PRIVACY POLICY

Henderson Robb Marketing, and its partners ("Henderson Robb Marketing", "we" or "us"), are committed to maintaining the accuracy, confidentiality, and security of your personal information.  This policy explains how Henderson Robb Marketing collects, uses, discloses and safeguards the personal information provided to us either directly by you or by a third party.

For the purposes of this policy “personal information” means any information about an identifiable individual and includes name, address, home telephone number, marital status, liabilities, assets, income, banking records, health records, claims history and other information of a personal nature. Personal information will not include an individual's business address or business telephone number.

PRINCIPLES

As part of our commitment to treat your personal information with respect, Henderson Robb Marketing has adopted the following ten “fair information principles” that are included in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”):  

Principle 1 – Accountability
Henderson Robb Marketing is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the Henderson Robb Marketing’s compliance with the following principles.

Principle 2 – Identifying Purposes
The purposes for which personal information is collected shall be identified at or before the time the information is collected.

Principle 3 – Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Principle 4 – Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by Henderson Robb Marketing. Information shall be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure, and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Principle 6 – Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 – Safeguards
Security safeguards appropriate to the sensitivity of the information shall protect personal information.

Principle 8 – Openness
Henderson Robb Marketing shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Principle 9 – Individual Access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the Henderson Robb Marketing’s compliance.


POLICIES


1. PURPOSE

Unless the purposes for collecting personal information are obvious and you provide your personal information for those purposes, Henderson Robb Marketing will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.  Generally, Henderson Robb Marketing collects, uses, and discloses personal information (including to and from third parties) for the following purposes:

• to communicate with you;
• to answer any queries you have about Henderson Robb Marketing;
• to provide you with information that you have requested;
• to inform you about Henderson Robb Marketing;
• to personalize your experience and improve customer services;
• for statistical purposes and to manage and improve our website;
• to inform you about Henderson Robb Marketing services and solutions that may be of interest to you;
• to send you newsletters, videos, surveys, promotional mailings and other information (you can opt-out from these communications anytime by following the steps as described in the respective newsletter or promotional email);
• to investigate, adjust and administer claims;
• to investigate, detect and prevent fraudulent insured transactions; and
• as may be required or authorized by law.
   

2. CONSENT

Henderson Robb Marketing will obtain consent to collect, use or disclose personal information except where, as noted below, we are authorized to do so without consent.  Consent can be implied (such as when you provide your name and address in order for us to provide you with information and services), express (express consent may be oral, in writing or electronic), and in some jurisdictions may be given by your authorized representative (such as your lawyer, a legal guardian or a person having a power of attorney).

Implied consent is inferred from the circumstances, including the relationship between the parties and the nature of the interaction. When Henderson Robb Marketing handles sensitive personal information, Henderson Robb Marketing obtains express consent. Sensitive information includes medical information or financial records for claims involving personal injury or income loss. In these circumstances, the sensitive personal information may not be collected until a claim is made and it becomes necessary to obtain such information to determine entitlement to benefits.

In certain circumstances, as permitted or required by law, Henderson Robb Marketing may collect, use or disclose personal information without the knowledge or consent of the individual, such as where personal information is publicly available, where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way, to investigate a breach of an agreement or a contravention of a law, to act in response to an emergency that threatens the life, health or security of an individual, for debt collection or to comply with a subpoena, warrant or court order.
By providing information about a third party, such as a family member, director, officer, or employees, you represent that you have obtained that person’s consent to the collection, use and disclosure in accordance with this policy.

You may choose to withhold or withdraw consent, however, this may affect the ability of Henderson Robb Marketing to provide services. Where the withdrawal or withholding of consent prevents Henderson Robb Marketing from providing adequate customer service, Henderson Robb Marketing may be unable to process your claim for payment.


3. LIMITING COLLECTION OF PERSONAL INFORMATION

Henderson Robb Marketing will only collect from you (or other sources) personal information that is necessary for the identified purposes. Henderson Robb Marketing may gather such personal information from you in person, via the Internet, via email, over the telephone or by corresponding with you via mail, facsimile, or from third parties who have your authority to disclose such personal information to us.


4. LIMITING USE, DISCLOSURE AND RETENTION OF PERSONAL INFORMATION

Henderson Robb Marketing will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Henderson Robb Marketing retains personal information only as long as necessary to accomplish the identified purposes or satisfy our legal or business obligations.

Henderson Robb Marketing never sells personal information, or other information relating to you, to any organization, including charities or direct marketing groups.
Henderson Robb Marketing discloses or transfers personal information to third parties, including related or unrelated companies ("service providers"), that carry out certain functions on its behalf.  These service providers will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose than for delivering the service to Henderson Robb Marketing in accordance with Henderson Robb Marketing’s instructions and policies.

Henderson Robb Marketing may also disclose information about you to third parties, including the content of your communications, in order to: (a) comply with the law or respond to lawful requests or legal process; (b) protect the rights or property of Henderson Robb Marketing or our customers, including the enforcement of our agreements or policies; or (c) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of Henderson Robb Marketing employees, customers or the public. We may also disclose personal information as part of a corporate transaction such as a merger or sale of assets.

Some of your personal information will be stored on servers in Canada, but some data may be processed and stored by service providers that are outside of Canada.  Accordingly, your personal data may be transferred to and processed in locations outside of Canada.  In these situations Henderson Robb Marketing will ensure (by entering into a written agreement or otherwise) that an adequate level of data protection is maintained by the service providers outside of Canada in accordance with applicable law. However, such information is subject to the laws of the other countries, including the United States, and may be accessible to law enforcement and national security authorities of those other countries, including the United States.


5. ACCURACY
Henderson Robb Marketing will make reasonable efforts to ensure that personal information is as accurate, complete and up-to-date as is necessary for the identified purposes.  Individuals may request correction to their personal information in order to ensure its accuracy and completeness. 


6. SAFEGUARDS
Henderson Robb Marketing will protect personal information with safeguards appropriate to the sensitivity of the information. The methods of protection will include physical measures, organizational measures and technological measures. However, your use of the internet and electronic mail is at your own risk.


7. OPENNESS

Henderson Robb Marketing will make the following information available: how to gain access to personal information; the type of personal information held by Henderson Robb Marketing and what personal information is made available to related entities; general information concerning our policies respecting personal information; and how to contact our Privacy Officer.

This Privacy Policy may change from time to time. The most recent version of this Privacy Policy will govern Henderson Robb Marketing’s use of your information.  Your continued consent to our collection, use and disclosure practices and/or your continued access to our website following the posting of any changes to this Privacy Policy shall constitute your acceptance of those changes. 


8. INDIVIDUAL ACCESS

Upon written request and subject to limited exceptions (see below), Henderson Robb Marketing will inform you of the existence, use and disclosure of your personal information and give you access to that personal information.

If you would like to make such a request, please contact the Privacy Officer of Henderson Robb Marketing at the address below. Please note that Henderson Robb Marketing may charge reasonable costs in providing access to and copies of personal information and will inform you if such costs arise. Please also note that before Henderson Robb Marketing is able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavour to respond within an appropriate timeframe.

Henderson Robb Marketing may refuse a request or be unable to provide access to all the personal information as permitted or required by law. Examples include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.


9. CHALLENGING COMPLIANCE

If you have a complaint regarding our compliance with privacy legislation or this policy, you may contact us at:

ONLINE PRIVACY STATEMENT

What information do we collect?

Henderson Robb Marketing and its partners ("Henderson Robb Marketing ", "we" or "us") collect information from you when you register on our site, comment on our site, send us an email to an email address provided on our site or fill out a form.  When using our site, you may be asked to provide personal information, such as your name, email address, home or work address, or telephone number.  We may also collect demographic information, such as your postal code, age, gender, preferences, interest and favourites.  You may, however, visit our site anonymously.

We also collect information about your interaction with our website without identifying you as an individual.  For example, we receive standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring web site addresses.  We use technologies such as cookies (see more information below) to collect information about the pages you view, the links you click and other actions you take on our site and services. 

When you receive newsletters or promotional emails from us, we may use customized links or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information. 


What do we use your information for?

Any of the information we collect from you may be used in one or more of the following ways:

• To: (i) communicate with you; (ii) answer any queries you have about Henderson Robb Marketing; (iii) provide you with information that you have requested; and (iv) inform you about Henderson Robb Marketing.
• To personalize your experience and improve customer service. 
• For statistical purposes and to manage and improve our website. 
• To inform you about Henderson Robb Marketing services and solutions that may be of interest to you, and to send you newsletters, videos, surveys, promotional mailings and other information (you can opt-out from these communications anytime by following the steps as described in the respective newsletter or promotional email).  

How do we protect your information?

We use a variety of security technologies and organizational procedures to help protect your personal information from unauthorized access, use, or disclosure. 

The accessing and entering of information on Henderson Robb Marketing’s website by users takes place over the Internet which is an open and unprotected network. This data transfer takes place in non-encrypted form. When disclosing any personal information via an open network, you should be mindful that it is potentially accessible to others and consequently can be collected and used by others without your consent.  A third party may be able to trace a transaction, and/or your data may be lost during transmission or accessed by unauthorised parties. Henderson Robb Marketing does not accept any liability for direct or indirect losses as regards the security of your data during its transfer via the Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.


Do we use cookies?

Henderson Robb Marketing uses tracking technology such as cookies to gather connection data and to understand how users use our website.  A cookie is a small text file placed on your hard disk by a web server, which allows the web server to recognise your computer on connection to the Henderson Robb Marketing website, which in turn allows the server to make downloading of pages faster than on first viewing.

One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content and targeted advertising on your later visits to the website.  Cookies may also be used to establish statistics about the use of Henderson Robb Marketing’s website by gathering and analysing various data (e.g. most visited pages, time spent by users on visited pages).

Generally, you have the ability to accept or decline cookies by modifying your browser setting to decline cookies if you prefer.  If you choose to decline cookies, you may not be able to use certain features of our website that depend on cookies.  If you choose to accept cookies, you have the ability to delete cookies that you have accepted later.  If you choose to delete cookies, any settings and preferences controlled by those cookies will be deleted and may need to be recreated.


Do we disclose any information to outside parties?

Except as described in this statement, we will not disclose your personal information outside of Henderson Robb Marketing without your consent.  We will not sell, rent, distribute or otherwise make your contact or other data commercially available to any other third party, except with your prior permission.  Non-personally identifiable visitor information, however, may be provided to other third parties for marketing, advertising, or other uses.

Henderson Robb Marketing occasionally hires trusted third party service providers to help us conduct our business and to provide services to our customers and members.  These service providers will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose than for delivering the service to Henderson Robb Marketing in accordance with Henderson Robb Marketing’s instructions and policies.

We may also disclose information about you to third parties, including the content of your communications, in order to: (a) comply with the law or respond to lawful requests or legal process; (b) protect the rights or property of Henderson Robb Marketing or our customers, including the enforcement of our agreements or policies; or (c) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of Henderson Robb Marketing employees, customers or the public. We may also disclose personal information as part of a corporate transaction such as a merger or sale of assets.


Third party links

Occasionally, you will be able to obtain access to websites operated by third parties through Henderson Robb Marketing’s website.  These third party websites are not monitored or maintained by Henderson Robb Marketing and we do not endorse or accept any responsibility for their content or operation.  You access third party websites at your own risk. This Online Privacy Statement does not apply to those third party websites, so please read the privacy policy of each third party website prior to accessing or sending personal data to the site.


Data Storage and transfer outside of your country

Some of your data will be stored on servers in Canada, but some data may be processed and stored by service providers that are outside of Canada.  Accordingly, your personal data may be transferred to and processed in locations outside of Canada.  In these situations Henderson Robb Marketing will ensure (by entering into a written agreement or otherwise) that an adequate level of data protection is maintained by the service providers outside of Canada in accordance with applicable law.


Changes to This Privacy Statement

We will occasionally update this Online Privacy Statement.  The most recent version of this Online Privacy Statement will govern our use of your information and will always be available on Henderson Robb Marketing’s site.  When we post changes to this statement, we will revise the "last updated" date at the bottom of this statement. We encourage you to periodically review this statement to be informed of how we are protecting your information.


Your Consent

By using our site, or by using an email address provided on our site, you consent to the collection and use of your personal information as set forth in this Online Privacy Statement. 


Contacting Us

For more information about our privacy practices, go to the full Henderson Robb Marketing Privacy Policy. If you have any questions relating to the processing of your personal data, your privacy rights or this Online Privacy Statement, please contact us at:

Privacy Officer

Henderson Robb Marketing 401 Bay Street, Suite 1600, Toronto ON

M5H 2Y4 


Last update: March 17, 2016