CANRICH
CORPORATION PRIVACY CODE
Introduction To The Code
On January 1, 2004,
Canadian federal privacy legislation, and in some cases provincial privacy
legislation, will apply to provincially incorporated and regulated entities
that collect, use and disclose information about identifiable individuals in
the course of business and commercial activities. Canrich Corporation (“Canrich”) is required
to comply with the requirements of such legislation as of
This Privacy Code deals
with the collection, use, disclosure and protection of personal information by
Canrich. It also deals with the rights that each individual who is a Canrich
customer has to gain access to personal information that Canrich has about him
or her, and to have that information corrected if it is inaccurate.
Canrich is committed to
protecting the privacy and safeguarding the personal data and information of
individuals who are its customers. In merging its respect for each individual’s
privacy with its business objectives, Canrich has adopted the ten Privacy
Principles outlined below. Canrich limits the collection of personal
information from individuals to that which is permitted by law and which is
necessary to provide training, products and services with respect to the Canrich
Private Wealth Building SystemTM software. Periodically, Canrich may
ask for feedback from customers on products or services that Canrich is
providing or is considering providing.
There are situations
specific to the Canrich business where service and product providers, such as
Canrich, will disclose personal information to third parties in order to
provide effective and efficient services to their customers. For example,
personal information may be disclosed to:
● Service Providers: businesses such as real time data suppliers,
processors and record keepers that provide other goods and services with
respect to TSX Inc. and other marketplaces.
Canrich will only disclose
to such third parties the personal information of Canrich customers that these
service providers require in order to fulfil their service obligations to
Canrich and hence to Canrich’s customers. Every such disclosure will be made
subject to specific protection measures.
In addition, Canrich may
identify products or services that it believes to be of value to current, past
and prospective customers and to inform you of these products or services. If
you would prefer that Canrich does not use your personal information for this
purpose, please advise us by writing to the Privacy Officer at our
Canrich has prepared a
detailed Privacy Code expanding upon the following ten Privacy Principles to
ensure that your privacy is protected. If you would like a copy of this Privacy
Code, you may print this page or call us at 204-219-1576.
Canrich is accountable for
maintaining and protecting personal information that it has collected. A
Privacy Officer has been designated to ensure Canrich’s compliance with the
principles described in this Privacy Code.
Canrich will identify the
purpose of all personal information collected by it at the time of, or prior
to, the information being collected.
The knowledge and consent
of Canrich’s customers are required for the collection, use, or disclosure of
personal information, except as permitted by law or for security reasons.
The collection of personal
information will be limited to that which is necessary for the purposes
identified by Canrich. Information will be collected only by fair and lawful
means.
Canrich will not use or
disclose personal information for purposes other than those for which the
information was collected, except with the consent of the subject customers or
as may be permitted by law. Canrich will retain personal information only as
long as is necessary for the fulfillment of those purposes.
Canrich will maintain
personal information in an accurate, complete, and timely manner as is
necessary for the purposes for which it is to be used.
Canrich will protect
personal information with security safeguards appropriate to the sensitivity of
the information.
Canrich will make readily
available to its customers specific information about its policies and
practices relating to the management of personal information.
Upon making a request in
writing to our Privacy Officer, Canrich Corporation,
A customer may inquire
about or challenge Canrich’s compliance with these principles by contacting our
Privacy Officer.
The following definitions
apply to the Canrich Corporation Privacy Code:
“customer” — a person (an
identifiable individual) about whom Canrich collects information in carrying
out its computer software, information provision and customer service business.
This includes persons who have dealt with or intend to deal with Canrich, and
any other person who has contacted Canrich and provided his or her own personal
information to Canrich. This definition is intended to include both customers
and potential customers of Canrich.
“collection” — the act of gathering,
acquiring or obtaining personal information from any source, including from
third parties, by any means.
“consent” — voluntary agreement with
what is being done or proposed. Consent
can be either express or implied. Express consent is given explicitly, either
orally or in writing. Express consent is unequivocal and does not require any
inference on the part of Canrich seeking consent. Implied consent arises where
consent may reasonably be inferred from the action or inaction of the customer.
“control” — Canrich controls
personal information if the personal information is in the possession of
Canrich or a person to whom Canrich has disclosed the personal information,
excluding a person to whom such disclosure was permitted by law.
“disclosure” — making personal
information available to others outside Canrich’s administration department for
which the personal information was or is collected.
“personal information” — data or
information about an identifiable customer.
This definition of “personal information” includes information about a
customer or about any other individual if the customer or other individual is
identifiable as the subject of the information, but does not include aggregate
information that cannot be associated with a specific customer or individual.
“Personal information” may include, but is not limited to an individual’s name,
social insurance number, address, telephone number, e-mail address, date of
birth, family status, marital status, occupation, assets, investments,
liabilities, income, credit rating, whether or not credit was extended or
refused to the individual, credit and payment records of the individual.
“Canrich” — includes Canrich
Corporation and Canrich Capital Corporation, both
“use” — the treatment and
handling of personal information within the Canrich business department for
which the personal information is collected.
Detailed
Explanation Of Privacy Principles:
Canrich is accountable for
maintaining and protecting any personal information it has collected. A Privacy Officer has been designated to
ensure Canrich’s compliance with the principles described in this Privacy Code.
The identity of the
individual designated by Canrich as its Privacy Officer will be available upon
request.
Canrich is responsible for
personal information in its possession, custody or control, including
information that has been transferred to a third party for processing. Prior to disclosing any personal information
to any third party, Canrich will use contractual or other means to provide a
comparable level of protection while the personal information is in the
possession, custody or control of a third party.
Canrich will identify the
purposes of the collection of all personal information collected by it at the
time of, or prior to, the actual collection of the information.
Identifying the purposes
for which personal information is collected at or before the time of collection
allows Canrich to determine the information it needs to collect to fulfill
these purposes. The identified purposes will be specified to the customer at or
before the time of collection, either orally or in writing.
When personal information
that has been collected is to be used for a purpose not previously identified,
such new purpose will be identified before use.
The consent of the customer will be required before personal information
can be used for that purpose, unless the new use of that information is
permitted by law.
The knowledge and consent
of the customer are required for the collection, use, or disclosure of personal
information, except as may be permitted by law or for security reasons.
Such consent is required
for the collection of personal information and the subsequent use or disclosure
of this information. Canrich will obtain consent for the use or disclosure of
the information at the time of collection.
In certain circumstances, consent with respect to the use or disclosure
may be sought after the information has been collected, but before its use for
a purpose not previously identified.
Canrich will make a
reasonable effort to ensure that the subject customer is advised of the
purposes for which the personal information will be used. To make the consent
meaningful the purposes must be stated in such a manner that the customer can
reasonably understand how the personal information will be used or disclosed.
Consent can also be given by an authorized representative (such as a legal
guardian or a person having power of attorney).
A customer may withdraw
his or her consent at any time, subject to legal or contractual restrictions
and reasonable notice. Canrich will inform the customer of the implications of
such withdrawal. Absent any such withdrawal, a customer’s consent is valid for
the length of time needed to achieve the identified purposes.
The collection of personal
information will be limited to that which is necessary for the purposes
identified by Canrich.
Information will be collected
only by fair and lawful means.
Canrich will not collect
personal information indiscriminately.
Both the amount and type of information collected will be limited to
that which is necessary to fulfill the purposes identified.
Canrich may obtain personal
information from customers through hard copy, electronic or other means or
media. Personal information will be
collected by fair and lawful means.
Canrich will not use or
disclose personal information for purposes other than those for which the
information was collected, except with the consent of the customer or as may be
permitted by law. Canrich will retain personal information only as long as is
necessary for the fulfillment of those purposes.
As regards any disclosure
to any third party service provider, only the provision of personal information
which is necessary for the provision of such services will be provided by
Canrich to such service provider. Every such disclosure will be made subject to
the protection measures specified
Personal information that
has been used to make a decision about a customer will be retained long enough
to allow the customer access to the information after the decision has been
made. Canrich is subject to legislative
requirements with respect to retention periods.
Canrich will maintain
personal information in such an accurate, complete, and timely manner as is
necessary for the purposes for which it is to be used.
The extent to which personal
information must be accurate, complete and up-to-date will depend upon the use
of information, taking into account the interests of the customer. Information
must be sufficiently accurate, complete and up-to-date to minimize the
possibility that inappropriate information may be used to make a decision about
the customer.
Canrich will not routinely
update personal information, unless such a process is necessary to fulfill the
purposes for which it was collected.
Personal information that is used on an on-going basis, including
information that is disclosed to third parties, should generally be accurate
and up-to-date, unless limits to the requirement for accuracy are clearly set
out.
Canrich will protect
personal information with security safeguards appropriate to the sensitivity of
the information.
The security safeguards
must protect personal information against loss or theft, as well as
unauthorized access, disclosure, copying, use, or modification. Canrich will
protect personal information regardless of the format or media in which it is
held.
The nature of the
safeguards will vary depending on the sensitivity of the information that has
been collected, the amount, distribution, and format of the information, and
the method of storage.
Canrich will make readily
available to its customers, specific information about its policies and
practices relating to the management of personal information.
Canrich will be open about
its policies and practices with respect to the management of personal
information. Customers are able to acquire information about Canrich’s policies
and practices through its publications, Website and by telephone.
Upon request in writing, a
customer will be informed of the existence, use and disclosure of his or her
personal information and will be given access to that information, except where
permitted by law. A Canrich customer will have the right to challenge the
accuracy and completeness of the information and have it amended as
appropriate.
Canrich will respond to a
written request for customer access within thirty (30) days after receipt of
the request. Canrich will allow the customer access to this information unless
to do so would:
• reveal personal
information about a third party;
• breach a
solicitor-client privilege;
• potentially threaten the
life or security of another individual;
• disclose personal
information collected to investigate a breach of an agreement or contravention
of law; or,
• reveal information
generated in the course of a dispute resolution process.
In addition, Canrich will
provide an account of the use that has been made or is being made of this
information and an account of the third parties to which it has been disclosed.
If such a request is denied, the customer will be given reasons for the denial.
Before Canrich provides an
account of the existence, use, and disclosure of personal information of a
particular customer, the customer may be required to provide sufficient
information to permit Canrich to provide an account of the existence, use and
disclosure of personal information. The
information provided will only be used for this purpose.
A customer may inquire
about or challenge Canrich’s compliance with these principles by contacting
Canrich’s Privacy Officer. Canrich has
procedures in place to receive and respond to complaints or inquiries about its
policies and practices relating to the handling of personal information. The
complaint procedures are easily accessible and simple to use.
Canrich will investigate
all complaints. If a complaint is found to be justified through either the
internal or external complaint review process, Canrich will take appropriate
measures, including amending its policies and practices, if necessary.