This policy governs our dealing with “personal information”. Generally speaking, personal information means any information that can identify an individual such as age, gender, home or cell telephone number, address, date of birth, education, family status, purchasing and spending habits, investments, tax returns, financial information, religion or ethnic background. In general, personal information does not include business contact information such as your name, title or position, business or business e-mail address, telephone or facsimile number and information available from public records.
NATURE OF INFORMATION COLLECTED: The nature of the personal information we collect and use is dependent upon the information and services requested. Subject to applicable law, it may include:
PURPOSES OF COLLECTING INFORMATION: We primarily collect, use and disclose personal information to serve our clients. Common purposes for which we collect personal information include:
When personal information has been collected and is to be used or disclosed for a purpose not previously identified, the new purpose will be identified and consent obtained prior to its use.
INFORMATION ABOUT SERVICE PROVIDERS: We may collect information about third-party agents, vendors and suppliers who provide goods, services and information to WaterStreet. This information would include name and contact information as well as any information (such as banking information) that we need to pay you for your services and other relevant information, such as experience and qualifications. This information is used to assess suitability for particular tasks, to contact them and to pay them for their services.
THIRD PARTY SERVICE PROVIDERS: To the extent we enter into arrangements with service providers to store, handle or process personal information on our behalf, such as for data processing, document storage, software support and offices and financial back room support, our policy will require such parties to provide comparable privacy protection while the information is processed or handled by them.
PRIVACY AND OUR WEBSITE:
Online Communications – You may choose to voluntarily submit personal information to us for the purpose of asking a question, obtaining information, reviewing or downloading a publication or attending an event. We use such personal information you provide only for the purpose for which you have provided it. If you have provided us with contact information in the past, we may combine the information with information submitted on the website. We provide an on-going opportunity to unsubscribe to contact from WaterStreet by telephoning 1-877-WSGROUP.
E-mail Communications – We may periodically send out e-mail communications to businesses and individuals in our contact database. If you do not wish to receive further materials from us you may ask us not to contact you for this purpose by telephoning 1-877-WSGROUP.
Links – Our website may contain links to other websites. Operators of such sites may also collect personal information. Please consult the privacy policies for such third party websites. WaterStreet is not responsible for the manner in which such third parties collect, use or disclose personal information.
CONSENT: We will obtain consent for the use, collection and disclosure of personal information, either express or implied. We assume that an individual has consented to our reasonable collection and use of personal information consistent with purposes for which the information was given when the individual initiates contact with us or voluntarily provides personal information to us. We also assume that clients who retain us consent to the reasonable collection, use and disclosure of their personal information to our staff and affiliates including without limitation, WaterStreet Family Capital Counsel Inc., for the purposes for which we were retained. We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given. If you provide personal information about another person to us, we assume you have the consent of that individual to enable us to collect, use or disclose their information as described in this policy. We will only provide information to third parties when we have authorization to do so or where legislation requires that we do so. All personal information is held in strict confidence. We do not make personal information available in any manner to third parties for any purpose such as advertising or other solicitation.
RETENTION: Personal information will be retained for as long as we consider necessary to ensure the accuracy of client records, to enable us to provide quality service and advice to clients and to account to regulatory authorities. When personal information is no longer required, it will be destroyed.
SAFEGUARDS: Personal information is protected with appropriate security precautions against loss, theft or unauthorized use whether on paper or electronically stored. Staff is trained to be aware of the importance of maintaining the confidentiality of personal information. Care is used in the disposal and shredding of personal information. Third party contractors who have access to personal information will be required to confirm that they follow appropriate privacy practices.
ACCURACY: We will make every effort to ensure that personal information is accurate, complete and up-to-date. It is your right to review the information we have on file and the use that has been made of that information. You may challenge the accuracy and completeness of the information and have it amended as appropriate.
YOUR ACCESS TO YOUR PERSONAL INFORMATION: You can ask to view your personal information by contacting our Privacy Information Officer (see below under Challenging Compliance). You can request that corrections be made where you can show that the information we possess is inaccurate.
Questions and concerns may be directed to:
Audrey L. Robinson