(December 1, 2016)
Our Commitment to Privacy
For clarity, we will collect, use and disclose personal information that you provide to us, but our system will not necessarily function to collect personal information that is contained in documents you store, access or distribute through use of our products or services that is encrypted. However, personal information that is contained in documents that you store, access or distribute through use of our products or services that is encrypted may be collected should such collection be required by law.
Personal information may include, for example, your name and home address, your date of birth and gender, health information, your occupation, your personal financial records or credit information, or any personal identification numbers.
We may collect, use or disclose personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:
- To provide products and/or services to you and/or access to our website;
- To comply with our legal obligations and regulatory requirements;
- To provide information to anyone working with or for us as needed for the provision of our services;
- To develop and manage our business and operations;
- For billing, accounting and debt collection services relating to our products and services;
- To distribute publications, invitations, and other communications that we believe may be of interest to our clients, customers and other individuals;
- To respond to your questions and concerns;
- To contact you for survey or client satisfaction purposes, or for the purpose of market or other types of research;
- To detect and protect us and third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with our insurers;
- To otherwise communicate with our insurers;
- For internal, external and regulatory audit purposes; and
- For any other purpose for which we have your consent.
When we receive personal information from you for the purposes of providing you with our services, you are providing us with consent as follows:
- to allow us to deal with that personal information in a reasonable manner;
- to allow us to use and store your personal information for the purpose of providing you with the products and services you purchase from us and to utilize this website; and
- to allow us to transfer your personal information outside of Canada (in which instance your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your personal information by us.
If you need to provide us with personal information about other individuals (including any of your service providers or representatives to whom you will permit access, distribution or other use of your personal information and any documents that you store or distribute through use of our products or services, or any other individual), you represent and warrant to us that, where required by law and prior to your disclosure to us, you will obtain the consent of each individual to the collection, use and disclosure by us for the specific purpose(s) that the disclosure is made to us by you, including consent for us to contact such individual as required by law including Canada’s Anti Spam Laws (An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents Act and the Telecommunications Act (S.C. 2010, c. 23) (“CASL”).
Providing us with your personal information is always your choice. When you request products and/or services from us, utilize our services, or register with our website, we ask that you provide information that enables us to respond to your request and/or provide you with our services. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for these purposes.
There are legal exceptions where we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if we must comply with a court order or governmental order. In such instances we may be required to obtain personal information incorporated in any documents that you store, access, distribute, or otherwise use through our products and/or services.
Collection of Personal Information
We may collect personal information about you from other sources, such as government ministries, departments or agencies, government registries, investigators, health institutions or organization, insurance companies or financial institutions. By using our website and/or service(s) you consent to our collection of your personal information from other sources.
Use of Personal Information
Disclosure of Personal Information
We do not sell client lists or personal information to others. In providing our services or access to our website, we may need to disclose the personal information we collect to other service providers or agents who perform various functions for us, provided such suppliers agree to keep all personal information private, confidential and secure and to use the personal information only to carry out work on our behalf.
In certain circumstances, we may be required to provide personal information to third parties for legal or regulatory purposes.
Privacy and Our Websites
Each time a visitor comes to the website, our web server collects and logs certain information in access logs. These access logs are kept for a reasonable period of time. These access logs include, but are not limited to, information such as the following: your machine’s TCP/IP address, your username (if applicable), files accessed, the date and time of such access, and other information pertaining to your activities on our website. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. We may use this non-personal information to optimize our website and/or services.
We may, from time to time, use “cookies” solely for security and authentication purposes.
Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or services. At your option, you may turn off our “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of our websites, products and/or services. To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser.
Retention and Destruction of Personal Information
The amount of time we will retain personal information varies, depending on the services we have provided and the nature of the personal information that we hold. We retain personal information for such period of time as is necessary for us to maintain sufficient information so we may respond to any issues that arise at a later date or as is required by law.
When personal information is no longer required by us or by law, we will either convert it into an aggregated non-identifying form or we will appropriately destroy or erase the personal information in a manner that is in accordance with our current policies and procedures.
Safeguarding Personal Information
We employ reasonable physical, electronic and procedural safeguards that are designed to protect our systems and personal information under our control against unauthorized access and use. In accordance with appropriate industry standards in Canada, all safety and security measures are appropriate to the sensitivity level of the information collected.
We may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and we do not have any control over such external servers or services.
Email is frequently our preferred method of communicating with you and others, and, unless you object, we may use unencrypted plain text or html-based emails when communicating with you. These emails, and other electronic means by which we may communicate with you, may contain information that is confidential, unless you instruct us not to send such information electronically. We may communicate with you through other electronic means, in accordance with the contact information you provide to us.
While we make every effort to secure all electronic communications within our control, there are inherent risks involved with exchanging information electronically. For example, such information may be accidentally or deliberately intercepted by third parties. We are unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.
We will endeavour to be compliant with CASL in our commercial electronic communication with you. Should you fail to provide us with the requisite consent to send you commercial electronic messages, or withdraw such consent, we may be unable to provide, or continue to provide, some of our services that can only be provided if we receive appropriate and required personal information. CASL consent can be provided or withdrawn by contacting our privacy officer listed below.
Keeping Information Accurate / Access and Correction
It is important to us that your personal information held by us is accurate and complete. Having accurate information about you enables us to give you better service. You can help us keep personal information up-to-date by keeping us informed of any changes, such as a change of address, telephone number or any other circumstances.
With some exceptions, you have the right to access, verify and amend the information we have about you after we have received your written request and authenticated your identity.
We may charge a reasonable fee for providing information in response to an access request, and, upon request, we will provide an estimate of any such fee upon receiving a request to access information. We may require a deposit for all or part of the fee.
Where applicable or permitted, we will make the information available within 30 days or provide written notice when we require additional time to respond to a request for access to information.
In some situations, we may not be able to provide access to certain personal information as the right to access personal information is not absolute. If we do not provide you with the requested information, we will notify you in writing and explain our reason(s) for not fulfilling your request.
Despite our efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know and we will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from us.
Withdrawal of Consent
You may, at any time, withdraw your consent to our collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions. Should you choose to withdraw your consent, we may be unable to provide, or continue to provide, some of our services that can only be provided if we receive appropriate and required personal information. Consequently, should you choose not to provide us with the required personal information, we may be unable to offer these services to you.
You may, at any time, ask us not to send you further marketing materials about our services or if you do not wish to receive further invitations, you may unsubscribe or ask us not to contact you for these purposes.
Please contact our privacy officer to obtain further information about our policies and procedures, to seek access to personal information we may have about you, or if you have any unresolved inquiries or concerns. We will respond to you promptly and do our utmost to resolve your concerns. We may need to ask you for personal information to verify your identity.
Chief Privacy Officer
Contact: Luke Kyleman
Address: 110 Spadina, 3rd Floor, Toronto, Ontario, M5V 2K4
Successors and Assigns