Introduction

The Blackstone Energy ecoBoss® Sustainability App (the “App”) is operated by Blackstone Energy Services Limited (“BESL”, “we”, or “us”).  BESI respects your privacy and is committed to protecting it through our compliance with this privacy notice (the “Privacy Notice”). This policy explains how we collect, use, share, and protect your Personal Information (as defined below) from users of the App (“Users”), and how it works together with the privacy policy of our technology partner, JouleBug, who provides the underlying platform for the App. If there is any conflict or inconsistency between this  BESL Privacy Notice and the privacy policy of JouleBug as it relates to your use of the App, the terms of this BESL Privacy Notice will govern.

Effective Date 

This Privacy Notice is effective as of August 15, 2025.

Accountability

BESL is responsible for the Personal Information under our possession and control.  We have designated a Privacy Officer to be responsible for our compliance with this Privacy Notice and privacy legislation.  BESL will make known, upon request, the title of the person or persons designated to oversee BESL’s compliance with this Privacy Notice.

BESL is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing.  BESL shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

BESL shall implement policies and practices to give effect to these principles, including:

  • implementing procedures to protect Personal Information;
  • establishing procedures to receive and respond to complaints and inquiries;
  • training staff and communicating to staff information about the organization’s policies and practices; and
  • developing information to explain the organization’s policies and procedures.

Definitions

To better understand this Privacy Notice, BESL has set out some basic definitions to use when reading and interpreting it.

  • Collection: the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
  • Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. 
  • Disclosure: making Personal Information available to a third party for that party’s own use.
  • Personal Information: information about an identifiable individual that is recorded in any form but does not include aggregated information or depersonalized that cannot be associated with a User. 
  • Service: means the energy sustainability challenge service that BESI provides through the App. 
  • Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of BESI.
  • Use: the treatment, handling and management of Personal Information by and within BESI.

What Personal Information Do We Collect?

We collect the following types of Personal Information when you use the App:

  • Username, email address, and organization (if provided) when you register (“Registration Information”); 
  • identifiers such IP address, device ID and user ID from your browser or mobile device; 
  • geolocation data (if you enable location services);
  • user-generated content, such as photos, comments, and sustainability actions you enter or upload;
  •  usage data and analytics, including how you interact with the App; and
  • cookies and similar technologies to enhance your experience and analyze usage.

This information may be collected directly by BESL or by JouleBug, our technology partner, as part of providing the App.

Note: If you upload content to the App that contains Personal Information of another individual, such as a photograph, you represent and warrant that you have obtained all necessary permissions and possess the legal right to do so. You are solely responsible for ensuring that any such content complies with applicable privacy laws and does not infringe upon the rights of others.

How Do We Use Your Personal Information?

We use your Personal Information to:

  • provide and operate the App and its features, including contest participation and communications;
  • personalize your experience and make recommendations;
  • analyze and improve the App and the Services;
  • communicate with you about your account, support requests, and updates;
  • send you marketing or promotional communications; and
  • comply with legal obligations and ensuring fair play.

We may also use aggregated or anonymized data for analytics and reporting.

Data Retention and Deletion Rights

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.

You have the right to request the deletion of your Personal Information that we have collected or maintain about you, subject to certain legal exceptions. To request deletion, please contact us using the information provided below. We will respond to your request in accordance with applicable laws.

When you cancel your account or our services, your Personal Information will be retained for a period of 90 days following cancellation, after which it will be permanently deleted. 

Consent

We respect your privacy and, unless otherwise required by law, we will not collect, use, transfer or disclose your Personal Information without your prior consent. Your consent may be expressed or implied, as described below. You may expressly give your consent in writing, verbally or through any electronic means.  In certain circumstances, your consent may be implied by your actions, such as   downloading and accessing the App and registering for the energy sustainability challenge, which constitutes implied consent for BESL to provide you with the Services and disclose your Registration Information to our applicable Client.

You may opt out of the collection and use of your device’s geographic location by disabling location services in your device or App settings. Please note that disabling location services may limit certain features of the App.

You may opt out of cookies and similar tracking technologies by adjusting your browser or device settings. Disabling cookies may affect your experience and the functionality of the App.

You may opt out of receiving marketing communications from us by following the unsubscribe instructions in our emails or by contacting us directly.

In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when BESL wants to use information for a purpose other than those identified above).  The form of consent sought by BESL may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, BESL shall take into account the sensitivity of the Personal Information and the reasonable expectations of our customers and Users.  BESL will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive. 

Do We Disclose or Transfer Your Personal Information to Others?

We may share your Personal Information with our service providers that help us with our business operations, including  technical support, analytics, and marketing. All data collected through the App, including your Personal Information, will be stored on the servers of our App licensor (JouleBug) located in Canada, but may be processed outside of Canada for technical (e.g. support) or legal reasons. In the event that Personal Information is processed in the United States or other jurisdictions, it may be subject to the laws of those jurisdictions. We require our service providers to keep your Personal Information secure and maintain compliance with ISO 27001, SOC 2 and other industry standards and to use it only for the purposes we specify, unless we or they have obtained your consent. We have entered written agreements with all service providers who process Personal Information on BESL’s behalf that comply with applicable data protection laws.

We may also share aggregated or anonymized data with affiliates, partners, or third parties for analytics, research, or business purposes. This information cannot be used to identify you.

We may transfer any information we have about you in connection with a merger, sale, insolvency, bankruptcy, corporate reorganization, or other change in corporate control.

We will disclose your Registration Information only to the client partner who has sponsored your energy sustainability challenge (our “Client”), for participant and verification purposes.   In addition, certain Personal Information related to the challenge, including leaderboard information, photographs, and the names of winning participants, may be disclosed to the challenge sponsor and/or made public in connection with the administration and promotion of the challenge.

We will disclose Personal Information without your knowledge or consent if required by law, such as in response to a court order, subpoena, warrant or other legal requirement, or if we believe it is relevant to the investigation of a breach of law.

How Do We Protect Your Personal Information?

We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. These measures include encryption of data in transit or at rest where appropriate, limiting employee access through passwords and graduated levels of clearance, and requiring our service providers to implement comparable security measures. Our hosting environment includes managed firewalls, automated patching, disaster recovery readiness, automated failover mechanisms, and 24/7 monitoring. Our infrastructure is designed to comply with GDPR, HIPAA, ISO 27001, and SOC 2 standards.

While we strive to protect your Personal Information, communications via email or chat may not be encrypted. We ask that you do not share sensitive information through these channels. You are responsible for maintaining the confidentiality of your account credentials and for taking reasonable steps to protect your own information.

Although we take precautions against possible breaches, no company can fully eliminate the risks of unauthorized access. We cannot guarantee that unauthorized access, hacking, data loss, or breaches will never occur. Please use caution when providing sensitive information.

Do We Collected Non-Identifiable and Aggregated Information and How Do We Use It?

Non-Identifiable and Aggregated information is data and information that is aggregated or anonymized in such a manner that it cannot be connected to you or any User.  This may include energy consumption trends among Users, demographic information and aggregated analytic data (e.g. mobile device).   BESI may use aggregated or anonymized data for analytics, research, or business purposes, including understanding the type and quality of actions taken in the energy sustainability challenge; this data cannot identify users. Aggregated information that does not identify individual users will also be shared with the challenge sponsor for reporting, analytics, and program improvement purposes.

User Rights

You have the right to access, correct, or request deletion of your Personal Information that we have collected or maintain about you, subject to certain legal exceptions. You also have the right to request information about the categories and specific pieces of Personal Information we collect from you. To exercise any of these rights, please contact us using the information provided below. We will respond to your request in accordance with applicable laws.

Contact Information

If you have questions or concerns about Personal Information collected by us and would like assistance accessing that information, please contact our Privacy Office:

Mail: 400-2323 Yonge St. Toronto, ON M4P2C9
Email: info@blackstoneenergy.com

Regarding Children and Minors

Our website and the services offered on our website are not directed to children under the age of 16 years. We will not knowingly collect Personal Information about a child under the age of 16.

Cross-Border Transfers and Jurisdiction

Your Personal Information is primarily stored and processed in Canada. In the event that data is transferred or accessed outside of Canada, including in the United States, it will be subject to the laws of those jurisdictions. We require our service providers to maintain compliance with applicable data protection laws and industry standards

Third-Party Links and Social Media

The App and our website may contain links to third-party websites, services, or social media platforms. These third parties have their own privacy policies and practices, which may differ from ours. We encourage you to review the privacy policies of any third-party sites or services you interact with, as we are not responsible for their privacy practices or content. 

Your interactions with these third-party platforms are governed by their respective policies and terms.

Policy Changes

BESL reserves the right to modify and amend this Privacy Notice from time to time in its sole discretion. We will post any amendments on our website at https://blackstoneenergy.com/privacy-policy/. If we make material changes to this Privacy Notice, we will notify you by sending a notice to the email address you provided, by posting a prominent notice in the App, or by other reasonable means. We encourage you to review this Privacy Notice regularly to stay informed about our privacy practices.