CANNEX recognizes that the security and privacy of Personal Information is very important. Therefore, we have adopted this policy to protect Personal Information. This policy applies to CANNEX Financial Exchanges Limited and CANNEX USA Inc. (“CANNEX”) and it applies to Personal Information that we use through the services we provide to our corporate and institutional clients (Customers or Subscribers), participants and attendees at our events, through the site and market research. If we make any material changes to our Privacy and Security Policy, we will post a prominent notice on our site notifying you of the change.
Collecting, Using and Disclosing Personal Information
Information from Customers or Subscribers and their Users
CANNEX makes available its services to Customers or Subscribers and their Users via www.cannex.com, intranet, email or XML web services. If you are an employee/officer/director/principal/agent (Users) of one of our Customers or Subscribers, we generally collect Business Contact Information. Business Contact Information means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Business Contact Information is exempted from privacy laws in Canada.
Information from our Customers or Subscribers and their Users’ End Clients
We collect, use, and disclose certain Personal Information at the direction and on behalf of our Customers, Subscribers and their Users from individuals (End Clients) in order to complete a transaction. For example, in order to process a GIC transaction on behalf of a Customer we may send the End Client’s name, date of birth, social insurance number, identity verification documents and banking information (Personal Information) to an issuer – financial institution. CANNEX shall only use information that is necessary to deliver requested services to our Customers or Subscribers.
CANNEX has no business relationship with such End Clients. CANNEX does not collect, access, store, disclose or use such Personal Information, except as directed by our Customers, Subscribers and their Users or as required by law. Customer or Subscriber and their Users are responsible for obtaining any consent necessary for the completion of a transaction. CANNEX is not responsible for the privacy practices of companies to whom it receives or sends Personal Information. CANNEX reserves the right to use anonymous data for any purpose in its sole discretion.
Information from Attendees at our Events
We may collect, use and store information that you provide us to register for CANNEX programs and events. For some events, we may make certain information of all event attendees available to other event attendees and event sponsors. The information made available may include name, employer, title, business address, and email address. This information is considered Business Contact Information and is not covered by this policy.
Information from Market Research Surveys
From time to time, CANNEX may conduct co-sponsored market research in order to enhance the provision of our services as well as our Customers’ products and services. Market research is generally conducted via online or telephone surveys and questionnaires in which Personal Information may be collected from respondents who voluntarily provide it (expressly consent). Respondents are not required to participate in these surveys or to provide the Personal Information requested. Companies and organizations that co-sponsor surveys may receive and distribute survey results without any personally identifiable information about respondents. Companies and organizations that co-sponsor surveys will be permitted to use underlying data for their own internal business purposes.
Information from CANNEX Website Visitors
In order for our Customer or Subscribers and their Users to use all of the features of the services on this site, it is necessary for CANNEX to collect certain information.
By signing up for a newsletter, requesting information and providing feedback or completing any other form on this site, the visitor agrees that CANNEX may collect, use, and store information provided for the applicable business purposes indicated on the page. CANNEX may use this information to provide other information, products or services (for example, on subsequent visits to this site or through an email subscription).
Information from Cookies and Similar Technologies
CANNEX logs IP addresses and browser types to analyze trends, administer this site and to gather demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
Sharing Information with Third Parties
We do not share, disclose, sell, rent or otherwise provide your information to third parties for marketing purposes or other business purposes.
We may use your information including Personal Information with our affiliates for purposes consistent with this Privacy and Security Policy. Our suppliers and contractors may have access to your Personal Information to perform certain business related functions such as providing email services and technology services to us.
We may use or disclose information with an individual’s knowledge or consent to protect our rights or interests or to resolve any disputes arising from the use of the services.
We may also share information with third parties when the collection, use or disclosure of Personal Information is permitted or required by law and for example in the following circumstances:
- disclose Personal Information to a government institution if we have reasonable grounds to believe that the information relates to a contravention of the laws of Canada, a province or a foreign jurisdiction
- disclose Personal Information made to another organization and is reasonable for the purposes of investigating a breach of an agreement or a contravention of the laws of Canada, or for the purposes of detecting or suppressing fraud or of preventing fraud
- use or disclose necessary Personal Information in association with a prospective business transaction (e.g. acquisition or merger) so long as the information is safeguarded and the information is returned or destroyed if the transaction does not proceed
Please note, if applicable, information may be collected, used, disclosed or processed outside your jurisdiction and may be subject to the laws of a foreign jurisdiction including but not limited to foreign governments, courts, law enforcement and regulatory agencies.
Retaining Personal Information
We will retain Personal Information only as long as necessary to fulfill the identified business purpose. Even if we return or destroy Personal Information it may persist on electronic backup or archival media made in the normal course of business for an additional period of time or for legal or tax reasons.
CANNEX is committed to maintaining an effective information security program in line with reasonable industry standards. CANNEX uses administrative, technical, and physical safeguards to protect:
- the security and confidentiality of information
- against any anticipated threats or hazards to the security or integrity of such information
- against unauthorized access to or use of information which could result in substantial harm or inconvenience to individuals.
CANNEX uses industry-standard security measures such as SSH and TLS. We will continually review and update our security policies and controls as technology changes to ensure ongoing security. We have entered into confidentiality agreements with our suppliers, agents, representatives and employees (“Representatives”) and our Representatives are expected to maintain the confidentiality of such information. CANNEX is not responsible for the data security practices of companies to whom it receives or sends Personal Information.
Please note that no transmission over the Internet can be 100% secure and thus, we cannot guarantee the security of Personal Information. Moreover, any unprotected electronic communication over the Internet is not secure or confidential, subject to possible interception or loss, and possible alteration. We are not responsible for and we shall not be liable for any damages in connection with any Personal Information contained in any unprotected email, text message or any other electronic message sent to us.
Any attempted or actual security breach shall be directed to CANNEX’s Manager of Information Security and legal counsel, which are responsible for determining response procedures, depending on the severity and nature of the event and applicable laws and regulations.
Depending on where you live, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing. Should there be a security breach that affects End Clients, the Customer or Subscriber shall be responsible for disseminating notice of such a security breach to those End Clients.
If you become aware of any vulnerability in our site or services, simply send us an email to firstname.lastname@example.org and we shall investigate the matter as soon as possible.
Control and Access to your Personal Information
If at any time you wish to be removed from any email or other list, simply send an email to email@example.com.
If at any time you wish to access your Personal Information, simply send us an email to firstname.lastname@example.org. A minimal fee may be charged and we may verify your identity prior to providing access to your Personal Information. Where a fee may apply, we will inform you of the cost and request further direction from you on whether or not we should proceed with the request.
If you believe that any Personal Information we are holding about you is incorrect or incomplete, simply send us an email to email@example.com. If applicable, we will correct any information found to be incorrect and notify any third parties as required by applicable laws.
IF YOU ARE A CLIENT OF ONE OF OUR CUSTOMERS OR SUBSCRIBERS AND THEIR USERS, AND YOU WANT TO EDIT OR DELETE ANY INFORMATION CAPTURED ABOUT YOU, YOU SHOULD CONTACT THE PERSON OR ENTITY DIRECTLY.
Questions and Complaints
We encourage you to contact us with any questions, concerns or complaints with respect to your Personal Information at the address listed herein.
CANNEX Financial Exchanges Limited
1200 Bay Street, Suite 1001
Canada M5R 2A5
Attention: Privacy Officer c/o Legal Department
Last Updated: October 1, 2018