WEBSITE PRIVACY POLICY

Last Updated: March 10, 2020

Our Commitment to Privacy: 2533974 Ontario Inc dba Ram Advisory (“RAM”, “it”, “us” or “we”) is committed to protecting the privacy and confidentiality of personal information in its possession.

This privacy policy explains how personal information is collected, used and disclosed concerning RAM’s customers and other individuals.  RAM is committed to collecting, using and disclosing personal information responsibly and in accordance with this privacy policy. 

If you do not consent to the collection, use and disclosure of your personal information in accordance with this privacy policy, do not provide RAM with any personal information.  It is important to note that some of RAM’s products and services can only be provided if RAM receives appropriate and required personal information.  Consequently, should you choose not to provide RAM with the required personal information, RAM may be unable to offer these products and services to you.

Personal Information: For the purposes of this privacy policy, the term “personal information” means any information that is defined to be personal information under applicable privacy laws.  Usually, this refers to any information about an identifiable individual or any information that can be used to identify an individual.

Personal information may include, for example, your name and home address, your date of birth and gender, health information, your occupation, your personal financial records or credit information, or any personal identification numbers.

In most circumstances, personal information does not include the business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information, such as information in a public directory, is not personal information under this privacy policy.

Purposes: RAM may collect, use or disclose personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:

·       To provide products and/or services to you and/or access to RAM’s website;

·       To comply with RAM’s legal obligations and regulatory requirements;

·       To provide information to anyone working with or for RAM as needed for the provision of RAM’s services;

·       To develop and manage RAM’s business and operations;

·       For billing, accounting and debt collection services relating to RAM’s products and services;

·       To distribute publications, invitations, advertising, and other communications that RAM believes may be of interest to RAM’s clients, customers and other individuals;

·       To provide for the safety, health, security and emergency preparedness of RAM’s staff, guests and visitors who are located on RAM’s premises;

·       To respond to your questions and concerns;

·       To contact you for survey or client satisfaction purposes, or for the purpose of market or other types of research;

·       To detect and protect RAM and third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with RAM’s insurers;

·       To otherwise communicate with RAM’s insurers;

·       To access third party services’ accounts;

·       To generate analytics;

·       To support hosting and backend infrastructures of RAM or of third parties that assist RAM;

·       To generate location-based interactions;

·       To manage contacts and to manage the sending of messages;

·       To undertake registration and authentication of users;

·       To generate and provide social features;

·       For internal, external and regulatory audit purposes; and

·       For any other purpose for which RAM has your consent.

Consent: Privacy legislation requires RAM to obtain the consent of an individual to the collection, use or disclosure of personal information in many circumstances.

By providing your personal information to RAM, you agree that RAM may collect, use and disclose your personal information in accordance with this privacy policy and as otherwise permitted or required by law, and that RAM may access, process and store your personal information in Canada or another jurisdiction.

RAM may receive or otherwise obtain personal information relating to you from your FacebookTM or LinkedIn account, and/or from other social networking sites and/or webpages, to collect any of the following information: information about you, your friends lists, your private data, your requests, your activities, your app notifications, your birthday calendar, book actions, your chats, your checkins, your contact email list, your created events, your created notes, your current city or other geo-tracked or otherwise collected location information, your custom user actions, your deals, your education history, your emails or other messages, your events, your export posts, your family members and relationship status, your fitness actions, your hometown, your interests, your notification management, your photos, your tagged places, your upload photos, and your work history.

When RAM receives personal information from you for the purposes of providing you with RAM’s services or for other uses identified herein by RAM, you are providing RAM with consent as follows:

  1. to allow RAM to deal with that personal information in a reasonable manner;

  2. to allow RAM to provide your personal information to third parties it engages to provide or support RAM’s website;

  3. to allow RAM to use and store your personal information for the purpose of providing you with the products and services you purchase from RAM and to utilize this website; and

  4. to allow RAM to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your personal information by RAM.

If you need to provide RAM with personal information about other individuals, you represent and warrant to RAM that, where required by law and prior to your disclosure to RAM, you will obtain the consent of each individual to the collection, use and disclosure by RAM for the specific purpose(s) that the disclosure is made by you.

Providing RAM with your personal information is always your choice. When you request products and/or services from RAM, utilize RAM’s services, or register with RAM’s website, RAM asks that you provide information that enables RAM to respond to your request and/or provide you with RAM’s services. In doing so, you consent to RAM’s collection, use and disclosure to appropriate third parties of such personal information for these purposes.

There are legal exceptions where RAM will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if RAM must comply with a court order or governmental order.

If RAM sells its business or merges with another party, your consent will be implied to transfer your information to RAM’s successor for the same purposes as set out in this privacy policy.

Collection of Personal Information: RAM collects your personal information in accordance with this privacy policy.

RAM may collect personal information about you from other sources, such as social networking sites or websites having links to or from this Website, government ministries, departments or agencies, government registries, investigators, health institutions or organizations, insurance companies or financial institutions.  By using RAM’s website and/or service(s) you consent to RAM’s collection of your personal information from other sources.

Use of Personal Information: RAM uses your personal information in accordance with this privacy policy. RAM’s staff may use your personal information for the purposes identified in this privacy policy.

Disclosure of Personal Information: RAM will only disclose your personal information for the purposes set out in this privacy policy.

RAM does not sell client lists or personal information to others. In providing RAM’s services or access to RAM’s website, RAM may need to disclose the personal information RAM collects to other service providers or agents who perform various functions for RAM, provided such suppliers agree to keep all personal information private, confidential and secure and to use the personal information only to carry out work on RAM’s behalf.

In certain circumstances, RAM may be required to provide personal information to third parties for legal or regulatory purposes.

Privacy and Our Websites: Each time a visitor comes to the website, RAM’s web server may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities on RAM’s website or social network sites and/or webpages linked thereto. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. RAM may use this non-personal information to optimize RAM’s website, products and/or services.

RAM may, from time to time, use “cookies” solely for security and authentication purposes. Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or services.  At your option, you may turn off RAM’s “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of RAM’s websites, products and/or services.  To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser. 

RAM may, from time to time, engage third parties to assist with this Website, and such third parties may track your usage, locate your geographic position, collect personal information, send messages to you on behalf of RAM, push notifications to you, and use “cookies”, as discussed herein. 

By accessing and browsing RAM’s website, products and/or service(s), you agree that RAM, or any third party it engages or that assists RAM,  may collect, use and disclose any information collected about you through RAM’s website, products and/or services or that you provide to RAM through RAM’s websites, products and/or services as described in this privacy policy.

RAM’s website, products  and/or service(s) may contain links to other sites and may provide forms on behalf of other organizations.  This privacy policy only applies to personal information that we collect, use and disclose.  RAM is not responsible or liable for the privacy practices of third parties, including any organizations on the behalf of which RAM provides forms, and RAM strongly recommend that you review a third party’s privacy policy before disclosing any personal information to the third party.

Retention and Destruction of Personal Information: The amount of time RAM will retain personal information varies, depending on the services RAM has provided and the nature of the personal information that RAM holds.  RAM retains personal information for such period of time as is necessary for RAM to maintain sufficient information so RAM may respond to any issues that arise at a later date or as is required by law.

When personal information is no longer required by RAM or by law, RAM will either convert it into an aggregated non-identifying form or RAM will appropriately destroy or erase the personal information in a manner that is in accordance with RAM’s current policies and procedures.

Safeguarding Personal Information: RAM employs reasonable physical, electronic and procedural safeguards that are designed to protect RAM’s systems and personal information under RAM’s control against unauthorized access and use. In accordance with appropriate industry standards in Canada, all safety and security measures are appropriate to the sensitivity level of the information collected.

RAM may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and RAM does not have any control over such external servers or services.

Electronic Communications: Email is frequently RAM’s preferred method of communicating with you and others, and, unless you object, RAM may use unencrypted plain text or html-based emails or messages when communicating with you.  These emails or messages, and other electronic means by which RAM may communicate with you, may contain information that is confidential, unless you instruct RAM not to send such information electronically. RAM may communicate with you through other electronic means, in accordance with the contact information you provide to RAM.

While RAM makes every effort to secure all electronic communications within RAM’s control, there are inherent risks involved with exchanging information electronically.  For example, such information may be accidentally or deliberately intercepted by third parties.  RAM is unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.

RAM will endeavour to be compliant with Canada’s Anti-Spam laws (“CASL”) in RAM’s commercial electronic communication with you. Should you fail to provide RAM with the requisite consent to send you commercial electronic messages, or withdraw such consent, RAM may be unable to provide, or continue to provide, this website or some of RAM’s products and/or services that can only be provided if RAM receives appropriate and required personal information. CASL consent can be provided or withdrawn at: https://www.ramadvisory.co/contact

Keeping Information Accurate / Access and Correction: It is important to RAM that your personal information held by RAM is accurate and complete. Having accurate information about you enables RAM to give you better service. You can help RAM keep personal information up-to-date by keeping RAM informed of any changes, such as a change of address, telephone number or any other circumstances.

With some exceptions, RAM has the right to access, verify and amend the information RAM has about you after RAM has received your written request and authenticated your identity.

RAM may charge a reasonable fee for providing information in response to an access request, and, upon request, RAM will provide an estimate of any such fee upon receiving a request to access information. RAM may require a deposit for all or part of the fee.

Where applicable or permitted, RAM will make the information available within 30 days or provide written notice when RAM requires additional time to respond to a request for access to information.

In some situations, RAM may not be able to provide access to certain personal information as the right to access personal information is not absolute.  If RAM does not provide you with the requested information, RAM will notify you in writing and explain RAM’s reason(s) for not fulfilling your request.

Despite RAM’s efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let RAM know and RAM will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from RAM.

Withdrawal of Consent: You may, at any time, withdraw your consent to RAM’s collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions.

Should you choose to withdraw your consent, RAM may be unable to provide, or continue to provide, this website or some of RAM’s products and/or services that can only be provided if RAM receives appropriate and required personal information.  Consequently, should you choose not to provide RAM with the required personal information, RAM may be unable to offer tis website and such products and/or services to you.

You may, at any time, ask RAM not to send you further marketing materials about RAM’s products or services or if you do not wish to receive further invitations, you may unsubscribe or ask RAM not to contact you for these purposes.

Privacy Concerns: RAM will respond to questions and concerns relating to RAM’s personal information handling practices and this policy. 

Contact Information: Please contact RAM to obtain further information about RAM’s policies and procedures, to seek access to personal information RAM may have about you, or if you have any unresolved inquiries or concerns. RAM will respond to you promptly and do RAM’s utmost to resolve your concerns.  RAM may need to ask you for personal information to verify your identity. RAM can be contacted at: https://www.ramadvisory.co/contact

Changes to this Privacy Policy: This privacy policy is effective as of August 26, 2016.  RAM reserves the right to change this privacy policy, and any of RAM’s policies and procedures concerning RAM’s practices for handling personal information, at any time and without any prior notice.  If RAM has modified or amended our privacy policy, RAM will post the most current version on RAM’s website.  Any changes that are made to this privacy policy will apply to both any personal information that RAM holds prior to the effective date of the amended privacy policy and any personal information that RAM collects on or after such effective date.

Successors and Assigns: RAM’s successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this privacy policy.

© 2533974 Ontario Inc, 2020.