Privacy
Statement
Protecting Customer Information
The Darwin Event Group (known as 'Darwin') considers protection of its
customers' information an important part of its business. Darwin has
long-standing security measures in place to preserve the confidentiality
of sensitive information, including personal information received on
behalf of its customers.
Background
The federal government has passed legislation dealing with the collection,
use and disclosure of information about any identifiable individual.
This legislation is called the Personal Information Protection and Electronic
Documents Act or PIPEDA, and applies to commercial activities across
Canada that collect, use and/or disclose personal information, except
in those provinces that have passed substantially similar legislation.
In those jurisdictions, the substantially similar provincial legislation
will apply.
Scope of this Policy
This policy sets out ten principles that will be observed by Darwin
in the collection, use and disclosure of information of customers. If
personal information is made anonymous by removing details so that an
individual is not identifiable to the user or recipient of that information,
it is not governed by this Policy but still will be treated with appropriate
safeguards.
Darwin's customer base is such that it collects personal information
from customers only in very rare circumstances. Darwin collects business
information from its customers to enable Darwin to perform contracted
exhibitor services. Only very infrequently will any identifiable personal
information be collected. If any personal information is collected,
Darwin will obtain consent at the time of the collection, disclosure
and/or use.
The Privacy
Principles
Principle 1 - Accountability
Darwin is responsible for maintaining and protecting the personal information
under its control and has designated a privacy officer to be accountable
for compliance with the principles described in this policy.
The Privacy Officer may be contacted at:
Privacy Officer
Darwin Event Group
2047 Langille Dr.
Coldbrook, NS, Canada
B4R 1C3
info@darwineventgroup.com
Under this principle, Darwin is responsible not only
for personal information in its physical possession or custody, but
also for personal information that is transferred by Darwin to a third
party for processing. Darwin will use contracts with such third parties
to require them to give an appropriate level of protection to the personal
information while it is being processed.
Darwin has established and implemented:
(a) procedures to protect personal information;
(b) procedures to receive and respond to complaints and inquiries;
(c) staff training and information programs to explain this policy
and related personal information protection procedures and practices;
and
(d) practices to ensure that customers and other individuals who contact
Darwin have access to this policy and to any available materials that
explain Darwin's policies and procedures.
Upon request, Darwin will disclose the name of the current
Privacy Officer.
Principle 2 - Identifying Purposes for Collection
of Personal Information
Darwin will identify the purposes for which personal information is
collected at or before the time the information is collected.
Depending on the specific circumstances, Darwin may collect personal
information for one or more of the following purposes:
(a) to provide exhibition and related services;
(b) to keep materials related to any activities carried on by Darwin,
or in determining whether to accept any person as a customer, or keeping
records of purchases, sales or other transactions; and
(c) to comply with legal and regulatory requirements.
When a new customer account is opened, Darwin will
ensure that the purposes for which the personal information is collected,
used and disclosed is identified by Darwin and documented on the relevant
documents. Thereafter, Darwin will collect only the personal information
that is necessary for the purposes that have been identified to the
customer.
Circumstances may arise where Darwin wishes to use or disclose personal
information for a new purpose. Darwin will ensure that personal information
is not used or disclosed for that new purpose unless the individual
is informed of the new purpose and gives his or her consent.
The methods used by Darwin to notify individuals of the proposed purposes
for which personal information is collected, used or disclosed may be
by telephone, in person, in writing, by email or by any other means
of communication which is likely to reach the concerned individual.
Darwin does not use cookies on its sites which may link to other websites
that use cookies. You are advised to check the terms of those other
websites for details of their use of cookies.
Principle 3 - Consent
The knowledge and consent of the customer are required for the collection,
use, or disclosure of personal information by Darwin, except where inappropriate
(eg. emergency situations).
Except when the under-noted exceptions apply or except
as permitted by law, Darwin will make a reasonable effort to ensure
that the individual is advised in advance of the purposes for which
his or her personal information will be collected, used or disclosed:
- Information collected in the past: For personal
information collected before this policy came into effect, Darwin
will ensure that personal information about each individual is used
and disclosed for the purposes described in Principle 2 of this policy.
- Withdrawal of Consent: An individual may withdraw
his or her consent to collection, use or disclosure at any time, subject
to legal or contractual restrictions and reasonable notice. Darwin
will inform the individual of the implications of such withdrawal
of consent, which generally would limit Darwin's ability to provide
the individual with the requested product of service.
- Disclosure for Business Transfers: Darwin may be
involved in the sale, transfer or reorganization of some or all of
its business from time to time. As part of that sale, transfer or
reorganization, Darwin may disclose personal information to the acquiring
organization, but will require the acquiring organization to agree
to protect the privacy of that personal information that is consistent
with this policy, and in accordance with the relevant federal or provincial
law.
- Outsourcing: Darwin may transfer personal information
to a third party for processing. In that regard, Darwin will use contractual
or other means to provide comparable level of protection while the
information is being processed by a third party.
To make the individual's consent meaningful, Darwin
will state the purposes in such a manner that the individual can reasonably
understand how the information will be used or disclosed.
Darwin will not, as a condition of the supply of products
or services, require an individual to consent to the collection, use
or disclosure of personal information beyond that required to fulfill
Darwin's explicitly specified, and legitimate purposes.
When a new account is opened for an individual, Darwin
will obtain explicit, signed consent for the proposed collection, use
and disclosure or personal information concerning that individual. (In
the case of a corporate account, Darwin will require that corporation
to represent and warrant that it has the consent of each individual
of the corporation, as the case may be, to their personal information
being disclosed to, and used by Darwin, for specified purposes.)
Darwin will never obtain consent by deception. Depending
on the specific circumstances, Darwin may obtain consent in the following
ways:
(a) an application form to seek consent, collect information and inform
the individual of the use that will be made of the information;
(b) a check-off box to request that their name and address not be given
to the other organizations; (c) orally in person or over the phone;
(d) at the time the individual uses a product of service; or
(e) deeming consent unless the individual expressly informs Darwin to
the contrary.
Principle
4 - Limiting Collection of Personal Information
Darwin will limit the collection of personal information to that which
is necessary for the purposes identified by it. Darwin will collect
personal information by fair and lawful means.
Although Darwin will collect personal information primarily
from the individuals concerned, with the individual's consent, Darwin
may also collect information from external sources identified to Darwin
by the individual for this purpose. If personal information is collected
from a third party, Darwin will note their identity unless there is
a lawful reason for not doing so.
Principle
5 - Limiting Use, Disclosure and Retention of Personal Information
Darwin will not use or disclose personal information for purposes other
than those for which it was collected, except with the consent of the
individual or as required by law. The Company will retain personal information
only as long as necessary for the fulfillment of those purposes.
Darwin generally retains personal information for 3
to 7 years after an account is closed, which is necessary for the identified
purposes and for legal or business purposes.
Darwin will destroy, or make anonymous, any personal
information no longer needed for its identified purposes or for legal
or business requirements.
Principle
6 - Accuracy of Personal Information
Darwin will keep personal information as accurate, complete,
and up-to-date as is necessary for the purposes for which it is to be
used.
Darwin will generally rely on individuals to provide
up-dated information, such as changes to addresses, phone numbers and
other contact information.
If an individual successfully demonstrates to Darwin
that personal information is inaccurate, incomplete, out of date, or
irrelevant, Darwin will revise the personal information. If necessary,
Darwin will disclose the revised personal information to third parties
that were provided with the wrong information to permit them to revise
their records as well.
Principle
7 - Safeguarding Personal Information
Darwin will protect personal information using security safeguards that
are appropriate to the sensitivity level of the personal information
received.
Security arrangements are employed to protect personal
information against loss of theft, as well as unauthorized access, disclosure,
copying, use, modification, or disposal. Darwin will protect personal
information regardless of the format in which it is held.
The nature of Darwin's safeguards will vary depending
on the sensitivity of the personal information that has been collected,
the amount, distribution, and format of the information, and the method
of storage. The more sensitive personal information will be safeguarded
at a higher level of protection.
Currently, Darwin employs physical measures including
locked premises and locked filing cabinets (for sensitive information).
Access to computerized information is protected by passwords.
Darwin will inform employees about its practices and
procedures for protecting personal information and will emphasize the
importance of complying with them. As a condition of employment, employees
will be required to conform to Darwin's policies and procedures concerning
the security of personal information.
When Darwin discloses personal information to third
parties, it will require these third parties to safeguard all personal
information in a way that is consistent with Darwin's measures and which
complies with these principles.
Darwin will use care in the disposal or destruction
of personal information to prevent unauthorized parties from gaining
access to the information.
Principle
8 - Openness Concerning Policies and Practices
Darwin will make readily available to individuals specific information
about its policies and practices relating to the management of personal
information. Individuals whose personal information is in the custody
and control of Darwin will be able to acquire information about Darwin's
privacy policies and practices without unreasonable effort. This information
will be made available in a form that is generally understandable.
The information made available by Darwin will include:
(a) the contact information of the Privacy Officer;
(b) the means of gaining access to personal information held by Darwin;
(c) a description of the type of personal information that is held
by Darwin, including a general account of its use;
(d) a copy of any brochures or other information that explain Darwin's
policies, standards, or codes; and
(e) a description of the type of personal information that is made
available to related subsidiaries or affiliates of Darwin.
Darwin will also employ its website to make public information
concerning its privacy policies and procedures.
Principle
9 - Individual Access to Personal Information
Upon written request, Darwin will (i) inform an individual of the existence,
use and disclosure of his or her personal information and (ii) give
the individual access to that information, except where the law requires
or permits Darwin to deny access. Individuals are entitled to challenge
the accuracy and completeness of that personal information and request
that it be amended, if appropriate.
In providing an account of third parties to whom Darwin
has disclosed personal information about an individual, Darwin will
attempt to be as specific as possible. When it is not possible to provide
a list of the organizations to which Darwin has actually disclosed personal
information about an individual, Darwin will provide a list of organizations
to which it may have disclosed personal information about the individual.
Darwin may require the individual to provide sufficient
information to permit Darwin to provide an account of the existence,
use and disclosure of personal information. The information provided
by the individual in response to Darwin's request will be used only
for this purpose.
Darwin will respond to an individual's request within
a reasonable time. Darwin may respond to the request at a cost to the
individual if it informs the individual of the estimate of the fee in
advance, and it may require the individual to pay a deposit for all
or part of the fee.
Where Darwin is entitled to withhold access to personal
information, and that information is severable from other information
for which access is requested, Darwin will provide access to any edited
copy of the personal information after severing such information.
Where Darwin is satisfied on reasonable grounds that
an individual successfully demonstrates that personal information is
inaccurate or incomplete, Darwin will correct the information as required.
Darwin will send the corrected personal information to third parties
having access to the information in question.
Where Darwin disagrees with the requested correction,
Darwin will annotate the personal information with the correction that
was requested but not made.
Principle
10 - Challenging Compliance
An individual will be able to direct a challenge concerning compliance
with the above principles to the Privacy Officer. Darwin will establish
procedures to receive and respond to complaints or inquiries about Darwin's
policies and practices relating to the handling of personal information.
The complaint procedure will be easily accessible and simple to use.
Darwin will inform individuals who make inquiries or
lodge complaints of the use of the existence of relevant complaint procedures.
Darwin will investigate all complaints. If Darwin finds
that a complaint is justified, Darwin will take appropriate measures,
including, if necessary, amending its policies and practices.