Privacy policy

At Bullfrog Power Inc. (“Bullfrog Power”, “we”, “us” or “our”), protecting your personal information and respecting your privacy is fundamental to how we operate. We are committed to maintaining the accuracy, confidentiality, and security of your personal information in accordance with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and all other applicable privacy legislation.

Bullfrog Power operates this website and may offer certain products and services through an e-commerce store or checkout powered by Shopify, including nature-based solutions, carbon offsets, digital certificates, blockchain-backed records, tokens, and related environmental products and services. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information provided to us directly by you, through your use of the Services, through Shopify or other service providers, or through blockchain, registry, digital records, or related systems used to support certain purchases. For the purposes of this Privacy Policy, ‘Services’ means any products, solutions, and related services that we provide, market, offer, or sell through our website, online platforms, applications, our sales representatives, or through in-person interactions, including any associated customer support or related activities. By using and accessing any of the Services, you acknowledge that you have read this Privacy Policy and understand how we collect, use, and disclose your information as described below. By selecting the opt-in checkbox at checkout, you agree that your name may be displayed on the Impact Gallery and Impact Explorer. You acknowledge that once displayed on the blockchain, this information is generally public and cannot be altered or removed, including if you later withdraw your consent. If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy will prevail with respect to the collection, use, disclosure and the protection of personal information.

Our privacy practices follow the ten PIPEDA fair information principles: accountability; identifying purposes; consent; limiting collection; limiting use, disclosure, and retention; accuracy; safeguarding customer information; openness; access; and handling customer complaints and suggestions. Each principle is addressed below.

Types of Information We Collect
When we use the term “personal information,” we mean any information recorded in any form that identifies or can reasonably identify you as an individual (“Personal Information”). Personal information does not include business contact information (such as a business address or business telephone number) or information aggregated in a way that cannot be connected to you (“Non-Personally Identifiable Information”). We may also set and access cookies on your computer or record order IDs using distributed ledger technology to identify your account, to allow for proper functioning of the website and, loyalty programs and collect Non-Personally Identifiable Information. We do not use cookies to retrieve information from your computer that we did not originally send in a cookie.

• Contact details including your name, address, billing address, shipping address, phone number, and email address.
• Financial information including credit card, debit card, and financial account numbers, payment card information, transaction details, form of payment, and payment confirmation.
• Account information including your username, password, security questions, preferences and settings.
• Transaction information including the items you view, add to your cart, add to your wish list, or purchase, return, exchange, or cancel, and your past transactions.
• Communications with us including information you include in customer support inquiries or other correspondence.
• Device information including information about your device, browser, or network connection, your IP address, and other unique identifiers.
• Usage information including how and when you interact with or navigate the Services.

Sources of Personal Information
We may collect Personal Information from the following sources:

• Directly from you when you create an account, visit or use the Services, communicate with us, or otherwise provide us with your information.
• Automatically through the Services from your device when you use our products or services or visit our websites, including through cookies and similar technologies.
• From our service providers when we engage them to enable certain technology and when they collect or process your Personal Information on our behalf.
• From third parties who have your authority to disclose such Personal Information to us. While we try to ensure that every such third party has your consent, if you believe a third party has inappropriately disclosed your Personal Information to us, please contact us immediately.

Identifying Purposes
Prior to or at the time any Personal Information is collected, we will identify the purposes for which it is being collected. We collect Personal Information for the following purposes:

• To provide products or services to you or someone you represent.
• To establish, administer, and maintain responsible commercial relations and to communicate with customers and potential customers.
• To understand our customers’ needs and preferences.
• To establish your identity and verify information you provide.
• To manage, administer, collect, or otherwise enforce accounts and our business relationship with you.
• To communicate with you and protect you and us from error and fraud.
• To provide, tailor, and improve the Services, including processing payments, fulfilling orders, arranging shipping, facilitating returns and exchanges, and creating a customized shopping experience.
• To send marketing, advertising, and promotional communications by email, text message, or postal mail, and to show you relevant online advertisements, subject to compliance with Canada’s Anti-Spam Legislation (“CASL”).
• To comply with applicable law, governmental or regulatory authority, or other law enforcement purposes.
• In connection with any assignment of contracts or business transactions outside the ordinary course of business.
• For any other reasonable purpose for which you have provided express consent or in which your consent can be reasonably implied.
• For purposes of maintaining quality service.

Consent
We will not collect, use, or disclose your Personal Information without your prior consent. Your consent may be expressed (in writing, verbally, or through electronic means) or implied by your actions. By providing us with Personal Information or authorizing a third party to do so, you signify your consent to our collection, use, storage, and disclosure of your Personal Information in accordance with this Privacy Policy. 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 we want to use information for in a purpose not previously identified. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. See “Withdrawing Consent” below.

Limiting Collection
The Personal Information we collect is limited to what is necessary for the purposes identified to you. We may gather such information in person, over the telephone, by postal mail, facsimile, email, through your use of our website and Services, or from authorized third parties. When you visit our website, information is not collected that could personally identify you unless you choose to provide it voluntarily.

How We Use and Disclose Your Personal Information
Personal Information collected will only be used in accordance with the purposes for which it was originally collected, unless you have otherwise consented or when required or permitted by law. We may disclose your Personal Information to:

• Shopify, vendors, and other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).

• Business and marketing partners to provide marketing services and advertising to you. Our business and marketing partners will use your information in accordance with their own privacy notices.

• Lenders, financers, investors, collection agencies, credit reporting agencies and bureaus, and counterparties to agreements, as permitted by law.

• Our subsidiaries, parent companies, and/or affiliates to ensure the proper administration of this Privacy Policy.

• Any party involved in a potential or actual business combination, sale, or transfer of all or part of our business.

• Authorities as required by law, such as in response to a legal proceeding, court order, or government request. In such cases, we will only disclose what is required.

Any disclosure to a third party will be limited to what is necessary to fulfill the intended purpose. All third parties to whom we disclose Personal Information are contractually bound to respect and maintain its confidentiality in a manner consistent with this Privacy Policy.

Relationship with Shopify
Certain Services are hosted by Shopify, which collects and processes Personal Information about your access to and use of the Services to provide and improve them. Information you submit to the Services will be transmitted to and shared with Shopify, as well as third parties that may be in countries other than where you reside. To help protect, grow, and improve our business, we use certain Shopify enhanced features that incorporate data from your interactions with our store. Shopify is responsible for the processing of your Personal Information in these circumstances. To learn more about how Shopify uses your Personal Information and your available rights, please visit the Shopify Consumer Privacy Policy at https://privacy.shopify.com/en.

Accuracy
We shall make every reasonable effort to ensure your Personal Information is accurate and up to date. You are encouraged to notify us of any inaccuracies or errors. Where appropriate, we will communicate corrections to other parties who may have received incorrect information from us. Before we can provide information or correct inaccuracies, we may ask you to verify your identity and provide other details to help us respond to your request.

Safeguarding Your Information
We use standard technologies and maintain current security standards to protect your Personal Information against unauthorized access, disclosure, inappropriate alteration, or misuse. We have implemented physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Please be aware that no security measures are perfect or impenetrable. We cannot guarantee “perfect security,” and information you send to us may not be secure while in transit. We recommend that you do not use unsecured channels to communicate sensitive or confidential information to us.

Retention of Personal Information
Personal Information retained or stored by us will be limited to what is necessary for the intended purposes for which it was collected, or to which you have otherwise consented. How long we retain your Personal Information depends on factors such as whether we need it to maintain your account, to provide the Services, comply with legal obligations, resolve disputes, or enforce applicable contracts and policies.

Your Rights and Choices
Upon your request, and depending on where you live, you may have some or all the following rights with respect to your Personal Information:

• Right to Access / Know. You may request access to and information about the Personal Information we hold about you, including how we have used or disclosed it.

• Right to Delete. You may request that we delete Personal Information we maintain about you.

• Right to Correct. You may request that we correct inaccurate Personal Information we maintain about you.

• Right of Portability. You may request a copy of your Personal Information and, in certain circumstances, request that we transfer it to a third party.

• Managing Communication Preferences. You may opt out of receiving promotional emails at any time by using the unsubscribe option in our emails. We may still send you non-promotional emails, such as those about your account or orders.

We will not discriminate against you for exercising any of these rights. We may need to verify your identity before processing your requests. You may also designate an authorized agent to make requests on your behalf, provided they supply proof of authorization. We will respond to your request in a timely manner as required under applicable law.

Anti-Spam Policy (CASL)
We maintain a strict no-spam policy. In accordance with Canada’s Anti-Spam Legislation, we will not send you commercial electronic messages advertising products and services that you have not expressed an interest in, nor will we permit your Personal Information to be used by third parties or affiliates for such a purpose, unless we have your express consent. If you receive unsolicited emails from us, our vendors, or agents, please notify our Privacy Officer at the address set out below and include the offending email with all headers intact.

Withdrawing Consent
You may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent for any or all purposes for which we have collected or received your Personal Information, except for any purpose required by law or for which consent is not legally required. To withdraw consent, please provide written notice to us at the contact information below.

Children’s Data
The Services are not intended to be used by children, and we do not knowingly collect any Personal Information about children under the age of majority in your jurisdiction. If you are the parent or guardian of a child who has provided us with their Personal Information, you may contact us using the contact details below to request that it be deleted.

Third Party Websites and Links
Our website and Services may contain links to third-party websites or online platforms not governed by this Privacy Policy. We are not responsible for the privacy or security practices of such sites, including the accuracy or reliability of information found on them. We suggest that you review the privacy statements of those sites to understand how your information may be collected, used, shared, and disclosed. Our inclusion of such links does not imply any endorsement of the content, owners, or operators of those platforms.

International Transfers
We may transfer, store, and process your Personal Information outside the country in which you reside. Where Personal Information is transferred outside of Canada or the European Economic Area, we will rely on recognized transfer mechanisms such as the European Commission’s Standard Contractual Clauses or equivalent contracts issued by the relevant competent authority, unless the transfer is to a country that has been determined to provide an adequate level of protection.

Openness and Changes to This Privacy Policy
This Privacy Policy provides an overview of our policies and practices relating to the management of Personal Information. We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will post the revised policy on our website, update the “Last Updated” date, and provide notice as required by applicable law. We will not make retroactive changes to practices associated with your Personal Information without your consent.

Accountability — Privacy Officer
We have a designated Privacy Officer who is accountable for compliance with PIPEDA and applicable privacy legislation. The Privacy Officer is responsible for ensuring the collection, use, storage, disclosure, and destruction of Personal Information is conducted in accordance with relevant privacy law and this Privacy Policy, and for addressing any concerns, complaints, and questions you may have.

Handling Customer Complaints and Suggestions
If you have concerns or complaints about privacy, confidentiality, or our Personal Information handling practices, or would like to correct or discuss any of your Personal Information, please contact our Privacy Officer:

Privacy Contact: Samuel Kampeligi
Email: sk@envestcorp.com

Bullfrog Power Inc.
110 Yonge Street, Suite 602
Toronto, Ontario, M5C 1T4
Phone: 1.877.360.3464

Before we can provide information or correct any inaccuracies, we may ask you to verify your identity and provide other details to help us respond to your request. We will endeavor to respond within an appropriate timeframe. Depending on where you live, you may also have the right to appeal our decision or lodge a complaint with your local data protection authority.

Acknowledgment

You acknowledge that the exchange of electronic communication is vulnerable to attack by viruses and other destructive electronic programs. As a result, we cannot ensure the security or privacy of Personal Information that you provide to us over the internet, and you acknowledge that we assume no liability or responsibility in connection with any Personal Information that you provide to us over the internet.