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This Digital Privacy Policy is effective as of October 13, 2020.
The Associated Senior Executives of Canada Limited (“we”, “our”, “us”) recognizes the importance of your right to privacy and wants you to be familiar with: (i) how we collect, use, disclose and transfer any Personal Information that individually identifies you; and (ii) our commitment to endeavor to meet our obligations under applicable Canadian privacy laws.
This Digital Privacy Policy (“Policy”) is our policy on how we will collect, use, disclose, and transfer Personal Information of visitors (“you”/”your”) who use our website/mobile site (collectively, “Site”) and our services (“Services”). By accessing and/or using this Site and/or our Services and providing your Personal Information you acknowledge you have read and understood this Policy, you accept the terms of this Policy, you agree to adhere to the terms and conditions posted on this Site and you agree and consent to our collecting, using, disclosing and transferring your Personal Information in accordance with this Policy. Please do not use this Site, our Services or provide your Personal Information to us if you do not accept any terms of this Policy, do not agree with any terms or conditions posted on this Site or do not consent to our collecting, using, disclosing or transferring of your Personal Information in accordance with this Policy.
“Personal Information” means any information about an identifiable individual. “Anonymous Data” means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals. We do not consider Personal Information to include Anonymous Data.
The types of your Personal Information we may collect includes, without limitation, your name, physical address, email address, telephone number, IP address, involvement with us, personal information you give us that we did not request (such as personal information you voluntarily put into an email to us) and our Services payment information.
We collect, use, disclose and transfer your Personal Information that we collect for the purposes for which it was collected, as follows, in accordance with applicable law:
We may collect your Personal Information: (i) when you provide it to us by accessing and/or using this Site and/or our Services; or (ii) from third party sources.
For example, you may provide your Personal Information if you access and/or use this Site and/or our Services, including the recording of virtual communications between you and our advisors, make a request to receive our Services or information, send us a question or provide feedback, respond to surveys or questionnaires, post comments or other content on this Site, register to receive newsletters, articles or updates about our Services, participate in features of this Site and our Services that ask for your Personal Information, and in order to resolve your complaints or concerns.
Your personal information posted, used or disclosed on a Facebook page, Instagram page, Flickr page, LinkedIn page, Twitter page, Telegram page or other social networking page or site is subject to that site’s privacy policy, and is not subject to this Policy.
We limit the collection of your Personal Information to that which is necessary to fulfill the purposes identified in this Policy and we collect, use, disclose and transfer your Personal Information only in accordance with this Policy.
Your Personal Information will not be used without your consent for purposes other than those for which it was collected in accordance with this Policy or in accordance with applicable law. From time to time, we may wish to use your Personal Information for new or additional purposes in which case we will amend this Policy to include these new or additional purposes and will obtain your consent through your continued access to and/or use of our Services and/or this Site. We also will let you know when this Policy is updated. We retain your Personal Information only for as long as we need it to fulfill the purposes for which it was collected and to meet and comply with our legal obligations.
We may generate Anonymous Data from your Personal Information collected through this Site and/or Services by removing information that makes the data personally identifiable to an individual. Such Anonymous Data includes, without limitation, information we collect from your access to and/or use of this Site and/or Services. We may use this Anonymous Data and aggregated data for any reasonable purpose subject to applicable law and disclose such data to our service providers, data processors and other third parties (“Third Parties”) in our sole discretion.
We may use your Personal Information, and disclose your Personal Information to Third Parties for their use, under the following circumstances:
As stated, we may engage Third Parties to perform certain services on our behalf. These Third Parties may store, process and/or transfer your Personal Information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada. As a result, your Personal Information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. Subject to applicable law in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on Personal Information that are equivalent to those that apply in Canada.
This Site may contain links to other sites owned and operated by third parties (“Linked Site(s)”). This Policy applies only to this Site and not to Linked Sites. We provide links to Linked Sites solely as a convenience for you and for informational purposes only. We do not endorse, and are not responsible for, Linked Sites, including the privacy practices, if any, or the content of Linked Sites. Linked Sites may collect and treat information collected differently from this Site so please carefully read and review the privacy policy of each Linked Site you visit and/or make any necessary inquiries in respect of the privacy policy of the Linked Site with the operator of the Linked Site.
As you interact with this Site, we and this Site’s operators may use automatic data collection technology and services on this Site, including, without limitation, cookies and web beacons.
A cookie is a small data file that is placed on the hard drive of your computer to make your interaction with this Site faster and more personal. Cookies are used to “remember” users’ preferences on this Site, recognize users when they return to this Site and monitor how users use this Site. We may use cookies to personalize this Site, improve this Site and users’ experience at this Site and enhance the functionality of this Site.
Web beacons are small strings of code used to understand how users navigate through and process content in this Site, to count users at this Site’s pages and to create user profiles. We may include web beacons in HTML-formatted e-mails we send to determine which e-mails are opened.
Information tracked through these mechanisms includes, without limitation: (i) the user’s IP address; (ii) the type of web browser and operating system being used; (iii) access to and use of this Site, including pages visited and activities on this Site; and (iv) other sites visited before visiting this Site. These mechanisms are not used to access Personal Information.
Information obtained may be used by us and third parties to track traffic coming to this Site from advertising they run on other sites. For instance, we may use third party programs/services, such as AdWords run by Google Inc. (“Google”) to collect information about your visits to this Site in order to serve advertisements on our behalf across the Internet. In addition, Third Parties also may use information about your visits to other sites to target advertisements for services available from us.
You can set your internet browser to decline cookies or to notify you when cookies are stored in order that you can decide in each case whether or not you want to accept cookies and doing so results in web beacons not tracking your activity on this Site. If you do not accept cookies, you may be restricted in how you are able to access and/or use this Site and some areas of this Site may not perform properly. You can delete cookies that are stored on your hard disk at any time.
Our Site uses third party analytics services, such as Google Analytics a web analytics service of Google. Google Analytics uses cookies to analyze how you access and/or use this Site.
Information generated by cookies about your access and/or use of this Site (including your IP address) is sent to a Google server in the U.S. and stored there. Google will use this information to evaluate your access and/or use of this Site, compile reports on Site activity for us and this Site’s operators and provide other Site activity-related internet services.
Additionally, Google may transfer this information to a third party when required by law or in the case of a third party processing information on Google’s behalf. In no case will Google use your IP address in connection with any other information held by Google.
By accessing and using this Site and/or our Services and providing your Personal Information, you consent to the processing of data about you collected by Google in the manner described and for the above-mentioned purpose. The consent for collection and storage of data can be withdrawn at any time in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Given the debate concerning the use of analytical tools using full IP addresses, we note this Site uses the “Anonymize IP” function of Google Analytics that works with a shortened form of IP addresses to avoid direct personal identification. We also use cookies to carry out frequency assessments, page usage assessments and marketing assessments. For these assessments, we use this cookie information without a link to your Personal Information.
We maintain reasonable security safeguards to protect your Personal Information against loss, theft and unauthorized access. Personal Information you provide to us is exchanged on a secured server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, although we are committed to protecting your Personal Information, we cannot ensure or warrant the security of any such information you provide to us. We also take reasonable steps to ensure that our advisors are aware of the importance of maintaining the confidentiality of your Personal Information.
You may request access to your Personal Information which we may hold by contacting us at contactus@a-s-e.ca and we will respond within the time periods provided for under applicable law. We will need to verify your identity before providing you with the Personal Information we hold about you. There is no cost for such access request unless you require copies of records.
We may not be able to provide you with access to your Personal Information if it cannot be separated from the Personal Information of others, cannot be disclosed for reasons of security or commercial confidentiality or is protected by legal privilege. If we cannot provide you with access to your Personal Information, we will advise you of the reasons unless prohibited by law from doing so.
You may request to update, change, correct, complete or delete from our files your Personal Information by contacting us at contactus@a-s-e.ca. We will endeavor to comply with your request. Where appropriate, the amended information will be transmitted to Third Parties having access to such information.
We are committed to protecting the privacy of children so we do not knowingly collect or solicit Personal Information from children under the age of 13 or allow them to request information through this Site. If a child under the age of 13 has provided Personal Information the child’s parent or guardian may contact us at contactus@a-s-e.ca for the purpose of deleting this information.
If you have opted to receive email communications from us we may use your Personal Information provided to:
You will always have the opportunity to “unsubscribe” or opt out from receiving any of our e-mail or other communications at any time if you no longer wish to receive them by contacting us at contactus@a-s-e.ca. If you “unsubscribe” or opt out we will only contact you: (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Policy; and/or (iii) to receive Services related messages.
We reserve the right to change or replace this Policy at our sole discretion at any time. We will post the most current version on this Site and we will indicate at the top of this page the date this Policy was last revised. Your continued access to and/or use of our Services and/or this Site after any such change constitutes your acceptance of the terms of this Policy as revised.
By accessing and/or using this Site and/or our Services and providing your Personal Information, you signify your acceptance of the terms of this Policy, your agreement to adhere to the terms and conditions posted on this Site and your consent that we may collect, use, disclose and transfer your Personal Information in accordance with this Policy.
Please do not access and/or use this Site, our Services or provide any Personal Information if you do not accept any terms of this Policy, do not agree with any terms or conditions posted on this site or do not consent to our collection, use, disclosure or transfer of your Personal Information in accordance with this Policy; and please contact us at contactus@a-s-e.ca so we can address your questions or concerns.
Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes regarding your Personal Information identified in this Policy at any time by contacting us at contactus@a-s-e.ca. If you refuse or withdraw your consent, you acknowledge we may not be able to provide you or continue to provide you access to this Site, our Services or information that may be of value to you.
If you have questions, comments or concerns about this Policy or would like report any violation of this Policy then contact us at contactus@a-s-e.ca and we will endeavor to get back to you promptly.