Privacy Policy
Policy on the Collection, Use and Disclosure of Personal Information (“Privacy Policy”)
Pronto Commissions recognizes the importance of privacy and the sensitivity of personal information. As a company providing financial services, we have an obligation to keep confidential all personal information we receive. We are therefore committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the financial services we provide. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.
Who We Are
Pronto Commissions is a private company providing a wide range of financial and real estate services. In so doing, we may utilize the services of consultants and agencies that may, in the course of their duties, have limited access to the personal information we hold. These include computer consultants, bookkeepers, accountants, file storage companies, web site managers, maintenance staff and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they will follow appropriate privacy principles.
What is Personal Information?
Personal information is information that identifies you or by which your identity could be deduced. Personal information includes information that relates to your personal characteristics (e.g., gender, age, income, home address, phone number etc.)
We Collect Personal Information
We collect information only by lawful and fair means and not in an unreasonably intrusive manner. Whenever possible we collect your personal information directly from you at the start of our relationship and during the course of our dealings with one another. However, in some cases, we may obtain information about you from other sources such as:
- your bank, financial institution or financial lender
- from a government agency or registry
- your employer
To help us make credit decisions about clients, prevent fraud, check the identity of new clients and prevent money laundering, we may on occasion also request information about you from the files of consumer reporting agencies such as credit bureaus.
Consent
In most cases we will request your consent to collect, use or disclose your personal information. While we may request your consent in writing, in some circumstances we may accept your verbal consent or consent may be implied through your conduct with us.
Use of Personal Information
Like all financial service companies, we collect, use and disclose personal information in order to provide services to our clients.
However, we also use personal information to:
– administer our databases;
– invoice clients for services and collect unpaid accounts;
Disclosure of Personal Information
Under certain circumstances, Pronto Commissions will disclose your personal information. These circumstances include the following:
- when you have consented to the disclosure;
- when we are required or authorized by law to do so (e.g. by court subpoena);
- when the services we are providing to you requires us to give your information to third parties (e.g. a solicitor) In such a case, your consent will be implied unless you advise us otherwise;
- where it is necessary to establish or collect accounts;
- if we engage a third party to provide administrative services to us (such as computer back-up services or file storage);
- if the information is already publicly known.
Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If during the course of our relationship, any of your information changes, please inform us so that we may update our records accordingly.
Protecting Personal Information
We understand the importance of protecting your personal information. Pronto Commissions therefore takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. For that reason, we have taken the following steps to protect your information:
- The premises are equipped with adequate security;
- File access to personal information is restricted;
- Technological safeguards have been put in place to prevent unauthorized computer access;
- Certain information is maintained in locked filing cabinets to which access is limited;
- Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy;
- External consultants and agencies with access to personal information must agree to be bound by our Privacy Policy.
Retention and Destruction of Personal Information
It is necessary to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. Our customer and contact directories are updated as often as possible, and contact names and information are deleted as necessary. If you wish to be removed form our directory, please contact us and we will ensure that the information is removed promptly. We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and when hardware is discarded, we ensure that the hard drive is physically destroyed. Alternately, we may send some or the entire client file back to the client.
You Can Look At Your Information
With a few exceptions, you are entitled upon request, to access any personal information we hold about you. Summary information is available free of charge. However, more detailed requests which require copying of documentation or archival retrieval may be subject to our normal recovery policies.
Correcting Errors
If you believe that there is a mistake in the personal information maintained by our company , you have the right to ask that it be corrected. This applies to factual information only and not to any professional opinions we may have formulated. To assist us in correcting any errors, we may ask you to provide us with supporting documentation. Where a mistake has been discovered, we will make the correction and notify anyone to whom we have sent the information. If we refuse your request to correct certain information, we will advise of our reasons for doing so.
Denial of Access To Personal Information
Your rights to access your personal information are not absolute. We may deny access when:
- denial of access is required or authorized by law (such as when a record containing personal information is subject to a claim of legal professional privilege);
- information relates to existing or anticipated legal proceedings against you;
- granting you access would have an unreasonable impact on another person’s privacy;
- to do so would prejudice negotiations with you;
- to protect our firm’s rights and property; or
- the request is frivolous or vexatious.
If we deny your request for access to personal information we will explain our reasons for doing so in writing.
Web Site
Our web site may contain links to other sites which are not governed by this Privacy Policy.
On our web site, like most other commercial web sites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.
Do You Have A Concern?
If you have any questions related to this Privacy Policy please write to us at:
Pronto Commissions
386 Berkley Street
Winnipeg, MB.
R3Y 1J6
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer who will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
For more general privacy inquiries, or if you are not satisfied with our response to your privacy questions or complaints, you may contact the Information and Privacy Commissioner of Canada who oversees the general administration of privacy legislation. The Information and Privacy Commissioner can be reached at:
112 Kent Street
Ottawa, ON
K1A 1H3
Phone: (613) 995-8210
Toll Free: (800) 282-1376
Fax: (613) 947-6850
Web Site: https://priv.gc.ca