Effective Date: June 1, 2017
Your Privacy Rights
In Canada, organizations engaged in the collection of personal information in the course of commercial activities must comply with the Personal Information Protection and Electronic Documents Act (the “Act”).
The Company is responsible for the personal information we collect, use, maintain and disclose. To ensure this accountability, we have developed this policy, and trained our staff about our policies and practices.
What is “personal information?”
Personal information is any information that identifies you, or by which your identity could be deduced. It does not include your name, business address, business title, professional designation(s) or business telephone number.
Automatic information is information that we collect automatically whenever you interact with this website such as your IP address, the type of computer you use, and the web browser you use. An IP address is a number assigned to your computer when you connect to the Internet. Each time you visit this site, our web server may automatically recognize and collect this information. Automatic information also includes "cookies" and "web beacons". A "cookie" is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. Among other things, cookies provide a means for us to keep track of your online patterns and preferences. By understanding which areas of the site you visit, cookies allow us to present information, products and services that are of personal interest. A cookie will not allow us to learn any personal information (such as your real name and address) that you have not otherwise disclosed. Most browsers are initially set up to accept cookies. You can change your browser so that it will not automatically accept cookies. However, if you do so, it is possible that some portions of the site may not function as intended. "Web beacons", also known as clear GIFs or single-pixel GIFs, are small image files that we may place on web pages and within web-based email newsletters that we send. Working in conjunction with cookies, web beacons allow us to accurately count the number of unique users who have visited a specific page and the number of times those pages are displayed.
Why do we collect personal information from you?
We collect personal information from you to communicate with you, to respond to your enquiries, update you on news and events, or re-market our products and services to you through Google's Adwords program.
In most cases, we shall ask you to provide explicit consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your verbal consent. Sometimes, your consent may be implied through your conduct with us, such as when you submit comments or questions to us on our website.
Use of Your Information
We use your personal information to communicate with you. If you tell us that you no longer wish to receive information about our services, we will not send any further material.
Disclosure of your Personal Information
Under certain circumstances, the Company will disclose your personal information:
· when we are required our authorized by law to do so, for example if a court issues a subpoena;
· when you have consented to the disclosure;
· if the information is already publicly known;
Updating Your Information
Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date.
If any of your information changes, please inform us so that we can make any necessary changes.
Is My Personal Information Secure?
The Company takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
· premises security;
· restricted file access to personal information;
· deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
· internal password and security policies.
Access to Your Personal Information
You may ask for access to any personal information we hold about you.
Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.
If the Company holds information about you and if you can establish that it is not accurate, complete and up-to-date, the Company will take reasonable steps to correct it.
Can I be Denied Access to My Personal Information?
Your rights to access your personal information are not absolute.
We may deny access when:
· denial of access is required or authorized by law;
· when granting you access would have an unreasonable impact on other people’s privacy;
· to protect our firm’s rights and property;
· where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request to correct information, we shall explain why.
How Long do you Keep my Personal Information?
We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.
Communicating with Us
You should be aware that email is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.
Request for Access
If you have any questions, or wish to access your personal information, please write to our Privacy Officer at::
Simmons Sharpe Inc.
33 Davies Avenue
Toronto, ON M3C 2L1
Although the Act does not apply to our employee information, we have elected to follow privacy “best practices” in this area. If you apply to the Company for a job, we need to consider your personal information, as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained with our privacy procedures for employee records.
On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimise our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.