ONLINE PRIVACY STATEMENT
PLEASE READ THIS PRIVACY NOTICE CAREFULLY AND REFER TO CLC’s LEGAL NOTICE FOR DEFINITIONS AND GENERAL INFORMATION. CLC is committed to the privacy and protection of Users’ Personal Information collected through this Site in compliance with the Privacy Act (the “Act”). This Online Privacy Statement (this “Statement”) provides the guiding principles applied by CLC to the collection, use, disclosure, retention and disposal of and access to Personal Information on this Site. Since privacy-related issues and requirements are subject to constant change, CLC reserves the right to amend this Statement at any time without notice, and Users are encouraged to review it regularly. ACCESS TO AND USE OF THIS SITE ARE ALSO GOVERNED BY THE LEGAL NOTICE, WHICH CONTAINS PROVISIONS CONCERNING PRIVACY AND OTHER ISSUES THAT YOU, AS A USER, SHOULD REVIEW.
CLC is responsible for Personal Information under its control. This Statement relating to Personal Information rests upon eight key principles:
- Identifying the purpose for the Personal Information;
- Obtaining consent for the Personal Information;
- Limiting the collection of the Personal Information;
- Limiting the use, disclosure and retention of the Personal Information;
- Ensuring accuracy of the Personal Information;
- Ensuring safeguards for the Personal Information;
- Responding to enquiries; and
- Complying with law and practices.
1. Identifying Purpose.
The collection of Personal Information through CLC’s Site is for the following purposes:
(a) to establish and maintain responsible commercial relations with Users and improve CLC’s ongoing communications with them;
(b) to understand Users’ needs; or
(c) to manage and develop CLC’s businesses and operations.
Users provide their Personal Information through the Site by one of three ways: by sharing their name and e-mail address when registering through the “Contact Us” page at any CLC Site; by voluntarily submitting their inquiries through the “Contact Us” page at any CLC Site; or by voluntarily submitting information to CLC through e-mail or by paper form requesting to include their name and e-mail address to CLC’s distribution or mailing list.
2. Obtaining Consent.
Consent for the collection of Personal Information by CLC is not required by the Privacy Act. CLC will, however, seek consent from Users by utilizing a double opt-in procedure through CLC’s Site. When subscribing to the Site or requesting information about CLC, Users will be required to complete a form. This double opt-in procedure ensures that CLC has the correct contact information of the Users and that Users have provided their confirmation and given their consent to the collection, use, disclosure, retention and disposal of and access to their Personal Information. Users may withdraw their consent at any time by simply clicking the “Unsubscribe” link at the bottom of the email newsletter or other form of communication from CLC.
3. Limiting Collection.
4. Limiting Use, Disclosure and Retention.
CLC will not disclose Personal Information without Users’ knowledge and consent, unless required by law. CLC will retain and dispose of Personal Information in accordance with CLC’s retention and disposal procedures, its internal records management, and with applicable law.
5. Ensuring Accuracy.
When subscribing or requesting more information on any CLC Site, Users acknowledge that the Personal Information they provide must be correct and current.
6. Ensuring Safeguards.
Personal Information under the control of CLC is kept in confidence and protected with measures that are appropriate to the sensitivity of such information. CLC is committed to ensuring that Personal Information is protected from loss, unauthorized access, copying, use, modification or theft and that protection is provided in accordance with industry standard security practices and with CLC’s procedures in respect thereof.
7. Responding to Enquiries.
Each government institution or Crown agency that is subject to the Act has an official performing the duties of a Privacy Coordinator. At CLC, the Privacy Coordinator is the Corporate Secretary. All requests made under the Act and received by any CLC office must be forwarded to the Corporate Secretary for processing. Enquiries related to this Statement or CLC’s privacy practices must be directed to:
Canada Lands Company CLC Limited
1 University Avenue, Suite 1200
Toronto, Ontario M5J 2P1
Attention: Corporate Secretary/Privacy Coordinator
8. Complying with Law and Practices.
Any User who wishes to make an inquiry or challenge the compliance or practices of CLC may do so through the Corporate Secretary, in writing. On receipt of a written inquiry or challenge, the Corporate Secretary will document the inquiry or challenge, conduct an investigation as necessary, and respond to the User. Should it be determined that CLC did not comply with this Statement or with provisions of the Privacy Act or Access to Information Act, a remedial action will be included in the response. If required, Users may contact the Office of the Privacy Commissioner of Canada.