1. PURPOSE OF THIS POLICY
2. WHO ARE WE AND WHAT DO WE DO
3. HOW TO CONTACT US
§ sending an email to: firstname.lastname@example.org
§ calling us at: 306.425.2020
§ by mail: PO Box 840, La Ronge SK, S0J 1L0
4. WHAT IS PERSONAL DATA?
Personal data is information that can identify an individual, either directly or when combined with other data.
Names, e-mails, addresses, localization, IP-addresses, photos, and account information all are directly identifying data. Health information, income, religion and cultural profiles and the like is also personal data.
Furthermore, and crucial in the present context, data on user behaviour is also personal. Cookies can track and register individual users’ browsing activities, like what articles they scroll past and which ones they choose to click on.
5. WHAT ARE COOKIES?
Cookies are small text files or code that can be used by websites to make a user’s experience more efficient. The law states that we can store cookies on your device (i.e., smartphone, computer or other electronic device) if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.
Our website uses necessary cookies to help us ensure that it is working as expected, optional analytics cookies to help us understand how visitors use it and optional functionality and targeting cookies to give you the best experience.
Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Watt Agencies, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies: These Cookies are essential to provide you with services available through our Website and enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.</p>
Functionality Cookies: These Cookies allow us to remember choices you make when you use our Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
6. WHAT PERSONAL INFORMATION DO WE COLLECT?
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our brokerage services. We offer services for auto and license issuing as well as extended insurance coverage on your home, rental or vacation properties, motor vehicles and commercial business. Additionally, we offer personal income tax preparation with a CRA registered representative.
Our primary goal in collecting personal information from you is to help us:
§ verify your identity;
§ deliver our Services;
§ manage your account
§ contact you by e-mail, telephone, SMS or other electronic communication such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
§ improve, develop and market new Services;
§ carry out requests made by you on our website or in relation to our Services;
§ investigate or settle inquiries or disputes;
§ provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information
§ comply with any applicable law, court orders, other judicial process, or the requirements of a regulator;
§ enforce our agreements with you;
§ other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience
§ protect the rights, property or safety of us or third parties, including our other clients and users of our website or our Services; and
§ use as otherwise required or permitted by law.
To undertake these goals we may process the following personal information:
If you are a visitor to our website:
§ Contact information and email address where appropriate.
§ Demographic information such as your address, preferences and interests.
§ Other information relevant to the provision of Services.
If you are an individual client in receipt of our Services or prospective individual client:
§ Contact information including your email address.
§ Information that you provide to us as part of us providing the Services to you.
§ Relevant information as required by Know Your Client and/or Anti-Money Laundering regulations and as part of our client intake procedures. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from you or through the use of online sources or both.
§ Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs.
§ Other information relevant to provision of Services.
If you are an individual whose personal information is processed by us as a result of providing the Services to others (including individual clients and corporate clients), we will process a variety of different personal information depending on the Services provided. This may include personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ officers or personnel, any opponent or vendor or purchaser personal information including personal information relating to their legal advisors, other advisors or personnel as relevant or similar.
We might also need to process personal information in relation to other third parties instructed either by our own clients or other persons or companies involved with us providing the Services to our client.
This is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of a law firm providing legal services.
For clients and prospects, we also collect information to enable us to market our products and Services which may be of interest to you. For this purpose we collect:
§ Name and contact details.
§ Other business information such as job title and the company you work for.
§ Areas or topics that interest you.
§ Additional information may be collected.
7. HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use your information for the following purposes:
Fulfilment of Services
We collect and maintain personal information that you voluntarily submit to us during your use of our website and/or our Services to enable us to perform the Services. Please note also that our Terms of Business apply when we provide the Services.
What is our legal basis?
It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.
Our website uses various user interfaces to allow you to request information about our Services including electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your Service enquiry. This information is used in order to enable us to respond to your requests.
What is our legal basis?
It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.
Business administration and legal compliance
We use your personal information for the following business administration and legal compliance purposes:
§ to comply with our legal obligations (including any Know Your Client or Anti-Money Laundering or Anti-Bribery, conflicts or similar obligations including, but without limitation, maintaining regulatory insurance);
§ to enforce our legal rights; and
§ to protect the rights of third parties.
What is our legal basis?
Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.
We carry out the following marketing activities using your personal information:
§ Postal marketing
§ Email marketing
§ We use information that we observe about you from your interactions with our website, our email communications to you and/or with Services (see the Client Insight and Analysis section below for more details of the information collected and how it is collected) to send you marketing communications.
What is our legal basis?
It is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications where you have consented to receive such marketing communications, or where we have a lawful right to do so.
Client insight and analysis
We analyse your contact details with other personal information that we observe about you from your interactions with our website, our email communications to you and/or with our Services such as the Services you have viewed.
§ an IP address to monitor Site traffic and volume;
§ a session ID to track usage statistics on our website;
§ information regarding your personal or professional interests, demographics, experiences with our products and contact preferences.
By using this information, we are able to measure the effectiveness of our content and how visitors use our website and our Services. This allows us to learn what pages of our website are most attractive to our visitors, which parts of our website are the most interesting and what kind of offers our registered users like to see.
We also use this information for marketing purposes (see the marketing section above for further details).
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available.
8. WHAT IS OUR LEGAL BASIS TO USE OR PROCESS YOUR PERSONAL INFORMATION?
We respect your privacy! However, it is necessary for us to use your personal information:
§ To perform our obligations in accordance with any contract that we may have with you.
§ It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
§ It is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.
9. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We may share personal information with a variety of the following categories of third parties as necessary:
§ Our professional advisers such as lawyers and accountants.
§ Government or regulatory authorities.
§ Professional indemnity or other relevant insurers.
§ Regulators/tax authorities/corporate registries.
§ Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers.
§ Third party service providers to assist us with client insight analytics, such as Google Analytics.
§ Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.
Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.
Our website use certain Tags, log files and other technologies of which you should be aware.
11. THIRD PARTY CONTRACTORS AND OTHER CONTROLLERS
As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers, who will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.
Further, we may appoint external data controllers where necessary to deliver the Services. When doing so we will comply with our legal and regulatory obligations in relation to the personal information, including but without limitation, putting appropriate safeguards in place.
What is our legal basis?
It is necessary for us to perform our obligations in accordance with any contract that we may have with you.
It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
12. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
For visitors to the Site, we will retain relevant personal information from the date of our last interaction with you in compliance with our obligations under the current General Data Protection Regulations or for longer if we are required to do so according to our regulatory obligations.
For Service provision to any client, we will retain relevant personal information for at least seven years from the date of our last interaction with that client and in compliance with our obligations under the current General Data Protection Regulations or similar legislation around the world, or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.
If personal information is only useful for a short period (i.e., for specific marketing campaigns) we may delete it.
13. CONFIDENTIALITY AND THE SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorized access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
All of our partners, employees, consultants, workers and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.
14. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS
You have the following rights in relation to the personal information we hold about you:
Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
§ relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
§ processing your personal information for direct marketing purposes.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant Supervisory Authority or Privacy Commissioner.
15. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS
The Site may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as Watt Agencies has no control over information that is submitted to, or collected by, these third parties