We, at TOEMA SUPPLY SERVICES INC. (hereinafter TOEMA) recognize the importance of client privacy and the sensitivity of the personal information that we may have concerning any individual. We have a professional and ethical obligation to keep confidential all information we receive from the client subject to the client’s instructions to provide our services. Further, we are committed to safeguarding the personal information we have or control concerning any individual.

Your privacy rights

TOEMA manages your personal information in compliance with the existing federal privacy laws.

Why we collect personal information

We collect personal information for the purposes of serving the business needs of our customers. We require information to:

• Understand and assist you, our client,
• Ensure information is accurate and up-to-date,
• Structure our targeted approach to your needs while providing our services.

What personal information do we collect?

Personal information is any information that identifies you. In Canada in general most of the business contact information such as your office address, job title, business phone number, email address, fax number or other related business contact information is not considered personal information. We follow reasonable and prudent business practices to collect use and disclose your personal information for the purpose of providing you with our business services.

How do we collect your personal information?

We collect information only by lawful and fair means. When we make directed individual requests for your relevant sensitive personal information from a particular organization or business, we will obtain your written consent. Wherever possible we collect your personal information directly from you. We may ask you for your consent, at the point of your initial contact and during the course of our relationship. Your consent may be in writing, verbal or implied as necessary to further your needs.

Dependent on the services provided, with your consent, we may obtain this relevant information from:

• You and your dependent family members
• Educational institutions (to verify your educational history)
• Your employer (for example, evidence for background assessment)
• Law enforcement (if relevant or according to specific regulations)

Consent

Our practice is to request either your written or express oral consent, which may be given in person or over the telephone if your identity is authenticated.

If you volunteer to provide relevant personal information verbally or in writing, we assume that you are consenting to the collection, use and disclosure of your personal information as described in this Privacy Statement, or, when you initiate contact with us, we may determine that consent has been implied for us to collect, use and disclose personal information in a reasonable manner.

There are certain circumstances where we are required or permitted by law, to collect, use and disclose personal information without consent. We will handle all personal information confidentially and will substantiate the legal authority to collect, use and disclose personal information in these circumstances.

Disclosure without consent

Under certain circumstances, we will disclose your personal information without your consent:

• when we are required or authorized by law to do so, for example if a court issues a subpoena;
• when the use of the information is necessary to respond to an emergency that threatens the life, health or security of an individual or the public;
• when it is necessary to establish or collect our fees; or
• when the information is already publicly known.

Use of your information

We use your personal information to provide our business services to you.

We generally use Personal Information for the following practical purposes:

• providing services, either directly to you or through third parties;
• replying to your comments, questions and inquiries;
• meeting certain legal requirements.

We may also use the Personal Information we obtain to provide you with company information, such as email notifications, newsletter subscriptions or other information which may be of interest to you. You may at any time withdraw your consent by notifying us, and we will not send you any such material.

We do not disclose or sell your personal information or business contact information to any third party to enable them to market their products and services.

Who do we release information to?

When we release information about you, it is done to serve specific needs, in the course of providing our services. With your consent, we may provide information to:

• Our staff who use the information to for the reasonable business purpose of providing you with our services;
• To a third party we contract to provide administrative services to our organization (like computer back-up services or archival file storage) and the third party agrees to comply with our privacy policy.

Accuracy of your information

You have the right to request a correction of the personal information that we hold about you. We rely on you to provide us with accurate and up-to-date personal and business contact information and to maintain contact with you. If during the course of our professional relationship, any of your information changes, please inform us so that we can make any necessary changes.

How do we protect your personal information?

In order to protect your personal information, we will:

• Not collect, use or disclose your personal information for any purpose other than those we identify to you or are reasonably evident.
• Only disclose your personal information to those persons who have a need to know your personal information for the purposes stated in this Privacy Statement.
• Keep your personal information only for as long as needed it to fulfill the stated purpose or as required by law.
• Maintain your personal information in as accurate, complete and up-to-date a form as possible.
• Keep your personal information physically secure, for example, in secure offices, rooms and/or filing cabinets.
• Maintain technological safeguards such as passwords or encryption for your sensitive personal information.

Access to your personal information

You may request access to the personal information we have about you. The request must be in writing and directed to the TOEMA’s Chief Executive Officer. We will charge a reasonable fee for retrieval and copying of your personal information. If the retrieval or copying or your request is extensive, we will notify you of the fee prior to retrieval and copying.

Can I be denied access to my personal information?

There are exceptions to your right to access your personal information. By law, we must deny access when:

• your file contains personal information on a third party and the information cannot be severed to maintain the privacy of the third party information;
• required or authorized by law (for example, when a record containing personal information about you is subject to a claim of legal professional privilege by one of our other clients).

We have the right to deny access to your information and may deny access when your information relates to existing or anticipated legal proceedings against you, including unpaid bills to the TOEMA.

If we deny your request for access to, or refuse a request to correct information, we shall explain why. In all cases we will attempt to mediate a resolution if possible.

Communications by email

E-mail is not a secure, confidential method of communicating your confidential and personal information with us. We will not use email to send personal or confidential information unless you authorize this form of communication by sending us and accepting our correspondence via email, and accept all the inherent risks associated with this type of communication.

Third-party websites

Our web-site or other commercial materials may contain links or references to third party websites and/or other information sources. TOEMA content related to our web-site and/or the services may also be made directly available on third party websites. Please be aware that these third party websites and/or materials are not governed by this Privacy Policy and that your Personal Information may not be protected on such third party websites. We encourage you to read the privacy policies applicable to every website you visit.

Changes to this privacy statement

We may review and change our Privacy Statement from time to time in order to update our privacy commitment to you in keeping with current privacy laws.

Contact information and resources

Please contact us, if you:

• Wish to access your personal information
• Wish to change your consent regarding the manner in which we collect, use and disclose your personal information as outlined in our Privacy Statement.
• Have concerns about our privacy policies or how we’ve handled your personal information