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Pinchin Ltd. - Privacy Policy

Introduction

Pinchin Ltd. (“Pinchin”) respects the privacy of our employees, our clients, and our partners and ensures that the personal information we collect from these parties are kept secure and protected in accordance with the applicable Canadian federal and provincial privacy laws including the Personal Information and Protection and Electronic Documents Act (“PIPEDA”), and the ten principles of fair information use laid out therein.

PIPEDA defines personal information (“Personal Information”) broadly as “information about an identifiable individual” and includes “any factual or subjective information, recorded or not, about an identifiable individual” such as:

  • Name, age, ID numbers, income, ethnic origin, or blood type;
  • Opinions, evaluations, comments, social status, or disciplinary actions; and
  • Employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).

PIPEDA defines Personal Information broadly, does not include business contact information including an employee’s name, title, business address, telephone number, facsimile number or email addresses, which an organization collects, use or discloses solely for the purpose of communicating with a person in relation to their employment, business or professional.

The types of Personal Information that Pinchin may collect includes:

  • Your name
  • Home address
  • Telephone number
  • Personal email address
  • Billing and account information

Pinchin’s Privacy Policy is designed to meet or exceed the requirements of PIPEDA. Pinchin reserves the right to modify or supplement this Privacy Policy at any time.

Pinchin’s Privacy Policy complies with the following Ten Principles of PIPEDA:

Principal 1: Pinchin is responsible for Personal Information under its possession, custody or control and a designated Privacy Officer is accountable for Pinchin’s compliance with this Privacy Policy and the procedures outlined in this Privacy Policy.

Principal 2: Pinchin shall inform individuals of the purpose for which personal information is collected at or before the time the information is collected.

Principal 3: Pinchin requires the knowledge and consent of the individual for the collection, use, or disclosure of Personal Information, except in certain circumstances where consent is not required.

Principal 4: Pinchin shall only collect what Personal Information that is necessary for the identified purpose and such information shall be collected by fair and lawful means.

Principal 5: Pinchin shall not use or disclose Personal Information for purpose other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Pinchin shall only retainer Personal Information for as long as necessary for the fulfillment of such purposes.

Principal 6: Pinchin shall ensure that Personal Information is as accurate, complete, and up-to- date as is deemed necessary for the purpose for which it is to be used.

Principal 7: Pinchin shall protect Personal Information by establishing and operating security safeguards appropriate to the sensitivity of the information, which is held, and to prevent any unauthorized activity relative to the information.

Principal 8: Pinchin shall make available to individuals upon receipt of a written request, specific information about its policies and practices relating to the management of Personal Information and its complaints handling process.

Principal 9: Pinchin shall, upon the receipt of a written request from individuals, inform them of the existence, use, and disclosure of any Personal Information about them, and they shall be given access to such information except as may be limited by law. Pinchin shall amend Personal Information as deemed appropriate to ensure continued accuracy.

Principal 10: Pinchin shall provide a means for individuals to challenge compliance with the above with Pinchin’s Privacy Officer.

Principal 1: Be Accountable

1.1           Pinchin is responsible for Personal Information under its possession or custody including information that has been transferred to a third party for processing. Where we have disclosed information to third parties we have utilized contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

1.2           Pinchin has a designated Privacy Officer who is accountable for Pinchin’s compliance with the Privacy Policy and Procedures outlined herein. The Privacy Officer has been given support and the authority to intervene on privacy issues relating to any of our organizations operations.

1.3           Pinchin’s Privacy Officer can be email at Privacy@pinchin.com

Principal 2: Identifying The Purpose 

2.1           Pinchin shall inform individuals of the purpose of which personal information is collected at or before the time the information is collected.

2.2           In general, Pinchin collects, uses and discloses Personal Information about our clients and service providers in order to provide our clients with professional consulting services. More specifically, we collect, use and disclose your Personal Information for the following purposes:

  • To establish and manage client relationship and provide consulting services including, but not limited to, the sharing of Personal Information by and between Pinchin personnel and affiliated companies for such purposes;
  • To share Personal Information to and from third parties for the purpose of providing consulting services;
  • To consider whether Pinchin should establish a commercial relationship with clients, suppliers and other third parties, including to evaluate credit standing and to match credit bureau or credit reporting agency information;
  • 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 obligations;
  • To understand and respond to clients, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
  • To develop, exchange, market, sell or otherwise provide Pinchin’s products and services;
  • To market, sell or otherwise provide products and services of third parties with whom Pinchin has a commercial relationship;
  • To distribute Pinchin newsletters, bulletins, conference information and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers;
  • To develop and management our knowledge-management precedent systems and databases;
  • To develop and manage Pinchin’s business and operations;
  • To detect and protect Pinchin and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with Pinchin policies and contractual obligations;
  • To engage in business transactions, including the purpose, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Pinchin;
  • As permitted by, and to comply with, any legal or regulatory requirements or provisions; and
  • For any other purpose to which you consent.

Principal 3: Obtain Valid, Informed Consent

3.1           Pinchin requires the knowledge and consent of the individual for the collection of Personal Information and the subsequent use or disclosure of this information, except in those circumstances where personal information can be collected, used or disclosed without the knowledge and consent of the individual, including, but not limited to:

3.2           Consent:

  • If it is clearly in the individual’s interest and consent is not available in a timely way;
  • If knowledge and consent would comprise the availability or accuracy of the information and collection is required to investigate a breach of an agreement or contravention of a federal or provincial law;
  • If it is publicly available as specified in the regulations;
  • When it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
  • Where it is produced by individuals in the course of their employment, business or profession – as long as the collection is consentient with the purpose for which the information was produced;

3.3           Used:

  • If it is publicly available as specified in the regulations;
  • If the use is clearly in the individual’s interest and consent is not available in a timely way;
  • When it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
  • where it is produced by individuals in the course of their employment, business or profession – as long as the collection is consentient with the purpose for which the information was produced;

3.4           Disclosed:

  • To a lawyer representing Pinchin;
  • To collect a debt the individual owes to the Pinchin;
  • To comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction.

3.5           Pinchin, except where exceptions apply, will always make a reasonable effort to ensure that the individuals are advised in advance of the purpose of which their personal information will be collected, used or disclosed. In that vein, to make the individual’s consent meaningful, Pinchin will state the purpose in such a manner that the individual can reasonably understand how the information will be used or disclosed.

3.6           Pinchin will not require an individual to consent to the collection, use or disclosure of information beyond that required to fulfil the explicitly specified and legitimate purposes.

3.7           By submitting Personal Information to Pinchin you agree that we may collect, use and disclose such Personal Information in accordance with this Privacy Policy.

3.8           Subject to legal and contractual requirements and upon reasonable notice, you may refuse or withdraw your consent to certain identified purposes at any time by contacting Pinchin’s 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.

3.9           If you provide Pinchin with Personal Information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consent from such person to enable us to collect, use and disclose such Personal Information for the purpose outlined herein.

Principal 4: Limiting Collection

4.1           Pinchin shall limit its collection of Personal Information to that which is necessary for the identified purpose and such information shall be collected by fair and lawful means.

4.2           Pinchin will not collect Personal Information indiscriminately, and will limit its collection of Personal Information to that which is necessary to fulfil the purposes identified.

4.3           Pinchin will not collect Personal Information by misleading or deceiving individuals about the purpose for which the Personal Information is being collected.

 

Principal 5: Limiting Use, Disclosure and Retention

5.1           Pinchin shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Pinchin shall only retain Personal Information for as long as necessary for the fulfillment of such purposes.

5.2           From time to time, Pinchin may disclose your personal information to:

  • Service providers, including an organization or individuals retained by Pinchin to perform functions on its behalf including. but not limited to, marking, data processing, document management and office services;
  • Organizations or individuals retained by Pinchin to evaluate your creditworthiness or to collect debts outstanding on an account;
  • Financial institutions, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financial arrangements;
  • Any person who, in the reasonable judgment of Pinchin, is providing or seeking the information as your agent;
  • Any third party or parties where you consent to such disclosure or where disclosure is required or permitted by law.

5.3           Personal Information that has been used to make a decision about an individual shall be retained long enough to allow the individual access to the information after the decision has been made. This period will not exceed applicable industry standards or any legislative requirement with respect to retention periods.

5.4           Pinchin shall destroy, erase or make anonymous any Personal Information that is no longer required to fulfil the identified purposes

5.5           Use of Cookies: When an individual visitor accesses the Pinchin website, we may use a browser feature called a ‘cookie’ to collect information such as the type of internet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, page viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us we will not know who the individual visitors are. In addition to the identified purpose described herein, we may use this website information and share it with other organizations with which we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browser either, to notify them when they have received a cookie or, to refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.

5.6           Use of Online Communications: In order to provide our website visitors with a service or information, visitors may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, participating in a seminar or other event, and participating in contests and surveys. If you are known to Pinchin as a registered user of an online service, we may combine and store Personal Information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.

5.7           Use of E-Mail Communications: Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the services of Pinchin and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of your preferences and if you decide you do not want to receive any future marking or promotional e-mails from Pinchin.

5.8           Use of Links: Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies than Pinchin and Pinchin is not responsible for such third party websites or for any collection, use and disclosure of Personal Information by these third parties.

Principal 6: Accuracy

6.1           Pinchin shall ensure that Personal Information is as accurate, complete, and up-to-date as is deemed necessary for the Purpose for which it is to be used.

6.2           Pinchin will make reasonable efforts to keep the personal information that is used on an ongoing basis – including information that is disclosed to third parties – accurate and up- to-date, unless limits to the requirement for accuracy are clearly set out.

6.3           Pinchin will generally rely on individual customers to provide updated information, such as changes to customer addresses and other contact information.

Principal 7: Safeguards

7.1           Pinchin shall protect Personal Information by establishing and operating security safeguards appropriate to the sensitivity of the information which are held, and to prevent any unauthorized activity relative to the information.

7.2           Pinchin will utilize security safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modifications in whatever format in which it is held.

7.3           The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and formation of the information, and the method of storage, with more sensitive information being safeguarded by a higher level of protection.

7.4           Pinchin will utilize various methods of protecting Personal Information including:

  • Physical measures, for example, locked filing cabinets and restricted access to offices;
  • Organizational measures, for example, security clearances and limiting access on a “need-to-know” basis; and
  • Technological measures, for example, the use secure data networks protected by industry standard firewall, encryption and password protection systems.

7.5           When Pinchin disposes or otherwise destroys Personal Information, care shall be used to prevent unauthorized parties from gaining access to the Personal Information.

7.6           When Pinchin discloses Personal Information to third parties, they will require these third parties to ensure the information is used only for authorized purposes and that the thirdparties utilize methods of safeguarding the Personal Information that is consistent with PIPEDA.

Principal 8: Openness

8.1           Pinchin shall make available to individuals upon receipt of a written request, specific information about its policies and practices relating to the management of Personal Information and its complaints handling process.

8.2           Pinchin will be open about their policies and practices with respect to the management of Personal information.

8.3           Pinchin will make information on its Privacy Policy available on its website.

Principal 9: Individual Access

9.1           Pinchin shall, upon the receipt of a written request from individuals, inform them of the existence, use, and disclosure of any Personal Information about them, and they shall be given access to such information except as may be limited by law. Pinchin shall amend personal information as deemed appropriate to ensure continued accuracy.

9.2           Upon a written request, Pinchin shall inform an individual whether or not it holds Personal Information about the individual.

9.3           Where Pinchin holds Personal Information about the Individual, it shall allow the individual access to this information and, when relevant, shall provide an account of the use that has been made or is being made of the Personal Information and an account of the third parties to which it has been disclosed.

9.4           Pinchin may require the individual to provide sufficient information to permit Pinchin to provide an account of the existence, use and disclosure of Personal Information. The information provided shall only be used for this purpose.

9.5           If an individual successful demonstrates the inaccuracy or incompleteness of the Personal Information, Pinchin shall amend the information as required. Depending on the nature of the information challenged, amendment involves the correction, deletion or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.

Principal 10: Challenging Compliance

10.1        Pinchin shall provide a means for individuals to challenge compliance with the above principles with Pinchin’s Privacy Officer.

10.2        Upon written request, individuals who wish to inquire or file a complaint about the manner in which Pinchin handled their Personal Information, or about Pinchin’s personal information policies and procedures, will be informed of our applicable complaint procedures.

10.3        Pinchin shall investigate all complaints and if a complaint is found to be justified, Pinchin shall take appropriate measures including, if necessary, amending its policies and practices.