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REDWOOD HOMES INC. 1. Objective & Scope of Policy Redwood Homes Inc. is committed to respecting your privacy and has prepared this Policy to inform you of our policy and practices concerning the collection, use and disclosure of Personal Information. This Policy governs Personal Information collected from and about i) individuals who are or may become Clients of Redwood Homes Inc. and ii) individuals or organizations with whom Redwood Homes Inc. works with. Using contractual or other arrangements, Redwood Homes Inc. shall ensure that agents, contractors or third party service providers, who may receive Personal Information in the course of providing services to Redwood Homes Inc. as part of our delivery of building and management services, protect that Personal Information in a manner consistent with the principles articulated in this Policy. This Policy does not cover aggregated data from which the identity of an individual cannot be determined. Redwood Homes Inc. retains the right to use aggregated data in any way that it determines appropriate. In the event of questions about: i) access to your Personal Information; ii) Redwood Homes Inc. collection, use, management or disclosure of Personal Information; or iii) this Policy; please contact: Jeff Becker, President 524 First Street Collingwood, Ontario L9Y 1C1 (705) 444-1322 ext 22 jbecker@georgian.net
2. The Collection, Use & Disclosure of Personal Information For the purpose of this Policy: “Client” means an individual who may or has purchased Redwood Homes Inc. homes or services; “Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information. Your provision of Personal Information to Redwood Homes Inc. means that you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy. I you do not agree with these terms, you are requested not to provide any Personal Information to Redwood Homes Inc. or a Representative working with Redwood Homes Inc. Unfortunately, certain services can only be offered if you provide Personal Information and consequently, if you choose not to provide us with any required Personal Information, Redwood Homes Inc. may not be able to offer you those services. This office only collects Personal Information necessary to effectively provide professional building services to clients. Redwood Homes Inc.’s use of Personal Information is limited to these purposes. Redwood Homes Inc. does not sell, trade, barter or exchange for consideration any Personal Information it has obtained. Unless permitted by law, no Personal Information is collected about an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information. Personal Information will be collected, to the extent possible, directly from the individual concerned. Redwood Homes Inc. does not knowingly collect Personal Information from anyone under the age of 18, especially children under 13, and does not use such information if Redwood Homes Inc. discovers that it has been provided by a minor. Personal Information may also be transferred to another company in the event of a change of ownership of all or part of Redwood Homes Inc. Redwood Homes Inc. may disclose Personal Information of Clients to organizations that perform services on its behalf. This will only be done if such organizations agree to use such information solely for the purposes of providing services to Redwood Homes Inc. and, with respect to that information, to act in a manner consistent with this Policy. Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where Redwood Homes Inc. is obliged to disclose information without consent. Such circumstances may include:
Where obliged or permitted to disclose information without consent, Redwood Homes Inc. will not disclose more information than is required. 3. Accuracy Redwood Homes Inc. endeavors to ensure that any Personal Information provided by Clients and in its possession is as accurate, current and complete as necessary for the purposes for which Redwood Homes Inc. uses that data. Information contained in files that have been closed is not actively updated or maintained. 4. Retention Redwood Homes Inc. retains Personal Information for as long as Redwood Homes Inc. believes it is necessary to fulfill the purpose for which it was collected and Firm legal or business requirements. 5. Security Redwood Homes Inc. endeavors to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. Redwood Homes Inc. further protects Personal Information by restricting access to it to those Employees and Contractors that the management of Redwood Homes Inc. has determined need to know that information in order that Redwood Homes Inc. may provide services to Clients. 6. Access to Personal Information Redwood Homes Inc. permits access to and review of Personal Information held by Redwood Homes Inc. about an individual by the individual concerned. If an individual believes any Personal Information concerning that individual is not correct, that person may request an amendment of that information by sending a request to the person indicated in Section1 of this Policy. Redwood Homes Inc. reserves the right not to change any Personal Information, but will append any alternative text the individual concerned believes appropriate. Where not required to be retained by the Firm, an individual may also request that Redwood Homes Inc. delete an individual’s Personal Information from Redwood Homes Inc.’s system and records. However, due to constraints of computer technology and the fact that Redwood Homes Inc. backs up its system, Personal Information may continue to reside in Redwood Homes Inc.’s system after deletion. Individuals, therefore, should not expect that their Personal Information would be completely removed from Redwood Homes Inc.’s system in response to an accepted request for deletion. Redwood Homes Inc. reserves the right to decline access to Personal Information where the information requested: a) Would disclose the Personal Information of another individual or of a deceased individual; b) Would disclose business confidential information that may harm Redwood Homes Inc. or the competitive position of a third party; c) Is subject to solicitor-client or litigation privilege; d) Could reasonably result in: i) serious harm to the treatment or recovery of the individual concerned; ii) serious emotional harm to the individual or another individual; or iii) serious bodily harm to another individual; e) May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions; f) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information; or g) Does not exist, is not held, or cannot be found by Redwood Homes Inc. Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure. Where information will be disclosed, Redwood Homes Inc. will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request. Redwood Homes Inc. will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the frequency with which information is amended, the purpose for which the information is used, and the nature of the information. To guard against fraudulent requests for access, Redwood Homes Inc. will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections. 7. Amendment of Practices and this Policy This statement is in effect as of January 1, 2004. Redwood Homes Inc. will, from time to time, review and revise its privacy practices and this Policy. In the event of any amendment, an appropriate notice will be communicated to Clients and others in an appropriate manner.
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