- Personal Information
- Privacy Principles
- Why does Capelle collect personal information?
- Privacy and our websites
- How to obtain access to personal information
- How does Capelle protect personal information?
- Further information
Principle 1 – Accountability
Principle 2 – Identifying Purposes for Collection of Personal Information
Capelle identifies the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which Capelle collects, uses or discloses personal information are described in Section 4 below.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of his or her personal information, except where inappropriate or as permitted by law. In obtaining consent, Capelle uses reasonable efforts to ensure that an individual is advised of the identified purposes for which his or her personal information will be used or disclosed. In determining the appropriate form of consent, Capelle has taken into account the sensitivity of the personal information and the reasonable expectations of a reasonable person. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the Capelle Privacy Officer. The implications of such withdrawal are described above.
Principle 4 – Limiting Collection of Personal Information
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Principle 6 – Accuracy of Personal Information
Personal information held by Capelle is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used and to minimize the possibility that inappropriate information may be used to make a decision about an individual. Capelle does not routinely update personal information, unless such process is necessary to fulfill the identified purposes. We rely on individuals to inform us of any changes to their personal information or to any personal information you have provided to us. To update personal information, please see Section 9.
Principle 7 – Security Safeguards
Capelle guards personal information by using industry standard security safeguards appropriate to the sensitivity of the information. Capelle uses reasonable efforts and industry standard security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction. Personal information disclosed by Capelle to third parties is subject to contractual agreements which stipulate the confidentiality of the information and the limited purposes for which it is to be used.
Principle 8 – Openness Concerning Policies and Practices
Principle 9 – Individual Access to Personal Information
Upon written request from an individual pursuant to Principle 8, Capelle will inform the individual of the existence, use, and disclosure of his or her personal information and, subject to certain exceptions, will give the individual access to that information. If access is granted, Capelle will give the requesting individual a reasonable opportunity to review the personal information collected by Capelle. Personal information will be provided in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. Capelle may extend such 30 day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Capelle or the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. If access is lawfully denied, Capelle will notify the requesting individual in writing, give reasons for the denial, and inform the individual of the recourses open to him or her.
Principle 10 – Challenging Compliance
Capelle may collect, use and/or disclose personal information for the following purposes:
- to consider whether Capelle should establish or continue a commercial relationship, including without limitation, to extend credit and to evaluate credit standing and to match credit bureau or credit reporting agency information, to check references and to confer with banking institutions;
- to establish and maintain commercial relations with clients, investors, shareholders, suppliers, financial institutions, insurers, and affiliates, and to provide ongoing products and services, administer accounts, make and receive payments, and fulfill contractual obligations;
- to understand and respond to client needs and preferences, including to communicate with clients and to provide them with consulting, support and other services;
- to conduct surveys, contests and promotions;
- to conduct research and statistical analysis;
- to distribute newsletters, press releases, promotional information and other material to individuals, in any format or media, including via third party mailing houses;
- to develop, enhance, market, sell, provide and inform you of Capelle’s products and services;
- to develop, enhance, market, sell, provide and inform you of products and services of third parties, including our affiliates and suppliers, with whom Capelle has a commercial relationship;
- to manage and develop Capelle’s businesses and operations;
- to update and verify our databases and information provided by third parties;
- to detect and protect Capelle and other third parties against error, negligence, breach of contract, theft, fraud and other illegal activity, to comply with Capelle’s audit requirements, and to audit compliance with Capelle’s corporate policies, procedures, laws and contractual obligations;
- to engage in and carry out business transactions that may involve the sale or transfer of personal information, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Capelle or its affiliates;
- as permitted by, and to comply with, any legal or regulatory requirements or laws;
- to send commercial electronic messages to clients and potential clients; and
- for any other purpose to which an individual consents.
In addition to the above purposes, from time to time Capelle may disclose personal information to:
- its agents, affiliates or service providers, including an organization or individual retained by Capelle to perform functions on its behalf or to provide services to Capelle (such as marketing, data processing, software development, website hosting, information technology and office services), subject to the provision that such organization or individual does not collect, use or disclose the personal information for any purpose other than to perform such functions or provide services to Capelle;
- a person who, in the reasonable judgment of Capelle, is providing or seeking the information as an agent of the subject individual; or
- any third party or parties, with the consent of the subject individual or where disclosure is required or permitted by law.
On-line and Off-line Communications – In order to provide you with a product, service or information, you may voluntarily submit personal information to us for purposes such as registering for our services, obtaining information, corresponding with us (including through electronic means), and participating in contests and surveys. We may combine and store personal information about your use of our websites and the online information you have provided with certain other online and offline information we may have collected.
Electronic Communications – If you send us an inquiry from our website, send us a request for a consultation or discussion, organization design information, organization design conference information or executive briefings information, or other similar Capelle services, Capelle may send you electronic communications with information that may be useful to you, including information about Capelle and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional electronic messages from Capelle.
Links – Our websites may contain links to other websites which are provided to you as a convenience only. You are advised that personal information you submit through other third party websites will be governed by the respective policies and privacy practices of those websites, if any. Capelle has no responsibility for such third party websites.
Upon your written request and subject to certain exceptions, Capelle will inform you of the existence, use and disclosure of your personal information and will give you access to that information. Access requests must be sent in writing to our Privacy Officer at the contact information in Section 9 below.
To help guard the confidentiality of personal information, Capelle uses industry standard administrative and technological safeguards appropriate to the sensitivity of the personal information. For instance, we operate secure data networks protected by firewall and password protection systems. Personal information is stored in secured locations and on servers controlled by Capelle, located either at our offices or at the offices of our service providers. Personal information collected will be destroyed, erased or made anonymous, in accordance with applicable laws, when it is no longer required to fulfill the purposes for which it was collected.
For more information about Capelle’s privacy practices, to amend or obtain access to your personal information, to opt-out or withdraw your consent, or if you have privacy-related questions or concerns, please contact our Privacy Officer at:
Capelle Privacy Officer
Capelle Associates Inc.
First Canadian Place
100 King Street West, Suite 5600
Toronto, ON M5X 1C9
Telephone: (416) 236-3044
Facsimile: (416) 231-9915