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.
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.
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.
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.
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.
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.
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.
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 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.
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:
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:
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.
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:
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:
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.
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.
Service is the https://www.rtds.com/ website operated by RTDS TECHNOLOGIES INC.
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 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 are small files stored on your device (computer or mobile device).
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.
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
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:
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
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.
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
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:
USE OF DATA
RTDS TECHNOLOGIES INC. uses the collected data for various purposes:
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
RTDS TECHNOLOGIES INC. may process your Personal Data because:
RETENTION OF DATA
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.
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).
RTDS TECHNOLOGIES INC. may disclose your Personal Data in the good faith belief that such action is necessary to:
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:
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).
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.
We may use third-party Service Providers to monitor and analyse the use of our Service.
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.
For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
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
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
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
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 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
AdRoll remarketing service is provided by Semantic Sugar, Inc.
You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page:
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).
The payment processors that we may work with are:
Apple Store In-App Payments
Google Play In-App Payments
PayPal / Braintree
LINKS TO OTHER SITES
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
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.