Last Updated: October 31, 2023
What personal information do we collect?
- We collect personal information directly from users of our website www.woodcliffe.ca (the “Website”) and services related to the Website, including name and email address. Users may also provide additional information by choosing to fill out free-form fields on our Website, if any, and we may also automatically collect and generate information from your access and use of the Website, including through Google Analytics (the “Usage Data”) (collectively, the “personal information”).
- By using our Website or services, you are choosing to provide us with your personal information and you acknowledge and consent to the processing of your personal information in Canada.
- Our Website collects users’ location information.
Why do we collect personal information and how is it used?
- We collect personal information to facilitate the use of our Website and services.
- We may also use the Usage Data in aggregate and de-identified form for research and evaluation purposes.
Is personal information shared or disclosed?
- Personal information provided to us is never sold or rented to other organizations.
- We also use certain third party service providers who may access to the information we collect.
- We may also disclose or share personal information for fraud prevention, and other permitted disclosures under applicable law.
How do we protect personal information?
- We have implemented safeguards to protect personal information under our control, and regularly review our practices to ensure they align with reasonable practices appropriate to the level of sensitivity of the information, in order to safeguard personal information against loss or theft, unauthorized access, alteration, or disclosure.
What are the risks?
- Although we take steps to safeguard the personal information under our control, “perfect security” does not exist online or elsewhere. In particular, we cannot guarantee the security of information posted or transmitted using our Website or via email. It is possible that third parties may unlawfully intercept or access such information.
What are your choices?
- You may request access to and review of your personal information in our possession, subject to certain limitations.
- You may also request that we change or delete your personal information in our possession. We will make best efforts to comply with such requests, subject to certain limitations.
What else should you know?
- You can contact us with questions, complaints, or to access your personal information.
This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose, and otherwise process (collectively, “process”), and how you may correct, update, and access, your personal information that you provide as a user of: (a) the website operated at www.woodcliffe.ca, and other locations from time to time (the “Website”); and (b) the services we provide through the Website (collectively, the “Service”).
1. Personal Information
For the purposes of this Policy, “personal information” means any identifiable information about an individual (e.g., an individual’s name, home address, telephone number, and email address), except any information exempted by the applicable laws of Canada and other jurisdictions. For example, in Canada, personal information does not include any business contact information that is processed solely to communicate with that person about their employment or profession.
When you use our Website or Service, we may collect the following personal information from you:
- Contact information such as name, email address, mailing address, and phone number;
- Unique identifiers such as username, account number, and password; and
- Usage Data.
Your personal information may be collected when:
- You register for an account with us;
- You fill out free-form fields on our Website;
- You connect with us through social media;
- You communicate with use by phone or email; and
- You otherwise use our Website or Service.
We only collect personal information that we need. We encourage you not to provide us with any personal information beyond what is necessary and as requested by us.
Collection from Third Parties
We do not knowingly collect your personal information from a third party unless you consent or we are otherwise exempted, required, or permitted by applicable laws to do so. If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected.
Links to Other Sites
To the extent that our Website contains links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party applications.
Information about Minors
This site is intended solely for users who are not minors (19 years of age or older). We do not knowingly collect personal information about any minor. No such minor, nor any parent or guardian of such minor, should submit such minor’s personal information to us through the Website or otherwise for any reason or under any circumstances.
2. Google Analytics and Usage Data
We collect the Usage Data to gain information about the way you use our Website and Service. The Usage Data may include performance data of the Website, the site from which you came and the site to which you are going when you leave our Website, the pages you visit, the links you click on, how frequently you access our Website, whether you open emails or click the links contained in emails, whether you access our Website from multiple devices, last login time, and other actions you take on our Website.
3. Purpose for Which Personal Information is Processed
We may process your personal information for the following purposes (the “Purposes”):
- To verify and authenticate your identity;
- To ensure that the Website or Service is optimized for your use and benefit;
- To analyze user experience and improve the Website;
- To operate, maintain, and provide you with the Service, and the features and functionality of the Website;
- To communicate with you to provide you services, contacts, materials, and/or recommendations for your needs as identified by you through phone, email, or the Website;
- To carry out our obligations arising from any contracts entered into between you and us;
- To comply with internal policies and procedures and other legal, accounting, or security requirements;
- To share your personal information with our employees, contractors, consultants, and other third party service providers, such as hosting providers, advertising agencies, or customer service agencies (“Third Party Processors”) who require this information to assist us with establishing, maintaining, and managing our relationship with you, as well as optimizing and providing the Website or Service for your use and benefit. Please note that we may change or add Third Party Processors at any time, in our sole discretion, in either Canada or elsewhere. We encourage you to reference this Policy from time-to-time, to obtain updated information.
We will only process your personal information for the Purposes identified above and will not otherwise process your personal information without your consent.
4. Disclosure of Your Personal Information
We may disclose your personal information for the Purposes as described in this Policy in the following ways:
- To our employees and contractors;
- To our business partners;
- To our Third Party Processors; and
- To law enforcement, government or regulatory bodies, or other lawful authorities.
5. Legal Basis for Processing Your Personal Information
We will process your personal information only with your knowledge and consent, except where exempted, required, or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be: (a) express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent; or (b) implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Your authorized representative can also provide your consent. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. By using our Website or Service, or by otherwise choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.
If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Website or Service or otherwise provide any personal information to us.
You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice, by: (i) changing your privacy preferences through the Website; (ii) deleting your account with the Website and stopping use of the Website; or (iii) opting out of the use of your personal information by contacting our Privacy Officer (see Section 11 below). However, if you withdraw or change your consent, we may not be able to provide you with the Service through the Website.
Other Legal Bases
Aside from consent, we may also process your personal information under other legal bases, as permitted by the applicable laws.
6. Security of Personal Information
The security of your personal information is important to us. We protect personal information using physical, technological, and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration, or disclosure.
However, no method of transmission over the Internet, or method of electronic storage, is completely secure. As such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.
7. Requests for Access to and Correction of Personal Information
Applicable privacy laws allow, to varying degrees, grant individuals the right to access and/or request the correction of errors or omissions in their personal information that is in our custody or under our control. You may request access to and review of your personal information in our possession. However, access may be declined where permitted or required by applicable law.
You may request that we change or delete your personal information in our possession. We reserve the right not to change any personal information if we do not agree that it is inaccurate or outdated, but will append any alternative text the individual concerned believes appropriate.
If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
8. CASL Policy
We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes, and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities, including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting and updating this Policy, we undertake various transparency initiatives to ensure we comply with CASL, which include:
- Consent—We do not send you CEMs without your consent. This consent typically must be “express” (expressly acknowledged by you), but in certain circumstances can be “implied” or specifically exempt from consent requirements. We adopted our sign-up, registration, and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) as per CASL. When we collect your electronic contact information, you will know the exact purposes behind the collection.
- Content—We adopted processes to ensure that our CEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:
- Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
- Provide you with our contact information; and
- Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
- Clarity—We ensure that each aspect of a CEM, including its header, content, or any links or URLs, conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.
If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 11 below.
9. Retention of Your Personal Information
We generally keep personal information only for as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate purposes. More specifically, we retain personal information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws or protect our interests. When personal information is no longer necessary or relevant for the identified purposes, or is no longer required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated, or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules, and practices for information and records retention and destruction that apply to personal information.
10. Updates or Changes to this Policy
This Policy was last updated on the “Last Updated” date set out at the top of this page. We will occasionally update this Policy and revise the “Last Updated” date accordingly.
If we make any material changes, we will either: (a) notify you by email (sent to the email address listed in your account); or (b) provide a notice on the Website or otherwise through the Service before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification. We encourage you to review this page periodically for the latest information on our privacy practices to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Policy.
11. Contact Information for Privacy Officer
You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our Privacy Officer by emailing [email protected]
If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.