1. Purpose and Application
2. Definition of Personal Information
“Personal information” means information about an identifiable individual, such as age, name, income, marital status, health information, physical description, employment information, educational history and credit information.
Personal information does not include information that is publicly available, such as information in a telephone directory or business contact information (i.e., information that would typically appear on a business card) when such information is used for business-related purposes.
3. Collection of Personal Information
In order to effectively operate our business and improve the quality of the services we provide to our Partners, we collect personal information from our Partners. We primarily collect personal information when our Partners visit our website and consent to receiving electronic messages from the Company. When one of our Partners visits our website, we also automatically receive and record information on our servers from such Partner’s browser, including his or her IP address, cookie information and the pages on our website that he or she visited. The personal information we collect from our Partners generally includes, but is not limited to:
email address; and
We collect personal information only in accordance with all applicable laws, including the Personal Information Protection and Electronic Documents Act (Canada). The Company limits the collection of personal information to that which is necessary for the purposes identified by the Company and is consistent with applicable laws.
4. Use and Disclosure of Personal Information
We use and disclose personal information about our Partners in some, or all of the following ways:
for internal record keeping, research and statistical purposes;
to improve the performance of our website and the quality of user experience; and
to provide our Partners with updates on the development of our business and other information which we believe may be of interest to them.
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the applicable Partner or as required by law.
5. Notification and Consent
By receiving or reviewing a copy of this Policy and/or providing personal information to us, Partners will be deemed to have been notified of, and to have consented to, our intended collection, use and disclosure of personal information for the purposes stated in this Policy unless they advise us otherwise.
There may also be times when Partners provide us with personal information beyond what has been requested. In those circumstances, the provision of that personal information to the Company will be deemed to be consent for the Company to collect, use and disclose that information in accordance with this Policy.
The Company does not sell, share or trade the personal information of Partners collected online or from third parties. Personal information collected by the Company will be disclosed only for the purposes stated in this Policy.
7. Cookies and Tracking Technologies
You may choose to decline cookies if your browser permits but doing so may affect your ability to access or use certain features of our website.
8. Storage and Security
We understand the importance of using security safeguards to protect personal information against loss, theft or unauthorized access or disclosure. We make all reasonable efforts to ensure that all personal information is protected against such risks. We employ physical, administrative and technological measures to protect personal information, regardless of the format in which it is held, in accordance with applicable law. We also limit access to personal information to only those individuals who are required to access such personal information for the purposes described in this Policy.
Personal information is retained for only as long as needed to reasonably fulfill the purposes for which it was intended and for legal or business purposes. Personal information that is no longer required will be destroyed using secure means, including shredding paper records and permanently deleting electronic records.
9. Access and Correction
Partners may submit a written request to the Company to access their personal information. When making an access request, we may require specific information to confirm a Partner’s identity and the Partner’s right to access such personal information.
Partners may also request that we correct personal information that is in our possession or control. The Company will take reasonable steps to correct the personal information that is in our possession or control if that information is not accurate and we receive adequate notice of such inaccuracy.
We will endeavor to respond to any request for access or correction as soon as possible in accordance with applicable law. If access or correction is refused, we will provide reasons for the refusal, the name of the person who can answer questions about the request and advise of the right to have the decision reviewed by the applicable regulatory authority.
10. Further Information
We endeavor to be transparent about how we manage personal information and privacy issues. Any questions or concerns about this Policy or about our collection, use and disclosure of, and access to, personal information can be directed to our Investor Relations department by email at email@example.com.
11. Effective Date & Amendments
This Policy is effective as of the date set out below. We may update this Policy from time-to-time by posting a new version on our website. Any changes to this Policy will be effective from the time that the revised version of the Policy is posted on our website.
Effective Date: February 15, 2021