Version 1.0 (July 21, 2021)
OUR COMMITMENT TO PRIVACY
Circular Materials is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. Circular Materials shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
Circular Materials shall implement policies and practices to give effect to these principles, including:
III. THE INFORMATION WE COLLECT
Personal Information that Circular Materials collects includes, but is not limited to:
The categories of Personal Information you provide may include:
Circular Materials collects non-Personal Information (“NPI”) about Users when they interact with the Site or use our services. For instance, NPI may include, but is not limited to, browser name, type of computer or device, and technical information about a User’s means of connecting to the Site, such as operating system, Internet service provider utilized, and mobile network information. See the section below entitled “How does Circular Materials collect, use and share NPI?” for more information.
Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any other User. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.
IV. HOW DOES CIRCULAR MATERIALS USE PERSONAL INFORMATION
Circular Materials collects Personal Information for the following purposes:
V. HOW DOES CIRCULAR MATERIALS COLLECT, USE AND SHARE NPI?
Circular Materials uses NPI in an ongoing effort to better understand and serve our customers and to improve the content and functionality of our Site.
No NPI by itself, or together with aggregated Personal Information, can be tracked to a specific individual's Personal Information.
Circular Materials respects your privacy and, unless otherwise required by law, Circular Materials will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing Circular Materials with Personal Information to register is implied consent to use such information to provide you with the services.
Where appropriate, Circular Materials will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Circular Materials wants to use information for a purpose other than those identified above). In obtaining consent, Circular Materials will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by Circular Materials may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Circular Materials shall take into account the sensitivity of the Personal Information and the reasonable expectations of Circular Materials’ Users. Circular Materials will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, you must provide notice to Circular Materials in writing.
VII. LIMITING USE, DISCLOSURE AND RETENTION
Only Circular Materials’ employees, agents, contractors, service providers (and their employees and contractors) with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about you. All such employees and contractors will be required as a condition of employment to contractually respect the confidentiality of Circular Materials Users’ Personal Information.
Circular Materials will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Circular Materials.
Circular Materials will disclose Personal Information without your knowledge or consent if Circular Materials receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your Personal Information. If Circular Materials receives a written request from a police officer or other law enforcement agency with authority to request access to your Personal Information in the course of an actual or potential investigation into a breach of a law, Circular Materials’ policy is to provide the requested information.
VIII. COOKIES & OPT-OUT
In order to improve the Site, Circular Materials may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive. Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. Circular Materials may generate reports based on the use of these technologies an aggregated basis.
You are able to disable cookies directly in your website browser. Visit www.AboutCookies.org for information. If you reject cookies, you may still use the Site, but your ability to use some features or areas of our site may be limited.
IX. HOW CAN I ACCESS MY PERSONAL INFORMATION
Upon request, Circular Materials will provide you information regarding the existence, use and disclosure of your Personal Information and you will be given access to that information. Circular Materials will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, Circular Materials may not be able to provide access to all of your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Circular Materials will provide the reasons for denying access upon request.
We have implemented administrative, technical and physical measures to safeguard your Personal Information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access of Personal Information. This includes:
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit Personal Information to us using our Site if you consider that information to be sensitive.
XI. INQUIRIES; CHALLENGING COMPLIANCE
Circular Materials will respond to all such inquiries or complaints within 14 business days of receipt. Circular Materials will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Circular Materials finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact Circular Materials’s Privacy Office as follows:
800-1881 Yonge Street
XII. STORAGE OUTSIDE OF CANADA
Your Personal Information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your Personal Information. However, if your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
XIII. CHILDREN AND MINORS
The Site is not directed to children under the age of 13 years. Circular Materials will not knowingly collect Personal Information about a child under the age of 18. Circular Materials does not allow minors (persons who are under the age of majority in their place of residence) to use the services provided on the Site.