We are committed to protecting your personal information and your privacy in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). We are responsible for your personal information under our control and have appointed a Privacy Officer who is accountable for our personal information handling practices.
1. Effective Date
2. What Personal Information Do We Collect?
Personal information is information about an identifiable individual. It is information that identifies you or could be combined by us or our service providers and affiliates with other information to identify you or other individuals. This information includes personal e-mail address, home addresses, telephone numbers, credit card or financial information, social insurance numbers or driver’s license numbers and may include your age, your income, and other similar information when associated with you. Personal information may also be information containing details as to whether you have opened our promotional e-mails or how you have used our website, if we can associate that personal information with you. If you are a business customer or prospective business customer, personal information does not include your title, business address and business telephone number when we use that information to contact you in your business capacity.
The information we collect from you depends on the nature of the services provided to you. We collect personal information from you when you inquire about our services, become a client of the firm, communicate with us using our web forms to make a request or ask a question, or otherwise submit personal information to us with your communication.
We may also receive personal information about you from other sources, including for example from: your employer, our service providers, government agencies and regulators, financial institutions, credit bureaus or others third parties.
If you have a question or complaint about our personal information handling practices, please contact our Privacy Officer, by email at email@example.com at any time.
4. Why We Collect and How We Use Your
We require our service providers to keep your personal information secure. In addition, our service providers may not use or disclose personal information for any purpose other than providing the services on our behalf unless we or they have obtained your consent.
We may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our business or as part of a corporate reorganization, share or asset purchase or other change in corporate control.
We may disclose your personal information if it is necessary for us to collect a debt from you or where we have reason to believe that it is relevant to the investigation or decision to investigate a breach of the laws of Canada, a province or territory of Canada, or a foreign jurisdiction, and we are legally permitted to do so.
We may disclose personal information without your knowledge or consent if required by law, including without limitation, if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information.
We may also disclose your personal information any third party or parties, where you consent to such disclosure.
5. Links to Third-Party Website and Social Network Plug-Ins
6. Storage Outside of Canada
Your personal information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
7. Protecting Your Personal Information
We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees, and the use of, your personal information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our website if you consider that information to be sensitive.
We collect and use your personal information in order to provide you with professional services. Some examples include:
- to establish and manage our client relationship with you;
- to provide personal services to you;
- to share with third parties for the purpose of providing professional services, including for example with government agencies or regulatory bodies;
- to establish and maintain billing practices including issuing invoices, administering accounts, collecting and processing payments and to fulfill contractual obligations;
- to understand and fulfill your requests for information about our services;
- to communicate with you about your requests or the services we provide to you;
- to develop or enhance the delivery of our services or to market those services to you;
- to manage and develop our client information management practices and databases;
- to comply with legal, regulatory or other reporting requirements or obligations we may have; and
- for any other purpose to which you consent.
We retain your information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.
8. Personalized Offers and Web Analytics
We also automatically collect information when you visit our website in order to customize your experience. For example, we may collect information about what site referred you to our website, your browser type, operating system type and version, language, and your Internet Protocol (“IP”) address. We also collect information about how you browse through our website, including logging the pages you visit and the amount of time you spend on certain pages. We use this information for a number of technical purposes to ensure that our pages load correctly in your browser, as well as to personalize our offers to you. We also use this information to improve our website. For example:
- we use IP addresses to correct pages for your geographical location;
- we log the frequency of visits to certain pages on our website and how visitors navigate through our website in order to detect problems, improve our website and learn about what services are of interest to our clients or prospective clients; and
- we track whether certain types of promotional e-mails were opened by you and whether you sought information about a particular service in order to make inferences about other services you might be interested in.
9. Cookies and Interest Based Advertising
Our website may use small pixel files (small images) and cookies (small text files) to keep track of your browser so that you will be recognized when you visit other website where our third-party ad management providers may show you advertisements from us based on your visit to our website. Some of these advertisements may be customized to particular products and services that you viewed or they may be based on inferences about services that you might be interested in. This is called “interest-based advertising”.
10. Disclosure of Your Personal Information to Third Parties
We do not sell or rent your personal information to any third parties. We may share your personal information with our service providers that help us with our business operations, including, data processing and storage, or with credit reporting agencies, financial institutions and other organizations which assist us in providing services to you.
11. Withdrawing Consent and Opting-Out
You may choose to withdraw your consent or opt-out from receiving marketing or promotional electronic messages from us, at any time, by clicking through the unsubscribe links included in such messages.
Requests related to marketing and promotional activities, will be processed no later than ten (10) days of any such request. For all other requests, we will process them as is reasonably practicable.
Please note that even if you have withdrawn your consent, or opted-out from receiving marketing or promotional materials from us, we may still contact you from time to time, as may be required or permissible by law, such as to provide you with recall information about your vehicle.
12. Access, Correction and Deletion of Your Personal Information
You have the right to access, update, correct inaccuracies, and delete your personal information in our custody and control, subject to certain exception prescribed by law. If you have questions or concerns about the personal information we have collected about you and would like assistance in accessing, updating, correcting, and deleting that information, please contact our Privacy Officer by email at firstname.lastname@example.org. We will try to complete your request as is reasonably practicable.