Access Gas Services Inc. and Access Gas Services (Ontario) Inc. (collectively, “Access”) and its affiliates doing business in Canada ("us", "we" or "our") respect your privacy and we are committed to maintaining the confidentiality and security of your personal information. This Privacy Policy (the "Policy") describes the personal and business contact information that we collect from you or that you provide to us when you visit our website or use our services, and our practices for collecting, using, protecting, and disclosing that information.

This Policy covers this website and any other website or service that links directly to this website (collectively, the "Site").

Please read this Policy carefully to understand our practices regarding your personal and business contact information. When you access our Site, or submit any personal and business contact information to us by any means, your information will be managed in accordance with this Policy. If you do not agree with our policies and practices, your choice is to not use our Site or use our services. By accessing or using this Site or using our services, you consent to this Policy. Our Policy may change from time to time. Your continued use of the Site after we make changes to the Site is deemed to be acceptance of those changes.

Our Policy applies to information we collect:

• Through your interaction on this Site;
• In email, text, and other electronic messages between you and Access personnel;
• In email, text, and other electronic messages between you and this Site;
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Site.

"personal information" means identifiable information about an individual that, by itself or in conjunction with other information, may be used to specifically identify or contact an individual, but does not include Business Contact Information.

"business contact information" means any information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession such as the individual's name, position name or title, work address, or work telephone number.

We collect, use and maintain different types of personal information about individuals with whom we interact. Personal Information includes but is not limited to:

• Contact and identification information, such as name, address, home telephone number and personal email address;
• Product and service-related information, including account information or energy usage information;
• Information that individuals provide to us directly, by completing surveys, entering contests or providing comments;
• Credit and financial information, such as billing and credit history or payment history;
• Customer relationship information, such as customer service requests, voicemail recordings of customer service calls, or account history;
• Information that is publicly available about the individual.

We may also collect and use personal information and business contact information that individuals have provided to our subsidiaries, affiliates, business partners and/or businesses related to us.

• Directly from individuals when it is provided to us, including personal information;
• Product and service-related information, including account information or energy usage information;
• When individuals access or use our services or devices;
• Automatically as individuals navigate through the Site;
• From third parties or publicly available sources (e.g. from social media services, forums, commercially available services, etc.)

If an individual accesses the Site through a service or another website, app, service or log-in ("Other Service"), the information we collect may also include the individuals user ID and/or user name associated with that Other Service, any information or content Other Service is permitted to share with us, such as a profile picture, email address or friends' lists, and any information made public in connection with that Other Service (collectively, "Additional Content"). When accessing our Site through Other Services, individuals authorize us to collect, store, and use any and all Additional Content in accordance with this Policy. We may also share information that we collect about you with Other Services with whom we partner with or advertise on.

We may provide you the ability to submit reviews, comment on or rate goods, products and services on our Site. Any information provided by individuals in this regard may be published on our Site.

When you visit our Site, we may automatically collect your internet service provider's address, the web page from which you came, and a record of your activity on our Site. We do this using cookies, log files and web beacons ("automatic data collection tools" or "data collection technologies"). We may also allow certain trusted third-party providers to utilize cookies to analyze how users use our Site. We may use "session cookies" (cookies that last until you close your browser) or "persistent cookies" (cookies that last until you or your browser deletes them). If you are concerned about cookies, most browsers permit individuals to opt out of cookies by visiting the browser's settings.

We may use energy consumption information for customer support, system restoration, and research and development activities for new products and services, and other similar purposes. We may also provide certain usage information to selected third parties, such as our business partners, for marketing purposes, where we have obtained your specific consent.

We monitor and record any communications we have with you, like phone conversations and emails. This ensures that we are providing good service and meeting our regulatory and legal responsibilities.

• To manage and develop our businesses and operations, including business relationships with third parties, contractors or consultants we use to develop products, services or business strategies or to assist us to establish, maintain, and manage our business relationship with you, such as marketing our products and services or contacting you regarding our products and services;
• For regular reporting activities to our affiliates in and outside of Canada;
• To protect our rights and property or protect the safety of a person or a group of persons;
• To a third party, in the event of a change in ownership, in which information of individuals held by us is among the assets transferred.

We require our third-party providers to enter into contractual agreements, which will generally require these third-party providers to comply with similar confidentiality and data security standards as Access and prohibit them from further disclosing or using your information other than to carry out the purposes for which the information was disclosed by us.

On rare occasions, we may use or disclose your information without your knowledge or consent where we are permitted or required by applicable law, court order, legal process, or regulatory requirements to do so.

We may also use, transfer, lease, sell or otherwise commercialize analytic or aggregated information for any and all purposes without further notice or obligation to you. You will not have any rights arising from the creation, collection or use of the analytic information. Although we have taken steps to anonymize the personal information, the parties to whom we disclose this analytic information may combine it with information they already have or obtain from others about you.

We may transfer or disclose certain personal information to third party service providers and to affiliated entities in connection with the performance of certain technological or administrative functions, such as data processing, data management, and data storage. Prior to transferring or making disclosures, we will take appropriate steps to ensure that these service providers safeguard and use the personal information only for authorized purposes set out in this Policy or in accordance with applicable laws.

• Protecting the confidentiality of all personal information when doing business internally or externally with other organizations; and
• Using appropriate and effective security safeguards, including physical, administrative, and technological safeguards, against such risks as loss or theft, unauthorized access, disclosure, copying, use or destruction, regardless of the format in which it is held.

Our safeguards were developed in accordance with industry standards, yet we cannot guarantee that such safeguards are always 100% effective or that they are impenetrable from breaches, and any information you transmit to us is done so at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Site, the unauthorized use, access or disclosure of your personal information that may occur as a result of transmission over networks outside of our control, or access of encrypted information by unauthorized persons.

We retain information in accordance with our legal or business practices. Once the information is no longer required to fulfill the purpose for which it was collected and no longer required or permitted to be retained for legal or business purposes, it may be destroyed or made anonymous. We do not undertake any obligation to retain your data for any particular length of time and only anticipate retaining your personal information for as long as it is useful.

By submitting your information to us or obtaining our services, you consent to the collection of and use of your information in the manner described in this Policy.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer at privacyrequests@rockpointgs.com. In some circumstances, a change or withdrawal of consent may limit our ability to provide products or services to you.

We reserve the right to send you transactional or informational emails such as customer service communications or bills in connection with the products you have purchased or changes to this site or our policies.

When making an access request, we may require specific information from you to confirm your identity and right to access, as well as to search for, and provide you with, the personal information that we hold about you. We may charge you a fee to access your personal information in instances that require a disproportionate effort but we will advise you of any fee in advance. We may decline to process requests that are frivolous or unreasonably repetitive, risk the privacy of others, or are extremely impractical. If you need help in preparing your request, please contact our Privacy Officer.

This Policy does not create or confer on any individual or on us any rights, or impose on us any obligations beyond any rights conferred or obligations imposed by Canadian privacy legislation.