2. What is Personal Information?
3. What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.
As a general rule, the Company collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions as permitted by and in accordance with the applicable privacy legislation ).
From time to time, we may utilize the services of third parties in our business and may also receive personal information about you collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
4. Why Do We Collect Personal Information?
The Company collects personal information to enable us to manage, maintain, and develop our business and operations, including:
5. How Do We Use and Disclose Your Personal Information?
We may use or disclose your personal information:
We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
6. When Do We Disclose Your Personal Information?
We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist the Company in the provision of services to you; and third parties whose services we use to conduct our business.
Further, your personal information may be disclosed:
7. Your Consent is Important to Us
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
9. How is Your Personal Information Protected?
The Company maintains physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with our regulatory obligations and obligations under applicable law. When personal information is no longer necessary, we destroy, erase or anonymize such information.
10. Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.
If any of the personal information we have about you is incorrect, please advise us; we will correct such information if you provide evidence to us that it is incorrect. In some circumstances we may not agree with your request to correct your personal information and will instead append an alternative text to the record in question.
11. Access to Your Personal Information
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. For example, we cannot provide access to personal information relating to other people or personal information protected by legal privilege. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
We store your personal information at our offices in Canada and outside of Canada.
GAP PLUS policy wording includes the following clause relating to consent to collection, retention, use and disclosure of Personal Information:
For the purposes identified, personal information may be disclosed to Optiom’s related or affiliated organisations or companies, their agents/mandataries, and to certain non-related or unaffiliated organisations or companies. Your personal information may be transferred to, retained or accessed by our offices, affiliates and service providers based outside Canada in the United Kingdom and in the United States of America, and may be subject to access by the government, courts, law enforcement or regulatory agencies of Canada and other jurisdictions. Further information about Optiom’s personal information protection policy may be obtained by contacting Optiom’s Privacy Officer at 1-844-427-7587 or through email@example.com
12. Inquiries or Concerns?
13. Privacy Officer