Privacy Policy

We understand that privacy is important to you. At the same time, we may need to collect and use some personal information about you. This privacy policy explains how we deal with personal information and how you can raise any concerns you may have about privacy with our Privacy Officer.

Personal Information

We need certain personal information from you to help us serve you effectively. That personal information includes your name and address. It also includes any other information specifically about you – how we can call or contact you, any financial arrangements you have made with us and any special instructions you want us to know.

Privacy Officer

We have appointed a Privacy Officer to ensure that we comply with our Privacy Policy. The Privacy Officer will be glad to answer your questions or deal with any concerns or complaints you may have.

You can get in touch with the Privacy Officer by e-mail or by telephone at 416-979-2900.

Why Do We Collect Personal Information?

We will do our best to advise you why we are collecting any item of personal information either before or at the time we collect it. We will be happy to answer any questions you may have on why we collect personal information.

We Need Your Consent to the Collection, Use and Disclosure of Personal Information

We need your consent before we can collect personal information from you, use it or disclose it. We will usually ask for your consent when we obtain personal information and tell you what we propose to do with it. We will sometimes imply your consent to collect and use certain information; for example, by completing and submitting a form, you will be consenting to our collecting the personal information in that form and using it as indicated in that form. Please ask us to clarify anything you do not understand.

Sometimes we may ask you for optional information because we believe it will help us serve you better. However, you will never be required to provide personal information as a condition to using our services, unless we need that information to provide the service.

Sometimes we may need to use personal information you have already provided to us for another purpose not disclosed when you submitted the information. Before we do that, we will get your consent to our proposed use. In some cases, however, we may be required by law to use personal information we have already collected for a purpose other than the purpose for which it was collected. We will not request your consent for something we are obliged to do by law.

When you consent to the use of personal information as we have described it to you, we will assume that you are also consenting to other closely related uses that most people would consider reasonable in the circumstances. We might, for instance, send you a notice for a similar event or recommend a new product if you have previously expressed interest. We consider this would be reasonable use of your personal information even if you have not specifically consented to it. We will not, however, make any unrelated use of your personal information without receiving your consent first.

You may consent to our collection and use of personal information in various ways, including completing and submitting a form. You may also give your consent verbally if you telephone us and we collect personal information over the telephone.

You may withdraw any consent you have given us, unless doing so breaks the law or breaches a contract between us. You must, however, give us reasonable notice before you withdraw consent. When you propose to withdraw consent, we will inform you how that will affect our relationship, and you understand that withdrawing consent may affect the services we can provide to you.

We may aggregate personal information for our own uses and to provide to others but this information will no longer be personally identifiable.

We Will Safeguard Your Personal Information

We will protect your personal information so that it will not be lost or stolen. Our safeguards will depend to some extent on the sensitivity of the personal information and on the amount, distribution and format of the personal information and the nature of storage. We will only make personal information available to those authorized to use it for the purposes we identified to you when we collected the personal information.

We have taken several measures to secure personal information. We lock away paper records and restrict access to them in our offices. We provide appropriate security clearances for those handling personal information. We require everyone who accesses electronic forms of personal information to use passwords and we use appropriate encryption. Our employees are aware of the importance of maintaining your personal information in confidence.

Sometimes we may need help in processing information. This means someone other than one of our employees may process personal information for us. We will ensure that anyone working with personal information maintains the same standards of privacy as we do.

We Will Not Retain Personal Information for an Unlimited Time

We have developed a policy regarding the minimum and maximum periods for retaining personal information. In some cases, these retention periods are set by law. If we use personal information to make a decision of some kind about you, we will keep that personal information long enough to allow you to access the personal information after the decision has been made.

We have developed guidelines setting out how we will destroy personal information at the end of the retention period. If you would like a copy, please contact the Privacy Officer.

We Will Keep the Personal Information We Collect Accurate

We will make every effort to make sure that all personal information we collect is as accurate, complete and up-to-date as necessary to carry out the purposes for which it is being used. The degree of accuracy, completeness and timeliness depends on the use we are making of the personal information.

You Can Review the Personal Information We Have about You

Generally, you may review all the personal information we have collected from you. If you would like to know whether we have personal information about you in our files, we will tell you. We will also tell you how we use your personal information and to whom we disclose it.

In some exceptional circumstances, we may not be able to provide access to all of the personal information we have collected about you. These exceptions will be limited and very specific. If we cannot give you full access to personal information, we will tell you why. We may need to restrict access, for instance, if the personal information you want to review also contains information about other individuals. There may be legal reasons we cannot disclose information, or the personal information may be subject to solicitor-client or litigation privilege.

If you ask us to review personal information we have about you, you may need to reveal enough personal information to allow us to identify your file. We will only use the personal information you provide to allow us to make that identification, but we will not be able to satisfy your request to review your file unless we can identify it clearly as yours.

We will usually be able to tell you the specific organizations to which we have disclosed personal information about you. In some cases, however, we may need to give you a list of organizations to whom we may have disclosed personal information about you without specifying whether we have actually done so or not.

We will respond to any request you make for personal information about your file as promptly as we can and at minimal cost to you. We will provide the personal information to you in a form you can understand. If you have special requirements concerning the format in which personal information should be provided, we will do our best to satisfy them. We may ask you to pay for our actual costs of reproducing your record.

We Will Correct Any Errors in the Personal Information in Your File

If you can show us that the personal information we have collected about you is inaccurate or incomplete, we will change the personal information. If appropriate, we will forward our changes to those parties to whom that information has already been provided.

We Have Established Complaint Procedures

You may contact the Privacy Officer to challenge any decision our employees have made regarding your personal information in our records. We have specific complaint procedures in place. You can obtain a full copy of those procedures and information on handling complaints from the Privacy Officer. You may also complain about the way your personal information has been collected, used or disclosed, or is proposed to be collected, used or disclosed, by contacting the Privacy Officer and following the complaint procedure.

We will follow the complaint procedure and make any appropriate changes to your personal information and to our policies and procedures.

On-Line Policies

Our privacy policy applies to all information you send us on-line. There are also some special concerns about on-line communications, either through e-mail or Internet web sites, that we want to address.

Visiting Web Sites

When you visit our web site, we learn that you signed on, which pages you visited and any content you downloaded.

Using Internet Transaction Services

If you order goods from us on-line, we collect your logon id as well as all the other information you provide during your session. We use this information to respond to your questions and provide the products and services you ordered. We may also use this information to determine what other products and services we might recommend to you.

Cookies

A cookie is a small file that contains information about you. The web site creates the cookie when you visit the site. Cookies can track which sites you visited before coming to the site, which pages you visited on the site and other information about you.

Some cookies are called “session cookies.” These contain information only during the time you are logged on to the site. The information is not copied and is lost when you leave the site. During the time you are visiting the site, however, the session cookie identifies you and authenticates your access to the site. We will use session cookies in the future.

Other cookies are called “persistent cookies.” Information about you in these cookies is written to your hard drive, where it stays until the cookie expires. The web site can read this information from your hard drive when you sign on to the site. We will use persistent cookies in the future.

Most browsers do not distinguish between session cookies and persistent cookies. To use our on-line services, your browser must be set to accept cookies.

E-Mail

If you send us e-mail, we learn your exact e-mail address and any other information you send by e-mail. We use your e-mail just as we would any written form of communication, and we save e-mail in case we need to correspond with you further. We do not send e-mail addresses to anyone else. We may send you further information about our products and services by e-mail after you have contacted us by e-mail. You may tell us to stop sending such information at any time. If you ask us to put you on a regular e-mail mailing list, we will remove your name from that list whenever you ask us to do so.

Remember that e-mail is not usually encrypted. We generally set up proper encryption arrangements for any sensitive information we request by e-mail or at our web site. You should be very careful not to transmit such information by unencrypted e-mail.