Before collecting any Personal Information, The Company will identify why the Personal Information is required and how it will be used. This Personal Information is documented and kept on file at The Company's offices. The Company will obtain the Customer's consent before using or disclosing Personal Information for purposes other than the original reasons given.
The Company collects and uses a Customer's Personal Information for the following general purposes
We will collect Customer consent separately with respect to the sending any “commercial electronic messages”, as defined in Canada’s anti-spam legislation, found at S.C. 2010, c.23, as amended (“CASL”).
We may use, share and disclose a Customer's Personal Information to our affiliates, associates, agents, suppliers and such other third parties as The Company, acting reasonably, may deem necessary for the fulfillment of the purposes noted above or where otherwise permitted by law. In the unlikely event that The Company or substantially all of its assets are acquired by a third party, a Customer's Personal Information may be one of the assets transferred to such third party.
Except in certain extraordinary circumstances, The Company does not collect, use or disclose a Customer's Personal Information without their knowledge and consent. Such extraordinary circumstances may include, without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent.
Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Customer, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous.
The Company strives to ensure that a Customer's Personal Information is as accurate, complete and up to date as necessary for the purposes for which it is used. Information is updated only when necessary to fulfill specified purposes.
The Company has security safeguards in place designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Personal Information under the care of The Company. The nature of the safeguards depends on the sensitivity, format, location and storage of the Personal Information. These security measures may from time to time include locked cabinets, computer passwords, software firewall's to stop hackers, encryption software, restricting access to Personal Information to only those employees or representatives who have a need to know and, if deemed necessary by The Company in its sole discretion, confidentiality covenants from third parties to whom Personal Information has been disclosed.
E-mail and the internet are not a 100% secure medium, and Customers should be aware of this when contacting us to send Personal Information.
Upon written request of a Customer, The Company will provide such Customer with access to his or her Personal Information. The Company will correct or amend any inaccuracies in the Customer's Personal Information, and such amended information will be forwarded to any third parties who require access to the information. The Company has the right to refuse a request for access to Personal Information:
If the request of a Customer for such individual's Personal Information is denied, the individual will be informed in writing of the reasons for the denial, as well as any recourse available to such individual.
Access to a Customer's Personal Information will be at no cost to such Customer. Minimal charges may apply, however, for the transcription, reproduction or transmission of documents containing Personal Information.
If a complaint ("Complaint") regarding The Company's handling of Personal Information is received, an individual ("Investigator") with the skills necessary to conduct an investigation fairly and impartially will be assigned. The Investigator will have access to all relevant records and will be permitted to speak with employees of The Company who handled the Personal Information access request. The complainant will receive notification of the outcome of the investigation clearly and promptly. Any inaccurate Personal Information or policy/procedure changes will be modified, if necessary, based on the outcome of the Complaint.
This document was last updated on September 24, 2015