This document defines the privacy policy which is observed by TFS Energy Solutions, LLC d/b/a Tradition Energy (the “Company”, “Tradition”, “we” or “us”) as it pertains to the data protections and privacy measures required by the EU General Data Protection Regulation (the “GDPR”) relating to EU individuals. This policy is concerned with how we collect information from individuals in the EU, what we do with it and what controls you have.

The Company is a Delaware limited liability corporation headquartered at 9 West Broad Street, 9th Floor, Stamford, CT 06902.  In the context of this policy, Tradition is what is known as the “controller” of the personal data you provide to us.

By accessing this Site and using our services, you agree to be bound by the Privacy Statement. As our business grows and changes, and as technology and Internet use and practices change, the Company may, from time to time, determine that changes in its policies, including this Privacy Statement, are prudent. Each time you use the Site or our Services, the current version of the Privacy Statement will apply.

We take our duty to securely process your personal data very seriously and believe very strongly in our customers’ right to privacy and adherence to legal and ethical standards. This policy explains how we collect, manage, use and protect your personal data.

INFORMATION COLLECTED

The personal data we collect depends on what we use it for, but we will only collect personal data that we actually need in relation to the work and services that we provide. As Tradition operates in the business-to-business market, the majority of the information collected is related to individuals in their professional capacity rather than their personal capacity.

The personal details we may collect are: name, email address, telephone numbers, job title and postal addresses. These details all relate back to the organisation the individual is working for, never to the individual person themselves outside their place of work.

We also collect other, non-personal information about your business and preferences which includes, but may not be limited to:

• Transactional information including information about the services you purchase or about which you made an enquiry.
• Event and conference participation information which you may register for by responding to invitations from Tradition.
• Information from your devices (including mobile devices) and applications you use to access our websites, applications or services such as the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data and your IP address.

We only use aggregated or anonymous information which does not identify individual visitors to our website. We gather this information using cookies or similar technologies, please see the section below entitled Our Use of Cookies.

We do not collect any sensitive data and we ask that you do not send us, and you do not share any sensitive personal information (i.e. information related to racial or ethnic origin, political opinions, religion or other beliefs, health or criminal background etc.).

PURPOSE OF COLLECTION OF DATA

The information is either needed to fulfil your request or to enable us to provide you with a more personalised, targeted and helpful service. You don’t have to disclose any information to browse our sites and you can manage your privacy settings within your browser or our applications at any time. However, if you choose to withhold requested information, we may not be able to provide you with certain services.

The following list highlights how we use the information we collect from you:

• To communicate and manage our relationship with you for the fulfilment of any contracts entered between you (or your employer) and Tradition, specifically:
• To fulfil our obligations relating to the ongoing delivery of a service and business transactions, including ongoing support and update communications
• To contact you to gain feedback about the ongoing service and future services we are delivering or might deliver
• To tailor marketing to your needs, respond to your requests and provide information that may be of interest to you.
• We may use your personal information to notify you about new product releases, new service developments and Tradition business updates.
• We may use your personal information to notify you about industry updates within the energy sector.
• To contact you to see if you would like to take part in our customer research. With prior consent, we may post testimonials which may contain personal information.
• To communicate with you about a conference, webinar or other event.
• To comply with legal requirements. We may be required to disclose your personal information in order to comply with legally mandated reporting, disclosure, or other legal process requirements. We will use reasonable efforts to limit the personal information provided for these purposes.
• To monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual.
• To deliver information to you which may be useful to you, based on your use of our applications and services.

HOW WE OBTAIN THE DATA

To the extent permissible under applicable law, we collect your personal information in a number of ways:

• When you provide it to us directly (for example over the telephone, SMS, fax, email, post or completing forms on our site) as a result of a general enquiry, or the actual placing of an order for our Services.
• When interacting with us using social media sites (e.g. LinkedIn, Twitter and Facebook).
• When you provide permission to other organisations to share it with us.
• When we collect it as you use our website (we will ask for your permission before we do so).
• When you have given it to a third party and you have provided permission to pass your information on to us.

We combine the information from these sources with the information you provide to us directly. Where you ask us to provide a specific service, you may be asked to give consent to your data being collected. This may be verbally, online or by signed consent form.

LEGITIMATE INTERESTS

We process data under the grounds of Legitimate Interest under Recital 47 of the GDPR. Broadly speaking Legitimate Interests means we can process your personal information if:

1. We have a genuine and legitimate reason; and

2. We are not harming any of your rights and interests.

The Company’s services enable businesses to procure and manage their energy and disseminate market news. We have a legitimate interest in being able to use personal data such as name and contact details to support our existing customers and to market our products and services to existing and prospective business customers in order to grow our business.

When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – you can change the way you hear from us or withdraw your permission for us to process your personal details at any time, please see Opt-out Policy and Procedure below.

PROTECTING YOUR DATA

We take appropriate measures to ensure that the personal information disclosed to us is kept secure, accurate, and up to date.

Any information submitted through our website will not be shared with any third party without your prior consent, unless required by law. We may disclose your personal information if required to do so by law or to protect and defend the rights or property of Tradition. We will also maintain confidentiality of customer information when undertaking projects with other companies.

We are committed to protecting the security of your personal information and safeguarding information from unauthorised access. We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. However, the nature of communication via the internet restricts us from offering any guarantee to the privacy or confidentiality of information relating to the personal information passing over the internet. In gaining access via the internet, you acknowledge and accept that electronic communication may not be free from interference by unauthorised persons and may not remain confidential. You therefore accept that access is at your own risk.

YOUR RIGHTS

Opt-out policy and procedure:  You will always have the opportunity to opt out of our communications. We provide users with full control to manage the communications they receive from us. You can update your preferences or unsubscribe from the various communication offerings at any time, by clicking the “unsubscribe” or “update preferences” links contained within the communications or by contacting us directly.

Please note, some non-marketing communications are not subject to general opt-out, such as communications related to business transactions, software updates and other support related information, patches and fixes, quality assurance surveys, conferences or events for which you have registered, and disclosures to comply with legal requirements.

RIGHT TO REQUEST & UPDATE YOUR DATA

If you are based within the European Economic Area (EAA) or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights.

Right to be told if we are using your information and right to rectify:  You have the right to request from us confirmation of whether we are processing your personal data, and if so, access to that information. If any of the data we hold is inaccurate, you have the right to inform us that it should be updated. We will always accommodate such requests and update the information in a timely manner. Please contact us using the details provided below.

Before we are able to provide you with any information or correct any inaccuracies we may ask you to verify your identity and to provide other details to help us identify you and respond to your request.

RIGHT TO BE FORGOTTEN

You have the right to request the removal/restriction of your personally identifying data. This will include your specific contact information – name, email address, telephone numbers and postal address. In considering our response we undertake to ensure your interests, fundamental rights and freedoms are properly balanced against our legitimate interests, so we may retain other information that cannot specifically be used to identify you and are required to do this for contractual and compliance reasons. Please contact us using the details provided. We will honour customers’ requests to remove personal details in a timely manner (within one month of request).

RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION

You have the right to update your preferences and refine what information you can receive from us, and control whether we can use your data.

DATA RETENTION

Personal data is stored for varying lengths of time depending on the nature and purpose for which it was collected. We store personal data in line with any applicable statutory minimum periods, and then review it periodically to ensure it is still necessary to be retained for the purpose for which it was collected.

OUR USE OF COOKIES

Visiting this website with your browser settings adjusted to accept cookies tells us that you want to use www.tradition.com’s products and services and that you consent to our use of cookies and other technologies to provide them to you as described in this notice and in our Privacy Policy.

See below for information on how to modify the settings in your browser to notify you when you receive a new cookie and disable cookies altogether.

What is a cookie?

A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

How do we use cookies?

We may use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to: keep track of you whilst you navigate the website. We will use the persistent cookies to: enable our website to recognise you when you visit and provide you with a personalised service.

Session cookies will be deleted from your computer when you close your browser.

Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

Cookies and browser settings

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.

LINKS TO OTHER SITES

This Site may contain links to websites operated by other people or companies. Those websites may have their own privacy policy or no privacy policy at all. We do not have any responsibility for those websites, and we provide the links solely for the convenience of our visitors.

This Site is owned and maintained by TFS Energy Solutions, LLC at 9 West Broad Street, 9th Floor, Stamford, CT 06902 USA.

For further clarification please see http://tradition.com/privacy-policy.aspx .  Please send your questions or comments regarding this policy to:  GDPRprotection@traditionenergy.com.