OUR COMMITMENT TO PRIVACY
SCOPE OF POLICY
This Policy applies to our collection, use and disclosure of your personal information. This Policy does not impose any limits on the collection, use or disclosure of business contact information or certain publicly-available information.
We have designated a Privacy Officer who is responsible for our compliance with this Policy. The Privacy Officer’s contact information is set out below.
When collecting personal information, we will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection.
We collect, use and disclose your personal information for the following purposes:
- to provide and administer products and services you request, and to disclose the information for any purpose related to the provision of requested products and services;
- to authenticate your identity;
- to provide personal information to third-party suppliers of products and services (as discussed in more detail below);
- to manage or transfer our assets or liabilities, for example, in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products or services;
- to maintain accurate customer records;
- to protect us, yourself and others from fraud and error and to safeguard our business interests;
- to provide reports to credit bureaus;
- to collect debts owed to us;
- to comply with legal and regulatory requirements; and
- to distribute to third parties including financial institutions, payment processors, lawyers, financial institutions and government licensing bodies for any of the above purposes.
The collections, uses and disclosures listed above are a reasonably necessary part of your relationship with us. We may also collect, use and disclose your personal information as follows:
- we may use your personal information to offer additional or alternate products and services to you and may add your personal information to customer lists for this purpose; and
- we may share your personal information with suppliers and third parties so that they may offer their products or services to you.
You may instruct us not to use or share your personal information for any of these two purposes at any time by so notifying our Privacy Officer in writing. We acknowledge that the sharing of your personal information for any of those two purposes is at your option and we will not refuse you access to any product or service merely because you have instructed us to stop using or sharing your personal information in those ways.
When your personal information is to be used for a purpose not previously identified, we will disclose that the new purpose to you before such use, and we will seek your consent unless the use is authorized or required by law.
We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where:
- the information is publicly available, as defined by statute or regulation;
- we are obtaining legal advice; or
- we reasonably expect that obtaining consent would compromise an investigation or proceeding.
Other exceptions may apply.
Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of withdrawal of consent. If you notify us that you withdraw consent, we will inform you of the likely consequences of that withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.
LIMITS ON COLLECTION OF PERSONAL INFORMATION
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.
LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL INFORMATION
We will only use or disclose your personal information for the purposes set out above and as authorized by law.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retaining the information and retention is no longer necessary for a legal or business purpose.
We will take due care when destroying personal information so as to prevent unauthorized access to the information.
We may retain agents, subcontractors or service providers from time to time in relation to our business or the products or services that we provide. If we require a service provider to deal with your personal information, we will take reasonable steps to ensure that the service provider adheres to privacy procedures and will keep your personal information confidential. We will not provide more information than is necessary to the service provider and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.
Our service providers may be located outside of Canada, and you acknowledge that personal information may be processed and stored in foreign jurisdictions and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction.
We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.
If you demonstrate that your personal information is inaccurate or incomplete, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
SAFEGUARDING PERSONAL INFORMATION
We protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by our suppliers and agents.
Note that confidentiality and security are not assured when information is transmitted through e-mail or other digital or wireless communication. Please notify our Privacy Officer in writing if you do not want us to communicate with you through these means.
You have a right to access your personal information held by us.
Upon written request and authentication of identity, we will provide you with your personal information under our control. We will also give you information about how that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so.
We will make the information available within 30 days of receiving a written request or provide written notice where additional time is required to fulfil the request.
In some situations, we may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm our competitive position). We may also be prevented by law from providing access to certain personal information.
Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
We will, on request, provide information regarding our complaint procedure.
Any inquiries, complaints or questions regarding this Policy should be directed in writing to our Privacy Officer as follows: