Sense & Purpose

This Privacy Policy establishes rules to govern the collection, use and disclosure of personal information collected by S&P Inc. (“S&P”) from its customers and website users in the course of business, in compliance with federal and provincial privacy laws including the Canada Personal Information Protection and Electronic Documents Act (PIPEDA).

This Privacy Policy applies to all individuals whose personal information S&P collects, uses or discloses in the course of doing business. This includes individuals who are clients, website users and all individuals who are contract workers, contractors, and consultants to S&P. It is our policy to only disclose your personal information as required or authorized by law or as otherwise set out in this policy.

We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time. We will post the current version of this policy at: www.senseandpurpose.ca/privacy.

What is personal information?

For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person, but does not include a person’s name, title, business address or telephone number, as an employee of an organization. Where this Privacy Policy states that a list of items is “including”, the lists so described are meant to be examples and not exhaustive or exclusive.

This Privacy Policy applies to all personal information that is collected, used or disclosed by S&P on this website, in email, text and other electronic messages between you and S&P. S&P has designated a Privacy Officer to be accountable for the operation of this Privacy Policy. Individuals may question or report any privacy concerns, breaches, violations or compliance issues to S&P’s Privacy Officer at the address indicated below.

If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact S&P’s Privacy Officer hello@senseandpurpose.ca for guidance or clarification.

What personal information do we collect?

S&P collects and uses only the personal information that we need for providing services and operating our business. Generally, S&P collects the following personal information from individuals for the various purposes set out below:

name,
address, email address (work or home),
age, date of birth,
preferences,
comments

S&P collects, uses and discloses personal information for the following purposes:

to manage S&P’s business and operations, including customer relationships and matters;
to present our website and its content to you;
to carry out our obligations and enforce our rights arising from any contracts with you; and to meet legal and regulatory requirements;
to inform individuals about S&P’s products and services that we believe may be of interest to them or that you request from us;
to fulfil the purposes for which you provided the information or that were described when it was collected, or another other purpose for which you provide it;
to better understand an individual’s interests in our products and services;
to deliver, develop, enhance or improve products and services;
to evaluate suitability of candidates;
to provide information on future opportunities;
to verify access rights to our website;
to contact clients about appointments and meetings;
to meet regulatory requirements;
to conduct market research; and
to enforce our legal relationship with you; and
is necessary in contemplation of a business transaction.

We normally collect information directly from our clients. We may collect your information from other persons with your consent or as authorized by law. Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent.

In addition, we also receive and send data from our servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our site, if any. We may use tracking technologies in a variety of ways, including the following: keeping count of return visits to our site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best.

Finally, your Internet browser has a feature called “cookies,” which stores small amounts of data on your computer about your visit to our site. Cookies tell us nothing about who you are, however, unless you specifically give us personal information. You do not need to have cookies turned on to visit www.senseandpurpose.ca. You may also elect not to allow cookies to be collected by selecting certain options on your browser.

Consent

Ordinarily we ask for consent to collect, use, or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

You may withdraw consent to the use and disclosure of personal information at any time unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.

The purpose for collecting personal information is set out in this policy. Any necessary consents shall be obtained before personal information is collected, used, or disclosed.

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button).

In cases that do not involve sensitive personal information, we may rely on “opt-out” consent.

The amount and type of personal information collected by S&P shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law.

Personal information collected by S&P or on behalf of S&P will be sent to S&P’s head office in Toronto, Ontario and will be subject to the laws of Canada.

How do I obtain access to my personal information?

Upon request received by S&P in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information held by S&P should be directed to S&P’s Privacy Officer.

Requests must be made in writing or by e-mail. Individuals may be required to verify their identity to access their personal information. Any such documentation provided shall be used for verification purposes only.

S&P responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation.

A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee.

Requested information will be provided in a form that is generally understandable.

S&P will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has disclosed information, S&P will provide a list of organizations to which it is likely to have disclosed information.

Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from S&P, individuals wishing to view an original record will do so at S&P’s head office and under the supervision of designated S&P personnel.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Limitations on Access

S&P will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.

In the event that S&P refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. S&P will respond to your requests for access in accordance with applicable privacy legislation.

How will my personal information be maintained?

Personal information shall be kept as accurate, complete, and up to date as necessary for the purposes for which it is to be used. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by S&P and have it amended as appropriate.

Individuals seeking a correction or amendment to their personal information should direct their requests in writing to S&P’s Privacy Officer.

All formal requests to amend personal information must be accompanied by appropriate supporting documentation. S&P’s Privacy Officer will manage any exceptions. The amended information will be transmitted to third parties, as appropriate. If the individual is not satisfied with the results of the request, S&P shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.

How is my personal information stored and secured?

Personal information will be retained only as long as necessary to fulfill the purposes we collected it for and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render client personal information non-identifying or destroy records containing personal information once the information is no longer needed. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.

Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.

Please note that we use cloud-based services to store information in Canada. Where personal information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies.

We will notify all required authorities including the Office of the Information and Privacy Commissioner of Canada, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.

Challenging Compliance

Inquiries or complaints concerning compliance with this Privacy Policy should be addressed, in writing, to S&P’s Privacy Officer.

If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your Provincial Privacy Commissioner, as applicable.

Questions and Complaints

If you have a question or concern about any collection, use or disclosure of personal information by S&P, or would like to request access to your own personal information, please contact S&P’s Privacy Officer by email at hello@senseandpurpose.ca. We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

Privacy Policy

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