Privacy Policy

Effective May 13, 2026 · Version 2026-05-13.1 

This Privacy Policy (the “Policy”) describes how the operator of Energy Navigator (the “Company”) collects, uses, discloses, and otherwise processes personal information in connection with the software-as-a-service platform and related services, referred to as Energy Navigator 9.36 or Energy Navigator (the “Service”).

This Policy forms part of, and is incorporated by reference into, the Terms of Service governing the Service (the “Terms”). Capitalized terms not defined in this Policy have the meanings given in the Terms.

All correspondence may be directed to:

info@energy-navigator.ca | 403-872-2441

1. Introduction

  1. This Policy applies to personal information processed by the Company in connection with the Service and any related agreements with Customers.

  2. The Company’s practices are designed to comply with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (Canada), Alberta’s Personal Information Protection Act, and other applicable provincial legislation.

  3. For greater certainty, this Policy addresses personal information only and does not determine ownership or intellectual property rights in Customer Content, including energy models, HOT2000 files, or reports.

2. Role of the Company

  1. The Company acts primarily as a service provider processing personal information on behalf of the Customer in accordance with the Customer’s instructions.

  2. The Customer determines the purposes for which personal information is collected and submitted to the Service and is responsible for obtaining any required consents or lawful bases.

  3. For limited purposes such as account administration, billing, and internal operations, the Company is responsible for its obligations under applicable privacy laws, including safeguards, subprocessors, and breach response.

  4. For greater certainty, to the extent that Customer Content includes personal information, such personal information is processed by the Company solely in its capacity as a service provider acting on behalf of the Customer and in accordance with the Customer’s instructions and the Terms.

3. Personal Information We Collect

  1. The Company may collect and process the following categories of personal information:

    1. account and contact information;

    2. project and organizational information;

    3. Customer Content, including uploaded documents and files;

    4. technical and usage information;

    5. communications and support information; and

    6. billing and payment-related information.

4. Purposes of Processing

  1. The Company collects, uses, and otherwise processes personal information strictly in connection with the provision and operation of the Service and in accordance with applicable law. Without limiting the generality of the foregoing, personal information may be processed for the following purposes:

    1. to provide, operate, host, maintain, and support the Service, including account management, authentication, intake, processing, validation, analysis, and generation of outputs based on Customer Content, and to enable workflows between the Customer and authorized Users or counterparties designated by the Customer;

    2. to perform the Company’s contractual obligations to the Customer and to carry out the Customer’s instructions in respect of Customer Content;

    3. to communicate with the Customer and Users regarding the Service, including operational notices, security alerts, and support responses;

    4. to monitor, maintain, and improve the reliability, integrity, performance, and security of the Service;

    5. to develop, enhance, and improve the Service using de-identified or aggregated information; and

    6. to comply with applicable legal and regulatory requirements and enforce the Terms.

  2. For greater certainty, the Company does not use identifiable Customer Content for cross-customer analytics or machine learning training except as expressly permitted in the Terms or with the Customer’s authorization.

5. Disclosure of Personal Information

  1. The Company may disclose personal information:

    1. to service providers assisting in operation of the Service;

    2. to Customers and authorized Users;

    3. to third parties at the direction of the Customer;

    4. where required by law;

    5. in connection with business transactions; and

    6. to sub-processors and third-party service providers, including cloud hosting providers, infrastructure providers, and artificial intelligence or data processing service providers, who process personal information solely on behalf of the Company for the purpose of providing and supporting the Service, and who are subject to contractual obligations to protect such information.

6. AI, Analytics, and Data Use

  1. The Company may use de-identified or aggregated information to analyze, maintain, and improve the Service. Identifiable Customer Content is not used for cross-customer analytics, machine learning training, or product development, except as necessary to provide the Service, as permitted in the Terms, or with the Customer’s authorization.

7. Cross-Border Processing

  1. Personal information may be processed, stored, or accessed outside of Canada, including by the Company’s sub-processors and service providers. As a result, such information may be subject to the laws of jurisdictions outside Canada.

  2. The Company will make efforts to implement reasonable contractual and technical safeguards to protect personal information in accordance with applicable law.

8. Retention

  1. Personal information is retained only as long as necessary to fulfill the purposes for which it was collected, including the provision of the Service, and to comply with legal, contractual, and regulatory requirements.

  2. Upon termination or expiry of the applicable Customer relationship, personal information will be retained or deleted in accordance with the Customer’s instructions, applicable agreements, and applicable law.

9. Security

  1. The Company implements reasonable safeguards appropriate to the sensitivity of personal information. Absolute security cannot be guaranteed.

10. Security Incidents

  1. Where required by law, the Company will notify affected parties of breaches creating a real risk of significant harm.

11. Your Rights

  1. Individuals may have rights under applicable law to access, correct, or request information regarding their personal information. Where the Company processes personal information on behalf of a Customer, individuals should direct such requests to the applicable Customer. The Company will provide reasonable assistance to the Customer in responding to such requests, as required by applicable law.

12. Marketing Communications

  1. The Company complies with applicable laws and provides unsubscribe mechanisms.

13. Cookies

  1. The Service uses cookies for operational purposes.

14. Changes

  1. The Company may update this Policy from time to time. Continued use constitutes acceptance where permitted by law.

15. General

  1. This Policy shall be interpreted consistently with the Terms and applicable law.

Last updated May 13, 2026. © 2026 Energy Navigator 9.36. All rights reserved.