Privacy Policy

Introduction

Greyter Water Systems, Inc. (“Greyter”, “we”, “us”, or “our”) offers smart water solutions that save water and money by reducing the water and wastewater demands of commercial and residential buildings. In connection with these activities, Greyter owns the websites greyter.com and mygreyter.com and the Greyter mobile application (collectively, the “Platform”). As a part of the Platform, Greyter also provides certain communications and services in connection with your access to and use of the Platform (collectively, the “Services”).

This Privacy Policy describes the way that we collect, use, and disclose your personal information in connection with your access to and use of the Platform and Services. We will only collect, use, and disclose your personal information in accordance with this Privacy Policy unless otherwise required or permitted by applicable law.

By accessing or using the Platform or Services, you signify your acceptance of this Privacy Policy and consent to our collection, use, and disclosure of your personal information as described in this Privacy Policy. You can withdraw your consent at any time by contacting our Privacy Officer as directed below; however, if you choose to withdraw your consent, we may not be able to provide you with access to or use of certain functionality or features of the Platform and Services.

Cross-Border Transfers

Greyter is subject to the Personal Information Protection and Electronic Documents Act (Canada) and applicable Canadian provincial privacy legislation. You acknowledge and agree that access to the Platform and Services are provided via the Internet and that your information, including personal information, may be: (i) transferred across provincial and national borders; and (ii) stored or processed in accordance with the terms and conditions of this Privacy Policy.

This Privacy Policy has a limited scope and application, and the Platform is intended for use in the United States and Canada. Consequently, the rights and obligations contained in this Privacy Policy may not be consistent with privacy requirements for all jurisdictions, and users from other jurisdictions acknowledge that their use of the Platform and the Services is at their own risk.

Minors

Our Platform is not intended for minors. We do not knowingly collect personal information from minors. If you are a minor, do not use our Platform or Services or provide any information about yourself to us. If we learn we have collected or received personal information from a minor, we will delete that information and any accounts associated with the minor. If you believe we might have any personal information from or about a minor, please contact our Privacy Officer using the details below.

What is personal information?

For the purposes of this Privacy Policy, personal information is any information about an individual or that identifies a specific individual.

Changes to this Privacy Policy

We may make changes, including material changes, to this Privacy Policy from time to time to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our Platform; we encourage you to check back often for updates. Your continued use of the Platform after an update or amendment to this Privacy Policy means that you consent to the collection, use, and disclosure of your personal information as described in the updated Privacy Policy.

What personal information do we collect?

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This personal information may include, but is not limited to:

• Personal contact and identification information, such as your name, mailing address, email address, IP address, and phone number;
• Account information, such as your username and password when you create an account;
• Personal information that is related to your employment, résumé, portfolio, volunteer experience, and work history, including any personal information that you include in employment applications or inquiries that you submit to us; and
• Personal information that you include in any feedback or communication that you provide to us.

We may also collect information related to your visit to our Platform, including the device (such as hardware model, firmware versions, and unique device identifiers), device-specific telemetry data (such as operational and diagnostic logs), device domain used to access our Platform, the operating system on your device, your device settings, application IDs, the type and version of your browser, crash data, other unique device identifiers, the website you came from to access our Platform, the page of our Platform you entered and exited at, any page within our Platform that is viewed by your IP address, and what country you are from. We use this information to monitor our Platform’s performance (such as number of visits, average time spent, page views, etc.) and for our business purposes (such as working to continually upgrade our Platform).

How do we collect personal information?

Greyter collects personal information from a variety of sources, including:

• Directly from you. For example, we collect your personal information when you create an account, complete forms or applications on our Platform, or otherwise communicate with us.
• From third parties. For example, when you authorize the builder of your home to engage our Services, including the installation of Greyter’s water system in your home, the builder may share information with us about you and your system.
• Automatically as you utilize the Platform. When you interact with the Platform, your browser or device may be subject to our collection of logging and other automatically collected information. This includes information collection via cookies, scripts, web beacons, and other technologies. The information we automatically collect may include your IP address, the date and time you accessed the Platform and the pages and content you accessed during your visit, language preferences, websites that you link to or from, whether you receive or open an email or other communication from us, and the links you click on within those emails, information from your mobile device or your computer about how you interact with the Platform, including unique device identifier, mobile network information, the type of device used and the operating system on that device, browser type, a list of files downloaded or pages viewed, and any errors encountered.

Please note that third parties may collect personal information about your online activities over time and across third-party websites and online services. These third parties may provide us with information in connection with content, widgets, components, cookies, or other tools used on the Platform. They may use this information to provide you with interest-based advertising or other targeted content and for other purposes. We may not control personal information once collected by these parties.

We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party websites or online services.

In all cases, we may collect and use other information you choose to provide or with your consent.

Why do we collect and how do we use personal information?

We collect personal information to provide you with the Services that are available on and through our Platform and which enables us to manage, maintain, and develop our operations. For example, we collect personal information:

• To establish, maintain, and manage our relationship with you, including by contacting you, so that we may provide you with any services or communications that you have requested;
• To contact you in connection with the maintenance of Greyter’s water system installed in your home;
• To allow you to register for, access, and use the functionalities and features available on and through the Platform, including with respect to Greyter’s water systems and tracking metrics;
• To allow you to participate in, subscribe to, or otherwise receive services and communications from us;
• If you inquire about employment opportunities at Greyter, to assess your suitability for employment with us and potentially to create, maintain, and administer an employment relationship with you;
• To be able to comply with your requests (e.g., if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
• To protect Greyter against error, fraud, theft, and damage to our Platform, Services, assets, or other properties;
• To conduct analysis and evaluations to understand usage and trends to improve our Platform, Services, communications, and operations;
• To enable us to comply with applicable laws or regulatory processes; and
• For any other reasonable purpose of which we may notify you or to which you consent.

By consenting to the collection, use, and disclosure of your personal information through our Platform, you allow us to fulfill the purposes for which we collect your personal information. When we collect your personal information for research, statistical, and development purposes, we ensure that any information used for our analysis and reports will be de-identified and aggregated in a manner that will not identify you. This de-identified information may be disclosed to third parties.

Marketing and transactional communications

We will collect your express consent prior to sending you any marketing communications unless an exception to obtaining your opt-in consent applies under Canada’s Anti-Spam Legislation (CASL). You will have the opportunity to opt out of receiving marketing communications at any time. For clarity, by using and accessing our Platform, you agree to receive transactional communications about your account and activities on or in connection with the Platform. For example, when you create an account or reset your password, you will receive an email confirming your account details

When and to whom do we disclose your personal information?

We may disclose your personal information for the purposes and in the circumstances set out below:

• To Affiliates, Employees, and Service Providers. We may disclose your personal information to our affiliates and our respective employees, contractors, consultants, service providers, and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, we use third-party service providers to assist us with the maintenance of Greyter’s water systems installed in your home. These third-party service providers may send you communications on our behalf.
• To Your Home Builder. In some jurisdictions, builders may be required to report installations of greywater systems. In connection with such requirements, we may disclose your personal information to your home builder, or other contractors or service providers, if you have authorized your home builder to engage our Services, including the installation of Greyter’s water system, for your home. Your home builder may send you communications on our behalf.
• To Your Municipality. In some jurisdictions, municipalities may require the tracking of greywater systems. In connection with such requirements, we may disclose your personal information to the municipality in which your home is located.
• For Business Transactions. Personal information may also be disclosed or transferred to another party during the course of, or upon completion of, a change in ownership of, or the grant of a security interest in, all or a part of Greyter or its affiliates through, for example, an asset or share sale or some other form of business combination, merger, or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.
• For Legal Requirements. Your personal information may also be disclosed:
  • as permitted or required by applicable law or regulatory requirements; to comply with valid legal processes, such as search warrants, subpoenas, or court orders; as part of Greyter’s regular reporting activities under applicable law; during emergency situations or where necessary to protect the safety of a person or group of persons; and
  • for any additional purposes for which we have obtained your consent to disclose your personal information.

Since we may share your personal information with third parties, as described in this Privacy Policy, your personal information may be collected, used, processed, stored, or disclosed outside of your jurisdiction of residence, including in Canada and the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction where local laws provide for a different level of protection for personal information. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security agencies in other countries may be entitled to access your personal information.

If you would like further information about our policies and practices regarding the third parties (including our service providers that may be located outside of your jurisdiction of residence) with whom we disclose your personal information and how these third parties collect, use, disclose, and store personal information, please contact our Privacy Officer using the contact details below.

By providing your personal information to us, you consent to our disclosure of this information to our service providers (and other third parties) as described in this Privacy Policy, including those that may be located outside of your jurisdiction of residence.

How is your personal information protected?

The security of your personal information is very important to us. We use commercially reasonable physical, electronic, and administrative measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depend on you. Where you have chosen a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. Do not share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Platform.

Please advise our Privacy Officer immediately of any incident involving the loss of, or unauthorized access to or disclosure of, personal information that is in our custody or control.

How long do we retain your personal information?

We don’t keep your personal information forever. We keep your personal information until the purposes for which it has been collected have been fulfilled, or for such other period as may be required by law, whichever is longer.

How do we use cookies?

A “cookie” is a small summary file containing a unique ID number. When you access our Platform, we may use cookies or similar automatic data collection technologies, including third-party cookies such as Google Analytics, to indirectly collect information about you. Cookies enable us to recognize your computer and greet you each time you visit our Platform without bothering you with a request to register. Cookies also enable us to keep track of services you view so that, if you consent, we can send you news about those services.

We may also use cookies to measure traffic patterns, to determine which areas of our Platform have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our services. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Platform may not be accessible or may not function properly.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (known as behavioral tracking, tailored, or targeted advertising). To learn more or to opt out of certain tailored advertising, please visit the Digital Advertising Alliance of Canada Opt-Out Tool for information. Note that you may still receive advertising even if you have opted out, but it may be less targeted.

Accessing and correcting your personal information

It is important that the personal information we hold about you is accurate and current. You have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the collection, use, and disclosure of your personal information, you may also send an email to our Privacy Officer using the details below to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to: (i) help us confirm your identity and your right to access the Platform and Services; (ii) provide you with the personal information that we hold about you; and (iii) make your requested changes to your personal information. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you or that we may have destroyed, erased, or made anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons, subject to any legal or regulatory restrictions. If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer using the details below.

How do we obtain your consent, and how can you withdraw it?

It is important to us that we collect, use, and disclose your personal information only when we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism), or expressed. We may collect, use, and disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Typically, we will seek your consent at the time that we collect your personal information. In certain 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 Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. If you withdraw or vary your consent, we may not be able to provide you with the communications and/or services you request through our Platform. For example, if you would like to receive our communications but are not willing to provide your email address, we will not be able to fulfill your request.

Links to third-party websites

Our Platform may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only, and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies, or actions of the third parties that operate these websites. Greyter is not responsible for how such third parties collect, use, or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Interpretation of this Privacy Policy

This Privacy Policy does not create or confer upon any individual any rights or impose upon Greyter any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal or provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with such privacy laws.

Contact information

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer in writing or by email. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction. We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows: