Your Privacy Rights
Beginning on January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act, (“the Act”) and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. The Act gives you rights concerning the privacy of your personal information. The Act makes GrowthEngine Media responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and trained our support staff about our policies and practices.
Why Does GrowthEngine Media Need Personal Information?
GrowthEngine Media provides advertising services to a wide range of clients. In doing so, it requires personal information in order to fulfill the terms of its advertising contracts and to fulfill its professional responsibilities. As well, it occasionally produces and distributes materials concerning its services and new developments in the advertising industry.
What Personal Information Do We Collect and How Do We Collect It?
GrowthEngine Media collects personal information relevant to our clients. According to the Act, Personal information is defined as follows: “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. The information we collect may go beyond contact information and include financial information (as an example) depending on the service.
In order to provide meaningful advice to our clients, we collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you.
In most cases, we ask you to consent, if we collect, use, or disclose your personal information. Sometimes, your consent may be implied through your contact with us and the fact that we are hired to handle your site’s online advertising on your behalf.
Use of Your Information
We use your personal information to provide advertising and marketing services, to fulfill our own professional responsibilities and, occasionally, to include you in our marketing activities. If you tell us that you no longer wish to receive marketing information about our services, or about new developments in marketing, we will not send any further material to you.
Growthengine Media does not disclose personal information to any third party to enable them to market their products and services. For example, we do not provide our client mailing lists to others. However, we do engage the services of third party marketing firms to help us find clients and we take no responsibility for their actions with personal information.
GrowthEngine Media will retain personal information as long as may be necessary to complete our client agreements, fulfill our own professional responsibilities and conduct our business.
Disclosure of Your Personal Information
Under certain circumstances, and/or as part of our client agreement, GrowthEngine Media will disclose personal information, including:
- When we are required or authorized by law to do so
- When you have consented to the disclosure, expressly or by implication or its disclosure is necessary in the litigation or other matter about which we have been retained.
- Where it is necessary to establish or collect fees
- If the information is already publicly known.
Is Personal Information Secure?
GrowthEngine Media takes all reasonable precautions to ensure that personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect information are:
- Premises security
- Restricted file access to electronic personal information
- Deploying technological safeguards like password protection, security software and firewalls to prevent hacking or unauthorized computer access
- Internal password and security policies
- Procedures for the destruction of personal information when it is no longer required including shredding and the formatting of electronic media.
Access to Your Personal Information
You may ask for access to any personal information we hold about you. However, we may ask that we be reimbursed for the time and cost to us of such access at our normal rates.
Can I Be Denied Access to My Personal Information?
Rights to access your personal information are not absolute. We may deny access when:
- denial of access is required or authorized by law
- when granting you access would have an unreasonable impact on other people’s privacy
- when to do so would prejudice negotiations
- to protect our agency’s rights and property
- where the request is frivolous or vexatious
Communicating With Us
You should be aware that email and online form submittal is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information GrowthEngine Media does not take any responsibility for personal information collected by third party marketing firms.
Cookies and Other Tracking Technologies
Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our Site is accessed. It is not our practice to link the information we record using tracking technologies to any Personal Information you submit while on the Site. However, we reserve the right to use IP addresses and other tracking technologies to identify a visitor only when we feel it is necessary to enforce compliance with the Site’s policies, to protect the Site, our customers, or others, or when we believe in good faith that the law requires it.
Links to Other Sites; Public Venues
Requests For Access
If you have any questions, or wish to access your personal information, please write to our Privacy Contact at:
122 Parliament Street
Toronto, Ontario M5A 2Y9
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:
112 Kent Street,
Ottawa Ontario, K1A 1H3
If you apply to GrowthEngine Media for a job, we need to consider your personal information, as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our privacy procedures for employee records.