DIALOGUE PARTNERS INC.
PRIVACY POLICY
Dialogue Partners may collect Personal Information in the course of its activities and has prepared this policy to inform you about our ongoing commitment to ensuring that the Personal Information obtained remains accurate and confidential.
What is Personal Information?
"Personal Information" means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address).
Why Dialogue Partners May Collect Personal Information
Dialogue Partners may use the Personal Information you provide verbally or in writing (including via electronic media) in order to:
Establish a commercial relationship with you;
Provide you with our services;
Provide you with ongoing customer service;
Provide you with information about our products and services (including by means of direct marketing);
Process payments for products and services;
Meet legal and regulatory requirements; and
Such other purposes consistent with these purposes.
The personal information we ask for will depend upon which products or services you may obtain.
How Dialogue Partners Collects and Uses Personal Information
Dialogue Partners only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing products or services to our clients. We use only fair and lawful methods to collect Personal Information.
Our use of Personal Information is limited to the purposes described in this Policy and Dialogue Partners does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.
When Dialogue Partners May Disclose Your Personal Information
Dialogue Partners may disclose your Personal Information to:
Individuals or organizations who are our advisers or service providers; and
Individuals or organizations who are, or may be, involved in
(i) a transfer of all or part of the assets or business of Dialogue Partners;
(ii) maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems; or
(iii) a corporate re-organization of Dialogue Partners.
In the event sensitive Personal Information is provided to Dialogue Partners, we will not disclose such Personal Information unless it is required in order to provide you with our products or services.
Where Dialogue Partners discloses Personal Information to organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes of providing services to Dialogue Partners, our clients or the person concerned and to have appropriate safeguards for the protection of that Personal Information.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where Dialogue Partners is obliged to disclose information without consent. Such circumstances may include:
Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
Where Dialogue Partners believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
Where it is necessary to establish or collect monies owing to Dialogue Partners;
Where it is necessary to permit Dialogue Partners to pursue available remedies or limit any damages that we may sustain; or
Where the information is public.
Where obliged or permitted to disclose information without consent, Dialogue Partners will not disclose more information than is required.
Consent
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the information for a new or different purpose where the individual concerned has not already consented to such a use of their personal information.
By providing Personal Information to Dialogue Partners you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy.
Retention Of Personal Information
We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.
When your Personal Information is no longer required for Dialogue Partners’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.
Access To Your Personal Information
Dialogue Partners permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.
Dialogue Partners reserves the right to decline to provide access to Personal Information where the information requested:
Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm Dialogue Partners or the competitive position of a third party;
Would interfere with contractual or other negotiations of Dialogue Partners or a third party;
Is subject to solicitor-client, litigation or other legal privilege;
Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
Does not exist, is not held, or cannot be found by Dialogue Partners;
May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
May be withheld or is requested to be withheld under applicable legislation.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
Resolving Your Privacy Concerns
In the event of questions about: (i) access to your Personal Information; (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact Kim Hyshka, Managing Associate at Kim@dialoguepartners.ca or calling 1-866-269-1276.