NOTE: For important information about prudent use of the Internet, please visit the Federal Trade Commission’s web site at http://www.ftc.gov/ to learn more about such topics as Internet fraud, identity theft, phishing, spoofing, spamming, etc.
This policy addresses how Merit treats PII that Merit collects and receives, including information related to a Protected Party’s past use of Merit online services and ownership of mineral, partnership of other interests. “PII” is information about a Protected Party that is personally identifiable, such as the Protected Party’s name, physical address, e-mail address, telephone number, social security number or employer identification number, or other information that is not otherwise available from public sources such as telephone directories or government records.
Information Collection, Use, Sharing and Disclosure
General Collection and Use:
Merit collects PII from a Protected Party when the Protected Party (1) registers for access to Merit’s web site; (2) owns a royalty or other interest in assets owned and/or operated by Merit; (3) is an investor or potential investor in one of Merit’s affiliated partnerships; and (4) communicates directly with Merit, including e-mails and telephone calls received by Merit’s Land, Accounting, Investor Relations and other departments. Merit also collects PII with respect to certain Protected Parties when Merit acquires assets (and, as a result, inherits information from its predecessor working interest owners) or itself collects information regarding Protected Parties. Merit may choose to combine the PII of Protected Parties with information Merit obtains from its business partners or other affiliated companies for internal Merit surveying purposes.
When a User registers for web access with Merit, the User will be asked for information such as name, address, telephone number, zip code, investment experience and status (if accessing as an investor or potential investor). Certain other Users may send email or post comments via Merit’s web site in connection with royalty interest issues, etc. Once a User registers with Merit and logs onto the Merit web site, the User will not be anonymous to Merit.
Merit collects PII and other information about certain agents, contractors and suppliers who engage in other transactions with Merit and/or assist in providing support for Merit internal operations and services.
Merit automatically receives and records information on Merit web server logs from User web browsers, including User IP addresses, User cookie information and the particular web pages a User requests.
Merit uses User PII and other User information collected for the following purposes: (1) to verify the identity of Users; (2) to improve Merit services; and (3) marketing activities.
Merit may, from time to time, provide anonymous reporting of aggregate data to unaffiliated external clients; however, such reporting will be done on an anonymous basis using aggregated data that is not displayed in such a manner that it constitutes PII for individuals.
Merit Web Site Cookies:
Although Merit currently utilizes cookies only, Merit reserves the right to use other methods of online user session tracking, including but not limited to such technologies as web beacons, any time in the future.
Confidentiality and Security:
Merit has internal policies and procedures designed to keep Protected Parties’ PII safe. These include:
- Allowing access to PII only to authorized employees, agents, contractors or suppliers who need that information to perform specific job responsibilities;
- Maintaining physical, electronic and procedural safeguards that comply with federal regulations to guard PII, including appropriate security measures in place in Merit’s physical facilities to protect against the loss, misuse or alteration of collected PII, and requiring Merit subcontractors to employ the same safeguards;
- Training Merit employees on privacy and implementing disciplinary procedures for any employees who violate Merit procedures, and requiring that all Merit subcontractors train their employees regarding Merit privacy policies and procedures.
Merit internet access to account information is password-protected.
In certain areas within the Merit web site, Merit uses industry-standard Secure Socket Layer (“SSL”) technology and encryption to protect data transmissions.
Information Sharing and Disclosure:
Merit does not rent or sell PII. Merit does not share a User’s PII with unaffiliated individuals or companies except to: (1) provide products and services requested by such User; and (2) under the following conditions:
- When Merit provides PII and other information to contractors and unaffiliated companies who work either on behalf of or with Merit under agreements that provide for confidentiality of PII, such contractors and companies may use PII to assist Merit in fulfilling its business objectives as an energy company and investment advisor; however such confidentiality provisions prevent such contractors and companies from sharing or selling PII to any third parties not under any contractual obligations to Merit.
- When Merit is responding to subpoenas, court orders, or other legal process or procedure, including the requests of governmental authorities in conjunction with an investigation;
- When Merit believes it is necessary to share information with third parties in order to investigate, prevent or take action regarding: (1) illegal activities; (2) suspected fraud; and (3) situations involving potential threats to the physical safety of any person.
- When Merit transfers PII to a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate/partnership change.
Affiliated Partnership Privacy Policies
If a Protected Party believes that Merit is not following its stated Privacy Policies, the Protected Party may contact Merit at 13727 Noel Road, Ste. 1200, Dallas, Texas, 75229, Attn: General Counsel, 972-701-8377.