Introduction
Protecting your privacy and the confidentiality of your personal information (as defined below in the section entitled “Definition of Personal Information”) – over the Internet, on the telephone, or through our offices – has always been fundamental to the way we do business at Toronto Region Board of Trade (the “Board”). We operate on the basis of a Privacy Policy and related procedures that guide the handling of the personal information we collect. We have created this Privacy Policy in order to demonstrate our firm commitment to protecting the privacy of our members, guests, partners and website visitors and Internet users. This Privacy Policy and related procedures are consistent with the federal Personal Information Protection and Electronic Documents Act and other applicable privacy legislation.
Application
This Privacy Policy applies to how the Board collects, uses and discloses the personal information of Board Members, guests and partners. This Privacy Policy also governs personal information collected about the Board’s web site (“site”) users and explains how we use and disclose personal information that we collect from people who visit our site and otherwise interact with us through www.bot.com (“site”). It explains how we use cookies and similar technologies.
Definition of Personal Information
This Privacy Policy deals only with personal information handled by the Board. When used in this Privacy Policy, personal information means “any information about an identifiable individual.” This may include, for example, information you provide to us, such as your name, contact information, email address, as well as information relating to your use of an account you have created on our site (for example, if you are a Board Member or if you have created an account to buy a ticket or product).
It may also include other types of more technical information about your use of our site, as described in the Website Privacy section of this Privacy Policy. However, this technical information is only considered to be personal information when it can identify you as an individual.
Personal information that is de-identified and/or aggregated and cannot be associated with an identifiable individual is not considered to be personal information. Personal information also excludes your business contact information that the Board collects, uses or discloses solely for the purpose of communicating or facilitating communication with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work electronic address.
Changes
The Board reserves the right to change this Privacy Policy and it may be updated periodically, as required to keep current with rules and regulations, as well as new technologies and standards. Any changes will be posted on this page and, if the changes are significant, we will provide a more prominent notice.
Collection and Use of Personal Information
When the Board collects personal information directly from you, the purpose for the collection will be identified at or before the time the information is collected. The Board generally collects your personal information and uses it for the following purposes:
- to administer and maintain an up-to-date membership and other stakeholder rosters, including membership status, directories and account balances;
- to establish and maintain Board membership and offer member services;
- to establish and maintain other program accounts and offer related services; for the collection of a Member’s or other’s account;
- to register participants to Board events and programs, and its applications and channels;
- to offer and sell various Board products or services including information products (data, surveys and publications), events and any other products, programs or services the Board may offer from time to time;
- to process and administer payments for Board membership, product or services;
- to conduct membership and other stakeholder outreach and communications, including member surveys on policy issues so that we may better reflect the views of our Members in our advocacy initiatives. You have a Right to Withdraw Consent to the use of your personal information for communication with you for marketing purposes;
- to understand and assess the interests, preferences and changing needs of Members and other stakeholders with a view to improving our products and services and developing new ones;
- to provide personalized products and services as well as recommendations for Members and others;
- to meet legal and regulatory requirements and allow the Board to meet contractual requirements relating to our products and services; or
- to report a claim to our insurer or meet other reporting requirements under our insurance policies.
Unless required or authorized by law, the Board will not collect or use personal information for any other purposes without obtaining further consent.
For details on the type of information that we collect via our site and on how we use and share this information, please refer to the Website section of this Privacy Policy.
Consent
The Board seeks consent for all personal information we collect, use and disclose through information provided to individuals prior to collection, or at the time of collection.
In general, if you have voluntarily provided personal information to the Board, you have consented to the collection, use and disclosure of your personal information as described in this Privacy Policy. Moreover, by visiting, interacting with and/or using our site, you agree to benefit from, be bound by the terms and conditions of this Privacy Policy.
The Board will not use or disclose personal information for any purpose other than that for which you have consented or as described in this Privacy Policy. Should the Board require personal information for a new purpose, we will seek your consent.
Sharing and Disclosure of Personal Information
Your information may be made available by the Board to third-parties or service providers to fulfil the purposes for which it has been collected or as set forth in this Privacy Policy. The Board does not sell or trade personal information with third parties. However, we may share your personal information with your specific consent, when authorized by law or as follows:
- Service providers. We may hire service providers to perform services on our behalf, including its legal counsel, auditors and other advisors and independent third parties involved in the development, enhancement or marketing of the Board’s products and services. The Board requires its service providers to respect this Privacy Policy and restricts them from using personal information they receive from us for any purpose other than facilitate and carry out the services they have been engaged to provide or to disclose this information to others. Any service provider to whom we provide personal information is required to keep your information confidential and secure, under written agreements.
- Business transaction. We may disclose personal information to a third party, such as prospective or actual purchasers, assignees and creditors, in connection with a sale or transfer of business or assets, an amalgamation, re-organization, financing or refinancing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
- As permitted or required by law. From time to time, we may be compelled to disclose personal information to third parties, including governments or regulators, in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement, or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
- Credit grantors and reporting agencies. We may provide your personal information to credit grantors and reporting agencies, subject to applicable law.
Safeguarding Personal Information
The Board respects the privacy of our Members, partners, site visitors and will protect that privacy as vigorously as possible. We store personal information in electronic and physical files that are secure. Our security measures include secure on and off-site storage, restricted access to records and data processing equipment, password protocols and encryption and security software when you order a product or service online. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or receive from us electronically. This is especially true for information you transmit to us via e-mail. We have no way of protecting that information until it reaches us. Once we receive your transmission, we make our best efforts to ensure its security on our servers. Note however that payment information is filtered through an industry standard payment security protocol and security software when you order a product or service on-line.
Retention
Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. The Board has developed and implemented detailed retention principles, and will ensure destruction of personal information in a method that prevents improper access
Access/Correction of Personal Information and Inquiries
The Board respects your right to access and correct or amend your personal information. If you have an account with the Board, you can log into your account at any time to access and update the information have provided to us. You may also make a request to our privacy officer using the contact information in the section entitled “How to Contact Us.” Requests for access or correction, inquiries or any concerns about our management of your personal information should be in writing and include: your name, contact details, membership number and the nature of your request. We may require proof of your identity to ensure that we do not inadvertently disclose your personal information to someone else without your consent.
Website Privacy
The Board generally collects and uses personal information from or about its Website visitors and users as follows:
- Information you provide.In many cases, we collect personal information directly from you when you visit or use our site. For instance, we may collect the following types of information:
- Inquiries. You may provide information to us by email or filling out a form on the site. If you choose to identify yourself and provide us with personal information, we may use that information to respond to your message and to help get you the information you have requested. The Board treats emails the same way it treats letters sent to the Board.
- Online account and membership, registration and subscription forms. We collect the information you provide when you create an account on our website or fill out an online form, for instance to purchase a product, service or register for an event. We may also collect your information when you log-in on our site through your account and interact with us through your account. We will only use the information that you provide us in accordance with this Privacy Policy.
- Online credit card transactions. As a convenience to Members and other users, the Board accepts online credit card transactions through its secure server. The credit card information provided by users on our site is submitted directly to the Board staff. This information is not used for any other purpose.
- Technical information. When you visit our site, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit to our site, including the IP address of your computer and which browser you used to view our site, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, the date and time you accessed our site, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our Members and visitors. We treat this information as personal information when it is associated with your account or contact information.
- Your choices with cookies. You can block the use of cookies by activating the settings in your browser. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of our site. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on settings or visiting the website of its manufacturer.
- Google Analytics. We use Google Analytics which allows us to see information on site activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
- Privacy Policies of Third Parties. This Privacy Policy only addresses the collection, use and disclosure of information by the Board. Other websites that may be accessible through the Board’s site have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.
- Right to Withdraw Consent. Consent to the collection, use and disclosure of your personal information may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice, by using the contact information provided in the section entitled “How to Contact Us.” However, without such consent, the Board may limit the services or products it is able to provide to you.
- Personal Information Outside of Canada. Your personal information may in some cases be transferred to jurisdictions outside Canada. As a result, you understand that your personal information will be subject to the laws of other jurisdictions than Canada and may be available to foreign government authorities under lawful orders and laws applicable in such jurisdictions. Regardless of the company or person who processes your information and where it is processed, we will take steps to protect your information in accordance with applicable data protection laws and this Privacy Policy
Children
We do not knowingly collect personal information from children. Our services and Website are not meant for children. If we learn we have collected or received personal information from a child without parental confirmation, we will delete that information. If you believe we might have any information from or about a child, please contact us using the contact information detailed in the How to Contact Us section below.
How to Contact Us
If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that the Board has about you or that it may have disclosed to third parties, please contact our Privacy Officer:
Email: privacy@bot.com
Phone: 416.862.4503
Fax: 416.366.2444
Toronto Region Board of Trade
100 Queens Quay E, Suite 16
Toronto, Ontario
Canada
M5A 1B4