSat also maintains policies and practices which ensure the protection of Personal Information. Depending on the sensitivity of the information, the purposes for which it is used, and the format in which it is stored, we implement a combination of measures to protect Personal Information, including:

• Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limit their access to such information on a “need-to-know” basis;
• A designated privacy officer to monitor GHGSat’s compliance with applicable data protection laws;
• Employee privacy and data security training;
• Procedures for receiving, investigating and responding to complaints or inquiries regarding GHGSat’s information handling practices, including any security incidents involving Personal Information, and procedures for notifying the applicable regulator where required to do so;
• Framework governing the retention and destruction of personal information, as more fully described in Section 8 – How long will you retain my Personal Information? of this Notice;
• Contractual protections and other measures to ensure that service providers with whom we share Personal Information maintain adequate privacy protections and standards.

GHGSat also performs privacy impact assessments in certain circumstances if required by applicable privacy laws to ensure adequate mitigation measures are in place.

13. Accuracy

GHGSat uses reasonable efforts to ensure that personal information in our possession is kept as accurate, complete and up to date as possible. We do not routinely update Personal Information, unless such an update is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, we ask you to inform us, without delay, of any change in the information you provide to us.

14. Children Data

GHGSat does not knowingly collect Personal Information from children under the age of 14 years old in Quebec or any children of any age prescribed under applicable local laws. Children are not permitted to use the Website and / or our Services, and GHGSat requests that children do not submit any Personal Information to GHGSat or the Website.

15. Your Data Rights

GHGSat will respect any requests to correct, update or remove Personal Information from our distribution lists if you have joined a mailing list or subscribed to our newsletters. You may communicate with GHGSat by email at [email protected], if it is an email mailing list, by clicking “unsubscribe” at the bottom of the email. In addition, under the Act, in certain circumstances and depending upon your jurisdiction, by law you may have the right to:

Access:

Request access (or to know) to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you (as well as some related details) and to check that we are lawfully processing it.

Correction:

Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Deletion:

Request erasure or deletion of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to hold or otherwise process it. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to processing.

Refuse Processing:

Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.

Restrict processing:

Request the restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.

Cease dissemination:

Request that we cease disseminating your Personal Information to the extent required by law.

Withdraw consent:

You have the right to withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to help you, investigate the issue raised or respond to or resolve your complaint or query.

Note: GHGSat may have legal reasons not to comply with your request under this section and will inform you if that is the case. GHGSat may also require information to allow us to process your request and may request a fee where requests are unfounded and excessive; this is only where the applicable law allows fees.

If you wish to exercise any of the rights set out above, please contact:

GHGSat Inc.
1130 Sherbrooke St W, 15th floor
Montreal, Quebec
Canada, H3A 2M8
[email protected]

16. Complaint

Subject to the country and local jurisdiction in which you are a resident, you may have the right to make a complaint at any time to your relevant Data Protection Authority. For example, in Québec it is the Commission d’accès à l’information (www.cai.gouv.qc.ca). The General Data Protection Regulation and the UK GDPR also give you right to lodge a complaint with a supervisory authority, in particular (under the GDPR) in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns.

GHGSat appreciates the chance to deal with your concerns before you approach your relevant Authority, so please contact us in the first instance.

17. Privacy Notice for California Residents

Effective Date: January 1, 2020

This California Privacy Notice (this “notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to GHGSat Inc.’s and its subsidiaries’ (“Company” “us” “we” “our”) other privacy policies or notices.

To aid in readability, in some places we have abbreviated or summarized CCPA terms or language. Terms defined in the CCPA that are used in this notice shall have the same meaning as in the CCPA.

For more information on this notice or your California privacy rights email us at [email protected] or, write to us at: 1130 Sherbrooke St. W., 15th Floor, Montreal QC Canada H3A 2M8.

Personal Information we Collect

We have collected the following categories of personal information from Consumers within the last twelve (12) months:

Identifiers

This may include but is not limited to: a real name, postal address, Internet Protocol address, email address, social security number, driver’s license number, passport number, or other similar identifiers.

We collect this information directly from the Consumer for the purpose of responding to direct requests for information, recruiting, training, and conveying product specifications.

Personal Records

This may include, but is not limited to: signature, telephone number, education, employment, employment history, credit card number, or any other financial information or medical information.

We collect this information directly from the Consumer for the purpose of responding to direct requests for information, recruiting, training, and conveying product specifications.

Internet Usage Information

This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.

We collect this information directly from the Consumer for the purpose of tracking website traffic volume per page.

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as personal information and we reserve the right to convert, or permit others to convert, your personal information into deidentified data or aggregate consumer information.

Subject to restrictions and obligations of the CCPA, our vendors may also use your personal information for some or all of the above listed business purposes. Our vendors may themselves engage service providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an additional business purpose for which we are providing you notice.

Sharing Personal Information

We may share personal information with third parties for a business purpose. In the last twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers
• Personal Records
• Customer Account Details / Commercial Information
• Internet Usage Information
• Geolocation Data

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the last twelve (12) months, we have not sold any personal information.

California Privacy Rights

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification process. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected personal information.

If we cannot comply with a request, we will explain the reasons in our response. We will use personal information provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or clearly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Additionally, you have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining. Once we receive and confirm your request, we will disclose to you:

• The categories of PI we have collected about you.
• The categories of sources from which we collected your PI.
• The business or commercial purposes for our collecting or selling your PI.
• The categories of third parties to whom we have shared your PI.
• The specific pieces of PI we have collected about you.
• A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
• A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred.

If we sold your PI, we will explain:

• The categories of your PI we have sold.
• The categories of third parties to which we sold PI, by categories of PI sold for each third party.

Deletion Request Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your personal information that we did not collect directly from you.

Do Not Sell

We do not sell your personal information as such is defined under the CCPA, and until such time as we change this policy by updating this notice, will treat personal information collected under that policy as subject to a do not sell request.

Ours and Other’s Rights

Notwithstanding anything to the contrary, we may collect, use and disclose your personal information as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

18. Privacy Notice for Europeans and countries that have adopted the GDPR

If you are located within the European Union or another country that has adopted GDPR, the following applies:

1. You have the right to access, modify, rectify, limit and/or delete any personal data as well as a right of opposition, if necessary, subject to legitimate and imperative reasons, to the processing of these data. If you wish to exercise your rights, you can contact [email protected].
2. You also have the right to lodge a complaint with a supervisory authority.
3. For data processing based on your consent, you have the right to withdraw your consent to the processing of your data at any time. The withdrawal does not affect the lawfulness of processing based on your consent before its withdrawal. If you would like to withdraw your consent please contact [email protected].
4. You have the right to object to the processing of your personal data at any time on grounds relating to your particular situation. We ask you to provide the reasons and legitimate interest to back up your objection. In case of a legal objection, we shall no longer process your personal data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. We shall inform you on the grounds of our decisions.

Legal Obligation

You are obliged to provide your personal data based on government regulatory requirements for personal screening of visitors, and various other requirements. If you fail to provide your personal data, you may be denied the ability to do business with GHGSat Inc., or access to our facility.

Automated Processing

The processing of your personal data may be automatically processed or “screened” as necessary for entering into, or performance of, a contract between the data subject and a data Controller.

19. Changes to Our Privacy Notice

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will notify you through a notice on our website homepage.

20. Contact GHGSat

Should you have any questions about this Notice or our practices or about GHGSat’s handling of your information, you can contact us by email at [email protected]. Please provide a sufficiently detailed question or description of your concern.

LAST revised: May 2026