Policy Effective as of December 01, 2013
1. What personal information do we collect?
In this Policy, “personal information” refers to any information about the companies provided to FGW in the scope of FGW carrying out its mandate with their client. The types of personal information that FGW may collect from you from time to time include name of company, contact information of individuals in the company (such as owners, directors, officers, etc), financial data, business plans (including future plans on a going-forward basis), billing and account information, and customer relationship information (such as customer requests and feedback information requested or provided by or from you).
FGW attempts to ensure that collection of personal information is limited to that which is necessary to fulfill the identified purposes for which it is collected and that your personal information will be used only for such purposes.
2. Why does FGW collect personal information?
We collect personal information about you to enable us to serve you better and to develop our business and operations. More specifically, we collect, use and disclose your personal information for the following purposes:
- to establish, maintain and manage our client relationships in order to provide the services that have been requested;
- to be able to comply with your requests or inquiries;
- to establish and maintain commercial relationships including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual obligations;
- to understand and respond to your needs and preferences, including to contact and communicate with you and to conduct surveys, research and evaluations;
- to detect and protect FGW against error, negligence, breach of contract, fraud, theft and other illegal activity and to audit compliance with FGW policies and contractual obligations;
- to monitor quality control and respond to questions and concerns through correspondence with clients and consumers;
- to conduct research regarding the efficacy of our services and to facilitate ongoing communication of services information;
- as permitted by and to comply with, any legal or regulatory requirements or provisions, and
- for any other purpose to which you give consent.
3. To whom does FGW disclose your personal information?
From time to time, FGW may use and disclose your personal information: for the purposes described in this Policy or for any additional purposes for which we have obtained your consent. FGW may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with establishing, maintaining and managing our relationship with you.
In particular, FGW may disclose your personal information to:
- service providers, including an organization or individual retained by FGW to perform functions on its behalf, such as marketing, data processing, document management and office services, etc;
- a financial institution, on a confidential basis and solely in connection with such matters as the assignment of a right to receive payment, the provision of security or other financing arrangements;
- another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of FGW through, for example, 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 Policy, unless you consent otherwise; or
- any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.
4. How can you express your privacy preferences?
It is important to FGW that where we collect, use or disclose your personal information we have your consent to do so. In general, we seek to obtain your express informed consent before collecting your information. Express consent can be given orally, electronically or in writing.
Subject to legal or contractual restrictions and reasonable notice, you may change or withdraw your consent at any time by contacting our Customer Relationship Manager at the address indicated below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide services or information that you requested or that could be offered to you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Customer Relationship Manager.
At FGW, we want you to be able to maintain control over how we use your personal information. In particular:
- You may have the right to “opt out” of some or all of the identified purposes, uses and disclosures listed in sections 3 and 4 above;
- You always have the option to instruct us not to use your name, address, e-mail address, etc. beyond providing you with the information or service you requested;
- E-mail communications will always include an identification of the sender and an “Unsubscribe” option;
- You have the right to access and rectify your personal information that we have on file, as discussed below in section 7.
In order to specify your privacy preferences, please contact our Customer Relationship Manager at the address below (see “Contact Us”).
5. How do we protect your personal information?
To help protect the confidentiality of your Personal Information, FGW employs administrative, technological and procedural safeguards that are appropriate to the sensitivity of the personal information. We operate secure data networks protected by industry standard firewall and password protection systems. Uses and disclosures of personal information by external individuals and organizations acting on behalf of FGW are governed by contracts that require personal information to be protected appropriately.
Documents containing personal information are kept in filing cabinets that are maintained in our offices. Access is limited to those who have a business need to know.
6. Where is your personal information stored?
Your personal information is stored in secured locations and on servers controlled by FGW, located either at our offices or at the offices of our service providers. For access to your personal information, please contact our Customer Relationship Manager via the contact information below. FGW shall retain your information for such length of time as required by law.
7. How can you access your personal information?
Upon written request, subject to certain exceptions, FGW will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. Access requests should be sent to our Customer Relationship Manager, using the contact information in the “Contact Us” section below. When requesting access to your personal information, 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 the personal information that we hold about you. We may charge you a fee to access your personal information to cover our costs; however, we will advise you of any fee in advance.
Your right to access your personal information is not absolute. Applicable law or regulatory requirements allow or require us to deny you access where access would inhibit the ability of FGW to comply with a legal obligation; where it has already been destroyed due to legal requirements or because we no longer need it for our business purposes and where access would reveal personal information about a third party.
In the event that we cannot provide you with access to your personal information, we will inform you of the reasons, subject to any legal or regulatory restrictions.
8. How can you update or correct your personal information?
You should advise FGW if you believe that your personal information is inaccurate. You have the right to ask for it to be corrected or updated. We may ask you to provide documentation to support your request for correction or updating.
9. Changes to this Policy; Interpretations
FGW reserves the right to modify or supplement this Policy at any time. If any changes are made to FGW’s use, collection or disclosure of your personal information that require your consent, we will not implement such changes until your consent has been obtained.
This Policy does not create or confer upon any individual any rights, or impose upon FGW 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 Policy and Canada’s federal and provincial privacy laws, as applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
10. Contact us
FGW has a Customer Relationship Manager to oversee compliance with this Policy. Should you have questions about this Policy or collection, use and disclosure practices of FGW, you may contact the Customer Relationship Manager in writing or by telephone as indicated below:
Attention: Customer Relationship Manager
10520 Yonge Street, 35B-336, Richmond Hill, ON L4C 3C7
+ 1 (647) 800-5006
The Customer Relationship Manager will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding FGW’s use of personal information.