Privacy Policy

Important legal information.

SPANL recognizes the importance of privacy and the sensitivity of personal information. We have an obligation to keep confidential all personal information we receive and hold. This Privacy Policy outlines how we manage personal information.

YOUR PRIVACY RIGHTS

From January 1, 2004, all organizations engaged in commercial activities must comply with the *Personal Information Protection and Electronic Documents Act* (the “Act”), unless the federal cabinet has exempted the organization because it is subject to “substantially similar” provincial legislation. To date, we are not subject to any such exemption orders.

SPANL is responsible for the personal information we collect, use, maintain and disclose. To ensure this accountability, we have developed this policy.

WHAT IS “PERSONAL INFORMATION?”

Personal information is any information about you, or by which your identity could be deduced. It does not include the name or business address or telephone number of an employee of an organization.

WHY DO WE COLLECT PERSONAL INFORMATION FROM YOU?

We collect personal information from you to:

provide services to you, in accordance with your instructions;
provide information to you about the investment climate and opportunities; and
advise you of developments at SPANL.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect information by lawful means only. We may collect personal information directly from you at the start of our association or during the course of our association with you.

Sometimes we may also obtain information about you from other sources, for example:

your professional advisers;
a government agency or registry; or
other consultants or individuals obtained by you or with your consent.
We may also collect personal information on our website (www.SPANL.ca). We only collect the information you provide to us voluntarily by sending us an e-mail message, completing forms or using the links contained on the website.

SPANL collects and uses your name, address, telephone number, email address and other information you submit on or through the website for the purposes for which you provided the personal information, to respond to your inquiries, and to provide you with updates and information that we think may be of interest to you. In providing SPANL with any personal information on or through this website, you consent to the collection and use of that information for these stated purposes. We currently do not use cookies on our website. (“Cookies” are small text files that recognize repeat visitors and track their visits to a website.)

On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

CONSENT

Consent for the collection, use and/or disclosure of personal information may be obtained orally or in writing and may be expressly given or implied. In determining how we obtain your consent, we will take into account the sensitivity of the personal information that we are collecting, using and/or disclosing.

USE OF YOUR INFORMATION

We use your personal information to provide services to you, or to otherwise interact with you. We may also use your personal information to include you in any direct marketing activities. We will assume that you have consented to such use unless you specifically advise otherwise. If you tell us that you no longer wish to receive information about our services or about new investment opportunities, we will not send any further material.

SPANL will not disclose your personal information to any third party to enable them to market their products and services without first obtaining express consent from you. For example, we do not provide our mailing lists to consultants we work with from time to time.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Under certain circumstances, we may disclose your personal information:

when you have consented to the disclosure;
when we are required or authorized by law to do so; for example, if a court issues a subpoena;
when the services we are providing to you require us to give your information to a third party, your consent will be implied, unless you tell us otherwise;
if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy; or
if the information is already publicly available.

UPDATING YOUR INFORMATION

Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If, during the course of our association with you, any of your information changes, please inform us so that we can make any necessary changes.

IS YOUR PERSONAL INFORMATION SECURE?

SPANL will take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. The steps taken to protect your information include:

office security;
restriction of access to electronically stored personal information;
deployment of technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access; and
internal password and security policies.

ACCESS TO YOUR PERSONAL INFORMATION

You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests that require archival or other retrieval costs may be subject to reimbursement of our retrieval expenses.

CORRECTING ERRORS

If SPANL holds information about you which we learn is not accurate, complete and up-to-date, SPANL will take reasonable steps to correct it.

CAN YOU BE DENIED ACCESS TO YOUR PERSONAL INFORMATION?

Your rights to access your personal information are not absolute. We may deny access when:

denial of access is required or authorized by law;
information relates to existing or anticipated legal proceedings against you;
when granting you access would have an unreasonable impact on other people’s privacy;
to protect our firm’s rights and property;
where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request to correct information, we will explain why. SPANL does not use your Social Insurance Number as a way of identifying or organizing the information we hold about you.

CREDIT BUREAUS

To help us make credit decisions about you, prevent fraud and prevent money-laundering, we may, on occasion, request information about you from the files of consumer reporting agencies.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required or necessitated by law, whichever is longer.

COMMUNICATING WITH US

You should be aware that email is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.

CHANGES TO THIS PRIVACY POLICY

Since SPANL regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. Please review our website for updates.

REQUEST FOR ACCESS

If you have any questions, or wish to access your personal information, please write to us, c/o our Privacy Officer.

INQUIRIES / COMPLAINTS

If you have any questions or concerns about how your personal information has, is or will be handled by SPANL or if you would like to register a complaint, please contact our Privacy Officer at:

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FOR FURTHER INFORMATION REGARDING THE ACT, PLEASE CONTACT:

Privacy Commissioner of Canada
112 Kent Street
Ottawa, Ontario, K1A 1H3
Tel: (613) 995-8210
Toll Free: 1-800-282-1376
Fax: (613) 947-6850