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Privacy Policy

This Privacy Policy was last updated on March 10, 2016.

  1. Introduction
  2. Personal Information
  3. Privacy Principles
  4. Why does Capelle collect personal information?
  5. Privacy and our websites
  6. How to obtain access to personal information
  7. How does Capelle protect personal information?
  8. Changes to this privacy policy
  9. Further information

1. Introduction

This Privacy Policy governs how Capelle Associates Inc. (“Capelle” or “we”) manages, in accordance with applicable laws, the accuracy, security and privacy of personal information you provide to us. This Privacy Policy contains a statement of principles and guidelines for the protection of the personal information of our individual clients, our clients’ employees, our clients’ individual customer personal information, service providers, suppliers and other individual people (“individuals” or “you”). The objective of the Privacy Policy is to document our responsible practices in the collection, use and disclosure of personal information, in accordance with applicable laws.

Capelle’s corporate headquarters are located in Ontario, Canada, but Capelle may collect, use, disclose or transfer personal information across provincial and national borders. As required, this Privacy Policy shall be supplemented by additional legal requirements of other jurisdictions where Capelle conducts business and additional legal requirements that apply to certain types and sources of personal information. Capelle operations located in jurisdictions with less stringent privacy laws are expected to make all reasonable efforts to meet the requirements of this Privacy Policy. Nothing in this Privacy Policy or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against Capelle or any third party or any of their respective directors, officers, employees, agents or representatives (collectively, the “Capelle Group”), nor will the existence of this Privacy Policy or its application impose any obligations or liability upon the Capelle Group, or add to any such obligation or liability, that the Capelle Group does not already otherwise have to any individual or person at law or otherwise.

Your Consent
BY SUBMITTING PERSONAL INFORMATION TO CAPELLE OR ITS SERVICE PROVIDERS OR AGENTS, YOU AGREE THAT CAPELLE AND APPLICABLE SERVICE PROVIDERS OR AGENTS MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION AS DESCRIBED IN AND IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, and reasonable notice, you may refuse or withdraw your consent to certain of the identified purposes in Section 4 by contacting the Capelle Privacy Officer. If you refuse or withdraw your consent to certain purposes, we may not be able to establish or maintain a commercial relationship with you or provide you with services or information which may be of value to you. If you provide us with personal information of another individual, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such individual to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

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2. Personal Information

In this Privacy Policy, “personal information” is defined as information about an identifiable individual and does not include aggregated information that does not allow an individual to be identified. An individual’s business contact information, such as his or her name, title, business address, business telephone and business facsimile numbers, are not considered to be personal information except in the Province of Québec. The types of personal information that Capelle may collect includes, without limitation, (a) personal information provided by our clients (including information about our clients’ customers and employees) so that we can provide services to our clients, (b) information provided by individuals requesting consultations and information regarding organization design, executive briefings, events and conferences, and other products and services; and, (c) unsolicited resumes or other personal information that may be submitted to Capelle by any means.

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3. Privacy Principles

Capelle collects, uses and discloses personal information in accordance with the following ten privacy principles which form the basis of this Privacy Policy.

Principle 1 – Accountability
Capelle is responsible for personal information under its control and has designated a Privacy Officer to be accountable for Capelle’s compliance with this Privacy Policy and applicable laws. Contact information for the Capelle Privacy Officer is provided in Section 9 below.

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
Capelle limits the collection of personal information, including the amount and the type of information, to that which is reasonably necessary for the purposes identified in this Privacy Policy.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Capelle does not use or disclose personal information for purposes other than those identified in this Privacy Policy, except as required or permitted by law. Capelle retains personal information for only as long as is necessary to fulfill the identified purposes.

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
Capelle policies and practices relating to the management of personal information are set out in this Privacy Policy. The policy is available on the Capelle website at www.capelleassociates.com and upon request to the Chief Privacy Officer via the contact information provided below.

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
Individuals may address a challenge concerning compliance with this Privacy Policy to the Capelle Privacy Officer via the contact information set out in Section 9 below.

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4. Purposes of Use of Personal Information by Capelle

Capelle may collect, use and/or disclose personal information for the following purposes:

  1. 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;
  2. 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;
  3. to understand and respond to client needs and preferences, including to communicate with clients and to provide them with consulting, support and other services;
  4. to conduct surveys, contests and promotions;
  5. to conduct research and statistical analysis;
  6. to distribute newsletters, press releases, promotional information and other material to individuals, in any format or media, including via third party mailing houses;
  7. to develop, enhance, market, sell, provide and inform you of Capelle’s products and services;
  8. 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;
  9. to manage and develop Capelle’s businesses and operations;
  10. to update and verify our databases and information provided by third parties;
  11. 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;
  12. 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;
  13. as permitted by, and to comply with, any legal or regulatory requirements or laws;
  14. to send commercial electronic messages to clients and potential clients; and
  15. 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:

  1. 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;
  2. a person retained by Capelle to fulfill one or more of the purposes described in this Privacy Policy;
  3. a person who, in the reasonable judgment of Capelle, is providing or seeking the information as an agent of the subject individual; or
  4. any third party or parties, with the consent of the subject individual or where disclosure is required or permitted by law.

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5. Privacy and our Websites

Cookies – When you access the Capelle websites, we may use a browser feature called a ‘cookie’ to collect information that is not personally identifiable (such as the type of Internet browser and operating system you use, the domain name of the website from which you came, number of visits, average time spent on our website, and pages viewed). A cookie is a small text file containing a unique identification number that identifies your browser, but not you, to our computers each time you visit one of our websites that uses cookies. Unless you specifically inform us (e.g. by sending us comments or an inquiry from our website), we will not know who you are. In addition to the identified purposes described in our Privacy Policy, Capelle may use this information gathered from cookies and share it with other organizations with which we have a commercial relationship to measure the use of our websites and to improve the functionality and content of the websites. If you wish, you can reset your browser either to notify you when you have received a cookie or refuse to accept cookies. However, if you refuse to accept cookies, you may not be able to use certain features on our websites.
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.

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6. How to Obtain Access to Personal Information

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.

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7. How does Capelle Protect Personal Information?

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.

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8. Changes to this Privacy Policy

Capelle reserves the right, at any time, to modify, alter, or update this Privacy Policy, and such changes, modifications, additions or deletions shall be effective immediately upon notice to you, which may be given by any means including, but not limited to, posting the updated version of this Privacy Policy onto the Capelle website or by electronic or conventional mail. You agree to regularly review the Privacy Policy posted on the website and to be aware of such revisions. Your continued use of the Capelle website or ordering of any products following any such change constitutes your agreement to follow and be bound by the Privacy Policy as changed. If at any time this Privacy Policy is no longer acceptable to you, you should immediately cease to use the Capelle website.

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9. Further Information

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
E-mail: privacy@capelleassociates.com

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10. Website Terms of Use

Please also review our Terms of Use, which apply to anyone who accesses, browses or uses our website. Our Terms of Use are available at https://www.capelleassociates.com/terms-conditions/.

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