1.0  About this Policy

1.1  For the purposes of applicable data protection laws, the controller of your personal data is Morgenroete.

1.2  This Policy applies to personal data we determine the purposes and means of processing.

1.3  Where a separate notice is provided for a specific activity (e.g., the Privacy Notice – Recruitment (M-DPR-NTC-001) for job applicants, or a Data Processing Addendum (M-DPR-AGR-001) for customer-controlled data), that notice or agreement applies in addition to, and where more specific prevails over, this Policy.

1.4  Our clients, personnel and visitors are located in countries around the world, particularly in regions with offshore energy activity, and we comply with the data protection and privacy laws applicable to our processing. These include, for example, the EU and EEA General Data Protection Regulation ("GDPR") and the United Kingdom GDPR; United States state privacy laws; Brazil's LGPD; India's Digital Personal Data Protection Act 2023; China's PIPL; Japan's APPI; South Korea's PIPA; Nigeria's NDPA; Saudi Arabia's PDPL; and Turkey's KVKK.

Depending on where you are located, the jurisdictions whose data protection laws may apply to you include, without limitation, the following (grouped by region and listed alphabetically):

Africa: Angola, Cameroon, Congo (Democratic Republic), Congo (Republic), Côte d'Ivoire, Egypt, Equatorial Guinea, Gabon, Ghana, Libya, Mauritania, Mozambique, Namibia, Nigeria, Senegal, Tanzania, Togo and Uganda (Lake Albert).

Americas: Brazil, Canada, Guyana, Mexico, Suriname, Trinidad and Tobago and the United States.

Asia: Bangladesh, Brunei, China, India, Indonesia, Japan, Kazakhstan, Malaysia, Pakistan, the Philippines, Singapore, South Korea, Thailand, Timor-Leste, Turkmenistan and Vietnam.

Europe: Azerbaijan, Cyprus, Denmark, Greece, Italy, the Netherlands, Norway, Romania and the United Kingdom.

Middle East: Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, Turkey and the United Arab Emirates (including the DIFC and ADGM regimes).

Oceania: Australia, New Zealand and Papua New Guinea.

Where a particular right or requirement applies only to residents of a specific region, this Policy states so.

1.5  You may contact us about this Policy or your personal data at any time by reaching out to our Legal Counsel (legal@morgenroete.ca).

1.6  Where we are required to appoint a data protection officer, or a local representative or registered agent, under applicable data protection law (e.g., in the European Economic Area, the United Kingdom, or other jurisdictions that require one), their details will be provided here or are available on request from our Legal Counsel (legal@morgenroete.ca).

2.0  Personal Data

2.1  We only collect data that is relevant and necessary for the purposes described in this Policy.

2.2  We collect personal data in three ways:

A.  Information You Provide:

• –  Identity and Contact Data: Name, Employer or Organisation, Job Title, email address, telephone number, and postal or delivery address.
• –  Enquiry and Correspondence Data: The content of enquiries, messages, requests for quotations or tenders, and other communications you send us.
• –  Account and Order Data: Log-in credentials, order history, and the details required to fulfil online-shop purchases and software or application subscriptions.
• –  Payment Data: Billing details processed through our payment providers; we do not store full payment-card numbers on our own systems.
• –  Recruitment Data: Where you apply for a role, the information described in the Privacy Notice – Recruitment (M-DPR-NTC-001).
• –  Marketing Preferences: Your choices about receiving communications from us.

B.  Information We Collect automatically when you interact with the Services:

• –  Device and Connection Data: IP address, device identifiers, browser type and version, operating system, language settings, and referring URLs.
• –  Usage Data: Pages viewed, features used, dates and times of access, and interactions with our Services and application.
• –  Cookies and Similar Technologies: As described in our Cookie Policy (M-DPR-POL-001).

C.  Information from Third Parties:

• –  Service Providers: Analytics, hosting, security, payment and application-distribution providers (including the Apple App Store and Google Play).
• –  Business Contacts and Public Sources: Where a colleague refers you, or from publicly available professional sources for legitimate business-development purposes.

2.3  We do not intentionally collect special category or sensitive personal data through the Services except where strictly necessary and permitted by law (e.g., health or accessibility information you volunteer, or diversity data handled under the Privacy Notice – Recruitment). Please do not send us sensitive personal data unless we specifically request it.

2.4  Some personal data is necessary for us to provide the Services or perform a contract with you — for example, the contact and payment details required to fulfil an order or provide a subscription. Where data is required on this basis we will make that clear at the point of collection, and if you do not provide it we may be unable to provide the relevant Service.

3.0  Usage of Personal Data

3.1  We use personal data only where we have a lawful basis to do so. Where the EU GDPR, UK GDPR or a comparable data protection law applies, the relevant legal bases are set out in the table below. Where United States state privacy laws apply, we process personal data for the business and commercial purposes described below and do not "sell" personal data or process it for "targeted advertising" as those terms are defined under those laws, except with any consent required and subject to your opt-out rights.

3.2  Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms and will provide further detail on request.

3.3  Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

4.0  Cookies and Similar Technologies

4.1  We use cookies and similar technologies to operate the Website, remember your preferences, measure performance and, where you consent, for analytics and marketing.

4.2  Non-essential technologies are only used with your consent, which you can give, refuse or withdraw through our cookie banner and settings. Full details are set out in our Cookie Policy (M-DPR-POL-001).

5.0  Marketing Communications

5.1  We will only send you marketing communications where you have consented, or where permitted by law in the context of an existing business relationship.

5.2  Every marketing message includes an easy way to unsubscribe, and you can change your preferences at any time by contacting us. Opting out of marketing does not stop essential service messages relating to your account, orders or the Services.

6.0  Sharing of Personal Data

6.1  We do not sell your personal data.

6.2  We share personal data only as described below and subject to appropriate safeguards:

• –  Service Providers (Processors): Hosting, IT, analytics, security, payment, communications and application-distribution providers who process data on our instructions under written contracts.
• –  Professional Advisers: Lawyers, auditors, insurers and consultants, where necessary and under duties of confidentiality.
• –  Authorities and Regulators: Where required by law, court order, or to establish, exercise or defend legal claims, or to protect our rights, users or the public.
• –  Corporate Transactions: A prospective or actual purchaser in connection with a reorganisation, merger, financing or sale of assets, under appropriate confidentiality protections.

7.0  Group Companies

7.1  We do not share your personal data among Morgenroete Group companies for their own independent purposes.

7.2  Any limited access within the Morgenroete Group is restricted to what is necessary to operate and support the Services on our behalf and is subject to equivalent protections to those in this Policy.

8.0  International Transfers of Personal Data

8.1  We operate internationally and use service providers in various countries, including the United States. Where we transfer personal data across borders, we implement safeguards recognised under applicable law, such as an adequacy decision, the European Commission's or United Kingdom's Standard Contractual Clauses or International Data Transfer Agreement or Addendum, or another lawful transfer mechanism, together with a transfer risk assessment and supplementary measures where appropriate.

8.2  Some countries require certain personal data to be stored or processed locally, or impose registration, prior-approval or assessment requirements before personal data may be transferred abroad; for example, in Africa (Nigeria), Asia (China, Indonesia, Kazakhstan and Vietnam) and the Middle East (Saudi Arabia and Turkey). Where such requirements apply to our processing, we take steps to comply with them, including obtaining any separate or explicit consent that local law requires for a cross-border transfer. You may request further information about the safeguards we use by contacting us.

9.0  Retention of Personal Data

9.1  We retain personal data only for as long as necessary for the purposes for which it was collected.

9.2  To determine how long personal data must be retained, we consider the amount, nature and sensitivity of the data, the purposes for which we process it, whether we can achieve those purposes by other means, the potential risk of harm from unauthorised use or disclosure, and applicable legal, accounting, tax, warranty and reporting requirements and limitation periods for bringing claims.

9.3  By way of indication, enquiry and correspondence data is typically held for the duration of the relationship and a reasonable period afterwards; order, payment and tax records are retained for the period required by law; and account and usage data is retained for as long as your account is active and for a limited period thereafter.

9.4  When personal data is no longer required, we securely delete or irreversibly anonymise it. Where deletion is not immediately possible (e.g., data held in secure backups), we isolate the data from further processing until deletion is possible.

10.0  How we protect Personal Data

10.1  We maintain appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse or alteration, including access controls, encryption in transit, network and application security, staff confidentiality obligations, and vendor due diligence.

10.2  No system is completely secure; where we are legally required to do so, we will notify you and the relevant regulator of a personal data breach within the applicable timeframe.

10.3  Security researchers may report vulnerabilities under our Vulnerability Disclosure Policy (M-SEC-POL-001).

11.0  Automated processing and Artificial Intelligence (AI)

11.1  We may use automated tools, including analytics and artificial-intelligence or machine-learning systems, to help operate, secure, personalise and improve the Services, to process survey, imaging and photogrammetry data within our applications, and to assist with customer support.

11.2  We do not make decisions producing legal or similarly significant effects concerning you based solely on automated processing without meaningful human involvement, save where permitted by law and with appropriate safeguards.

11.3  Where we use AI tools, we take steps to protect the confidentiality and integrity of personal data and do not use your personal data to train publicly available third-party AI models without a lawful basis.

12.0  Privacy Rights

12.1  Subject to applicable law and to any conditions and exemptions, you may have the following rights in relation to your personal data:

• –  Access: To obtain confirmation of, and a copy of, the personal data we hold about you.
• –  Rectification: To have inaccurate or incomplete data corrected.
• –  Erasure: To have personal data deleted in certain circumstances.
• –  Restriction and Objection: To restrict or object to certain processing, including processing based on legitimate interests and direct marketing.
• –  Portability: To receive certain data in a structured, commonly used, machine-readable format.
• –  Withdraw Consent: To withdraw consent where processing is based on consent.

12.2  Additional rights for United States residents:

12.2.1  Depending on your state of residence (e.g., California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana and other states with comprehensive privacy laws), you may also have the right to confirm whether we process your personal data, to access, correct and delete it, to obtain a portable copy, to opt out of any "sale" or "share" of personal data and of targeted advertising and certain profiling, and to limit the use of sensitive personal data.

12.2.2  We do not sell personal data or use it for cross-context behavioural advertising in the manner defined by those laws.

12.2.3  You will not be discriminated against for exercising your rights, and you may appeal a refusal of a request where the law provides for an appeal.

12.3  How to exercise your rights

12.3.1  To exercise any right, you may contact our Legal Counsel (legal@morgenroete.ca) directly or use an authorised agent where the law permits. We may need to verify your identity before acting on a request. We respond within the timeframes required by applicable law and will explain any refusal.

12.3.2  You also have the right to lodge a complaint with the data protection authority in your country or region; for example, in the United Kingdom, the Information Commissioner's Office; in the EEA, your local data protection authority; in the United States, your State Attorney General; and elsewhere the competent regulator; for example, in Africa, the Nigeria Data Protection Commission; in the Americas, the ANPD (Brazil); in Asia, the Data Protection Board (India), the National Privacy Commission (the Philippines), the Personal Information Protection Commission (South Korea) and the PDPC (Singapore); and in the Middle East, the SDAIA (Saudi Arabia) — although we would welcome the chance to address your concerns first.

12.4  Residents of other Countries and Regions

12.4.1  If you are located outside the regions specifically named above, you may still have rights under your local data protection law, which may include rights of access, correction, deletion, objection, portability, and rights concerning consent, sensitive data and automated processing.

12.4.2  We honour the rights that apply to you and will explain how to exercise them on request. Where local law requires separate or explicit consent; for example, for processing sensitive data or for transferring data across borders, we obtain it.

13.0  Children's Privacy

13.1  The Services are intended for business users and adults and are not directed to children.

13.2  We do not knowingly collect personal data from children or minors in any jurisdiction.

13.3  In the United States, we do not knowingly collect personal data from children under the age of 13 years (consistent with the Children's Online Privacy Protection Act); in the EEA and United Kingdom, the relevant age for a child's consent to information-society services is 16 years (or the lower age set by local law); and other jurisdictions set their own thresholds.

13.4  If you believe a child or minor has provided us personal data, please contact us and we will take appropriate steps to delete it.

14.0  Third-Party Websites and Services

14.1  The Services may link to third-party websites, platforms and application stores that we do not control.

14.2  This Policy does not apply to such third parties, and we encourage you to review their privacy notices.

14.3  We are not responsible for the privacy practices or content of third-party services.

15.0  Changes to this Document

15.1  Morgenroete may amend this document from time to time to reflect changes in law, regulation, technology, our operations, or best practice. The current version is always the one published on the Website, identified by the version and effective date shown above.

15.2  Where a change is material we will take reasonable steps to notify affected users (e.g., by a notice on the Website or, where appropriate, by email).

15.3  Your continued use of the Website or the relevant service after the effective date of a revised version constitutes acceptance of it.

16.0  Contact

16.1  Questions, requests or complaints relating to this document may be sent to our Legal Counsel (legal@morgenroete.ca).

16.2  We aim to acknowledge correspondence promptly and to respond substantively within the timeframes required by applicable law.

16.3  This Policy is governed by, and the resolution of any dispute relating to it will be subject to, the laws of the State of Wyoming, United States of America, and applicable United States federal law, without prejudice to mandatory data protection rights and remedies available to you under the laws of your country or state of residence.

1.0  Website Usage subject to Terms Agreement

1.1  Please carefully read these Terms of use before you begin use of the Website.

1.2  By accessing or using the Website, you indicate that you agree to be bound by the Terms. If you do not agree to the Terms, please do not use the Website.

2.0  Applicable Terms

2.1  These Terms govern general use of the Website.

2.2  Additional terms apply to specific activities and, where they do, they supplement these Terms and prevail to the extent of any conflict on their subject-matter:

• –  Cookie Policy (M-DPR-POL-001);
• –  Privacy Policy (M-DPR-POL-002);
• –  Disclaimers (M-LEG-DIS-001);
• –  Acceptable Use Policy (M-LEG-POL-001);
• –  Terms & Conditions – Shop (M-LEG-TER-002) for purchases;
• –  Terms & Conditions – Master (M-LEG-TER-003) for business services;
• –  End-User License Agreement (M-LEG-AGR-001) for our applications and software; and
• –  Notice of Intellectual Property (IP) (M-IP-NTC-001).

3.0  Eligibility and Account Security

3.1  You must be at least 18 years old and able to form a binding contract to use the Website.

3.2  Where the Website provides account features, you are responsible for keeping your credentials confidential and for all activity under your account, and you must notify us promptly of any unauthorised use.

4.0  Permitted Use of Website

4.1  We grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Website for your own lawful, personal or internal business purposes, subject to these Terms and the Acceptable Use Policy (M-LEG-POL-001).

4.2  You must not use the Website in any way that breaches the Acceptable Use Policy, infringes the rights of others, or interferes with the operation, security or integrity of the Website.

5.0  Intellectual Property (IP)

5.1  The Website and its content, materials, software, design, text, graphics, and the Morgenroete and all related names, logos and marks, are the property of the Morgenroete Group or its licensors and are protected by intellectual property laws.

5.2  Except as expressly permitted in these Terms or the Notice of Intellectual Property (IP) (M-IP-NTC-001), you may not copy, reproduce, distribute, modify, frame, republish or create derivative works from the Website or its content.

6.0  Content you Submit

6.1  If you submit content through the Website (e.g., an enquiry, upload or review), you confirm you have the right to do so, and you grant us a non-exclusive, worldwide, royalty-free licence to use that content for the purpose of operating the Website and responding to you.

6.2  You must not submit content that is unlawful, infringing, misleading, harmful or otherwise in breach of the Acceptable Use Policy.

7.0  Third-Party Links and Materials

7.1  The Website may contain links to third-party websites and resources. We provide these for convenience only and are not responsible for their content, availability or practices.

7.2  Access to third-party sites is at your own risk and subject to their terms.

8.0  Availability and Changes to the Website

8.1  We may change, suspend or withdraw all or part of the Website, and may restrict availability, without liability.

8.2  We do not warrant that the Website will be uninterrupted, error-free or free of harmful components.

9.0  Disclaimers

9.1  The Website and its content are provided on an "as is" and "as available" basis for general information purposes only.

9.2  Nothing on this Website constitutes an offer, quotation, or professional advice, and it may be updated without notice.

9.3  Nothing on this site creates a contractual relationship; engagements are governed by separately executed agreements.

9.4  To the fullest extent permitted by law, we disclaim all warranties, express or implied, including as to accuracy, completeness, currency, merchantability, fitness for a particular purpose, title, non-infringement and security.

9.5  Nothing on the Website constitutes professional, engineering, legal or other advice, and it must not be relied upon as such. Our full Disclaimers (M-LEG-DIS-001) form part of these Terms.

10.0  Limitation of Liability

10.1  Nothing in these Terms excludes or limits any liability that cannot be excluded or limited by law, including liability for death or personal injury caused by negligence or for fraud.

10.2  Subject to clause 10.1, to the fullest extent permitted by law we will not be liable for any indirect, incidental, special, consequential or punitive loss, or for loss of profit, revenue, business, goodwill, data or anticipated savings, arising out of or in connection with your use of, or inability to use, the Website; and our total aggregate liability arising out of or in connection with the Website and these Terms will not exceed the fees (if any) you paid to us to access the Website or, where no such fees were paid, a nominal amount of one hundred United States dollars (US$100).

11.0  Indemnity

11.1  You agree to indemnify and hold harmless the Group and its officers, directors, employees and agents from and against any claims, losses, liabilities and reasonable expenses arising out of your breach of these Terms or your misuse of the Website.

12.0  Privacy

12.1  Our handling of personal data in connection with the Website is described in our Cookie Policy (M-DPR-POL-001) and Privacy Policy (M-DPR-POL-002).

13.0  Governing Law and Jurisdiction

13.1  These Terms and any dispute or claim arising out of or in connection with them or their subject-matter are governed by the laws of the State of Wyoming, United States of America, and applicable United States federal law.

13.2  You and we submit to the exclusive jurisdiction of the state and federal courts located in the State of Wyoming, except that we may bring proceedings to protect our rights in any competent court, and nothing in this clause deprives a consumer of the protection of mandatory laws of their country of residence.

14.0  General

• –  Entire Agreement: These Terms and the documents referred to in them are the entire agreement between us about the Website.
• –  Severability: If any provision is found unenforceable, the remaining provisions continue in full force.
• –  No Waiver: A delay in enforcing a provision is not a waiver of it.
• –  Assignment: We may assign or transfer these Terms; you may not without our consent.
• –  Force Majeure: We are not liable for failure or delay caused by events beyond our reasonable control.

15.0  Changes to this Document

15.1  Morgenroete may amend this document from time to time to reflect changes in law, regulation, technology, our operations, or best practice.

15.2  The current version is always the one published on the Website, identified by the version and effective date shown above. Where a change is material we will take reasonable steps to notify affected users (e.g., by a notice on the Website or, where appropriate, by email).

15.3  Your continued use of the Website or the relevant service after the effective date of a revised version constitutes acceptance of it.

16.0  Contact

16.1  Questions, requests or complaints relating to this document may be sent to our Legal Counsel (legal@morgenroete.ca).

16.2  We aim to acknowledge correspondence promptly and to respond substantively within the timeframes required by applicable law.

1.0  Cookies and Similar Technologies

1.1  Cookies are small text files placed on your device when you visit a website.

1.2  Similar technologies include pixels, tags, software development kits (SDKs), local storage and device identifiers.

1.3  Cookies and similar technologies together allow a website or application to:

1.4  Cookies may be "first-party" (set by us) or "third-party" (set by a provider we use).

1.5  Cookies may be "session" cookies (deleted when you close your browser) or "persistent" cookies (that remain until they expire or you delete them).

2.0  Categories of Cookies We Use

2.1  Embedded tools on the Website pages may set their own cookies, governed by their providers' policies.

2.2  A detailed and regularly updated list of the specific cookies and similar technologies we use, including their name, provider, purpose and duration, and whether they are first- or third-party, is available through the "Cookie Settings" control on the Website. As the specific technologies in use can change, that live list, rather than this document, is the definitive record of the cookies currently deployed.

3.0  How we Obtain Your Consent

3.1  We do not set any non-essential cookie until you provide consent.

3.2  When you first visit the Website, and periodically afterwards, we present a cookie banner. Strictly Necessary cookies are set automatically because the Website cannot function without them.

3.3  Our cookie banner provides you the option to "Accept All", "Reject All", or "Choose which Categories to Allow" with equal prominence and with no pre-ticked boxes.

3.4  You may choose to change or withdraw your consent at any time through the "Cookie Settings" control on the Website.

3.5  Withdrawing consent will not affect processing already carried out and may affect the availability of certain features.

4.0  Managing Cookies through Your Browser

4.1  Most browsers allow you to view, block or delete cookies through their settings, and to signal your preferences using controls such as the Global Privacy Control.

4.2  Blocking cookies may prevent parts of the Website and its services from functioning correctly.

4.3  Guidance is available in your browser's Help documentation.

5.0  Legal Basis

5.1  Where required by applicable law, including the EU ePrivacy rules, the UK Privacy and Electronic Communications Regulations, and equivalent requirements in other jurisdictions, we rely on your consent for all non-essential cookies, and on our legitimate interests for strictly necessary cookies.

5.2  Personal data collected through cookies is handled in accordance with our Privacy Policy (M-DPR-POL-002).

6.0  Changes to this Document

6.1  Morgenroete may amend this document from time to time to reflect changes in law, regulation, technology, our operations, or best practice.

6.2  The current version is always the one published on the Website, identified by the version and effective date shown above. Where a change is material we will take reasonable steps to notify affected users (e.g., by a notice on the Website or, where appropriate, by email).

6.3  Your continued use of the Website or the relevant service after the effective date of a revised version constitutes acceptance of it.

7.0  Contact

7.1  Questions, requests or complaints relating to this document may be sent to our Legal Counsel (legal@morgenroete.ca).

7.2  We aim to acknowledge correspondence promptly and to respond substantively within the timeframes required by applicable law.