PRIVACY POLICY

NEGLIA DESIGN INC.
Currency: January 31, 2018

At NEGLIA DESIGN INC. (“Neglia Design”, “we”, “our” or “us”), we are committed to protecting the privacy and the confidentiality of personal information of our customers (“Customers”). In order to comply with applicable privacy legislation and to instil confidence in our Customers that the personal information they entrust to us is safe, we have developed this Privacy Policy. We want our Customers to know why we ask for their personal information, how we use it, what safeguards we employ and how to contact us with privacy-related questions.

In this Privacy Policy, “Personal Information” means information that specifically identifies a Customer as an individual and is provided to or collected by Neglia Design. The type of personal information Neglia Design collects, uses and discloses may include a Customer’s name, age, gender, residential mailing address, residential phone numbers or email addresses, financial, credit and banking information. Personal Information does not, however, include a Customer’s business title, business address, business telephone number in such individual’s capacity as an employee of an organization or enterprise, or navigational information (which is anonymous and includes information such as your IP address, the type of browser you are using or the website you visited immediately prior to ours).

I. Identifying the purposes and Use of Personal Information

Before collecting any Personal Information, Neglia Design will identify why the Personal Information is required and how it will be used. This Personal Information is documented and kept on file at Neglia Design’s offices in Canada. Neglia Design will obtain the Customer’s consent before using or disclosing Personal Information for purposes other than the original reasons given.

Neglia Design collects and uses a Customer’s Personal Information for the following purposes:

Collecting, recording and using Personal Information relevant to the performance of the services rendered to and for a Customer;
Recording and determining the services received by a Customer during his or her relationship with us;
Marketing our services;
Administration, billing, accounting and collection in relation to a Customer’s relationship with us;
Protecting against fraud and error;
Offering a Customer additional services which may be of interest to such Customer, and personalizing the Customer’s on-line experience;
Communicating with a Customer generally or to ensure Customer satisfaction;
Analysing trends, administering our website, tracking Customer’s movements within our website, gathering demographic information and conducting market research;
Improving the services offered to Customers in the future;
Enabling Customers to post comments and/or images and upload and download information;
Communicating Personal Information to an agent, intermediary or other third party during the course of a contract or mandate for the performance of any of the purposes listed in this Privacy Policy;
Complying with all applicable laws; and
Such other specific purposes which are communicated to a Customer by Neglia Design and its representatives before collection of the Personal Information.

We may use, share and disclose a Customer’s Personal Information to our affiliates, associates, agents, suppliers and such other third parties as Neglia Design, acting reasonably, may deem necessary for the fulfillment of the purposes noted above or where otherwise permitted by law. In the unlikely event that Neglia Design or substantially all of its assets are acquired by a third party, a Customer’s Personal Information may be one of the assets transferred to such third party.

II. Consent

Except in certain extraordinary circumstances, Neglia Design does not collect, use or disclose a Customer’s Personal Information without their knowledge and consent. Such extraordinary circumstances may include, without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent.

A Customer’s consent will be obtained at the time of collection of the Personal Information, or when a new use for the Personal Information is identified. A Customer may withdraw their consent at any time, subject to any legal or contractual restrictions and on the provision of reasonable notice to Neglia Design. If a Customer chooses to withdraw his or her consent, he or she is required to do so in writing to the Chief Compliance Officer (please see Section VII of this Privacy Policy). Any implications to withdrawing consent will be explained to the Customer at the time written notice of such withdrawal is received by Neglia Design. Such implications may include, but are not limited to, a breakdown, interruption or cessation of Neglia Design’s relationship with the Customer.

By retaining the services of Neglia Design, Customers have consented to the disclosure of their Personal Information to a third party in the circumstances, or for the purposes, set out in this Privacy Policy.

III. Limiting collection

Neglia Design limits the collection of a Customer’s Personal Information to that which is necessary for the purposes identified in this Privacy Policy, or for any additional purpose identified to the Customer before collection of the Personal Information.

IV. Limiting use, disclosure and retention

Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Customer, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous.

V. Accuracy

Neglia Design strives to ensure that a Customer’s Personal Information is as accurate, complete and up to date as necessary for the purposes for which it is used. Information is updated only when necessary to fulfill specified purposes. Customers should provide Neglia Design with any updates to their Personal Information in writing to the Chief Compliance Officer (see Section VII of this Privacy Policy) on a timely basis.

VI. Safeguards

Neglia Design has security safeguards in place designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Personal Information under the care of Neglia Design. The nature of the safeguards depends on the sensitivity, format, location and storage of the Personal Information. These security measures may from time to time include locked cabinets, computer passwords, software firewalls to stop hackers, encryption software, restricting access to Personal Information to only those employees or representatives who have a need to know and, if deemed necessary by Neglia Design in its sole discretion, confidentiality covenants from third parties to whom Personal Information has been disclosed.

E-mail, telephone and the internet are not a 100% secure medium, and Customers should be aware of this when contacting us to send Personal Information.

Neglia Design may collect user information from this website (for example, via cookies which are alphanumeric identifiers transmitted from a website to a visitor’s browser and IP address). The information that is collected is generally not Personal Information as is does not allow us to identify you. This information is used solely for enabling us to provide you with a customized online experience and to find ways to improve our website. Some of our third party service providers (i.e. advertisers) may also use cookies on our website. We have no access to or control over these cookies. This Privacy Policy covers the use of cookies by Neglia Design only and does not cover the use of cookies by any third parties. Although cookies are widely used, it may be possible to disable cookies via your browser settings. However, in so doing, some websites may not function properly or optimally.

This website may contain links to other third party websites that are not governed by this privacy policy, including websites containing interactive maps. Although we endeavour to link only to websites with high privacy standards, our Privacy Policy will no longer apply once you leave this website. We are not responsible for privacy policies employed by other third parties or any foreign affiliates, since they would be governed by privacy legislation applicable in their country of residence. We suggest, therefore, that you examine the privacy statements of those websites to learn how personal information may be collected, used and/or disclosed.

This Privacy Policy is governed pursuant to the laws of Canada and governs Personal Information regardless of your location when you access this website. Personal Information may be stored outside of the jurisdiction in which you reside and processed by us, one of our affiliates or a third-party service provider as set out in this Privacy Policy. Further, Canadian governmental authorities may be entitled to access your Personal Information.

VII. Accountability and Openness

Neglia Design is responsible for the Personal Information under its control and has appointed a Chief Compliance Officer to ensure that we comply with all applicable privacy legislation and the terms of this Privacy Policy. Personal Information provided to third party service providers with whom Neglia Design has a contractual agreement will have levels of protection comparable to the internal protection of Personal Information maintained at Neglia Design.

The Chief Compliance Officer addresses and investigates questions or concerns regarding a Customer’s Personal Information. The Chief Compliance Officer may be reached by mail at 302 King Street East, Toronto, Ontario M5A 1K6, Attention: Chief Compliance Officer, or by email at Neglia@NegliaDesign.com. A copy of this Privacy Policy, and any future updates or amendments hereto, are available at [www.negliadesign.com] and upon request from Neglia Design.

VIII. Individual access

Upon written request of a Customer, Neglia Design will provide such Customer with access to his or her Personal Information. Neglia Design will correct or amend any inaccuracies in the Customer’s Personal Information, and such amended information will be forwarded to any third parties who require access to the information. Neglia Design has the right to refuse a request for access to Personal Information:

If the information is protected by legal privilege;
If granting access would reveal confidential commercial or financial information;
If doing so would reasonably be expected to threaten the life or security of another individual;
If the information was collected for purposes related to the detection and prevention of fraud;
If the information was generated in the course of a formal dispute resolution process;
If the information would likely reveal Personal Information about another Customer;
If the request is vexatious or frivolous; and/or
To protect Neglia Design’s rights and property.

If the request of a Customer for such individual’s Personal Information is denied, the individual will be informed in writing of the reasons for the denial, as well as any recourse available to such individual.

Access to a Customer’s Personal Information will be at no cost to such Customer. Minimal charges may apply, however, for the transcription, reproduction or transmission of documents containing Personal Information.

IX. Challenging compliance

If a complaint (“Complaint”) regarding Neglia Design’s handling of Personal Information is received, an individual (the “Investigator”) with the skills necessary to conduct an investigation fairly and impartially will be assigned. The Investigator will have access to all relevant records and will be permitted to speak with employees of Neglia Design who handled the Personal Information access request. The complainant will receive notification of the outcome of the investigation clearly and promptly. Any inaccurate Personal Information or policy/procedure changes will be modified, if necessary, based on the outcome of the Complaint.

X. Currency of this Privacy Policy

Neglia Design reserves the right to change this Privacy Policy at any time and from time to time. Any changes or additions to section I of this Privacy Policy regarding those situations where Neglia Design will collect, use or disclose Personal Information will not apply to a Customer without the prior consent of such Customer. All Customers are encouraged to contact Neglia Design to determine if any updates have been made to this Privacy Policy.