YOUR PRIVACY RIGHTS
From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act, and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. The Act gives you rights concerning the privacy of your personal information.
CTL Leather is responsible for the personal information it collects and holds. To ensure this accountability, CTL Leather has developed this policy, and trained its staff about these policies and practices.
WHY DOES CTL LEATHER NEED PERSONAL INFORMATION?
CTL Leather provides products and services to a wide range of customers. In doing so, it may produce direct marketing materials concerning its products and services.
WHAT PERSONAL INFORMATION DOES CTL LEATHER COLLECT?
Personal information is any information that identifies you, or by which your identity could be deduced. If CTL Leather did not collect and use your personal information it could not provide you with products and services
HOW DOES CTL LEATHER COLLECT YOUR PERSONAL INFORMATION?
CTL Leather collects information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible, CTL Leather collects your personal information directly from you, at the start of your relationship with CTL Leather or employment with CTL Leather.
Sometimes CTL Leather may obtain information about you from other sources: example, from a government agency or registry, a prior employer, your accountant or your bank.
CTL Leather shall ask you to specifically consent, if it collects, uses, or discloses you personal information and shall request for your consent in writing. Sometimes, your consent may be implied through your conduct with CTL Leather.
USE OF YOUR INFORMATION
CTL Leather uses your personal information to provide products and services to you, to administer customer databases and to include you in any direct marketing activities. If you tell CTL Leather that you no longer wish to receive information about its products and services, or about new developments in the law, it will not send any further material.
CTL Leather does not disclose your personal information to any third party to enable them to market their products and services. For example, CTL Leather does not provide its customer mailing lists to other firms
DISCLOSURE OF YOUR PERSONAL INFORMATION
Under certain circumstances, CTL Leather will disclose your personal information:
- when it is required or authorized by law to do so, for example, if a court issues a subpoena;
- when you have consented to the disclosure;
- when the products and services it is providing to you requires it to give your information to third parties your consent will be implied, unless you tell us otherwise;
- if it engages consultants on your behalf;
UPDATING YOUR INFORMATION
Since CTL Leather uses your personal information to provide products and services to you, it is important that the information be accurate and up-to-date.
If, during the course of our relationship, any of your information changes, please inform us so that we can make any necessary changes.
IS YOUR PERSONAL INFORMATION SECURE?
CTL Leather takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modifications or disclosure. Among the steps taken to protect your information are:
- premises security;
- restricted file access to personal information;
- deploying technological safeguards to attempt to prevent hacking or unauthorized computer access;
- internal password and security policies.
ACCESS TO YOUR PERSONAL INFORMATION
You may ask for access to any personal information CTL Leather holds about you.
Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subjected to CTL Leather’s normal administration and disbursement fees.
If CTL Leather holds information about you and you can establish that it is not accurate, complete and up-to-date, CTL Leather 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. CTL Leather may deny access when:
- denial of access is required by law;
- information relates to existing or anticipated legal proceedings against you;
- when granting you access would have an unreasonable impact on other people?fs privacy;
- when to do so would prejudice negotiations with you;
- to protect CTL Leather rights and property;
- where the request is frivolous and vexatious.
If CTL Leather denies your request for access to, or refuses a request to correct information, it shall explain why.
CTL Leather does not use your Social Insurance Number as a way of identifying or organizing the information it holds upon you.
CAN YOU REQUEST ANONYMITY?
Whenever it is legal and practicable, CTL Leather may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on its website). The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires CTL Leather to confirm the identity of all new customers. It may also require CTL Leather to disclose information to FINTRAC in relation to certain large cash transactions.
To help us make credit decisions about customers, prevent fraud, check the identity of new customers and prevent money-laundering, CTL Leather may, on occasion, request information about you from the files of consumer reporting agencies.
COMMUNICATING WITH CTL LEATHER
You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting CTL Leather to send personal or confidential information.
REQUESTS FOR ACCESS
If you have any questions, or wish to access your personal information, please write to CTL Leather’s Privacy Contact at CTL Leather, 90 Carnforth Road, Toronto, ON, M4A 2K7, Attention: Management.
If you apply to CTL Leather for a job, it needs to consider your personal information as part of its review process. CTL Leather normally retains information from candidates after a decision has been made, unless they ask CTL Leather not to retain the information. If CTL Leather offers you a job, which you accept, the information will be retained in accordance with its privacy procedures for employee records.
Any website that CTL Leather has, from time to time, like most other commercial websites, may monitor traffic patterns, site usage and related site information in order to optimize its web service. CTL Leather may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.