On-line privacy concerns focus primarily on the protection of personal information which an individual reasonably expects to be kept private. “Personal Information” is defined in Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) as information about an identifiable individual.
Collection and Use
We will only collect personal information by fair and lawful means. We will not use or share the personal information provided to us in ways unrelated to the purposes for which it was collected.
We collect or use personal information when we provide and promote, or when you license, purchase or register for, products, services, functionality and other opportunities, when our functionality serves as a conduit to a third party, or when we reasonably believe that it will help administer our business. Our collection of personal information is often required in order to facilitate the functionality that you are using on our system. The type of personal information collected depends largely on the functionality that you use. In addition, such personal information collected may change over time since the range of products, services and functionality that we offer continues to expand and the technology we use continues to change. By providing us with personal information and using our functionality, you are deemed to have provided your permission to the collection and use of such information.
We collect and use such personal information as is reasonably required to provide the requested services, products, or information, and as is otherwise required or permitted by applicable laws, including as follows:
- Personal Information about yourself such as contact information (e.g. your name, company name, address, billing address, phone/fax numbers, e-mail address); billing information (e.g. such as credit card information); and information relating to the product, service or functionality that you are using.
- Depending on which products and services you have subscribed to and which privacy preferences you have indicated to us, we may use your contact information to provide periodic newsletters or to provide notices regarding products and services.
- We collect information from you that you submit through web forms, or by other means, to the Transaction Data Exchange “TDX” Service. By submitting information about another individual to TDX, you represent that you have, where required by applicable privacy laws, obtained the consent of such individuals to submit such information. We use information you submit to the TDX service as is reasonably required to provide the TDX service and by submitting information to the TDX service you consent to our disclosure of such information to the third parties with whom you agree to exchange data.
- We collect usage information such as data collected by our web sites (through technologies such as cookies). This information is used solely for enabling us to provide you with a customized online experience and to find ways to improve our offerings to you. Although cookies are widely used, it may be possible to disable cookies via your browser settings. However, in so doing, our web sites may not function properly or optimally.
We may collect and use your information for additional purposes that may be identified at or before the time that the information is collected or used.
Obtaining Your Consent
We may obtain your consent to use personal information by your express consent or we may determine that consent has been implied by the circumstances. Express consent may be given in writing (for example in an e-mail, a web form, through a web chat, or on paper); or verbally in person, over the telephone, or through online voice communications; or by your actions (for example, logging into or pressing certain buttons on our web sites or your use of our products or services).
When we receive personal information from you that enables us to provide you with a requested product, service or functionality, your consent to allow us to deal with that personal information in a reasonable manner is implied. If you need to provide personal information about other individuals, you must first obtain their consent for these purposes prior to your disclosure to us.
Providing us with personal information is always your choice. When you use our products, services or functionality, we ask that you provide information that enables us to respond to your needs. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for these purposes. You also authorize us to use and retain this personal information for as long as it may be required for the purposes described above.
Access and Corrections
You are entitled to access and verify your personal information. We will take reasonable steps to correct personal information that is not accurate.
Upon receipt of a written request, you will be able to review, within a reasonable time following such request, any personal information that is maintained in reasonably retrievable form. You may be required to provide specific identification information so that we can verify your identify before we provide you with the personal information we hold. Requests that require archival or other retrieval costs may be subject to a fee which will be communicated to you prior to retrieving the information. Access to your personal information may be denied in certain circumstances including when such denial is required or authorized by law or may have an unreasonable effect on other people’s privacy.
We may disclose personal information as follows:
- to third party service providers or agents who provide services to or on behalf of us (which third parties are obligated to maintain confidentiality and security of the personal information and are restricted from using such information other than as authorized by us or as otherwise permitted by law);
- to third parties when our functionality serves as a conduit to a third party, including to the third parties with whom you agree to exchange data using the Transaction Data Exchange “TDX” Service;
- as required by law; required to comply with a warrant or court order; related to an offence that has been or is about to be committed; required due to an emergency; made for the purpose of collecting a debt owed by you; protecting our rights and that of our users and third parties;
- to our legal, financial, insurance, and other advisors or in connection with the sale, reorganization, or management of all or part of our business or operations; and
We employ physical, electronic and procedural safeguards to protect our systems and all personal information under our control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected.
123 Front Street West