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1. Introduction

At Centrio, we’re committed to respecting and protecting your privacy. This Privacy Policy explains when and why we collect, use and share the Personal Information you provide to us or that is otherwise obtained or generated by us in connection with your use of the Centrio.com Website and its affiliates.

For the purposes of this Privacy Policy, “Centrio,” “we,” “us” and “our” refer to Centrio Energy Corporation, and “you” refers to you, the user of the Website.

1.1 Privacy Principles

We have two fundamental principles for collecting and processing your personal information:

• We only collect personal information required for providing services, conducting business or better understanding your needs.
• We will not share your personal information, without your consent, with any organization outside of our group of companies.

“Personal Information” may include your name, contact information, information about how you use our products and services, and information about your preferences, demographics, and interests.

1.2 Website Terms of Use

This Privacy Policy forms part of our Website Terms of Use, which are available at centrioenergy.com. Please read this Privacy Policy together with those terms.

1.3 Table of Contents

2. What Personal Information We Use
3. How Information May Be Used
4. Links to Other Websites
5. Accessing Personal Information
6. EU Data Protection Laws
7. Your Rights Regarding your Personal Information
8. Changes to this Privacy Policy
9. Our Accessibility Commitment
10. Questions and Concerns

2. What personal information we use

2.1 Basic Personal Information

The personal information we collect might include:

• Technical information collected by cookies about your navigation throughout the website, and other technical and browsing preferences, including your location and entry point to the website.
• Information submitted as part of completing online forms on the website.

2.2 Use of “Cookies”

A “cookie” is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. By continuing to browse the site, you agree to our use of cookies.

We use the following cookies:

• Strictly necessary cookies. Cookies required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies.

It’s possible to block cookies by setting your browser preferences. Turning off cookies may result in a loss of functionality when using our website.

3. How information may be used

3.1 Purposes of Collection

We may collect your Personal Information for a number of purposes, which may include:

• Ongoing review and improvement of the information, content and services provided on the website to ensure they are user friendly and to prevent any potential disruptions such as cyber-attacks.
• To analyze and report on Website traffic, marketing and usage trends.
• To allow you to use and access the functionality provided by the Website.
• To conduct analysis required to detect malicious data and understand how this may affect your IT system.
• For statistical monitoring and analysis of current attacks on devices and systems and for the ongoing adaptation of the solutions provided to secure devices and systems against current attacks.
• To communicate with you in in response to queries submitted via online forms on the website.
• To verify your information, including information submitted via online forms on the website.
• For in-depth cyber threat analysis.
• To understand your needs and interests.
• For the management and administration of our business.
• In order to comply with and assess compliance with applicable laws, rules and regulations and internal policies and procedures, including the Terms of Use.
• For the administration and maintenance of databases storing Personal Information.

3.2 Usage of Personal Information

When we use Personal Information, we make sure that the usage complies with law, and the law allows us and requires us to use Personal Information for a variety of reasons. These include:

• In order to perform our contractual obligations under the Terms of Use.
• We’ve obtained your consent.
• We have legal and regulatory obligations that we have to discharge.
• In order to establish, exercise or defend our legal rights or for the purpose of legal proceedings.
• It’s necessary for our legitimate business interests, such as: allowing us to effectively and efficiently manage and administer the operation of our business; maintaining compliance with internal policies and procedures; monitoring the use of our copyrighted materials; offering optimal, up-to-date security solutions for mobile devices and IT systems.

3.3 Other Centrio Affiliates

In some cases, and where allowed by law, we may share your Personal Information with our affiliates and business units when we believe that it will enhance the services we provide, but only in circumstances where such sharing conforms to law, any applicable confidentiality agreements and Centrio’s policies and practices. In addition, Centrio may disclose your Personal Information in the circumstances outlined below:

• With third-party agents, service providers and contractors for the purposes of providing services to us (for example, service providers who design, maintain or host the Website or any entity we consider reasonably necessary for the purposes outlined above). These third parties will be subject to confidentiality requirements (either by contract, professional obligation or otherwise) and they will only use your Personal Information as described in this Privacy Policy.
• To the extent required by law (for example, if Centrio is compelled by an obligation or a duty to disclose your Personal Information in order to comply with any legal obligation, including (without limitation) to investigate unauthorized attempts to modify the Website, install harmful files or cause damage to the Website or Centrio), or to establish, exercise or defend its legal rights.
• As part of a transaction, financing or for other business needs (for example, if Centrio sells any of its businesses or assets, applies for a loan, or opens bank accounts, in which case Centrio may need to disclose your Personal Information to the prospective buyer, lender or bank, as the case may be, as part of certain due diligence processes).
• If Centrio or any of its affiliates, divisions or other segments is acquired by a third party, in which case the Personal Information held by Centrio about you will be accessible to the third-party buyer.

4. Links to other websites

The website may contain links to other party websites that aren’t governed by this Privacy Policy. Centrio isn’t responsible for the content of links or third-party websites and your use of such third-party websites is at your own risk.

5. Accessing personal information

At your written request, we will use reasonable efforts to provide you with access to the Personal Information about you in Centrio’s possession. However, given the nature of the information collected through the website as described above, Centrio may not be able to associate information in its possession with you personally.

6. European union data protection laws

Where European Union data protection laws apply, the provisions in this section will apply in addition to the general provisions set out above. Pursuant to European Union data protection laws, Centrio Energy Corporation is the controller of your Personal Information collected and processed via the website.

6.1 Storing Personal Information

The length of time Centrio will hold your Personal Information will vary and will be determined by the following criteria:

• The purpose for which Centrio is using it: Centrio is required to retain the Personal Information for as long as is necessary to satisfy or meet the purpose for which it was obtained or any other legal purpose.
• Legal obligations: Laws or regulations may set a minimum period for which Centrio must retain your Personal Information.

6.2 Countries Outside the European Union

Where we transfer your Personal Information to another country outside the European Economic Area, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

• The country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Information.
• The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Information.
• Where the recipient is located in the U.S., it might be a certified member of the European Union–United States Privacy Shield scheme.
• In other circumstances the law may permit us to otherwise transfer your Personal Information outside Europe.

6.3 Transfer of Data

You can obtain more details of the protection given to your Personal Information when it’s transferred outside Europe (including a copy of the standard data protection clauses which we’ve entered into with recipients of your Personal Information) by contacting us using the details in section 10 below.

7. Your rights regarding your personal information

7.1 Your Rights

In all the above cases in which we collect, use or store your Personal Information, you may have the following rights, and, in most cases, you can exercise them free of charge. These include:

• The right to obtain information regarding the processing of your Personal Information and access to the Personal Information which we hold about you.
• The right to withdraw your consent to the processing of your Personal Information at any time. Please note, however, that we may still be entitled to process your Personal Information if we have another legitimate reason for doing so. For example, we may need to retain Personal Information to comply with a legal obligation.
• In some circumstances, the right to receive some Personal Information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party, where this is technically feasible. Please note that this right only applies to Personal Information which you have provided directly to Centrio.
• The right to request that we rectify your Personal Information if it’s inaccurate or incomplete.
• The right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Information, but we’re legally entitled to retain it.
• The right to object to, or request that we restrict, our processing of your Personal Information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Information but we’re legally entitled to refuse that request.
• The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

7.2 Exercising Your Rights

You can exercise your rights by contacting us using the details in section 10 below.

8. Changes to this privacy policy

We’ll review and may update this Privacy Policy from time to time. Please check our website frequently to see any updates or changes. Your continued use of the site following the posting of a revised Privacy Policy on Centrio.com constitutes acceptance of the updated Privacy Policy.

9. Our accessibility commitment

We’re committed to an accessibility standard that conforms with web Content Accessibility Guidelines 2.0, an internationally recognized benchmark for building accessible websites for people of all abilities.

We welcome input about how to help visitors get the best experience from our website. Please contact us at support@centrioenergy.com.

10. Questions and concerns

Please email us at support@centrioenergy.com with any questions or concerns you have about this Privacy Policy, to request access to Personal Information in our possession or to refuse or withdraw consent to our collection, use and disclosure of Personal Information.

By browsing or otherwise using the website, you are consenting to the terms of this Website Policy.

• This website, including without limitation all content, design, marks, layout, graphics, video and sounds, is the property of CenTrio, CenTrio affiliates, CenTrio service providers, licensors or contributors and subject to copyright, trademark, and other intellectual property protection, and other protection under applicable law. No intellectual property rights with respect to this website or any content thereof are granted or extended as a result of making them available. The content on the CenTrio.com website may not be reproduced, republished, used or modified without CenTrio’s express written consent.
• The content on CenTrio.com is for informational purposes only and isn’t investment, professional, legal, tax, accounting or other advice. Website users agree to bear all risks associated with their use of the website, including any reliance on the availability, accuracy, completeness, timeliness, usefulness or appropriateness of the website or its content. None of the content on CenTrio.com is an offer to sell, or a solicitation of an offer to buy, any securities, financial products, investments or other services.
• Certain information contained on this website may constitute “forward-looking statements” as defined in applicable securities laws. Forward-looking statements include statements that are predictive in nature, depend upon or refer to future events or conditions, and include statements regarding CenTrio’s competitive strengths, goals, expansion, growth, future success, operations, business, financial condition, expected financial results, performance, prospects, opportunities, priorities, targets, goals, ongoing objectives, strategies and outlook. In some cases, forward-looking statements can be identified by terms such as “expects,” “anticipates,” “plans,” “believes,” “estimates,” “seeks,” “intends,” “targets,” “projects,” “forecasts” or negative versions thereof, or future or conditional verbs such as “may,” “will,” “should,” “would” and “could.” Although CenTrio believes that the anticipated future results, performance, or achievements expressed or implied by the forward-looking statements are based upon reasonable assumptions and expectations in light of information available at the time such statement is or was made, no reliance should be placed on forward-looking statements because they involve known and unknown risks, uncertainties and other factors, which may cause the actual results, performance or achievements to differ materially. Some of the factors that could cause actual results to differ materially from expectations are discussed in the documents that CenTrio files with securities regulators [in Canada and] the United States. Except as required by applicable law, CenTrio undertakes no obligation to update or revise statements or information on this website, whether as a result of new information, future developments or otherwise.
• With respect to performance, note that past performance isn’t necessarily indicative of future results and there can be no assurance that comparable results will be achieved. Any target returns disclosed on this website are for illustrative and informational purposes only and no assurance, representation or warranty is made by any person that the target return will be achieved.
• The CenTrio.com website is provided “as is” and “as available” without any representation, warranty or condition of any kind, including but not limited to (i) any implied warranties or conditions of merchantable quality, fitness for a particular purpose and non-infringement of third-party rights and (ii) any representations or warranties that the website is free of viruses or other components that may infect, harm, or cause damage to your computer equipment or any other property when you access, browse, download from, or otherwise use the website. Without limiting the generality of the foregoing, CenTrio does not warrant that the website and its content, including any projections, predictions, forecasts or other forward-looking statements relating to CenTrio’s performance available on the website, will be accurate, complete or up-to-date, or that defects, inaccuracies or errors on the website will be identified or remedied. No reliance should be placed on any information or forward-looking statements posted on CenTrio.com.
• CenTrio.com or any part of the website may be periodically unavailable, and content on the website may be removed or modified at any time without notice. In addition, CenTrio may, in its sole discretion, restrict, suspend or cancel access to or use of the CenTrio.com website, for all or any one or number of users.
• You agree that in no event shall you seek to hold CenTrio liable, whether in contract, tort or otherwise, for damages (including direct, indirect, incidental, consequential, special, punitive, exemplary and aggravated damages and damages for loss of use, profits or revenue) or any other remedy relating to the use, availability or content of the centrio.com website. Except as required by any applicable mandatory law, in no event will the aggregate liability of CenTrio or any other entity that is part of CenTrio, or any of their respective shareholders, directors, officers, employees, vendors and agents with respect to all claims arising in connection with this Website Policy, the website, all content and all services exceed an amount equal to one hundred united states dollars. The preceding sentences in this paragraph shall not apply to the extent that any liability may not be excluded under applicable mandatory laws. the extent of this exception if any will depend on the country in which you reside and the capacity in which you use the website.
• You agree to indemnify and hold CenTrio, its affiliates and its representatives harmless against any and all liabilities, losses, damages, suits, claims, demands, costs (including court costs and legal fees), fines and actions of any kind or nature whatsoever for which they may become liable, or which they may suffer as a result of your use of CenTrio.com, your breach, violation or non-performance of any term or condition of this Website Policy or your violation of any third party’s rights relating to this website.
• This website may not be used by persons under the age of majority in their jurisdiction.
• This website may contain links to other websites. While we try to link only to websites that share our standards and respect for privacy, we aren’t responsible for the content, security or privacy practices of other websites. CenTrio does not endorse other websites or their content by linking to them from CenTrio.com.
• Some pages on CenTrio.com, or on third-party websites that are linked from CenTrio.com, are available only to clients with registered accounts and log-on credentials. You are responsible for the confidentiality of your log-on credentials and account information, and for all actions taken on the website while logged on with your credentials. Therefore, you should not disclose your log-on credentials or account information to anyone else and you should choose a unique password that isn’t used on any other account or easily guessed by others. CenTrio reserves the right to suspend or cancel website accounts and log-on credentials at any time, for any or no reason, and without notice. If you suspect that your log-on credentials have been compromised, please notify us immediately using the support contact information provided on the relevant account log-on page.
• This Website Policy will be governed by the laws of the State of New York, without regard to its rules of conflict of laws, except New York General Obligations Law § 5-1401. The state and federal courts located in New York County, New York, will have exclusive jurisdiction over any case or controversy arising from or relating to this Website Policy. Each party hereby consents irrevocably to personal jurisdiction in such courts with respect to any and all such matters, and waives any defense of forum non conveniens with respect to such courts. Notwithstanding the foregoing, either party may seek appropriate injunctive relief from any court having jurisdiction. Each party will and hereby does knowingly and voluntarily waive any right to a trial by jury in any case or controversy arising from or relating to this Website Policy.
• Your rights and obligations under this Website Policy are personal to you and may not be assigned to any other party.
• CenTrio has developed a Privacy Policy in order to inform you of its practices with respect to the collection, use, disclosure and protection of your information. You can find the Privacy Policy, which is incorporated into this Website Policy, on our home page and by using the website you agree to the terms of the Privacy Policy.