Setting Your Small Business Up for Success in 2014
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THIS VERSION IN EFFECT SINCE April 1st, 2010
OUR COMMITMENT TO PRIVACY
We have certain statutory obligations concerning the Personal Information in our care or control. Personal Information as used in this policy means any information defined as personal information in the Personal Information Protection and Electronic Documents Act ("PIPEDA").
In PIPEDA, Personal Information means information about an identifiable individual, but does NOT include the name, title or business address or telephone number of an employee of an organization. If you are a business owner or employee of a business, we do not require your consent to use or disclose this information. Personal Information does include your business email address, and your answers to survey questions that include identifiable information about you. Personal Information does not include answers to survey questions that identify business needs or preferences.
We provide our content at no cost to you. In return, we ask you to provide limited information, which may include certain Personal Information, about your business and your business needs. We share this information with carefully screened third party businesses whose products and services directly relate to your business needs ("Bizlaunch Partners"). By submitting your application for membership with us, you are giving us consent to share the information, including any Personal Information, in your application, with these Bizlaunch Partners. Further, in the event you complete any survey with us, you consent for us to share the information, including any Personal Information, in that survey with these Bizlaunch Partners. These Bizlaunch Partners may contact you directly from time to time to offer you discounts, promotions, or otherwise send you materials marketing their products and services.
At any time, you may choose to opt out of the continued Use of your Personal Information by making a request in writing to the Privacy Officer, whose contact information is outlined below, or in the alternative, by exercising the opt out process outlined in the correspondence provided to you by the Bizlaunch Partner.
A list of the types of Bizlaunch Partners that we may share your Personal Information with can be found on our website. Further, in the event you sign up for a particular seminar or webinar or other content that is sponsored by a particular company, in most instances, your Personal Information will be shared with that company, who is a Bizlaunch Partner.
We will also Use your Personal Information to contact you when we are offering future programs, products or services that may be of interest to you in light of your stated business needs or category.
In any instance where we intend to Use any Personal Information in a way that would require consent under PIPEDA, or any equivalent laws effective in the jurisdiction which we intend to Use the Personal Information (all effective laws in a jurisdiction collectively referred to as "Governing Laws"), notice of this Use will be provided and we will seek consent from you prior to any such Use. The form of the consent that we will seek before the Use of your Personal Information may vary depending upon the circumstances and the nature of information and Use in question. We will consider the sensitivity of the Personal Information and your reasonable expectations in determining what form of consent must be given. To the extent any Governing Laws require a particular form of consent be obtained from you prior to our Use of Your Personal Information, we will make all reasonable efforts to obtain that consent.
It is not a condition of supplying a product or service that you consent to the Use of your Personal Information beyond that Use required to provide the products or services requested, or to manage and develop our business and operations. We do require that you provide all the information requested, including Personal Information, in our application form, as a condition of membership. However, you may opt out of our Use or disclosure of the Personal Information in our possession by a request in writing to the Privacy Officer, whose contact information is below.
Upon receipt of a withdrawal of consent to Use or disclose Personal Information you have provided to us, we will immediately remove your Personal Information from our future recommendation list, and will ensure that any Bizlaunch Partners with whom we have shared your Personal Information ceases to use that Personal Information within 30 days of our receipt of your written request. However, we will not prohibit Bizlaunch Partners from further Use of information you have provided to us that is not Personal Information.
We may Use your Personal Information without your consent to collect a debt you owe to us, to comply with a subpoena, warrant or court order, to investigate a breach of any agreement or a contravention of a law, or where Use is clearly in your interests and consent cannot be obtained in a timely way, or as otherwise required or permitted by law.
You may refuse to provide us with your Personal Information and may, subject to legal or contractual restrictions and reasonable notice, withdraw your consent at any time to the continued Use of your Personal Information provided. The period of reasonable notice will vary depending on the nature of the information and its purpose to us. We will inform you of the implications of refusing or withdrawing consent, which may impact on our ability to serve you and to maintain our relationship, or preclude us from providing certain of our products or services.
COLLECTION OF PERSONAL INFORMATION
We will not collect Personal Information indiscriminately. We will limit the amount and the type of information we collect in order to determine your business needs, to facilitate our ability to recommend future Bizlaunch programs to you in the future. at the time we collect your Personal Information, at the time you consent to any additional Use of Personal Information, or as otherwise permitted or required by law. We may also collect information about your business and business interests or your personal interests to better serve you and foster our relationship.
We collect information only by lawful and fair means and not in any unreasonable or intrusive way. We may collect information by way of verbal or written correspondence including direct response surveys delivered personally or by fax, online surveys entered in at our website, emails, and telephone inquiries. In almost every instance, we will collect Personal Information from you directly. Any other collection of Personal Information will be made only where explicitly permitted under PIPEDA.
USE OF PERSONAL INFORMATION
We generally Use your personal information for the following purposes:
to determine whether we should establish a commercial relationship with clients, suppliers and other third parties, including to identify conflicts of interest, to evaluate credit standing and to match credit bureau or credit reporting agency information;
to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual obligations;
to share Personal Information to and from third parties for the purpose of determining your business needs, and otherwise providing our products and services to you and to them;
to understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties, to conduct surveys and market research, to assemble market research data, on both an individualized and collective basis, and to evaluate client service and satisfaction;
to develop, enhance, market, sell or otherwise provide our products and services;
to distribute our publications, seminars, invitations to events and other communications that may be of interest or relevance that we put in place or publish to individuals on our mailing lists and email lists, including through third party mailing and email service providers;
to engage in business transactions, including the purchase, sale, lease, merger, amalgamation and any other type of acquisition, disposal, securitization or financing involving us;
to detect and protect us, yourself and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with our policies and contractual obligations, and where necessary, to meet our insurance requirements;
to manage and develop our business and operations;
to maintain, develop and manage our document management, knowledge management and precedent systems and databases;
to consider the admission of individuals as employees or members of us;
as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
for any other purpose to which you otherwise provide your consent.
Your personal information may be accessed or stored in Canada or another jurisdiction, and the storage and access of Personal Information will at all times comply with the Governing Laws of that jurisdiction.
OUR WEB SITE
Every computer connected to the Internet is given a domain name and a set of numbers that serve as that computer's "Internet Protocol", or IP address. When a user requests a Web page from the Site, our web servers automatically recognize that user's domain name and IP address. The domain name and IP address reveal nothing personal about the user other than the IP address from which the user has accessed the Site. We may use this information to examine our traffic in the aggregate, but do not collect and evaluate this information on an individual basis.
LINKS TO OTHER WEB SITES
Our Site may contain advertisements for, information about, or links or references to, other businesses, resources or Web sites operated by other persons (collectively "Other Sites"), which are provided solely for the convenience of Site visitors. Other Sites may be subject to less stringent privacy standards. Other Sites are independent from us, and we are not responsible for the privacy practices, policies or actions of the third parties that operate Other Sites. We strongly encourage all Site visitors to review the privacy statements and policies of all Other Sites before providing them with Personal Information.
PRIVACY OF CHILDREN
Our Site is not directed to children. We do not sell products or services for purchase by children. We will not knowingly collect Personal Information from children.
RETENTION OF PERSONAL INFORMATION
We will retain information, including Personal Information, for as long as it is needed for the purposes for which it was collected. For example, if you send us Personal Information electronically to apply for employment with us, we will retain your Personal Information for a reasonable period to permit future consideration for employment. We will only store Personal Information for as long as permitted, given the nature of the Personal Information, your consent to our Use, and the nature of our Use thereof, under PIPEDA or Governing Law, whichever period is shorter. However, we will never disclose or Use your Personal Information after three (3) years from the date that you originally provided that Personal Information to us, unless we receive further consent from you.
PROTECTION OF PERSONAL INFORMATION
To secure the Personal Information under our custody or control from loss or theft, as well as unauthorized access, disclosure, copying, use, disposal or destruction, we employ physical, organizational and technological measures appropriate to the sensitivity of such Personal Information.
Nevertheless, there is an inherent risk involved in the exchange of information using any form of communication, such as email, telephone, fax transmission and courier service. We do not represent, warrant or guarantee that Personal Information will be protected against loss, misuse, interception or alteration, and assume no liability for any damages you may suffer as a result of loss, misuse, interception or alteration of information during any of such transfers.
YOUR ACCESS TO PERSONAL INFORMATION
Individuals may write to our privacy compliance officer to request access to Personal Information held about them in any of the manners provided below. However, an individual's right to access his or her Personal Information under our care or control is not absolute, for example, where the disclosure of Personal Information would cause security, legal or confidentiality concerns. We will deny access when
the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
the disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
the disclosure would have an unreasonable impact on other individual's privacy; or
the disclosure would reveal the identity of an individual who has provided Personal Information about another individual and the individual providing the Personal Information does not consent to disclosure of his or her identity.
In addition, we may deny access when
the disclosure would reveal confidential commercial information that, if disclosed, could, in the opinion of a reasonable person, harm our competitive position or that of any Bizlaunch Partner; or
the Personal Information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act under a collective agreement, under an enactment or by a court.
You can request details relating to the types of Personal Information that has been shared with Bizlaunch Partners, and the identity of these Bizlaunch Partners.
Access to your Personal Information is free of charge. However, a reasonable charge may be required when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request. We may also request that you provide sufficient identification to permit access to your Personal Information. Any such information shall be used only for this purpose.
ACCURACY OF PERSONAL INFORMATION
It is important that the Personal Information we hold about you is accurate, complete and current. We invite and rely on you to advise us, without delay, of any changes to your Personal Information which may be relevant to the products and services we or any relevant third party provide or may provide. We will amend the Personal Information forthwith provided that you demonstrate the inaccuracy or incompleteness of such information to our satisfaction.
Wherever it is legal and practical, we may consider offering the opportunity to deal with general inquiries without an individual disclosing their name or other Personal Information.
If you are not satisfied with or have any further concerns about our handling of your Personal Information, you are encouraged to contact our privacy compliance officer in writing again, setting out the reasons for your concerns. If, after our privacy compliance officer has reviewed and responded to your concerns, you remain dissatisfied, you may wish to contact any applicable governing bodies, including the privacy commissioner of Canada in writing at:
The Privacy Commissioner of Canada
3rd Floor, Place de Ville
112 Kent Street
Ottawa ON K1A 1H3
CHANGES TO THIS POLICY