Owen & Associates (“O&A”, “we”, “our”, “us”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use and disclose any personal information that individually identifies you and our commitment to meet our obligations under applicable Canadian privacy laws.
Depending on the Service, we may provide additional or different privacy notices for specific relations you have with us or to highlight how we use your personal information for specific Services. Where we do this, it will be clear which notices apply to which relations and Services.
- What Personal Information do we collect?
Personal information means any information about an identifiable individual. Anonymous data means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals (“Anonymous Data”). We do not consider personal information to include Anonymous Data.
We collect your personal information about you when you provide it to us or use our Services. We may also collect information about you from certain third parties. In most instances, you will decide what information you provide us. In certain instances, if you choose to not provide us with personal information, you may not be able to fully utilize our Services. The types of personal information that we may collect include, but is not limited to:
- Contact information such as your name, date of birth, home address, e-mail address, and company name;
- Social insurance number, payroll information, salary information;
- Name, date of birth, home address, and social insurance number of your dependent(s); and
- Your IP address.
- Purposes for Collecting Your Personal Information
We collect, use and disclose your personal information in order to provide you with our Services. We also collect, use and disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable laws. We will only use the personal information that we collect for the purposes for which it was collected. We collect your personal information for the following purposes and in accordance with applicable laws:
- To present our Site and its contents to you;
- To provide you with information, products, or Services that you request from us;
- To fulfill the purposes for which you provided the information or that were described when it was collected or any other purpose for which you provide it;
- To notify you about changes to our Site or any Services we offer;
- To improve our Site or Services, marketing, or customer relationships and experiences;
- To provide you with our Services;
- To verify and confirm your identity;
- To understand your insurance needs;
- To enroll you in a program;
- To establish and maintain commercial relations with you, including responding to your questions regarding our Services;
- To respond to questions that you send by email or through our Site;
- Subject to applicable law, to notify you about other services and events provided by us, which may be of interest to you;
- To customize the appearance of the Site displayed to you;
- To obtain your feedback regarding our Site and Services, including any surveys;
- To track behavioural information on the Site to serve similar content upon future visits;
- To support our business functions such as internal business processes, marketing and advertising; and
- To meet any legal or regulatory requirements.
- When Do We Collect Personal Information?
We may collect your personal information when you voluntarily provide it to us by using our Site and Services or from third party sources. For example, we may ask you to provide personal information if you:
- Use our Site and our Services;
- Send us a question or comment by email or phone;
- Register to receive newsletters, articles and updates about our Services; or
- Otherwise, participate in features of our Site and our Services that ask for personal information.
We may receive personal information about you from third party sources such as our payment processor, or if publicly available. We use this information to: (i) assist with our business operations; and (ii) to ensure that the Services that you purchased are delivered appropriately. You authorize the collection of your personal information from these sources and, if applicable, you authorize these sources to give us your personal information for the above-mentioned purposes.
If you speak with one of our representatives by telephone, you may be asked to provide personal information for the following reasons:
- To establish a record of the information that you provide;
- To take or verify instructions from you;
- To confirm your identity;
- To maintain quality service levels; and
- To assist in staff training.
- Limiting Collection of Personal Information
- Consent, Use Disclosure and Retention of Personal Information
Depending on the sensitivity of the personal information, your consent to our collection, use and disclosure of personal information 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.
We may generate Anonymous Data from personal information collected through the Site and Services by removing information that makes the data personally identifiable to an individual. Such Anonymous Data includes, but is not limited to, the information we collect from your use of our Site and Services. We may use this Anonymous Data and aggregated data for any reasonable purpose subject to applicable laws. We do not disclose this data to third parties.
We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected and to comply with our legal obligations.
We may also use and disclose your personal information to service providers, data processors and other third parties (“Third Parties”) under the following limited circumstances:
- When necessary to protect (i) our safety, property or other rights; (ii) our representatives, customers and users of the Site and stakeholders; (iii) to conduct investigations of possible breaches of law, including, including to detect and prevent fraud;
- To identify, contact or bring legal action against someone who may be violating an agreement that they have with us;
- To investigate breaches of security safeguards or cooperate with government or regulatory authorities pursuant to a legal matter;
- With your consent; or
- As otherwise required or permitted by law.
- Data Transfers
As discussed above, we may engage Third Parties to perform certain services on our behalf and to otherwise provide the Services. These Third Parties may store, process and transfer personal information on servers located outside of Canada. These counties include jurisdictions whose data protection laws may differ from those of Canada. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that comparable protections are in place to maintain protections on personal information that are equivalent to those that apply in Canada.
- Cookies, Web Beacons and Other Similar Technology
As you interact with this Site and Services, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site and Services and collects certain other information about you and your surfing habits. These data collection technology and services allow us to store and manage user preferences, enable content, deliver targeted advertising and collect usage data and analytics to ensure the smooth functioning of our Site on your computer or device. These data collection technology may include cookies, web beacons and other similar devices on this Site and Services to enhance functionality and navigation for our visitors. Cookies and other tracking technologies are commonly used by websites and apps through which information is collected about your online activities.
A cookie is a small data file that is placed on your computer or another electronic device so that your device will “remember” information when you visit a site.
Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Site. Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies.
We may use web beacons on this Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize this Site and improve your experience at our Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Site a user visits; and (iv) other sites a user visited before visiting our Site. Web beacons may also be used to deliver interest-based advertising to you.
You can set your internet browser up so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies that are already stored on your hard disk at any time. You will find more details on how to do this in the operating guide for your Internet browser program.
- Third-Party Analytics
We also use the cookies to carry out frequency assessments, page usage assessments and marketing assessments. For these assessments, we use this cookie information without a link to your personal information, so it is completely anonymous.
- How We Protect Your Information
We maintain reasonable technical, physical and organizational security safeguards to protect your personal information against loss, theft, and unauthorized access. Any personal information that you provide to us is exchanged on a secured server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.
We take reasonable steps to verify your identity before granting you access to your account on our Site, however, you are solely responsible for maintaining the secrecy of your username, password and any other account information. We also take reasonable steps to ensure that our employees are aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.
- Individual Access and Accuracy of Personal Information
You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.
You may request to update and change your personal information at the contact information set forth below. We will endeavour to correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information will be transmitted to third parties having access to such information.
- Electronic Communications
As part of signing up to receive the Services, you may have also opted in to receive email communications from us. If you opted-in to receive such communications, we may use the information to: communicate with you regarding Services and promotions; provide you with other information that you request; and/or improve our product and service offerings.
You will always have the opportunity to "unsubscribe" from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site, by e-mail at firstname.lastname@example.org or at the following telephone number: [•]
- How to Contact Us
- See your personal information that you have already sent us so that you can correct, update or delete it from our files;
- Ask that we not send you electronic communications or otherwise contact you; or
Please contact us at email@example.com and we will endeavour to respond to you promptly.