Our Commitment to Privacy
What is Personal Information?
“Personal Information” is information about an identifiable individual. Personal Information includes but is not limited to your name, residential address, telephone number, fax number and e-mail address.
What Information Do We Collect?
Personal Information and Business Contact Information is collected by us only when you directly provide it to us, such as when you provide us with your contact information or send us a question or comment, when you meet with us in person, or when you phone us with an inquiry.
18.8 also collects certain technical usage information about visitors to our Platform through the use of Google Analytics and cookies (collectively, “Technical Data”). We do not attempt to decrypt any encrypted Technical Data and we do not use Technical Data to serve any targeted or online behavioural advertising to users. In addition, we will not use Technical Data (either individually or collectively with other data) to identify an individual.
You can opt out of Google Analytics without affecting how you visit our Platform. For more information on opting out of Google Analytics across all websites you use, visit this Google page:
For What Purposes Do We Collect Information?
We collect and use Personal Information in order to:
- respond to your communications and inquiries;
- meet legal, regulatory and security requirements under federal and provincial laws; and
We do not collect more Personal Information than we require for the purposes for which such information is being collected, unless we are required or permitted by law to collect additional information.
We will notify the individual from whom the information is collected of the purposes for which we are collecting the information. This notice will be provided at or before the time that we collect the Personal Information. Depending on the way in which the information is collected, this may be done orally or in writing.
Disclosure of Personal Information
When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will communicate the new purpose prior to using the information for the new purpose, unless the new purpose is required or permitted by law. We do not sell our customer lists or other Personal Information.
We may transfer your Personal Information as an asset in connection with any contemplated or actual sale, merger or other disposal of all or part of our business or assets, or as part of a corporate reorganization or other change in corporate control, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In such circumstances, we will ensure that any transfer of Personal Information is subject to applicable law and reasonable data protection security protocols.
Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.
Personal Information of Minors
We do not knowingly track, collect, use or disclose the Personal Information of anyone under the age of 18, without the consent of a parent or legal guardian. However, we cannot always determine the age of persons who access and use our Platform. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or legal guardian to contact us to have this information removed from our records.
Security, Retention and Disposal of Personal Information
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education.
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.
While 18.8 employs advanced data encryption technology when interfacing with our users, Authorized Service Providers and other partners, you should be aware that there is a residual risk in transmitting any data electronically. Despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. This risk is inherent in all Internet dealings.
Processing and Storage of Personal Information
Your Personal Information may be transferred to, processed and/or stored in a foreign jurisdiction outside of the jurisdiction in which it was originally collected. As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction.
Links to Other Websites
Correcting Your Personal Information
We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information.
Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed by contacting our Privacy Officer as set out below.
Access to Personal Information
If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information.
You may contact our Privacy Officer at the contact information below to request access to Personal Information that we have about you. We will respond to requests within 30 days.
Questions and Further Information