Last revised: February, 2019
This privacy statement explains what information we gather about you, what we use that information for and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.
Who this privacy statement applies to and what it covers
This privacy statement applies to Change Connect Inc. with registered office address at #600 – 15 Allstate Parkway, Markham, Ontario, and our affiliates and related entities (“Small and Mighty Summit")
We are committed to protecting your privacy and handling your information in an open and transparent manner.
This privacy statement sets out how we will collect, handle, store and protect information about you when:
providing services to you or our clients
you use “our Website” or
performing any other activities that form part of the operation of our business.
When we refer to “our Website” or “this Website” in this policy we mean the specific webpages of changeconnect.ca designated as Canada in the upper right hand corner, and to specific webpages with a URL commencing ‘www.changeconnect.ca’.
ChangeConnect.ca is comprised of various global, country, regional and practice specific websites, each of which is provided by Change Connect Inc..
This privacy statement also contains information about when we share your personal data with other members of the Change Connect Network and other third parties (for example, our service providers).
In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
About other areas of changeconnect.ca
Please note that the other country and regional websites contained within changeconnect.ca are provided by other entities within the Change Connect Network and are not provided by us. Such websites, as well as other websites that may be linked to this Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of these other websites before disclosing any personal information.
What information we collect?
In the course of providing services to you, or our client and performing due diligence checks in connection with our services (or discussing possible services we might provide), we will collect or obtain personal data about you. We may also collect personal data from you when you use this Website or through digital interactions with you.
We may collect or obtain such data because you give it to us (for example in a form on our Website), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.
The personal data that we collect or obtain may include but is not limited to: your name; age; date of birth; gender; e-mail address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); family circumstances (for example, your marital status and dependents); employment and education details (for example, the organization you work for, your job title and your education details); sales strategy-related information (for example your growth projection); your postings on any blogs, forums, wikis and any other social media applications and services that we provide; your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your: dietary requirements (for example, where Change Connect would like to provide you with lunch during a meeting), health (for example, so that we can make reasonable accommodations for you in our buildings, products and services) and sexual orientation (for example if you provide us with details of your spouse or partner).
The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you or our client, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
Where we are provided with personal data about you by our client, we take steps to ensure that the client has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the client has provided you with notice of the collection (and other matters) and has obtained any necessary consent for us to process that information as described in this privacy statement.
We understand the importance of protecting children's privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
How we use information about you?
Use of personal information to provide services to our clients
We will use your personal data to provide you or our client with services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, our client, other members of the Change Connect Network, our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services.
Because we provide a wide range of services to our clients, the way we use personal data in relation to our services also varies. For example, we might use personal data:
about a client’s employees to help those employees manage their business projections
about a client’s employees and customers in the course of conducting an audit (or similar activity) for a client
about a client’s employees and customers in the course of implementing new human resources or customer relationship management systems
To provide immigration assistance to an individual, either directly or on behalf of a client
To support a client in the course of a forensic investigation
Use of personal information for other activities that form part of the operation of our business
We may also use your personal data for the purposes of, or in connection with:
applicable legal or regulatory requirements
requests and communications from competent authorities
client account opening and other administrative purposes
financial accounting, invoicing and risk analysis purposes
client relationship purposes, which may involve: (i) sending you thought leadership or details of our products and services that we think might be of interest to you; (ii) contacting you to receive feedback on services; (iii) contacting you for other market or research purposes; or (iv) managing our own customer relationship management processes;
recruitment and business development purposes (for example testimonials from a client’s employees may be used as part of our recruitment and business development materials with that employee’s permission)
services we receive from our professional advisors, such as lawyers, accountants and consultants
data analytics to better understand your digital interactions with us
protecting our rights and those of our clients.
Use of personal information collected via our Website
In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
to manage and improve our Website
to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information about our products and services that may be of interest to you
to manage and respond to any request you submit through our Website.
The legal grounds we use for processing personal information
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data.
As a result, we use your personal data for the purposes outlined above because : (a) of our legitimate interests in the effective delivery of our services to you or our client; (b) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests; (c) of the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency or (d) the information is required in order to provide our services to you or our client.
To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us); (iii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iv) the processing is necessary for the establishment, exercise or defence of legal claims or (v) you have made the data public..
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.
If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail email@example.com.
Who we disclose your information to?
In connection with one or more of the purposes outlined in the “How we use information about you?” section above, we may disclose details about you to: other members of the Change Connect Network; third parties that provide services to us and/or the Change Connect Network; competent authorities (including courts and authorities regulating us or another member of the Change Connect Network); your employer and/or their advisers; your advisers; credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “How we use information about you?” section above.
Our Website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.
Please note that some of the recipients of your personal data referenced above may be based in countries outside of the Canada, whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. Where the recipient is not a member of the Change Connect Network, the adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.
Further details of the transfers described above and the adequate safeguards used by Change Connect in respect of such transfers (including copies of relevant agreements) are also available from us by contacting firstname.lastname@example.org.
We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date.
These measures include:
education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data
administrative and technical controls to restrict access to personal data on a ‘need to know’ basis
technological security measures, including firewalls, multi-factor authentication, encryption and anti-virus software
physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
How long we keep your information for?
We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law or professional standards; (iii) the end of the period in which litigation or investigations might arise in respect of the services or (iv) as directed by Change Connect's own internal retention policies or practices, the length of which may vary depending on the nature of the information that is held. Further, any copies of personal data stored in our electronic backups will be destroyed in accordance with that backup’s ordinary lifecycle.
You have various rights in relation to your personal data. In particular, you have a right to:
obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you
ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete
ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data
withdraw consent to our processing of your personal data (to the extent such processing is based on consent)
To the extent prescribed by applicable law, receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract)
object to our processing of your personal data.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please email or write to us at the address below:
Change Connect Inc.
15 Allstate Parkway, Suite 600
Markham, ON L3R 5B4
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
Right to complain
If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.