OUR PRIVACY COMMITMENT
SCOPE OF POLICY
We collect two types of information from you: (i) information that you voluntarily provide to us (e.g. through a voluntary registration process, sign-ups or e-mails); and (ii) information that is derived through automated tracking mechanisms.
We may collect information such as your name and e-mail address, any name you use to identify yourself in the Services, details of your use of the Services (including information about when and how you use the Services, traffic data and your geographic location data), and details about your use of social networking and our Services.
Technical Tracking Information
We may collect technical information from your computer that does not identify you, including: the time you spend on our website; the pages you visit; the operating system and web browser software you use; and, if you locate our website through a search engine, the keywords you used to find us. This information is stored only in aggregate form and used for statistical analysis in an effort to understand how our users use our Services and to improve our Services. We reserve the right to attempt to link this information to an individual if it becomes necessary in order to investigate a security breach or other illegal activity related to our website.
We collect, use and disclose your personal information for the following purposes:
• to provide and administer Services, and to disclose the information for any purpose related to operation of accounts and provision of Services;
• to communicate with you through our Services and email;
• to authenticate your identity;
• to monitor your compliance with any of your agreements with us;
• to provide personal information to our suppliers and other third parties who need the information in order to deliver or support Services on our behalf;
• to ensure that the Services are presented in the most effective manner for you and for the device from which you access the Services;
• to protect us, yourself and others from fraud and error and to safeguard our business interests;
• 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.
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 may be required by law to disclose your personal information, for example to comply with valid legal processes such as a subpoena or court order. We may also need to disclose your personal information in order to protect our legal rights or property, or where failure to disclose your personal information may put the safety of another individual at risk.
We may retain agents, subcontractors or service providers from time to time in relation to our business or the Services. 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 us 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.