We will only use your personal information in accordance with this Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect is adequate, relevant, not excessive, and used for limited purposes as further described below.
- Scope of Policy
It is the Company’s policy to comply with the privacy legislation within each jurisdiction in which it operates. This Policy covers only those activities that are subject to provisions of Canada’s federal and provincial privacy laws, as applicable.
If you are unsure if or how this Policy applies to you, please contact our Privacy Officer for further information.
- What is Personal Information?
For the purposes of this Policy, personal information is any information about an identifiable individual, which includes information that can be used alone or in combination with other information to identify, contact or locate a single person. Personal information does not include a person’s business title or business contact information when used or disclosed for the purpose of business communications.
- What Personal Information Do We Collect?
We may collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:
- Contact and identification information, such as your name, address, telephone number and e-mail address;
- Product and service-related information concerning the products and services that we provide to, or receive from you;
- Credit and financial information such as your payment preferences; and
- Business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you;
- market-related information, which may include personal information, concerning market trends and activities impacting our business. Such information may include contract terms, financial information and other information for the purposes of market analysis and strategic planning;
- Information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.
Generally, the Company collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before se week out this information from such sources (such permission may be given directly by you, or implied from your actions as permitted by and in accordance with applicable privacy legislation.
From time to time, we may utilize the services of third parties in our business and may also receive personal information about you that has been collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by law or regulatory requirements, we may collect information about you without your knowledge or consent.
- Why do We collect Personal Information?
The Company collects personal information to enable us to manage, maintain, and develop our business and operations, including:
- To establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
- To be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
- To be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
- To be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
- To protect us against, error, fraud, theft and damage to our goods and property or other illegal activities;
- Compiling statistics for analysis of our business;
- To enable us to comply with legal, security, processing and regulatory requirements; and
- Any other reasonable purpose to which you consent.
- How do we use and disclose your personal information?
We may use or disclose your personal information:
- For the purposes described in this Policy; or
- For any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.
We may use or disclose personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
- When do we disclose your personal information?
We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on or behalf; third parties that assist the Company in the provision of services to you; and third parties whose services we use to conduct our business.
When we disclose your personal information to third parties, we require them to protect and handle your personal information in a manner consistent with our privacy practices and all applicable laws.
In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of the Company or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use and disclose your personal information in a manner that is consistent with the use and disclosure provisions of this Policy (including applicable privacy law), unless you consent otherwise.
Further, your personal information may be disclosed:
- As permitted or required by applicable law or regulatory requirements;
- To comply with valid legal processes such as search warrants, subpoenas or court orders;
- As part of the Company’s regular reporting activities to subsidiaries or affiliates;
- To protect the rights and property of the Company;
- During emergency situations;
- Where necessary to protect the safety of a person or group; or
- With your consent.
- Your Consent is Important to Us
Your knowledge of and consent to the Company’s collection, use and disclosure of your personal information is critical.
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an optout mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclosure your personal information for a purpose not previously identified (either in this Policy or separately), we will do so only in accordance with applicable privacy legislation.
As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by written communication addressed to our Privacy Officer using the contact information set forth below. The Company will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain personal information or withdrawing consent for the Company to collect, use or disclose your personal information could mean that we cannot obtain insurance coverage or other requested products, services or information for you as applicable.
We assume, that unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Policy.
- How is your Personal Information Protected?
The Company endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. Access to your personal information is restricted within our organization to those employees of ours and our affiliates who need to know that information in order to provide products or services to you. Our safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
- Updating and correcting your personal Information
It is important that the personal information we hold about you is both accurate and current. Please keep us informed if your personal information changes.
In some circumstances we may not be able accommodate your request to change your personal information (for example, where we believe such a change would violate any law or legal requirement or cause the information to be incorrect) and will instead append an alternative text to the record in question.
- Accessing Your Personal Information
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for you and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any such fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer as per section 16 of this Policy.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
We may not be able to provide you with access to your personal information in all circumstances, where this is the case, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
We store your personal information at our offices.
- International Transfers
We may store, access and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
By submitting your personal information, you consent to this transfer, access, storage or processing.
Generally, we retain your personal information for as long as necessary to fulfil the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records. We may retain personal data for longer when required by legal or regulatory obligations, professional indemnity obligations or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.
- Revisions to this Policy
- Interpretation of this Policy
Any interpretation associated with this Policy will be made by our Privacy Officer. This Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the term “including” is used, it shall mean “including without limitation”.
This Policy does not create or confer upon any individual any rights or impose upon the Company any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. If there is any inconsistency between this Policy and applicable privacy laws, this Policy shall be interpreted consistent with applicable law.
- Inquiries or Concerns
Privacy Officer: Gary Hirst
Telephone: (647) 256-5155
We will endeavor to answer your questions and advise you of any steps taken to address your concerns. If you are dissatisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at 1 800 282-1376.