THE SERVICE METHOD
Last Updated: [INSERT DATE PRIOR TO UPLOAD]
TYPES OF PERSONAL INFORMATION WE COLLECT
The term “personal information” means information about an identifiable individual, including name, address, email address, and other information about an individual.
- Information submitted by you, which may include, but is not limited to: first and last name, email address and telephone number;
- Log data, which may include, but is not limited to: Internet Protocol (IP) address, browser type, operating system, the web page that you visited before accessing our Website, the pages or features of our Website to which you browsed and the time spent on those pages or features, search terms, the links on our Website that you clicked on and other statistics; and
- Information sent by your device: device identifier, user settings, operating system, as well as information about your use of our Website.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.
As a general rule, TSM collects personal information directly from you.
In addition to the above, any information we collect or that you provide directly to us may be de-identified or aggregated with the information of other users in order to gain an understanding of the usage habits and preferences of our users and to assist us with the selection and adjustment of future content and features for the Website.
From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
WHY WE COLLECT, USE, AND DISCLOSE PERSONAL INFORMATION
- We may collect personal information from you for a variety of purposes, including to:
- establish, maintain and manage our relationship with you;
- enforce our Terms or any other agreement between you and us;
- review and improve the Website that we provide to you;
- comply with your requests;
- enable us to provide certain security and privacy safeguards;
- deal with security, debugging and technical support issues;
- protect us against error, fraud, theft and damage to our goods and property; and
- comply with applicable law or regulatory requirements.
HOW WE USE PERSONAL INFORMATION
Information Related to the Website
When you elect to register for the Website, you will be required to provide us with your contact information. We use this information to: (a) create your account during the registration process; (b) manage your account; and (c) to help us efficiently provide the Website. Additionally, in order to provide you with the Website, we will access and store information and data from your accounts. To the extent you add authorized users to your account (“Authorized Users“), we may collect information that you provide to us regarding those Authorized Users.
Our servers may automatically record your log data. We use this information to administer the Website and we analyze (and may engage third parties to analyze) this information to improve and enhance the Website by expanding their features and functionality and tailoring them to your needs and preferences.
We also use your personal information to contact you in connection with your use of the Website. We may use also use your personal information to tailor our Website to your interests and to track your compliance with our policies and terms.
Feedback, Questions and Comments
You may also provide us with feedback or a comment, question or complaint. We use this information to respond to you and may retain this information to assist you in the future. We also may use your feedback, comments, questions or complaints to monitor and improve our Website.
From time to time, we may also use your personal information to send you email or other communications that may be of interest to you and to tailor communications to your interests. You may opt out of any communications, other than communications necessary as part of any Website you use, by using the “Unsubscribe” mechanism or otherwise contacting us as set out in the “How to Contact Us” section below.
Information Collected Using Cookies and other Web Technologies
DISCLOSURE OF PERSONAL INFORMATION
Information Shared with Third Parties
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.
Information Disclosed in Connection with Business Transactions
We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of TSM or as part of a corporate reorganization or stock sale or other change in corporate control.
Information Disclosed for Our Protection and the Protection of Others
We and our service providers may provide your personal information in response to a search warrant or other legally valid enquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, United States or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims or to prevent actual or suspected loss or harm to persons or property.
In addition to the above, we may disclose your personal information with your consent for specific purposes that we advise you at or before the time we collect such personal information.
HOW WE SAFEGUARD PERSONAL INFORMATION
TSM endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.
The security of your personal information is important to us. Please immediately advise us at [INSERT EMAIL] of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
While TSM makes good faith efforts to safeguard your personal information and to secure your data during use of the Website, no transmission of data over the Internet, wireless network, or any other public network can be guaranteed to be 100% secure. In addition, if you are visiting, using or interacting with our Website from a country other than Canada, your personal information may be transferred to, and maintained on, computers located outside of your country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. TSM cannot ensure or warrant the security of any information that you transmit to us and we do not take any responsibility for any breach that may occur.
RETENTION OF PERSONAL INFORMATION
We retain personal information of users for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
YOUR CONSENT IS IMPORTANT TO US
In addition, you may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us at [INSERT EMAIL]. In some circumstances, a change in or withdrawal of consent may severely limit or even prevent our ability to provide our Website to you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to [INSERT EMAIL].
UPDATING YOUR PERSONAL INFORMATION
You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to limited exceptions prescribed by applicable laws. You may do so directly by updating your account or by emailing us at [INSERT EMAIL].
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
HOW TO CONTACT US
[INSERT MAILING ADDRESS]
ATTN: PRIVACY OFFICER