Effective June 19th, 2018
Origis Energy’s Privacy Practices at a Glance
|Purpose||Lawful basis||Relevant Personal Information||Retention period|
|Opt-in newsletter||Legitimate interest: to provide you with the newsletter you subscribed to||Name, email address||30 months from collection|
|Answer questions||Legitimate interest: to answer the questions you have send in through the contact form||Name, email address||30 months after last contact|
|Recruitment||Legitimate interest: to reply on your job application||Name, phone number, email address, resume/CV||Maximum 30 months after last contact|
|Contact||Legitimate interest: to contact you after we have received your contacts||Name, phone, email address||Maximum 30 months after last contact|
Personal Information We Collect
We collect data, including Personal Information that you provide on our Website and as you use the Website. “Personal Information” includes information that can be used to identify you as a natural person, directly or indirectly, in particular in combination with other information available to us such as an identification number, online identifier or one or more factors specific to your identity as a natural person and may include, but is not limited to, your:
- Contact information, such as name, address, phone number, email address (etc.);
- Demographic information, such as your age, zip code, property size, and your interest in our products and services;
Origis Energy aims at keeping the Personal Information we hold as accurate and up-to-date. Please ensure that the Personal Information you communicate to us is accurate and up-to-date.
If you fail to provide certain personal data when requested, we may not be able to perform the contract we have entered into with you (such as providing you with a product or service), or we may be prevented from complying with our legal obligations.
Each visitor to the Website may be identified by cookies or similar technologies (see our Cookies Policy) as well as by an IP address during their visit. Please note that IP addresses are automatically captured when you visit the Website. The information we collect depends on how you use our Website. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.
Personal Information We Collect From Other Sources
We and third parties we engage may combine information we collect from you over time and across our Website with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you (see our Cookies Policy).
How We Use your Personal Information
We only collect, use and store your Personal Information for the purposes of operating our business, delivering, improving, and customizing our Website as well as products and services we provide, sending marketing and other communications related to our business, providing you with information, products and services that you request from us, for other legitimate purposes we refer to the At A Glance table above.
As the case may be, we will provide you with the basis of such legitimate purposes upon its occurrence, prior to implementation of the related processing.
Origis collects Personal Information for a variety of purposes, including the following:
- Providing you with information you requested from us;
- Respond to an inquiry from you;
- Sending communications to you, including for marketing or customer survey purposes, either directly from Origis or, subject to your consent, as the case may be, from our third-party partners;
- Providing customer service and support;
- Improving the operation of the Website and/or help adjust the content of the Website to the general geographic location of you and for reporting purposes;
- Providing you with an Origis publication and/or providing you access to Origis’ online resources; and
- Managing a job application.
How We Share Your Personal Information
Where required or permitted by applicable law, we use or disclose your Personal Information to limited third parties when we believe, in good faith, that such use or disclosure is reasonably necessary to (i) comply with the legal obligation bearing on Origis, (ii) enforce or apply the terms of any agreement to which we are a party, or (iii) protect the rights, property or safety of Origis, Origis’ clients, or others.
We may also share your personal Information with our affiliate entities and other third-party business partners, providers, vendors or contractors acting on our behalf and under our instructions, whether located inside and outside of the European Union (“EU”) or the Economic Area (“EEA”), for the purposes of operating our business, delivering, improving, and customizing our Website as well as our products and services, sending marketing and other communications related to our business, to reply on job applications and when needed, with your consent.
Therefore, we may share Personal Information in the following ways:
- Within Origis and any of our affiliate entities located inside or outside of the EU/EEA, for purposes of Personal Information processing or storage in connection with the aforementioned purposes;
- With Origis’ business partners, vendors, authorized third-party agents or contractors to provide our products and services or facilitate transactions. Examples include, but are not limited to: processing or orders, hosting websites and providing support.
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by another company;
- If we share Personal Information with third parties for purposes other than those listed above, Origis will, for further protection of your privacy, share your Personal Information in aggregated and/or de-identified form that cannot be used to identify you;
Where mandated or permitted by applicable law, regulation or legal process, we will disclose your Personal Information to law enforcement officials, government authorities or other third parties, located inside and outside the country where you are located (including inside and outside the EU/EEA), where such disclosure is in accordance with due process of law and binding upon Origis, to the extent necessary to comply with legal process or meet national security requirements, protect the rights, property, or safety of Origis, its business partners, you, or others.
Links to Third-parties’ Websites
The Website may contain links to third-party websites that are operated by companies outside of our control. Your activities on those third-party websites will be solely governed by the privacy policies and procedures of those third parties. Origis takes no responsibility whatsoever for the content or information practices of such third parties and encourage you to review the privacy polices of these third parties before disclosing any information on their websites.
Security and Confidentiality of your Personal Information
The security and confidentiality of your Personal Information is important to us. We implement appropriate physical, administrative, and technical measures and safeguards designed to protect your Personal Information from loss, theft, misuse, alteration, unlawful or unauthorized access, use, or disclosure.
Origis also relies on reasonable measures to safeguard Personal Information in our possession, including:
- Enforcement of group-wide policies and procedures on Personal Information use, security and confidentiality;
- Restricting access to Personal Information to only those employees and third-party service providers on a “need to know” basis and under strict confidentiality requirements;
- Use of technologies to safeguard data during transmission, such as SSL encryption for some of the data that you provide via the Website and using appropriate security measures to safeguard the data we collect and possess;
- Use of reasonable measures and processes for detecting and responding to inappropriate attempts to breach our computer systems and networks.
The Internet and any communication thereon cannot be guaranteed to be secure at all times, and we cannot ensure or warrant the security of any Personal Information you provide us through this technology. In this regard, we have procedures to deal with any suspected data security breach and will notify you and any regulator of a suspected breach, as mandated by law.
Retention of Personal Information
We will retain your Personal Information for only as long as needed to fulfill the purposes for which it is collected. We will retain and use your Personal Information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets and enforce agreements to which Origis (or any of our affiliate entity) is a party.
For more information about the retention periods, please refer to the summary table above.
You have the right to access, obtain a paper or electronic copy, review, correct and update all your Personal Information stored by us, notably to confirm its accuracy. Subject to any relevant legal requirements and exemptions, you may also oppose to or limit the processing or your Personal Information or request that certain of your Personal Information be deleted from our files.
If you reside within the EU, you may also exercise you right to portability of your Personal Information where the lawful basis for the processing is (i) (a) a contract or (b) your consent and (ii) by automated means. Please note that such a request could be limited to the sole Personal Information you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.
Origis will make reasonable efforts to comply with the aforementioned requests, unless such requests are prohibited by law, or there is a legitimate purpose to retain your Personal Information, in which case we will inform you without undue delay. We reserve the right to verify your identity before any request relating to your Personal Information processed by us. Please direct any questions about your Personal Information using the contact details provided at the end of this Policy.
In accordance with this Policy, but excluding (i) any transfers of data to third parties performing tasks directly on our behalf and pursuant to our instructions and (ii) new processing operation requiring your prior consent, where we receive Personal Information directly from an EU or Swiss individual to which such Personal Information relates, we will offer the individual the opportunity to choose (as the case may be, through opt-out or opt-in) whether his or her Personal Information is (1) disclosed to a third party, including for direct marketing by third parties subject to opt-in exclusively; or (2) used for a purpose that is different than the purpose it was originally collected or subsequently authorized by the individual and compatible with that original purpose.
Any individual who wishes to opt out can do so freely and at any time by contacting Origis using the contact details provided at the end of this Policy.
Origis encourages parents and guardians to take an active role in their children’s online activities. Origis does not sell or offer its products and services to children. As such, our Website is designed for adult user interaction. We do not intentionally collect Personal Information from children under the age of 18. If you are a parent or legal guardian of a minor under the age of 18 and believe that the minor has disclosed personal information to us, please contact us using the contact details provided in this Policy.
If we obtain knowledge that we have collected children’s Personal Information in a manner not permitted by The Children’s Online Privacy Protection Act (“COPPA”), we will remove such data to the extent required by COPPA.
Transfer, Processing and Storage of Personal Information
As a global organization with affiliated entities located inside and outside of the EU/EEA and business processes in operation across borders, we may transfer your Personal Information to Origis’ headquarters in the United States of America, to any Origis affiliate entity worldwide or to third-party business partners, providers, vendors, or contractors, that are located inside or outside of the EU/EEA, for purposes described in the section “How We Share your Personal Information” above, including for the purpose of data processing or storage on behalf and under the control of Origis.
Origis implements cross-borders transfers in compliance with applicable privacy and data protection regulations, including Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data (the “GDPR”). Where mandated by applicable law, to ensure that your personal data does receive an adequate level of protection, Origis implements the appropriate measures to ensure that your Personal Information is treated across Origis affiliated entities and by the aforementioned third parties in a way that is consistent with and which respects the applicable privacy and data protection laws. Measures may include a data transfer agreement.
Choice and Opt-Out
We may send you service communications relating to the products or services we provide you via email (e.g. to inform you about changes to the product or service you requested from us, revisions of our terms and conditions or this Policy). As such service communications are necessary for the purposes of providing you with our products or services or complying without legal obligations, you will not be able to opt-out from receiving them.
Subject to your choices, we may also send you marketing communications via email. In addition to the “unsubscribe” link contained in each of our e-mail marketing communications, you may opt-out freely and at any time of receiving Origis newsletters or other e-mail marketing communications from Origis by sending an e-mail to email@example.com.
Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed personal information (as defined under that statute) of that California resident, for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request you may contact us by using the contact information at the bottom of this Policy.
Updates to this Policy
We reserve the right to update this Policy from time to time in order to reflect any changes to our products or services or to comply with changes in our legal and/or regulatory obligations. If we modify our Policy, we will post the revised version on the Website, with an updated revision date. Where such changes are substantial, we will also notify you by other means prior to the changes taking effect, such as by sending you an email notification or through the Website, products or services. By continuing to use our Website thirty days after such revisions are in effect, you will be deemed to accept and agree to the revisions and to abide by them.
If you have any question or would like to enquire about Origis’ privacy practices, the use of your Personal Information, or about this Policy, please contact us at:
Origis Energy USA Headquarters
Attn: Legal Department
800 Brickell Avenue
Miami, Florida 33131
United States of America
If you are not satisfied with our answer or the way we process your Personal Information pursuant to this Policy, you may also have the right to lodge a complaint with a data protection authority or a Court of competent jurisdiction. If you reside within the European Union, a list of national data protection authorities can be found here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.