1. Our Privacy Commitment
2. What personal information does Pascoe Canada collect?
In the course of conducting business with you, Pascoe Canada collects both personal and non-personal information. Personal information is any information that identifies you, or by which your identity could be deduced, including, without limitation, your name, e-mail address, home address, telephone number, age, marital status, gender, income, date of birth, credit card number, and any other information that identifies who you are or would allow someone to contact you. In general, personal information does not include publicly available information, such as business addresses and telephone numbers that are listed in a public directory or made available through directory assistance.
4. Identifying Purposes for Collection of Personal Information
4.1 Pascoe Canada will make a reasonable effort to specify the identified purposes, either orally or in writing, for which it collects, uses, or discloses your personal information at the time of collection or after collection but before use. Generally, Pascoe Canada will only collect information that is reasonably necessary for the purposes identified. Additional information may also be collected, if appropriate in the circumstances, with your permission. Pascoe Canada will collect, use, and disclose your personal information for, among other reasons, the following purposes:
(a) to provide and to communicate information about Pascoe Canada products and services, including, without limitation, sending out newsletters and other relevant information;
(b) to verify the identity of Pascoe Canada customers and suppliers;
(c) to fulfill your requests for products, services or information;
(d) for transaction, billing, and record-keeping purposes;
(e) to provide quality customer service and determine your needs;
(f) to inform you about and register you for up-coming events, programs, and other opportunities that may be of interest to you;
(g) to update your contact information in Pascoe Canada database;
(h) to measure and enhance the effectiveness of our marketing endeavors;
(i) to tailor our offerings to your preferences;
(j) to allow you to subscribe to our newsletter or mailing list;
(k) to protect you against fraud or error;
(l) to verify your identity for the purpose of obtaining access to our products and services;
(m) to meet legal, statutory and regulatory requirements; and
(n) such other purposes consistent with the foregoing purposes
4.2 If your personal information is to be used for a purpose not previously identified, Pascoe Canada will identify and document this purpose prior to such use and will provide you with an opportunity to opt out of this activity. Pascoe Canada will state the identified purposes in such a manner that you can reasonably understand how the information will be used and disclosed.
5.1 The cornerstone to protecting your privacy is consent. We will only collect, use, and disclose your personal information with your consent except where otherwise permitted or required by law. Depending on the type of personal information collected from you, and the purpose for which the information is collected, your consent may be express or implied. Express consent can be granted verbally, in writing, in person, electronically, or by telephone. Your consent is implied if we ask you to provide personal information with a stated purpose.
6. Withdrawing Consent
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Please note, however, that withdrawing your consent may affect our ability to provide you with the services, products or information that may be of value to you. To withdraw your consent, simply contact us at the e-mail address or address listed in Section 14.1 below.
7.1 Pascoe Canada will use its best efforts to ensure that personal information is kept as accurate, complete, and up-to-date as is necessary and possible for the purposes for which it is to be used. Pascoe Canada will provide individuals with reasonable access to their personal information and will update or correct any deficiency in personal information held by it if the individual concerned provides Pascoe Canada with particulars of any required updating or correction. (There are limited exceptions to this which are set out in the PIPEDA legislation.)
7.2 Pascoe Canada will rely exclusively on the representations made by you in determining the completeness, accuracy, and timeliness of the personal information and will have no further obligation to seek independent verification of any personal information supplied by you to Pascoe Canada.
8. Security Safeguards
8.1 Pascoe Canada strives to ensure that its security measures will protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, regardless of the format in which the information is held. Such measures will vary depending on the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, administrative, technological, as well as electronic and online security measures.
8.2 Pascoe Canada assumes no liability if your personal information is stolen, intercepted, altered, misused or otherwise interfered with by a third party.
8.3 All employees of Pascoe Canada with access to personal information are required, as a condition of their employment, to keep such information confidential.
8.4 Pascoe Canada shall use reasonable efforts to ensure that upon disposal and/or destruction of records, confidentiality of information shall be maintained.
9. Third Party Links
Pascoe Canada’s website located at www.pascoe.ca may provide links to third party websites as a convenience to the user. The inclusion of any link does not imply Pascoe Canada's
endorsement of any other company, its websites, or its products and/or services. These linked websites have separate and independent privacy policies, which we recommend that you read carefully. We have no control over such websites and therefore assume no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose and otherwise treat your personal information.
10.1 Pascoe Canada is committed to being open about its policies and practices with respect to the collection and maintenance of personal information. We are pleased to answer any questions that you may have regarding the collection and maintenance of personal information. Please direct your inquiries to our Privacy Officer.
11. Limitations on Use, Disclosure and Retention of Personal Information
11.1 Personal information will not be used or disclosed for the purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information will be retained only for as long as is required or appropriate to fulfill the identified purpose.
11.2 Pascoe Canada will record any new purpose for which it has obtained an individual’s consent to use, retain or disclose information.
11.4 Pascoe Canada will establish criteria for the retention of personal information, including, as appropriate, minimum and maximum retention periods.
11.5 Personal information that has been used to make a decision about an individual will be retained for a reasonable period to allow the individual access to the information after the decision has been made.
12. Access to Personal Information
12.1 Pascoe Canada will respond to any requests for access to information within a within thirty (30) days of your inquiry. We will assist any individual who informs us that they require assistance in preparing a request. We will not, however, respond to frivolous or vexatious requests for access to information. At the time of your request, we will need specific information from you in order to verify your identity before we can provide you with the personal information we hold. We will advise you whether or not we hold your information, and will disclose that information along with particulars with respect to its source, unless such disclosure is prohibited by law.
12.2 While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, Pascoe Canada reserves the right to impose a cost. In such circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available to the individual in a form that is clear and understandable.
12.3 In providing an account of third parties to whom Pascoe Canada may have disclosed personal information about an individual, we will attempt to be as specific as possible. If it is not possible to provide a list of the organizations to whom Pascoe Canada actually disclosed personal information, we will provide a list of organizations to whom such information may have been disclosed.
12.4 If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Pascoe Canada will amend the information as required. If a challenge is not resolved to the satisfaction of the complainant, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.
12.5 In certain circumstances, Pascoe Canada may be unable to provide access to some or all of the information it holds about an individual. Such circumstances include: (i) if disclosure would reveal confidential commercial information; (ii) if the information is protected by solicitor-client privilege; (iii) if the information was generated in the course of a formal dispute resolution process; or (iii) if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. Where permitted, the reasons for denying access to the personal information will be provided to the individual upon request.
14. Questions or Concerns
14.2 Pascoe Canada will investigate all complaints as expeditiously as possible and, if a complaint is found justified, we will take all appropriate measure to resolve the matter to the satisfaction of the complainant.
14.3 If Pascoe Canada does not resolve the matter to your satisfaction, you may contact:
The Privacy Commissioner of Canada
112 Kent St, Ottawa, Ontario K1A 1H3