This is a statement of the privacy practices applicable to Husky Midstream General Partnership and all divisions, subsidiaries and affiliate companies (“Husky Midstream”) and describes how we collect, use and disclose personal information of our customers, website users and other individuals.
Personal information is any information about an identifiable individual or that permits an individual to be identified, but does not, in most circumstances, include business contact information. Husky Midstream is committed to protecting the privacy of the personal information of individuals with whom we interact in accordance with applicable privacy legislation and in a manner that is consistent with our privacy practices. Respecting and protecting your privacy is important to us and a priority in our continuing relationship.
How We Collect, Use and Disclose Personal Information
When collecting personal information from you, we will explain how we intend to use it, we will collect only what we believe is reasonably necessary to meet those purposes, and we will not use or disclose it for other unrelated purposes without your consent, except in the limited circumstances prescribed by applicable law. Personal information will be retained by Husky Midstream for the period of time necessary to fulfill the purpose for which it was collected and as required by applicable laws. Husky Midstream has records management protocols that outline the procedures for the retention and destruction of Husky Midstream records, including personal information. If our privacy practices are not acceptable to you, please do not submit any of your personal information.
Personal information that Husky Midstream may collect, use and disclose includes, but is not limited to:
- investors and security holders to comply with securities and other laws;
- financial and media analysts, prospective and current investors and security holders to send information such as news releases, annual reports, interim reports and guidance documents regarding Husky Midstream to such individuals;
- landowners related to the establishment, management and termination of its leases of mineral or surface rights;
- landowners and other occupants of land related to the individuals impacted by the regulatory environments in which we operate our businesses, including information related to obtaining exploration or development permits and licenses, emergency planning, environmental stewardship and health and safety;
- customers related to the provision of products and services and to manage the relationship with the customer, including the granting of credit;
- applicants in connection with Husky Midstream’s scholarships and community-based programs; and
- individuals in order to meet other business, legal and regulatory requirements.
In the course of conducting our business, Husky Midstream may monitor the activities of individuals in respect of our operations and our property. For example, some Husky Midstream locations are equipped with surveillance cameras. These cameras are generally in high risk areas, office buildings or plant sites. Where in use, surveillance cameras are there for your protection and to protect against theft, vandalism and damage to Husky Midstream goods and property. Recorded images are routinely destroyed and not shared with third parties unless there is suspicion of a crime or to enforce our rights, in which case they are turned over to the police or other appropriate government agency or authority.
We may also monitor and record certain telephone calls. Generally, where telephone calls are routinely monitored, you will be informed that the conversation is being recorded at the beginning of the call and the purposes of the monitoring or recording either by an automated recording or by the customer service representative. If you do not wish to have your conversation monitored or recorded, please notify your contact.
Husky Midstream utilizes the services of many third parties in our business. We may share personal information with such third parties where they require such information to permit us to conduct our activities. We may use contractual and other means to require such organizations to use such information solely for the purposes of providing programs or services to us and under our instruction, and to act in a manner consistent with the relevant principles articulated in this Privacy Statement and applicable privacy law.
These third party service providers include, but are not limited to:
- information technology consultants;
- geophysical contractors;
- land brokers and land agents;
- road, well, pipeline and other facilities construction and/or maintenance contractors;
- environment, health and safety consultants;
- geophysical, engineering, environmental, or other consultants;
- credit rating agencies, credit providers and financial institutions;
- government authorities;
- ethics reporting system management providers; and
- third parties who assist in the administration of scholarships and community-based programs.
Husky Midstream may use the services of third parties in Canada, the United States, the United Kingdom and India. In addition, we may use certain cloud-based services to process or store information. Cloud-based services are software and hardware that are managed by third parties at remote locations, such as online file storage. We may match aggregated, statistical use information to parameters established by third parties; however, this aggregated information will not contain personal information.
Personal information may be transferred or disclosed by and between Husky Midstream affiliates in the course of our business activities. Personal information may also be transferred to another company, including a Husky Midstream affiliate, in the event of a major business transaction, including a change of ownership of all or part of Husky Midstream through an asset or share sale, or some other form of business combination, merger or joint venture. There are circumstances where the use and/or disclosure of personal information may be justified, permitted, or required without consent. Such circumstances may include:
- where required by law or by order of a court, administrative agency or other governmental tribunal;
- where the information has been requested by law enforcement or security intelligence services;
- where Husky Midstream believes, upon reasonable grounds, that it is necessary to protect the health or safety of an identifiable person or group;
- where it is alleged that the person concerned is: guilty of a criminal offence, civilly liable in a legal action, or guilty of professional misconduct;
- where it is necessary to permit Husky Midstream to pursue available remedies or limit any damages that we may sustain; and
- where the information is publically available.
At any time you may withdraw your consent to Husky Midstream’s collection, use and disclosure of your personal information, subject to applicable legal, contractual or regulatory restrictions and upon providing reasonable notice in writing to Husky Midstream. Unless you refuse consent or contact Husky Midstream to withdraw your consent, we assume that you have consented to our collection, use and disclosure practices as set out in this Privacy Statement.
If you do refuse or withdraw your consent, please be aware that this may affect certain aspects of your relationship with us, including being eligible for certain payments, benefits, goods or services provided by Husky Midstream, to the extent the personal information affected by the refusal or withdrawal of your consent was necessary to process such payments or benefits or provide such goods or services. Further, certain personal information is collected, used and disclosed by us as a result of legal, contractual, or regulatory requirements, and your general ability to withdraw or refuse to consent to the collection, use or disclosure of your personal information by Husky Midstream does not imply or confer upon you the right to withdraw or refuse your consent where to do so would interfere with such legal, contractual or regulatory requirements.
Our websites contain links to third party websites. If you click on one of those links, you will be taken to third party websites we do not control. This Privacy Statement does not apply to the information practices of third party websites. We recommend that you review the Privacy Statements of other websites carefully. We are not responsible for the personal information practices of such third party websites.
Security of Personal Information
Husky Midstream endeavors to maintain reasonable physical, procedural and technical safeguards appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent the loss, misuse, unauthorized access, copying, disclosure, or modification of your personal information. As part of those precautions, we restrict access to sensitive personal information to those individuals that we determine ‘need to know’ the information in order for us to carry on our business.
The security of the personal information in our custody and control is important to us; please advise us immediately of any incident involving the loss of or unauthorized access to or disclosure of any personal information that is in our custody or control using the contact information provided below.
Husky Midstream will permit you to access and review your personal information held by us unless the release of such information may be withheld as permitted or required by law. Upon receipt of a written request by an individual, we will, subject to the applicable privacy legislation, provide that individual with access to his or her personal information requested. We will only provide access where the written request contains sufficient detail to enable us, with reasonable effort, to identify that information in respect of which the written request is made. While our response will generally be provided at no cost, each individual making a request will be informed in advance of any charges that apply in connection with the information request. Charges may relate, for example, to the transportation, reproduction or transmission of the requested personal information.
If you would like to access, review or amend your personal information held by Husky Midstream, or if you have any questions pertaining to this Privacy Statement, you may contact the Ethics Help Line online through the Ethics Point website by selecting the following link: Ethics Help Line, or by telephone at 1-855-275-5925 for service in English, or 1-855-350-9393 for service in French.
To guard against improper or fraudulent requests for access, we will require sufficient information to allow it to confirm that the person making the request is authorized to do so before granting access or making corrections to the requested personal information. If we decide not to provide an individual with access to their personal information, we will provide the individual making the request with an explanation as to why the request has been all or partially denied. We will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, we may consider such factors as set out in privacy legislation and privacy commissioner and judicial decisions made thereunder, the frequency with which such information is updated, the purpose for which the information is used, and the nature of the information.
Changes to this Privacy Statement
This Privacy Statement may be updated periodically to reflect changes to our personal information practices. The revised Privacy Statement will be posted on the website. We strongly encourage you to review this Privacy Statement often for the latest information about our personal information practices.