In addition to our established policy of dealing with personal information in a sensitive manner, we at Burnbrae Farms Limited (“Burnbrae”) comply with all legislative enactments to ensure that our collection, use, retention, disclosure and disposal of personal information are carried out in accordance with established privacy laws.
- our accountability for our privacy practices;
- the purposes for which we collect personal information and the sorts of personal information that we collect across all channels of communication;
- the manner in which we use and disclose personal information;
- our security, retention and disposal processes relating to personal information;
- your right to access your personal information and to request corrections of same;
The Personal Information protected under this policy is information that can identify you as an individual. This includes information such as your name, date of birth, mailing address, telephone number and personal email address. It does not, however, include business contact information, such as your work email address, if we collect, use, or disclose such business contact information for the purpose of communicating with you in relation to your employment, business, or profession.
ARTICLE 1. ACCOUNTABILITY
Burnbrae Farms Limited
5434 Tomken Road
Attention: Privacy Officer
Phone Number 1 800 666 5979 Facsimile Number 905 624 5298 and Email Address firstname.lastname@example.org
1.2. We are responsible for the personal information under our control, including any personal information that we may transfer to a third party service provider for processing. Any service provider that we may engage to process or to otherwise deal with personal information on our behalf is not permitted to use, retain or disclose personal information transferred to it by us except in accordance with the terms of its services agreement with us. Depending on the circumstances, we may require a contractual commitment with that third party service provider to protect your personal information.
1.3. We have implemented policies and practices to give effect to our privacy commitment to you, including:
- personal information security processes (see Article 7 below);
- access, complaint and correction procedures (see Articles 9 and 10 below);
- a personal information retention and disposal policy; and
ARTICLE 2. IDENTIFYING PURPOSES FOR THE COLLECTION OF PERSONAL INFORMATION
2.1. In the course of business and other transactions Burnbrae may collect personal information for the purpose of providing you with general marketing, service and product information. This may include recording your identifying information to allow us to mail rebates and coupons or to deal with questions regarding our products requiring a response. We collect personal information for the purpose of understanding our customers’ needs, trends and preferences; developing our products and services; managing and developing our business and operations; meeting legal and regulatory requirements; and any other purpose to which you have consented.
2.2. We collect personal information about you that is reasonably necessary for the purposes described above. We may collect this information directly from you or from our Burnbrae website, our service providers or other sources that compile lists of purchasers of our product. Burnbrae may also conduct surveys and promotions where you might be asked to provide certain contact and eligibility information such as name, mailing address, telephone number, e-mail address, age and other information that may be required to provide or administer these services or promotion. We may collect personal information through questionnaires or from product-related comments, feedback or inquiries. Burnbrae has also taken steps to ensure that normal consumer inquiries can be made without the need to provide identifying information in situations where it is not required.
2.3. We explain our purposes for collection at or before the time of collection or these purposes will be immediately apparent, such as when a consumer signs up for certain newsletters. If personal information that has been previously collected is to be used or disclosed for a purpose not previously identified, we will, subject to our legal rights and obligations, identify that new purpose to you prior to the relevant use or disclosure.
2.4. We endeavour to ensure that persons collecting personal information on our behalf are able to adequately explain to you the purposes for which your personal information is being collected. If you have questions regarding a particular collection of information you may contact our Privacy Officer for more information at email@example.com
ARTICLE 3. CONSENT
3.1. Subject to our legal rights and obligations, we will obtain an appropriate form of consent for the collection, use and disclosure of personal information.
3.3. In certain limited circumstances, we may be required or permitted by law to collect, use or disclose personal information without your consent. For example, we may collect personal information without your consent if it is already publicly available, or if it is produced by you in the course of your employment, business, or profession (as long as the collection is consistent with the purposes for which you produced the information). We may use personal information without consent, for example, when it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim, or for the purposes of acting in respect of an emergency that threatens someone’s life, health or security. We may disclose personal information to another organization without consent if it is reasonable to do so for the purposes of investigating the breach of an agreement or contravention of a law or for the purposes of detecting, suppressing or preventing fraud, but only if obtaining consent would compromise the investigation or the ability to prevent, detect or suppress the fraud. We may also disclose personal information without consent to a government institution, a person’s next of kin, or a person’s authorized representative if it is necessary to identify an individual who is injured, ill, or deceased or so that a government institution may communicate with the next of kin or an authorized representative of an injured, ill or deceased individual. These examples are not exhaustive. Burnbrae’s priority is to protect your personal information. We will not collect, use, or disclose it without your consent unless required or permitted by law.
3.4. We may also collect, use and disclose personal information in relation to commercial business transactions. In cases where personal information is necessary in these circumstances, we may collect, use and disclose personal information without your consent. In such cases, we will enter into an agreement with the recipient of the personal information providing that the recipient will use and disclose that information solely for purposes related to the transaction, protect the information by security safeguards appropriate to the sensitivity of the information, and return or destroy the information if the transaction does not proceed. If the transaction does proceed, we will also into an agreement with the recipient providing that the recipient will use and disclose the information under its control solely for the purposes for which the personal information was collected, permitted to be used or disclosed before the transaction was completed, protect the information by security safeguards appropriate to the sensitivity of the information, and give effect to any valid withdrawal of consent. If a transaction that discloses your personal information is completed, you will be notified.
3.5. You may withdraw your consent to our collection, use or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. To exercise this right at any time please contact our Privacy Officer who will ensure that all personal information is removed from our records. If you withdraw your consent to certain uses of your personal information, we may no longer be able to provide you with certain of our products or services. Note that you may not be able to withdraw your consent to certain necessary uses or disclosures, as required by law.
3.6. If you have consented to receive promotional materials from us, we may periodically use your email address to send you information related to our products and services. If you would like to stop receiving promotional materials from us, you can opt out of emailing lists by clicking the unsubscribe link at the bottom of a promotional email.
ARTICLE 4. LIMITING COLLECTION
4.1. We will collect only that personal information that is necessary to achieve the purposes identified in Article 2 above. We collect personal information only by fair and lawful means.
ARTICLE 5. LIMITING USE
5.1. Personal information is used by a limited number of our personnel, on a “need to know” basis, while they are performing their functions. These include our marketing employees and other managers who respond to consumer inquiries or who administer newsletter lists and coordinate consumer contests.
5.2. We generally use personal information in order to receive and reply to your requests, inquiries and comments. Further, with your consent, we may send you information about products and promotions offered by us, contact you to conduct telephone surveys and market research, or send you coupons from time to time. We also use personal information to provide customer services, administer promotions and contests, and create a database of individuals who have registered to receive information from us. We use your personal information to understand your preferences, needs and interests and, with your consent, to offer you products and information that are likely to be of interest to you and personalizing your experience when visiting our website (such as by presenting you with information and offerings that we think will be of interest to you). We also use personal information to improve our products, manage and administer our business (including customer relations and defending and prosecuting legal claims), and ensure the security of our business operations (including our website). We use personal information to manage, administer, collect or otherwise enforce accounts and to maintain business records for reasonable periods and as required by law. Personal information can be used to meet legal, regulatory, insurance, security, accounting, and processing requirements. We may also use personal information for further purposes disclosed at the time of collection of personal information and otherwise with consent or as permitted or required by law.
ARTICLE 6. LIMITING DISCLOSURE
6.1. From time to time, we disclose or transfer personal information to other parties. Except as required or permitted by law (see Article 3, above), we will not disclose your personal information without your consent.
6.2. Where personal information is transferred by us to outside service providers that process personal information for us, reasonable steps will be taken to ensure that any such provider has personal information privacy procedures and policies in place that are at least comparable to those implemented by Burnbrae. We will further seek to ensure that any personal information that is transferred to such a third party service provider is returned to us, erased, destroyed, or otherwise made permanently anonymous at the end of the processing relationship.
ARTICLE 7. RETENTION
7.1. Personal information shall be retained for a reasonable period consistent with the purpose of collecting the information or as required by law.
7.2. Subject to Section 7.1 above, personal information that is no longer required in order to meet our identified and legitimate purposes will be destroyed, erased or otherwise made permanently anonymous.
ARTICLE 8. ACCURACY
8.1. We will not routinely update personal information, unless it is necessary to fulfil the purposes for which the personal information was collected. However, we will seek to ensure that personal information under our control is sufficiently accurate, complete and up-to-date to minimize the possibility that inaccurate personal information is used to make a decision about you.
ARTICLE 9. SAFEGUARDS
9.1. We protect personal information under our control with safeguards that are appropriate to the sensitivity of that information. These safeguards are designed to protect personal information in all formats against loss or theft, as well as against unauthorized access, disclosure, copying, use or modification. These safeguards include physical, electronic or procedural security measures and policies as required.
ARTICLE 10. OPENNESS
10.1. Information about our privacy-related policies and procedures is available upon request. This policy is one example of how we deal with personal information. If there is a specific question regarding an incidence of the collection, use or disclosure of personal information, please contact the Privacy Officer.
ARTICLE 11. INDIVIDUAL ACCESS
11.1. Subject to our legal rights and obligations, we will, upon receipt by our Privacy Officer of a written request for access, inform you about our possession, use or disclosure of your personal information, if any, and permit you to access that personal information if it is held or controlled by us. If you request such information or access, you must provide sufficient information with your request to permit us to provide an account of the existence, use and disclosure of that personal information. We may take reasonable steps to verify your identity before granting access or making corrections. Any personal information provided by us to you as a result of a request for access shall be in a generally understandable form.
11.2. We will respond to a request within a reasonable period of time and in any event within thirty (30) days of receipt of the request. We may extend this response deadline for up to an additional thirty (30) days if replying within thirty (30) days would unreasonably interfere with our operations, or if the time required to undertake any consultations necessary to respond to the request would make it impractical to meet that time limit. When necessary, we may also extend the response deadline for as long a period as is necessary to permit conversion of the personal information at issue into an alternative format that would allow a person with a sensory disability to read or listen to that personal information. We will provide written notice to you of any response period extension within thirty (30) days of your request. We will respond to a request for access at minimal or no cost.
11.3. In certain circumstances, we may not be able to provide access to all the personal information we hold about you. For example, we may not be able to provide information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, information that is subject to solicitor-client or litigation privilege, or information that is prohibitively costly to provide.
11.4. If you demonstrate to our satisfaction that your personal information that is held or controlled by us is inaccurate or incomplete, we will make appropriate amendments or we will add a note to your file about the inaccuracy you have pointed out. These amendments may involve the correction, deletion, or addition of personal information. Where appropriate, the amended personal information will be transmitted to other parties that have previously received the inaccurate or incomplete personal information.
ARTICLE 12. COMPLAINTS PROCEDURE