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PRIVACY STATEMENT
Definition of “Data” means The Data Group of Companies and its affiliates.
Introduction
Sundog is a Division of the Data Group of Companies.
Inherent throughout The Data Group of Companies corporate
culture, is our commitment to managing, enforcing and
practicing our privacy policy. We respect the privacy
of individuals, clients, suppliers, customers and business
partners who might collect, use or disclose personal
information. Our Privacy Policy provides you with all
of the safeguards set forth in (PIPEDA) the Canadian
federal Personal Information Protection and Electronic
Documents Act, on how “Data” manages your
personal information with great care as reflected throughout
our Privacy Policy.
It also applies to the management
of personal information in any form whether oral, electronic
or written. The Data Group of Companies is not engaged
in either buying or selling of personal information
for use in marketing or solicitation. The Privacy Policy
does not apply to information that is protected by
The Data Group of Companies other policies and practices
or through contractual arrangements, unless specifically
provided in such contractual arrangements.
Consent
By submitting personal information to The Data Group of Companies
or its service providers and agents, you agree that “Data” and
its service providers and agents may collect, use and disclose such personal
information in accordance with this privacy policy and as permitted or required
by privacy laws. Subject to legal and contractual requirements, you may refuse
or withdraw your consent to certain of the identified purposes at any time
by contacting the Privacy Officer. If you refuse or withdraw your consent,
we may not be able to provide you or continue to provide you with certain
services or information, which may be of value to you. Each third party partner
agrees to meet our standards of privacy, confidentiality and security. If
you provide “Data” or
its service providers and agents with personal information of another individual,
you represent that you have all necessary authority and/or have obtained all
necessary consents from such person to enable us to collect, use and disclose
such personal information for the purposes set forth in this Privacy Policy.
All employees and third party staff who in any way handle or manage Personal
Information have acknowledged and agreed to adhere to our Privacy Code and
the procedures that support that code.
The Privacy Principals for “The Data Group of Companies”
Our Privacy Management Plan includes guidelines on the collection, storage
and retention of personal Information as follows:
1. Accountability: “Data” is responsible for
personal information under its control and as a result has designated an
individual, need Sundog name here as Chief Privacy Officer,
the person who is accountable for the Sundog Division of The Data Group of
Companies compliance with the ten principles
2. Identifying Purposes: In general, “Data” collects,
uses and discloses personal information about you in order to provide our
customers, with document management forms, development and processing services.
More specifically, “Data” collects, uses and discloses your personal
information for the following purposes:
- To establish and maintain commercial relationships
with clients, suppliers and other third parties, including
to issue invoices, administer accounts, collect and
process payments, and to fulfill contractual and legal
obligations;
- To develop and manage our business and operations.
This may include the sharing of personal information
by and between “Data” personnel and affiliated
companies, and with third party service providers and
agents, for such purposes;
- To detect and protect “Data” and other
third parties to audit compliance with “Data” policies
and contractual and legal obligations;
- To distribute our newsletters and other material
to individuals on our mail and e-mail lists, including
via third party mailing houses and e-mail service providers;
- Provide products and services of third parties with
whom DBF has a commercial relationship; as permitted
by, and to comply with, any legal or regulatory requirements
or provisions; and for any purpose to which you consent. “Data” will
collect, use and disclose only that personal information
necessary for the valid business purposes that have
been identified.
3. Consent: The knowledge and consent
of the individual is required for the collection, use,
or disclosure of personal information, except as permitted
by Privacy Laws. Pursuant to this Privacy Policy, you
acknowledge your consent to “Data” for
collection, use and disclosure of your personal information,
or the personal information of another individual,
which you provided to “Data”, as stated
above.
4. Limiting Collection: The collection of personal information
shall be limited to that which is necessary for the purposes identified by “Data”.
Information shall be collected by fair and lawful means and may be collected
from other sources including but not limited to credit bureaus or other third
parties who represent that they have the right to disclose the information.
In most cases, collection shall be pursuant to appropriate contractual arrangements.
5. Limiting Use, Disclosure, and Retention: Personal information
shall not be used or disclosed for purposes other than those for which is
collected, except with the consent of the individual or as required or permitted
by Privacy Laws. Personal information shall be retained only as long as necessary
for the fulfillment of those purposes or as required by law.
6. Accuracy: Personal information shall be as accurate,
complete, and up-to-date as is possible. “Data” will update personal
information as and when necessary to fulfill the identified purposes or upon
notification from you. We will not routinely update personal information,
unless such process is necessary to fulfill the identified purposes. If ever
your contact and/or other personal information changes, please feel free
to contact us so that we can update our records.
7. Safeguards: Security safeguards, appropriate to the sensitivity
of the information, shall protect personal information. The security safeguards
are designed to protect personal information against loss or theft, as well
as unauthorized access, disclosure, copying, use, or modification. Technological
measures include use of passwords, firewalls and encryption.
8. Openness: “Data” shall make readily available
to you information about its Privacy Policy and practices relating to the
management of personal information, which is accessible on our website www.datagroup.ca
9. Individual Access: Upon request, subject to certain exceptions
under Privacy Laws, you shall be informed of the existence, use, and disclosure
of your personal information and shall be given access to that information.
You may wish to challenge the accuracy and completeness of the personal information
and have it amended as appropriate.
NOTE: In certain situations, under
Privacy Laws, “Data” may not be able to provide
access to all of your personal information it holds.
The reasons for denying access will be provided to you
upon request. Exceptions may include information that
is prohibitively costly to provide, information that
contains references to other individuals, information
that cannot be disclosed for legal, security, or commercial
proprietary reasons, and information that is subject
to solicitor-client or litigation privilege.
10. Challenging Compliance: You may wish to address a concern
in writing, regarding “Data’s” compliance with the above
principles to “Data’s” Privacy Officer. “Data” shall
investigate all complaints and respond within (30) thirty days. If a complaint
is found to be justified, “Data” shall take appropriate measures
to resolve the complaint, including, if necessary, amending this Privacy
Policy and practices.
Individuals can obtain more information as well as a
copy of the federal legislation through the Privacy Commissioner
of Canada ’s web site at www.privcom.gc.ca.
Privacy and Our Website
Cookies – When you access the The Data
Group of Companies’ website,
we do not use a browser feature called a “cookie” to collect
information.
Changes to Our Privacy Policy
“Data” reserves the right to modify or supplement
this Privacy Policy at any time. If we make a change to this Privacy Policy,
we will post such changes on our websites. We will provide to you such
revised Privacy Policy upon request to the Privacy Officer. However, “Data” will
obtain the necessary consents required under applicable Privacy Laws if it
seeks to collect, use or disclose an individual’s personal information
for purposes other than those to which your consent has previously been obtained
unless otherwise required or permitted by Privacy Laws.
Further Information
The Sundog Division of Data Group of Companies has appointed a Chief
Privacy Officer to oversee compliance with this Privacy Policy and applicable
Privacy Laws. For information on Sundog’s privacy practices, please
contact our Chief Privacy Officer at:
Genevieve Goldie Pagnotta ACI DR Practitioner
9195 Torbram Road
Brampton Ontario L6S 6H2
Direct (905) 494-4064
Fax (905) 791-9089
Email: gpagnotta@datagroup.ca
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