Privacy Policy – Canada
CHAMCO INDUSTRIES LTD. is committed to maintaining the accuracy, confidentiality
and security of personal information under its control.
This privacy policy (in conjunction with its related policies) is designed to
explain Chamco’s polices and procedures with respect of Chamco’s collection, use
and disclosure of personal information.
SCOPE OF POLICY
This policy governs the collection, use and disclosure of personal information by
Chamco from and about individuals who are not employed (as a director, officer
or employee) by Chamco. This policy applies to and governs Chamco Industries
Ltd. All references in this privacy policy to "Chamco", "we", "us", "our" and
like terms should be interpreted accordingly.
It is Chamco’s policy to comply
with the privacy legislation within each jurisdiction in which we operate.
Sometimes the privacy legislation and / or an individual's right to privacy are
different from one jurisdiction to another. This privacy policy covers only
those activities that are subject to the provisions of Canada’s federal and
provincial privacy laws, as applicable.
This privacy policy has a limited scope
and application and the rights and obligations contained in this privacy policy
may not be available to all individuals or in all jurisdictions.
PERSONAL INFORMATION
Within the policy, personal information refers to any information about an
identifiable individual, other than that person's business title or business
contact information (such as business phone and fax number, business address and
business e-mail) when used or disclosed for the purpose of business
communications.
WHAT PERSONAL INFORMATION DOES CHAMCO COLLECT?
Chamco collects personal information from individuals participating in and/or
impacted by Chamco’s business activities in Canada. Chamco collects and
maintains different types of personal information in respect of individuals with
whom Chamco interacts. This includes:
- contact and identification information, such as name, address, telephone number and e-mail address;
- product and service related information concerning the products and services that we provide to, or receive from, you;
- credit and financial information such as payment methods and preferences; and
- business relationship information, including information related to agreements, preferences, advisors and decision-makers, feedback and information requested or provided by or from you.
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 and public relations activities
and information related to our interactions with financial and other analysts
and advisors.
In the course of conducting its business, Chamco may monitor the
activities of individuals in respect of its operations and its property. For
example, some Chamco locations are equipped with surveillance cameras. These
cameras are generally in high risk areas or manufacturing sites. Where these
cameras are in use, surveillance cameras are there for the protection of
employees and third parties, and to protect against theft, vandalism and damage
to Chamco goods and property. Generally, video tape recording images are
routinely destroyed and not shared with third parties unless there is suspicion
of a crime, in which case they may be turned over to the police or other
appropriate government agency or authority.
As a general rule, Chamco 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).
From
time to time, we may utilize the services of third parties in our business and
may also receive personal information 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.
WHY DOES CHAMCO COLLECT PERSONAL INFORMATION?
Chamco collects personal information to enable us to manage and develop our
business and operations, including:
- to establish, maintain and manage relations with you so that we may provide you with, or receive from you, the products and services that have been requested;
- to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
- to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services and work to improve the products and services that you provide to us;
- to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
- to protect us against error, fraud, theft and damage to our goods and property;
- to enable us to undertake our environmental, health and safety activities, including incident planning, response and investigation;
- to enable us to comply with applicable law or regulatory requirements or to follow procedures mandated by these provincial regulatory bodies in respect of emergency planning, and environmental stewardship; and
- any other reasonable purpose to which you consent.
HOW DOES CHAMCO USE PERSONAL INFORMATION?
We use your personal information for the purposes described in this privacy
policy and for any additional purposes for which we have obtained your consent
to the use or disclosure of your personal information (which consent may be
express, deemed or implied, as explained below).
We may use your personal
information without your knowledge or consent where we are permitted or required
by applicable law or regulatory requirements to do so.
WHEN DOES CHAMCO DISCLOSE INFORMATION?
We share your personal information with our employees, contractors, consultants
who require such information to assist us with establishing, maintaining and
managing our business relationship with you, including: third parties that
provide services to us or on our behalf; third parties that collaborate with
Chamco in the provision of services to you; and, third parties whose services we
use to conduct our business.
In addition, personal information may be disclosed
or transferred to another party in the event of a change in ownership of, or the
grant of a security interest in, all or a part of Chamco through, for example,
an asset or share sale, or some other form of business combination, merger or
joint venture, provided that such party is bound by appropriate agreements or
obligations and required to use or disclose your personal information in a
manner consistent with the use and disclosure provisions of this Privacy Policy,
unless you consent otherwise.
Further, personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- to protect the rights and property of Chamco;
- during emergency situations or where necessary to protect the safety of a person or group of persons;
- where the personal information is public; or with your consent.
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.
Typically, we will seek your consent at the time that we
collect the personal information. In certain circumstances, your consent may be
obtained after collection but prior to our use or disclosure of your personal
information. If we plan to use or disclose your personal information for a
purpose not previously identified (either in this privacy policy or separately),
we will endeavor to advise you of that purpose before such use or disclosure.
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.
We assume that, unless you advise us otherwise, by
receiving a copy of this privacy policy or by continuing to deal with us, you
have consented to the collection, use and disclosure of your personal
information as explained in this privacy policy.
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.
YOUR INFORMATION IS PROTECTED
Chamco endeavours to maintain adequate physical, procedural and technical
security with respect to its offices and information storage facilities so as to
prevent any loss, misuse, unauthorized access, disclosure, or modification of
personal information. As part of those precautions, Chamco endeavours to
restrict access to personal information to those employees and others (i.e.
individuals or organizations providing services to Chamco) that it determines
need to know that information in order that Chamco may conduct its activities.
ACCURACY OF PERSONAL INFORMATION
Chamco endeavours to ensure that any personal information in its possession is as
accurate, current and complete as necessary for the purposes for which Chamco
uses that information.
To some extent, Chamco relies on individuals to update
their own personal information. For example, if an individual has had a change
of address or telephone number, marital status, or if they wish to make changes
to their banking information, the individual should complete the appropriate
documentation and forward to the appropriate contact within Chamco requesting
that the individual's file be updated. Unless an individual advises Chamco of
these important changes, Chamco has no way of knowing about them.
Chamco
reserves the right not to change any personal information and instead append any
alternative text the individual concerned believes is appropriate. For example,
Chamco may not change certain information contained in a file, but will attach a
sheet to that file indicating the amendment requested by the individual.
ACCESS TO PERSONAL INFORMATION
You can ask to see the personal information that we hold about you. If you want
to review, verify or correct your personal information, please contact the
Privacy Officer using the contact information set out below. 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.
If you require assistance in preparing your request, please contact the 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. 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 endeavour to
inform you of the reasons why, subject to any legal or regulatory restrictions.
PRIVACY OFFICER
In order to ensure compliance with this privacy policy, Chamco has appointed a
Privacy Officer to oversee all aspects of its privacy policies and practices.
The Privacy Officer may be contacted via e-mail at privacyofficer@chamco.com, or
via mail or courier at:
8900 Venture Avenue S.E.
Calgary, Alberta T3S 0A2
QUESTIONS
If an individual has questions with respect to Chamco’s privacy policies or
practices, or with the result of their request to access or correct their
personal information, they should address their questions, in writing, to the
Privacy Officer. The Privacy Officer will then endeavour to answer such
questions, report back to the individual and advise them of any steps taken to
address the issues raised by them. If the individual is unsatisfied with the
response, they may be entitled to make a written submission to the Privacy
Commissioner applicable for that individual's jurisdiction.
REVISIONS TO THIS POLICY
Chamco may from time to time make changes to this privacy policy to reflect
changes in its legal or regulatory obligations or in the manner in which we deal
with your personal information. We will post any revised version of this privacy
policy on our website www.chamco.com , and we encourage you to refer back to it
on a regular basis. Any changes to this privacy policy will be effective from
the time they are posted, provided that any change that relates to why we
collect, use or disclose your personal information will not apply to you, where
your consent is required to such collection, use or disclosure, until we have
obtained your consent to such change.
RESPONSIBILITY AND INTERPRETATION
It is the responsibility of the Privacy Officer to update this policy as
required. Any interpretation associated with this policy will be made by the
Privacy Officer. This policy includes examples but is not intended to be
restricted in its application to such examples, thus 'including' shall mean
'including without limitation'.
This Privacy Policy does not create or confer
upon any individual any rights, or impose upon Chamco any rights or obligations
outside of, or in addition to, any rights or obligations imposed by Canada's
federal and provincial privacy laws, as applicable. Should there be, in a
specific case, any inconsistency between this Privacy Policy and Canada's
federal and provincial privacy laws, as applicable, this Privacy Policy shall be
interpreted, in respect of that case, to give effect to, and comply with, such
privacy laws.