Last revised: August 12, 2018
At Foresight Retail Solutions, we are committed to protecting your privacy and safeguarding your personal, business and financial information. This Privacy Statement applies to Foresight Retail Solutions respective affiliates (collectively, “Foresight”, “we” or “our”).
The purpose of this Privacy Statement is to inform you about the types of Personal Information, as defined below, that Foresight collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.
As we are a national organization, this Privacy Statement is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and the regulations thereunder (“PIPEDA”) as
well as applicable provincial privacy legislation and regulations, including but not limited to, the Personal Information Protection Act (British Columbia), the Personal Information Protection Act (Alberta), the Personal Health Information Protection Act (Ontario) and An Act respecting the protection of personal information in the private sector (Quebec).
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page.
We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected and our Privacy
1. What is Personal Information?
“Personal Information” is any information that is identifiable with you, as an individual. This information may
2. How do we collect your Personal Information?
We will always collect your Personal Information by fair and lawful means (for example, when you engage us to provide services, use the Foresight website or speak to a Foresight representative). We collect Personal Information directly from you, or indirectly from third-party sources as otherwise permitted by applicable law.
From time to time, you may voluntarily provide Foresight with unsolicited Personal information (e.g. by providing information through the Foresight websites). If you do wish to provide such information for any reason, you consent to Foresight using that information in the ways described in this Privacy Statement or as described at the point where you choose to disclose this information.
Log files: In order to properly manage our website, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters and are generally non-identifiable.
Web beacons: To gather visitor statistics and manage cookies, we use electronic images called a “single-pixel GIF” or “web beacon.” Web beacons allow our third-party tracking tools, Adobe Analytics, Google Analytics
Marketing Automation: In order to provide you with the most personalized experience and give you access to products and services that are most relevant to you, Foresight uses marketing automation tools such as Oracle Eloqua to deliver targeted marketing campaigns across multiple Foresight platforms (e.g. via web, email, mobile, etc.) and create customer profiles by tracking your behavior and preferences while using Foresight platforms. All of Foresight’s electronic marketing activities are done in accordance with applicable legislation, including Canada’s Anti-Spam Legislation.
Finally, Foresight understands the importance of protecting children’s privacy online. The Foresight websites covered by this Privacy Statement are not intentionally designed for or directed at children 13 years of age or younger. It is Foresight’s policy never to knowingly collect or maintain information about anyone under the age of 13.
3. Where do we store your Personal Information?
Personal Information provided to us by our clients is primarily stored on servers in Canada. However, except where restricted by contractual arrangements or legal requirements applicable to specific clients, Foresight also may leverage the services of select service providers. Personal Information that is “in the cloud” may be stored on multiple servers in a number of locations around the world. Rest assured that Foresight has taken appropriate steps for the protection of Personal Information handled by our service providers. However, information transmitted to other countries may be subject to the laws and lawful disclosure requirements of the jurisdiction(s) where the information is stored.
4. How do we use your Personal Information?
We generally use your Personal Information for the following purposes (the “Purposes”):
• to provide you with professional services;
• to process and deliver products that you have ordered from us;
• to invoice and collect payment for professional services and products provided by us to you;
• to develop and maintain our relationship with you and communicate with you;
• to register you for events and conferences;
• to register you for, and facilitate your participation in, certain areas of our website, including our online bulletin boards, discussion or message forums;
• to research, develop, manage, protect and improve our professional assurance, tax or advisory services;
• to assist Foresight with improving its operational efficiency, marketing campaigns and customer service efforts through the use of data analytics;
• to gather your opinion and feedback through surveys;
• to enroll you in our contests or promotional programs;
• to process your application for employment and resume;
• to advise you about new products and services that may be of interest to you (Please note that in accordance with Canada’s Anti-Spam Legislation, you can choose not to receive any electronic marketing communications from us by clicking the “opt out” function contained in all Foresight electronic communications. You may choose not to receive any direct mail from us by contacting our Chief Privacy Officer as indicated in the “Contact Us” section below); and
• such other uses as may be permitted or required by applicable law.
We identify the purposes for which we use your Personal Information at the time we collect such information from
5. To whom do we provide your Personal Information?
We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.
For example, we may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes — such as service providers that provide telephone support or data storage or processing.
Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all of the business of Foresight or as otherwise permitted or required by law, in which case the use of your Personal Information by the new entity would continue to be limited by applicable law.
In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. These other jurisdictions may include the United States, India, United Kingdom, Mauritius, Uruguay or the jurisdiction of any other Foresight network firm (as per our engagement letters which allow us to draw on the resources of other firms), which latter jurisdiction(s) may be identified upon request.
To the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is
6. When and how do we obtain your consent?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your express consent to us either orally, electronically or in writing.
You may also consent to Foresight’s collection, use and disclosure of Personal Information by voluntarily providing us with Personal Information through a clear, affirmative action (e.g. by submitting an information request, participating in a survey, etc.). Foresight may also rely on your implied consent to the collection, use
We will not, as a condition of the supply of our professional services or products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.
With respect to our websites, should visitors subsequently choose to unsubscribe from mailing lists or any registrations, visitors may contact the webmaster of the appropriate site e.g. webmaster@Foresight.com.
7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
We ensure that all affiliates and other third parties, including Foresight member firms, which are retained to perform services on our behalf and are therefore provided with Personal Information are contractually required to observe the intent of this Privacy Statement and Foresight’s privacy and data security policies and practices.
8. How long will we use, disclose or retain your Personal Information?
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected, or as permitted or required by law.
9. How can you access your Personal Information that we have collected, utilized or disclosed?
If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally
10. How do you know that the Personal Information we have on you is accurate? provide your Personal Information?
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal
11. What if the Personal Information we have on you is inaccurate?
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
12. How fast will we respond to your written requests?
We will respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.
If you do not notify us within such thirty (30) day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within thirty (30) days. If, after the expiry of this second thirty (30) day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.
14. How do we know that it is really you requesting your Personal Information?
We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
15. What safeguards have we implemented to protect your Personal Information?
We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Marc Leveille, Chief Privacy Officer
675 Cochrane Dr, Suite 103,
Markham, ON L3R 0B8