QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) Privacy Policy

QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) recognizes the importance of privacy and the sensitivity of personal information. As advisors we have an obligation to use reasonable efforts to keep confidential all information we receive within an advisor -client relationship. We are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy. If you have any questions or concerns about your privacy, please contact us, using the contact information at the end of this policy. Whenever you provide us with personal information, whether in writing, over the telephone, or online, you will be referred to this Privacy Policy. If you do not agree with our Policy, please contact us at the address given at the end of this Policy, we would be pleased to address your concerns. Your use of a QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) website constitutes acceptance of and agreement with this Privacy Policy, described below, including your agreement and consent to QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)’s use of such information as described in it.

Your Privacy Rights

From January 1, 2004, all businesses engaged in commercial activities in Ontario must comply with the Personal Information Protection and Electronic Documents Act (the “Act”) and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. These obligations extend to paralegals and paralegal firms, including QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR). The Act gives you rights concerning the privacy of your personal information.

QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and trained our paralegals and support staff about our policies and practices.

Why Does QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)Need Personal Information?

QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) provides greeting cards and similar products to a wide range of clients. If we did not collect and use your personal information we could not provide you with our services.

In certain limited situations involving commercial vehicles we may, after advising you of our intentions, disclose some of your personal information to your employer or ex-employer. We use your personal information for internal purposes. We do not share this information outside QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) except with our approved agents, who help us to provide the service(s) you have requested. All of our approved agents are required to provide a level of privacy protection comparable to that provided in this policy and are not permitted to use your information for any other purpose, such as to market to you. We do not sell, rent or trade in personal information.

What personal information do we collect?

“Personal information” is any information that identifies you, or by which your identity could be deduced. For example we routinely collect the names, postal addresses, telephone numbers, e-mail addresses, age, credit card numbers, driver’s licence numbers, offence related information and driving record histories of our clients. Please note that “personal information” does not include either aggregate information that does not allow an individual to be identified, information about your visit to our websites which is not linked to you, information about your computer’s operating system and web browser software (this technical information is verified to ensure that our websites are optimized to serve our customers) or, the name, title or business address or phone telephone number of an employee of an organization.

How do we collect your personal information?

We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect your personal information in an active fashion directly from you, at the start of a retainer and in the course of our representation.

Sometimes we may obtain information about you from other sources for example:
• from a government agency or registry;
• your employer, if we are acting for you, at its request;
• your lawyer or other professional advisor;
• passively by recording data on the history of your acquisition of services from us.

Consent

In most cases, we shall ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us.

Use of Your Information

We use your personal information to provide advice and services to you, to administer our client databases.
QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) does not disclose your personal information to any third party to enable them to market their products and services. Your consent to our use of your personal information can be withdrawn at any time by following the directions at the end of this policy.

QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) will retain your personal information for only the period of time which is reasonable under the circumstances, generally 1 year from the date of the final transaction on the file, and once your personal information is no longer required for the purposes discussed above, it will be deleted.

Disclosure of your Personal Information

Under certain circumstances, QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)will disclose your personal information:
• when we are 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 services we are providing to you requires us give your information to third parties your consent will be implied, unless you tell us otherwise;
• where it is necessary to establish or collect fees;
• 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;
• if we engage expert witnesses on your behalf;
• if we retain other advisors in other jurisdictions, on your behalf;
• if the information is already publicly known.

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 the retainer, any of your information changes, please inform us by contacting us as described at the end of this Privacy Policy so that we can make any necessary changes.

Is My Personal Information Secure?

QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• premises security;
• restricted file access to personal information to only those with a need to know;
• deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
• internal password and security policies;
• secure disposal of personal information no longer needed; and
• screening and training of personnel.
QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) cannot, however, guarantee that loss, misuse or unauthorized use will never occur (e.g. that someone will overcome our security measures). If you receive any electronic communication which purports to be from QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)that you have any questions or concerns about, please contact us. Spam, improper use, and pirating of domain names and email addresses is a growing problem, so we appreciate hearing about incidents in order that we may investigate them and provide you the best customer service.

Access to Your Personal Information

You may ask for access to any personal information we hold about you by contacting us as described at the end of this Privacy Policy. Summary information is available on request and we will attempt to respond to the request within 30 days of receipt. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees and may take longer to respond to.

Correcting Errors

QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)attempts to ensure that personal information is accurate, complete and up-to-date for the purposes for which it is used. If QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)holds information about you and you can establish that it is not accurate, complete and up-to-date, QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR)will take reasonable steps to correct it.

Can I be Denied Access to My 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;
• the information was generated as a result of a formal dispute resolution process including a court case;
• when granting you access would have an unreasonable impact on other people’s privacy, security or proprietary information;
• to protect our firm’s rights and property;
• where the request is frivolous or vexatious or generates costs which are prohibitively expensive.
If we deny your request for access to, or refuse a request to correct information, we shall do so in writing and explain why.

QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) does not use your Social Insurance Number as a way of identifying or organizing the information we hold upon you and will not record it even if you submit it.

Can I request anonymity?

Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website).

Communicating with Us

You should be aware that any channel of communication, such as e-mail, is not 100% secure, and you should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy

Since QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR) regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time without notice. A copy of all amendments will be on file at our offices.

Requests for Access

If you have any questions, complaints or wish to access your personal information, please write to our Chief Privacy Officer at:

Quality Spindles and Railings Ltd
36 St SE,
Calgary, AB
T2C 2J4

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:
112 Kent Street,
Ottawa Ontario, K1A 1H3
1.800.282.1376.

Web Site

For your convenience our website may contain links to other sites, which are not governed by this privacy policy. Our site may also be referenced on or accessible through links contained on other sites, including sites of third party e-procurement networks. However, we have not investigated, and are not responsible for, the privacy practices or content of those sites. Their policies and protections may be different than those offered QUALITY SPINDLES AND RAILINGS / QSR CANADA (QSR). We encourage you to investigate and review the privacy practices of those sites prior to use.

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.

When you interact with our websites, we may use a browser feature, known as a “cookie” (which is a small computer file), to verify non-identifiable information about visitors to our websites and measure visitor traffic patterns. We do this to maintain the best possible websites. When you first visit our websites, the website manager may have implemented a program that creates a small computer file stored on your computer’s hard drive. We ensure that the minimum information required is placed in the cookie only so that we can recognize returning website visitors. The cookie does not contain personal information and we will not combine information in the cookie with personal information that would enable us to identify you individually. On subsequent visits to the website, our server communicates with your computer, reads the cookie, recognizes and confirms that you are a returning visitor. Our server uses this information to provide you with a “short cut” that facilitates the quickest, most efficient and best possible website experience.
Most browser software allows you to delete cookies. You should consult your ISP for information on how to delete cookies. This may interfere with our ability to personalize your experience at our websites and be recognized, or may slow down performance.