As of March 1, 2022
This Privacy Policy applies to TROIS Collective Inc. and its affiliates (collectively, “TROIS” or “we” or “us”) concerning activities that are subject to federal and Ontario privacy legislation.
This Privacy Policy addresses information about identifiable individuals who are our clients, third-party service providers and suppliers, users of our website (the “Site”), and other individuals with whom we may engage or transact (“Personal Information”) except for:
Business contact information;Information that is publicly available and recognized as such under applicable privacy legislation; andInformation that does not otherwise fall within the meaning of personal information under applicable Canadian federal and Ontario law.As of March 1, 2022
- Business contact information;
- Information that is publicly available and recognized as such under applicable privacy legislation; and
- Information that does not otherwise fall within the meaning of personal information under applicable Canadian federal and Ontario law.
For greater certainty, this Privacy Policy does not apply to information collected, used, or disclosed concerning corporate or commercial entities, or Personal Information of TROIS’ employees (which is governed by a separate TROIS Employee Privacy Policy).
By providing us with your Personal Information and/or using our Site, you accept this Privacy Policy and consent to its terms, as well as any other terms described to you when your Personal Information is collected and in our engagement arrangements with you. If you do not consent, please do not use the Site or otherwise provide your Personal Information to us.
TROIS reserves the right to modify or amend this Privacy Policy from time to time. Please refer back to this Privacy Policy regularly to ensure you know our then-current Privacy Policy.
Collection of Information
Personal Information
TROIS collects Personal Information verbally, by written correspondence, through the Site, in documents provided to us, and occasionally by survey. Personal Information is usually collected directly from our clients. However, Personal Information may also be obtained from other sources during the course of our work; for example, from:
- Other parties to a transaction or matter for which you have retained us;
- Government agencies or registries; and
- Accountants, business advisors, and other consultants.
By implication, our clients consent to the collection of Personal Information that is useful and necessary for the provision of our legal services and advice on the matters for which we have been retained.
To the extent that you provide Personal Information of another individual to TROIS, you represent that you have the necessary consent or authority to permit us to collect, use, and disclose such Personal Information for the purposes set out in this Privacy Policy.
Technical Information
We may use the following technologies and collect the following information that is automatically generated by your use of the Site and recorded by the standard operation of our Internet servers (collectively, “Technical Information”). Technical Information is generally used on an aggregate and anonymized basis that it is not linked to an identifiable individual. If we do use such information to identify an individual, we will treat it as Personal Information in accordance with this Privacy Policy.
- Log Files: Log files make a record of each visit to the Site and log a number of details, including: your operating system; the date, time, and duration of the visit; the pages and documents accessed; and the previous site accessed by you (such as the search engine that referred you to the Site). Such information is collected for aggregated statistical purposes only, such as to track the number of visits to the Site, the number of views to particular pages, time-based traffic patterns, and the proportion of visitors using certain devices. TROIS will not attempt to identify users according to their browsing activity through such records.
- Device Identifiers: A device identifier, such as an IP address, is a distinctive number associated with a device. We may use your device identifier to identify you when you visit the Site to determine repeat visitors and detect and prevent fraudulent activity. By using device identifiers to approximate geographic location (to a city level), we can determine your approximate time zone, and better understand the locations of users.
- Cookies: Cookies are small text files stored on your computer that identify your IP address to our computers each time you visit the Site. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them). We may use cookies to collect and store certain information that details your preferences, in order to facilitate a more personalized browsing experience. We may also use cookies to collect aggregated statistical information, similar to that collected through log files. You can disable or block cookies by following the instructions on your web browser. While you do not need to enable cookies to visit the Site, certain features of the Site depend on the use of cookies. Accordingly, if you choose to block cookies you may not be able to use those features or may lose preferences based on those cookies.
- Web Beacons: We may use web beacons, also known as pixel tags, clear GIFs, or other similar technologies in connection with some of the Site pages and HTML-formatted email messages. This allows us to track the actions of users and email recipients, and compile statistics about our Site and email response rates. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can disable or block cookies as noted above. If you turn off cookies, web beacons (or similar technologies) will still detect visits to these pages, but the notices they generate cannot be associated with other cookie information and are disregarded.
- Analytics: We use Google Analytics to provide statistics about the visitors to the Site. Google Analytics tracks and analyzes non-personally identifiable statistical information, including, without limitation, search engines, display advertising, pay-per-click networks, email marketing, and digital collateral such as links within PDF documents. For more information about Google Analytics, including instructions on how to control the information collected by Google, see: https://policies.google.com/technologies/partner-sites.
On an aggregate basis and in a non-personally identifiable form, Technical Information is used for the following purposes: (a) for Site and system administration purposes; (b) to improve the Site; (c) to conduct internal reviews of the number of visitors to the Site; (d) to help us better understand visitors’ use of our Site; (e) to respond to specific requests from our visitors; and (f) to protect the security or integrity of our Site when necessary.
Limits on Collection of Personal Information
We will not collect Personal Information indiscriminately or for no reason, and we will limit the collection of Personal Information to the purposes to which you have consented through this Privacy Policy or otherwise. As noted above, TROIS also collects Personal Information as authorized or required by law, and by our insurers.
The Site and our legal services are intended for and directed to individuals who are the age of majority or older in their jurisdiction of residence. We do not knowingly collect Personal Information of minors. However, if a minor (as defined by applicable law) provides us with their Personal Information without parental or legal guardian consent, we encourage the parent or legal guardian to contact us to have this Personal Information removed from our records.
Purposes of Collection Use and Disclosure of Personal Information
TROIS’ team members, collect, use and disclose Personal Information for purposes authorized or required by applicable federal and Ontario privacy legislation and, specifically, for the following purposes:
The Site and our legal services are intended for and directed to individuals who are the age of majority or older in their jurisdiction of residence. We do not knowingly collect Personal Information of minors. However, if a minor (as defined by applicable law) provides us with their Personal Information without parental or legal guardian consent, we encourage the parent or legal guardian to contact us to have this Personal Information removed from our records.
- To provide our consulting services and advice and to facilitate the provision of anticipated future consulting services and advice;
- To establish, maintain, and enhance our client and supplier relationships, including providing updates that we believe to be of relevance to our clients and sending holiday cards, professional development or other event invitations, alumni newsletters, and other greetings from TROIS;
- to avoid conflicts of interest;
- to satisfy our records retention requirements;
- to share information with third parties for the purpose of providing our services and advice, including data and information technology service providers, cloud-based service providers, other suppliers of products and services ancillary to the provision of our consulting services and, in the case of litigation, opposing counsel, foreign counsel, witnesses, and experts;
- To manage and develop our business, operations, and strategic planning;
- To detect and protect TROIS, our clients, you, and others from error, negligence, fraud, or other illegal activity, which may include providing Personal Information to insurers, auditors, investigators, or regulatory authorities;
- To issue invoices, process payments and collect debts owed to us; and
- To comply with other legal and regulatory requirements.
The above collections, uses and disclosures are a necessary part of our relationship with our clients and our third-party service providers and suppliers.
Disclosure of Personal Information
TROIS will disclose Personal Information to a third party without express consent, such as when required or authorized by law (if permitted with disclosure to you) (for example, if a court issues a subpoena), or where the services you have retained us to provide require us to give Personal Information to a third party (for example, to a medical benefits broker or vendor, etc.). TROIS will also disclose Personal Information with the consent of the affected individual or consent of another person authorized to provide that consent.
Safeguarding Your Personal Information
TROIS takes all reasonable precautions to ensure that Personal Information is safe from loss or theft and from unauthorized copying, use, access, modification, or disclosure. Such measures, which may necessarily evolve over time as the availability and effectiveness of methods vary, include physical, organizational, and technological safeguards, such as:
- Restricting access to certain but not all Personal Information to a limited set of our team members and third-party service providers and suppliers who need such information in order to facilitate the use of the information, and who are required to abide by this Privacy Policy and our privacy and security policies;
- Restricting access to our systems, electronic databases, or other electronic formats that may contain Personal Information through password protection and internal security policies; and
- Implementing technical security measures such as firewall technology, anti-malware screening, and data encryption technology.
We may exchange electronic versions of documents and emails with you and may maintain and process Personal Information using commercially available software and electronic systems. Unfortunately, the available technology is vulnerable to attack by viruses and other destructive electronic programs and may be intercepted or interfered with by third parties. We cannot guarantee that all electronic communications and documents will always reach the intended recipient, will always be virus-free, and will never be intercepted or interfered with by third parties, and we make no representation or warranty with respect to any electronic communications or documents. You consent to our exchanging electronic communications, including those containing confidential documents and other confidential information, unencrypted. In addition, while we routinely assess and monitor the security of our electronic systems and adopt safeguards intended to protect and prevent unauthorized access to and use of our electronic systems, we make no representation or warranty with respect to the security of electronic communications or our systems.
We make every effort to use the right technology for the efficient delivery of our services. We may use collaborative technologies, artificial intelligence, machine-learning document analysis, electronic signatures, etc. in connection with the provision of our services to our clients (sometimes managed internally and sometimes involving cloud-based systems). While we assess and monitor the security of our cloud-based third-party service providers, we make no representation or warranty with respect to the security of their systems.
When TROIS provides Personal Information of clients to third-party service providers or suppliers for the processing of data (e.g. for contracted services such as photocopying, printing, scanning, computer backup services, etc.) or to other third-party service providers or suppliers in respect of the services we are providing to our clients, we will ensure that those third parties agree to only use the Personal Information for the specified purposes, and to provide a level of protection to the Personal Information comparable to that adopted by TROIS.
Links to Other Websites
Our Site may provide links or references to websites operated by third parties. These links or references are provided solely as a convenience to you and not as an endorsement by TROIS. We are not responsible for the content of linked third-party sites and do not make any representations regarding the content or accuracy of materials on such third-party sites. If you decide to access linked third-party sites, you do so at your own risk. This Privacy Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies, or actions of third parties. In visiting any third-party websites, whether linked to this Site or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding and do not endorse, any third-party website or any content on such website. We encourage you to review the privacy policies of each website visited before using those websites or disclosing any Personal Information to third parties.
Access to Personal Information
You may have access to your Personal Information held by TROIS to the extent required by law. Individuals may write to or email our Privacy Officer at the address below to request access to Personal Information held about them. Upon written request and authentication of identity, we will comply with our legal obligations to provide you with your Personal Information under our control, information about how that Personal Information is being or was used, and a description of the individuals and organizations to whom that Personal Information may have been disclosed.
We may charge a reasonable fee for providing Personal Information in response to an access request and will provide an estimate of any such fee upon receiving an access request. We may require a deposit for all or part of the fee. We will make the Personal Information available within 30 days or provide written notice where additional time is required to fulfill the access request.
In some situations, we may not be able to provide access to certain Personal Information. For example, access would be denied if disclosure would reveal Personal Information about another individual, the Personal Information was collected for the purposes of an investigation, or disclosure of the Personal Information would reveal confidential commercial information that, if disclosed, could harm TROIS or any of its former, current or potential clients. There are also circumstances where TROIS may be prevented by federal or Ontario law from providing access to certain Personal Information.
If a request for access to Personal Information is denied, TROIS will provide an explanation of the reasons for such refusal.
Accuracy and Correction of Personal Information
We make reasonable efforts to ensure that the Personal Information we collect, use, or disclose is accurate and complete. In most cases, we rely on you and/or our client to ensure that the Personal Information provided to us is current, complete, and accurate.
If you demonstrate to us the inaccuracy or incompleteness of your Personal Information, we will amend the Personal Information as required. If appropriate under the circumstances, we will send the amended Personal Information to third parties to whom the Personal Information had previously been disclosed. If a request to correct the accuracy of Personal Information is not resolved to your satisfaction, we will annotate the Personal Information under our control with a note that the correction was requested but not made.
If you have any questions or concerns about this Privacy Policy or TROIS’ Personal Information management practices or records retention policies, please write to our Privacy Officer at:
Privacy Officer
TROIS Collective Inc.
150 King Street West, Suite 200
Toronto, Ontario M5H 1J9
e-mail:
privacyofficer@troiscollective.com
