Last Modified: August 25, 2022
In consistent with our obligations as professionals, we are dedicated in maintaining high standards of confidentiality and security when we collect, use, protect and disclose information gathered about you. TBDC follows strict privacy principles to ensure the confidentiality of the Personal Information we hold.
Please note: This Privacy notice does not apply to, and TBDC is not responsible for, any third-party websites which may be accessible through links from our website. If you follow a link to any of these third-party websites, they may have their own privacy policies and you will need to check these policies before you submit any personal data to such third-party websites. By providing your personal data to TBDC (whether via our website, by email, in person or over the phone), you are accepting the practices described in this Policy.
We take the protection of Personal Information seriously. Our obligations as a Designated Entity by the Ministry of Immigration, Refugees and Citizenship, imposes duties and obligations regarding the confidentiality of the information provided to TBDC by its clients. We require all professionals, staff members, employees, contractors, and agents who delivery and provide services to our clients to comply with these obligations.
All personal information collected by TBDC is authorized under legislation and is done in compliance with the Privacy Act.
What personal information do we collect about you
TBDC may collect and process different types of personal data during the course of our business activities and providing our services. These include:
- Basic personal details such as your name and job title;
- Contact data such as your telephone number and postal or email address;
- Financial data such as payment related information or bank account details;
- Demographic data such as your address, preferences or interests;
- Website usage and other technical data such as details of your visits to our websites or information collected through cookies and other tracking technologies;
- Personal data provided to us by or on behalf of our clients or generated by us in the course of providing our services, which may, where relevant, include special categories of personal data;
- Identification and other background verification data such as a copy of passports or your curriculum vitae or your education and employment history or details of professional memberships or utility bills or evidence of beneficial ownership or the source of funds to comply with client due diligence and collected as part of our client intake and ongoing monitoring procedures;
- Data that you may provide to us in course of registering for and attending events or meetings, including access and dietary requirements; and
- Any other personal data relating to you that you may provide.
In some cases, we collect Personal Information from third parties such as sponsors, regulatory and legal authorities, other organizations with whom we or you have dealings, such as government agencies, networking agencies, information, or service providers, and from publicly available records. We may also collect information from public sources in the context of an investigation, self-due diligence, proceedings related to the services we are providing to one of our clients.
How do we use and disclose Personal Information
TBDC will not disclose Personal Information to other persons, other than the following purposes:
§ To the extent required for establishing and compliance with legal obligations, as described to you at the time of collection;
§ To other third parties, such as sponsors, regulatory and legal authorities, other organizations with whom we or you have dealings, such as government agencies, networking agencies, information or service providers, but only where and to the extent you give us your permission to do so;
§ Our professional advisors (legal, financial, business, or other advisors), financial institutions and auditors;
§ Our insurers and insurance brokers;
§ Any purposes which is permitted or required by applicable law; and
§ To carry out any other purpose which is disclosed to you and to which you consent.
Why does TBDC collect, use and disclose Personal Information
TBDC collects, uses and discloses your personal information for the following purposes:
- to authenticate your identity;
- to operate, customize and improve our website, social media sites, mobile applications, advertisements, products and services;
- to allow you to use portions of our website such as our forums;
- to allow you to participate in our contests, and to administer those contests; to monitor your compliance with any of your agreements with us;
- to administer our provision of, and your payment for, products or services you request from us;
- to provide newsletters, electronic messages and information you request from us;
- to provide other information to you regarding our products and services or third-party products and services, unless you opt out of receiving that information;
- to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or merger;
- to protect us, yourself and others from fraud and error and to safeguard our business interests;
- to collect debts owed to us;
- to comply with legal and regulatory requirements; and
- For other purposes we may inform you about from time-to-time.
We may transfer your personal information across provincial or national borders to fulfil any of the above purposes (including both the necessary and the optional purposes), including to service providers located in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure laws in those jurisdictions.
When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by law.
We may work with other companies to provide services on our behalf, such as website hosting services, payment processing services and product delivery services. Those service providers will be permitted to obtain only the personal information they need to deliver the service in question, and they will be required to maintain the confidentiality of that information.
TBDC will not sell or rent your personal information to third parties, and will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent.
We may collect, use or disclose personal information without your knowledge or consent where:
- the information is publicly available, as defined by statute or regulation;
- we are obtaining legal advice; or
- we reasonably expect that obtaining consent would compromise an investigation or proceeding. Other exceptions may apply.
Your consent can be express, implied or given through an authorized representative such as a lawyer, agent, or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise. You may withdraw consent at any time, subject to legal, contractual, and other restrictions, provided that you give reasonable notice of withdrawal of consent to us. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.
Any material, information, or other communication (including questions, comments and suggestions) you transmit to us through our website, social media sites or other online sites, or mobile applications will be considered non-confidential and non-proprietary. We may forward your communications and other personal information to any of our offices or affiliates throughout the world in connection with any products or services you request, or in connection with any communications you wish to have with us, and you consent to us doing so.
Limits on Collection
TBDC will not collect information indiscriminately and will limit collection of information to that which is reasonable and necessary for the above purposes. We will also collect information as is otherwise authorized by law.
Limits on Using, Disclosing and Retaining Personal Information
TBDC will only use and disclose your personal information for the purposes set out above and as authorized by law. We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision, unless otherwise permitted or required by law. We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. We will take due care when destroying personal information so as to prevent unauthorized access to the information.
TBCD will make a reasonable effort to ensure that personal information we are using, or disclosing is accurate and complete. In some cases, we rely on you to ensure that certain information, such as your address or telephone number, is current, complete, and accurate. If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under its control with a note that the correction was requested but not made.
Upon written request and authentication of identity, TBDC will provide you with your other personal information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request.
In some situations, we may not be able to provide access to certain personal information. This may be the case where, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information.
Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
What is Aggregate Information
“Aggregate information” is standard web server/visitor traffic information, commonly referred to as ‘aggregate information’, regarding overall website traffic patterns. Web servers normally collect this type of basic information as part of their web log processes. This aggregate information does not identify you and thus does not constitute personal information. In addition to information provided by our visitors we use the normal Internet tracking tools associated with standard Internet protocols and web–based systems. This system information is typically stored in log files and the information is used for aggregate reporting. Aggregate reporting includes total number of visitors, most visited sections, peak traffic times, etc. Log files are simply transaction records web servers maintain. Those logs are used for recording information, such as:
- service provider IP addresses;
- browser versions;
- referring websites;
- search terms used;
- average number of pages requested;
- average duration of visit;
- total visitor traffic.
We use aggregate information gathered from your visit to better design our website. This information supplies us with a broad picture of how people use our website in order to help the management of our systems and to better serve our audience.
How do we protect your personal information? Our commitment to data security
In order to prevent unauthorized access to your personal information, maintain the accuracy of your personal information, and to ensure your personal information is used and disclosed only pursuant to this Policy, TBDC employees who have access to personal information strive to maintain physical, electronic, contractual and administrative safeguards to protect personal information collected with an appropriate level of physical or electronic security. However, confidentiality and security are not assured when information is transmitted electronically.
What about practices of linked sites
This privacy statement applies only to the Site. Please be aware that TBDC is not responsible for the privacy practices of other websites to which it has links. We encourage you to read the privacy statements of each and every website that requests personal information from you.
Please note: Cookies used by TBDC do not give us access to anything on your hard drive and cannot do anything to your computer. TBDC uses two types of cookies: session cookies (temporary) or persistent cookies (longer–term continuing use):
- Session cookies may be used to support on-line feedback/discussion, forms and registration and ‘e-commerce/shopping cart’ transactions. They are used only during your online session and expire when you close your browser. Without session cookies, moving around the Site could be much slower.
- Persistent cookies are different from session cookies because they are stored on your computer’s hard drive for some length of time. They are usually used if you want us to remember information about your Web preferences and passwords for automatic log-in purposes.
Remarketing / Targeted Advertising
TBDC may also disclose some of your personal information (such as your gender, age, location and interests) to the providers of targeted advertising services to help adjust the advertisements to your preferences; however, in that case, TBDC will contractually obligate the service providers to maintain the security of your information and only use it for the purpose of targeting TBDC’s ads to you. You can opt out of participating in these targeted ad programs by contacting our Privacy Officer as set out below.
– Access Personal Information that you have already provided so that you can correct or update it, or request that it be deleted; and
you may contact TBDC by email at info@TBDC.com or by mail at:
ATTN: Privacy Officer
Toronto Business Development Centre 325 Front St W.
Toronto Ontario M5V 2Y1