Types of Information We Collect
Personal information is any information recorded in any form that identifies or can identify you as an individual and includes any information provided to us by you or by third parties (“Personal Information”). While we try to ensure that every third party who discloses Personal Information to us has your consent to do so, if you believe a third party has inappropriately disclosed your Personal Information to us, please contact that third party. If they do not adequately respond to your inquiries, please let us know immediately. More detail of the type of Personal Information we collect and for what purposes is found below.
As part of our commitment to treat your Personal Information with respect, we operate in accordance with the PIPEDA fair information principles (the “PIPEDA Principles”): accountability; identifying purposes; consent; limiting collection; limiting use, disclosure, and retention; accuracy; safeguarding customer information; openness; access; and handling customer complaints and suggestions. An explanation of how we practice each PIPEDA Principle is set out below.
Prior to or at the time any Personal Information is collected, we will identify the purposes for which the Personal Information is being collected and how it may be used. These purposes, along with the consent for the collection and use will be documented.
We collect Personal Information for the following purposes:
- to provide products or services to you or someone you represent;
- to establish, administer and maintain responsible commercial relations and to communicate with our customers and potential customers;
- to understand our customers’ and potential customers’ needs and preferences;
- to establish your identification and to verify information you give us;
- to manage, administer, collect or otherwise enforce accounts and/or our business relationship;
- to communicate with you and safeguard your interests and ours and to protect you and us from error and fraud;
- to meet the requirements of applicable law, governmental or regulatory authority or other law enforcement purposes;
- in connection with any assignment of contracts or transactions involving us or our business out of the ordinary course of business;
- for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied;
- for purposes of maintaining quality service; and
- for the purpose of offering customers and users other products and services; and directing advertisements to you about products and services that may be of interest to you, including products from of us, our affiliates, and third parties with whom we have cooperative relationship, subject to compliance with Canada’s Anti-Spam Legislation.
In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when we want to use information for a purpose other than those identified above). In obtaining consent, we will use reasonable efforts to ensure that you are advised of the identified purposes for which Personal Information collected will be used or disclosed.
The Personal Information collected by us shall be limited to those details necessary for the purposes identified to you. We may gather such Personal Information from you in person, over the telephone or by corresponding with you via postal mail, facsimile, and the internet including e-mail or through your use of our website, or from third parties who have your authority to disclose such Personal Information to us. When you visit our website, information is not collected that could identify you personally unless you choose to provide it voluntarily.
Limiting Use, Disclosure, and Retention
Any Personal Information collected will only be used by us in accordance with the purposes for which it was originally collected unless you have otherwise consented, or when it is required or permitted by law.
In some instances, such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. In such cases, we will only disclose Personal Information required to be disclosed.
Any Personal Information retained or stored by us will be limited to what is necessary for the intended purposes for which it was collected or to which you have otherwise consented, all other Personal Information will be destroyed or de-identified in accordance with our document retention and destruction policy.
We shall make every reasonable effort to ensure your Personal Information is accurate and up-to-date, and you are encouraged to notify us of any inaccuracies or errors in your personal information. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us. Please note that before we are able to provide you with any information or correct any inaccuracies we may ask you to verify your identity and to provide other details to help us to respond to your request.
Safeguarding Customer Information
Upon your request, we shall inform you of the type of Personal Information we have collected, how we have used your Personal Information in the past, how we may in the future, and whether or not we have disclosed your Personal Information to any third parties (and, if so, to whom). Individuals may verify the accuracy and completeness of their Personal Information, and may request that it be amended, if appropriate. Please note that before we are able to provide you with any information or correct any inaccuracies we may ask you to verify your identity and to provide other details to help us to respond to your request.
Handling Customer Complaints and Suggestions
If you have a concerns or complaints about privacy, confidentiality or our Personal Information handling practices, or would like to correct or discuss any of your Personal Information, please contact our Privacy Officer at:
Attention: Jennifer Manning, VP & General Counsel
MaRS Centre, Heritage Building
101 College Street, Suite 345
Toronto, ON M5G 1L7
Before we are able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavor to respond within an appropriate timeframe.
We maintain a strict no-spam policy. In accordance with Canada’s Anti-Spam Legislation, we will not send you commercial electronic messages advertising additional products and services that you have not expressed an interest in, nor will we permit your Personal Information to be used by third parties or affiliates for such a purpose unless we have your express consent to send commercial electronic messages to you for such purpose.
If you receive unsolicited email from us, our vendors, or agents, please notify our Privacy Officer at the address set out above, and include the offending email with all the headers intact. Please be aware that it is not uncommon for spammers to hide behind someone else’s email account, as well as use mail servers that they do not own.
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by providing us written notice to the address above. You may not be able to withdraw your consent if it was collected for a purpose required by law..
You acknowledge that the exchange of electronic communication is vulnerable to attack by viruses and other destructive electronic programs. As a result, we cannot ensure the security or privacy of Personal Information that you provide to us over internet, and you acknowledge that we assume no liability or responsibility in connection any Personal Information that you provide to us over the internet.