Policies

Conflict Minerals Policy

1. PURPOSE

This policy provides a framework through which RTDS Technologies Inc. (“RTDS”) shall comply with Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act pertaining to Conflict Minerals.

2. SCOPE

On August 22nd, 2012, the U.S. Securities and Exchange Commission (“SEC”) published regulations implementing Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act (“Act”) governing Conflict Minerals. The Act requires companies to perform due diligence on the source and chain of custody of Conflict Minerals contained in their products. RTDS is not a SEC registrant and therefore not required to file a Conflict Minerals Report in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”). However, RTDS does recognize the need to comply to the Rule 13p-1 standards where applicable in relation to reporting requirements of its customer base who may be subject to such Rules, and have therefore taken steps to become compliant where appropriate and applicable.

3. DECLARATION

RTDS strives to have a Conflict Free supply chain, and is committed to sourcing products and materials from non-conflict sources;
RTDS expects that its suppliers have due diligence processes in place to identify the source of the Conflict Minerals contained in their products, and that those sources do not support conflict and violations of human rights;
To further the benefits of Section 1502 and promote its intended purpose, RTDS will work with suppliers with underdeveloped processes, providing information and guidance in an attempt to increase supply chain transparency throughout the world and into the DRC and surrounding region.

RTDS undertakes to provide all suppliers identified under the SEC regulations with a Reasonable Country of Origin survey (“RCOI”). This survey must be completed by those suppliers to ensure continued eligibility to do business with RTDS. By signing and submitting the survey, suppliers certify that they have procedures in place to demonstrate that materials and products are sourced in accordance with RTDS standards, and attest to the reliability of the survey responses. Based on the survey results, RTDS may require additional information from those same suppliers in order to determine whether or not a supplier’s products or materials are indeed “Conflict Free”.

RTDS is dedicated to working with its suppliers to help establish traceability of Conflict Minerals and assure that our products and materials are responsibly sourced. However, suppliers who are not responsive to RTDS’s requests for information via the RCOI survey process may be disqualified from doing business with RTDS. At a minimum, RTDS will look to establish new sources for products and materials where the origin of Conflict Minerals in those products cannot be ascertained.

Accessible Customer Service Policy

1. STATEMENT OF PURPOSE

This policy provides the framework through which RTDS Technologies Inc. (“RTDS”) shall comply with the Accessible Standard for Customer Service under The Accessibility for Manitobans Act (“AMA”).
RTDS strives to provide exceptional customer service and recognizes the importance of providing an accessible, barrier-free environment for people of all abilities who seek to obtain, use or benefit from our goods and services.
RTDS is committed to meeting the requirements of the AMA and its Customer Service Standard. We will make reasonable efforts to ensure that our policies, procedures and practices, including those outlined in this accessible customer service policy, are consistent with the principles of dignity, independence, integration and equality opportunity for people with disabilities.

2. SCOPE

This policy applies to all Employees, consultants, officers and directors of RTDS who interact with customers, service recipients, suppliers or vendors in Manitoba. As such, each person has a duty to review, understand and comply with the requirements outlined in this policy.
It is important to note that nothing in the AMA or its regulations diminishes the obligations of a person or organization with respect to persons with disabilities under any other enactment, and, in particular, under The Human Rights Code.

3. DEFINITIONS

Accessibility – As it relates to this policy, accessibility means people of all abilities have the opportunity to participate fully in everyday life. Accessible customer service is provided when all persons who are reasonably expected to seek to obtain, use or benefit from a good or service have the same opportunity to obtain, use or benefit from the good or service.

Assistive Device – A technical aid, communication device or other instrument or equipment used to maintain or improve people’s functional abilities in daily living. Some examples include wheelchair, screen reader, listening device, magnifying glass or cane.

Barrier – Anything that prevents a person with a disability from fully participating in everyday life, including physical barriers, architectural barriers, informational barriers, attitudinal barriers, technological barriers and systemic barriers. As it relates to this policy, accessibility barriers limit or prevent people from being able to get information, service and goods or to enter a space or be part of an activity.

Service Animal – An animal that has been trained to provide assistance to a person with a disability that relates to that person’s disability.

Support Person – In relation to a person who is disabled by a barrier, a person who accompanies the person to support the person obtaining, using or benefiting from a good or service provided by an organization, or assist the person in addressing his or her communication, mobility, personal care or medical needs.

The Human Rights Code – Provincial human rights law that protects specific individuals and groups in Manitoba from discrimination, including persons with physical or mental disabilities. Under The Code, failure to provide reasonable accommodation to a special need that is based on a protected group or characteristic is considered discrimination. The Code has special status over all other laws of the Province of Manitoba.

4. PROCEDURES

Communication
RTDS will make reasonable efforts to ensure that, when communicating with a person who self-identifies as being disabled by a barrier, the communication is done in a manner that takes into account the barrier. This may include offering alternative methods of communication or measures to meet their communication needs.

Assistive Devices
Persons disabled by barriers may use their own assistive devices as required when accessing our goods, services or facilities. In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be considered to ensure the access of goods and services.

Support Persons
Support persons are welcomed on RTDS premises. Persons with disabilities and their support person will not be prevented from having access to each other while on our premises. All customer/client confidentiality requirements and practices will also apply to support persons. We will let the public know in advance if support persons have to pay admission or service fees for training courses or conferences.

Service Animals
Persons with disabilities are permitted to be accompanied by their service animal and keep that animal with them in areas/premises that are open to the public. The person requiring the service animal is responsible for the care and control of the service animal at all times. A service animal may not be permitted when any one of the following conditions exists:

The service animal is disruptive and the animal’s owner is not able to effectively control it;
The service animal’s presence, behavior, or actions pose an unreasonable or direct threat to property or the health or safety of others; and
When other laws specifically prohibit service animals.

In the event that a service animal’s access is not permitted, RTDS will make reasonable efforts to accommodate the individual and will suggest other alternatives to provide assistance.

Accessibility Features and Temporary Disruption of Services

To ensure barrier-free access to our goods, services or facilities, RTDS will maintain our accessibility features on our premises so they can be used as intended, for example:

Keeping aisles, reception areas, meeting/training rooms, and accessible restrooms clear of clutter
Ensuring our entranceway is clear of snow and ice.
Allowing space for mobility devices and removing any potential tripping hazards.

In the event of a planned or unexpected disruption of services or facilities affecting persons disabled by barriers, we will post notices as soon as possible. A clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available. Notices may be displayed on our premises or by other means that are reasonable in the circumstances.

Feedback
RTDS welcomes feedback on how we provide accessible customer service. Feedback will help us identify barriers and respond to concerns. Feedback can be provided in the following ways:

By mail or In-person: RTDS Technologies Inc. 100-150 Innovation Drive, Winnipeg, MB, R3T 2E1
By Telephone: 204-989-9700
By E-mail: feedback@rtds.com

All feedback is directed to the Accessibility Committee. If the feedback requires a follow-up or action, we will respond as soon as possible and in a way that meets the specific communication needs.

Training and Documentation Requirements
RTDS will provide accessible customer service training to all employees, consultants, officers and directors of RTDS who interact with customers, service recipients, suppliers or vendors in Manitoba. New employees will be trained as part of their orientation upon employment. Continuous, on-going training will be provided as necessary. Training will include:

An overview of The Human Rights Code (Manitoba), The Accessibility for Manitobans Act, and the Customer Service Standard.
How to interact and communicate with people who face barriers to accessing goods and services, including people who use assistive devices, are assisted by a support person and/or are assisted by a service animal.
Our organizational policies, practices and measures, including updates or changes.

We will keep written record of our accessibility and training policies including a summary of our training material and detailed records of the training provided. Through our company website, we will let the public know that our written policies are available upon request.

Privacy Policy

Effective date: June 27, 2019

RTDS TECHNOLOGIES INC. (“us”, “we”, or “our”) operates the https://www.rtds.com/ website (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.rtds.com/

DEFINITIONS

Service
Service is the https://www.rtds.com/ website operated by RTDS TECHNOLOGIES INC.

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our
possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small files stored on your device (computer or mobile device).

Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for
which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.

INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we
send.

Usage Data
We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your
visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences
and various settings.
Security Cookies. We use Security Cookies for security purposes

USE OF DATA

RTDS TECHNOLOGIES INC. uses the collected data for various purposes:

To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), RTDS TECHNOLOGIES INC. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

RTDS TECHNOLOGIES INC. may process your Personal Data because:

We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
For payment processing purposes
To comply with the law

RETENTION OF DATA

RTDS TECHNOLOGIES INC. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

RTDS TECHNOLOGIES INC. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

RTDS TECHNOLOGIES INC. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF DATA

Disclosure for Law Enforcement
Under certain circumstances, RTDS TECHNOLOGIES INC. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or government agency).

Legal Requirements
RTDS TECHNOLOGIES INC. may disclose your Personal Data in the good faith belief that such action is necessary to:

To comply with a legal obligation
To protect and defend the rights or property of RTDS TECHNOLOGIES INC.
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability

SECURITY OF DATA

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. RTDS TECHNOLOGIES INC. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where RTDS TECHNOLOGIES INC. relied on your consent to process your personal information. Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

ANALYTICS

We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

BEHAVIORAL REMARKETNG

RTDS TECHNOLOGIES INC. uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google
Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Bing Ads Remarketing
Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

Twitter
Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook
Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA, the Digital Advertising Alliance of Canada in Canada or the European Interactive Digital Advertising Alliance in Europe, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Pinterest
Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data

You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy

AdRoll
AdRoll remarketing service is provided by Semantic Sugar, Inc.

You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page:
http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false

For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

PAYMENTS

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors that we may work with are:

Apple Store In-App Payments
Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

Google Play In-App Payments
Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

Stripe
Their Privacy Policy can be viewed at https://stripe.com/us/privacy

PayPal / Braintree
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Square
Their Privacy Policy can be viewed at https://squareup.com/legal
/privacy-no-account

LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHILDREN’S POLICY

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification
of parental consent, we take steps to remove that information from our servers.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, please contact us:

By visiting this page on our website: http://www.rtds.com/contact