Privacy Protection Policy
This Privacy Protection Policy applies to Highness Global Inc. and to Highness Global Capital Inc. (collectively, Highness, we, us, or our) including all of the services offered through the Site (Services) and sets out the privacy policies and practices for Highness, including a description of how we collect, use, share, store, manage, and disclose Personal Information (as defined below) submitted to us through the Site. Specifically, this policy outlines how Highness complies with provincial and federal regulations governing client information including the Privacy Act and the Personal Information Protection and Electronic Act (PIPEDA).
PIPEDA is the Canadian federal privacy legislation established in January 2004. Under PIPEDA no business may collect, use or disclose personal client information without clearly defining the purpose of such collection, use or disclosure and obtaining informed consent. The collection, use or disclosure is limited to purposes that a reasonable person would consider appropriate in the circumstances. The legislation further regulates the protection, retention and destruction of client information. PIPEDA offers clients the right to access their information upon request and challenge the information that is being retained.
“Personal Information” is any information about an identifiable individual. Highness recognizes the sensitivity of Personal Information and ensures that it should only be collected and retained for legitimate purposes and be handled with care and respect. In providing our Services it will be necessary to collect and use Personal Information about our clients.
Highness is committed to respecting your privacy rights. Our Privacy Protection Policy ensures that all of your Personal Information is handled properly with procedures in compliance with all federal and provincial requirements. To the best of our ability it will remain confidential and secure. Highness shall not collect, use, or disclose any Personal Information about any party, including you, (each, an Individual, Client or you) without that Individual’s knowledge and consent, except as herein provided or as may be specifically permitted or required by applicable law.
Our clients rely on us to safeguard their personal information and ensure its responsible collection and use. To do so, we have committed to the following principles:
- We will be transparent about how we handle your personal information and our privacy practices.
- We will use your personal information to benefit you and enhance client experience.
- We will protect your personal information and handle it responsibly.
Below is the full Highness Privacy Protection Policy for more information.
Please read this Privacy Protection Policy carefully.
By using our Site and Services, you agree to be bound by and accept our consent to the collection, use and disclosure by Highness of your Personal Information for the purposes described in this Privacy Protection Policy. Your consent will be effective from the date that you begin using our Site and Services until the date that you withdraw consent. You can always choose not to provide us with any of your Personal Information. However, if you make this choice, we may not be able to provide you with the Services that you request.
OUR PRIVACY OFFICER
Inquiries and complaints will be reviewed and dealt with in a reasonable and timely fashion. Specifics steps of Highness’s privacy complaint recourse process are:
- All complaints are directed to the Privacy Officer who will maintain a detailed file on the complaint.
- The complainant will be notified of receipt of the complaint. All other applicable parties will be provided notice as well.
- The Privacy Officer will conduct an investigation to gather all necessary facts pertaining to the complaint.
- Following the investigation, the Privacy Officer will make a determination that either no other remedy than a clear explanation to the client is warranted or that the complaint is substantiated and as such, specific action is required by Highness. Some examples of specific Highness recourse include implementing additional safeguards, employee training and documentation revision.
The client will be advised of the decision in writing with details of the findings and subsequent recourse action, if any. Where applicable, a formal apology will be issued by Highness or a third party for the mishandling of client information.
Clients who remain dissatisfied with the results can bring the complaint to the attention of the federal Privacy Commissioner who is the ombudsperson for complaints under PIPEDA at: Officer of the Privacy Commissioner at 112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario K1A 1H3. The request must be made in writing and include full contact details and as much detail as possible about the complaint.
Highness’s Privacy Protection Policy is intended to provide clients with comfort that their personal information is handled with the utmost importance and care. Highness is continually balancing clients’ right to privacy with the needs of the business and therefore, welcome any feedback on how privacy protection policies and procedures can be improved.
Any questions regarding this Privacy Protection Policy or complaints about Highness’s use or handling of Personal Information may be directed to Highness’s Privacy Officer (Privacy Officer) at firstname.lastname@example.org.
A. Collection and Use of Personal Information General
Highness collects and uses Personal Information in a lawful manner and only when it is reasonably necessary to do so for the provision of requested information or as may be required or permitted by applicable laws. This information is generally provided voluntarily by an Individual in applying for information on our Site.
Highness collects different types of Personal Information including but not limited to: name, contact information, age, financial information, social insurance number and personal email. Client information may be in paper or electronic form.
Highness will collect and retain Personal Information for a number of purposes including to: determine a client’s identity, provide services to clients, administer client accounts, establish and manage relationships (including conducting client evaluations and assessments), provide client communications and other commercial reasons.
The collected Personal Information will be used only for the stated purpose, a requisite ancillary purpose, or for such other purposes to which the Individual may later consent. Highness does not sell or rent client information – under any circumstances. We do not transfer collected information to competitors.
Consent for the collection, use, and disclosure of Personal Information may be express or implied, physical or electronic, given in writing, orally, or by toggling a check-off box, or by inference from the Individual’s conduct, such as (without limitation) by use of the Services or Site. The purpose of collection of personal information is for the sole purpose of providing services and in order to adequately communicate information.
All information concerning clients and their accounts are confidential and will not be disclosed to unless the intended purpose is disclosed. Should client information be required for a new purpose, Highness will take the necessary steps in order to seek additional consent.
Consent may be expressed in writing, orally or implied directly by the client. In most cases consent is obtained via provision of business cards, written agreement, applications, registration to events and/or by attendance. All client information collected by Highness will be kept confidential and shall not be disclosed to any third party, except for the specific reasons expressly identified or if the client has provided express consent.
Consent to use personal information may be withdrawn by a client at any time.
PERSONAL INFORMATION POSTED BY THE INDIVIDUAL
From time to time, Highness may offer interactive services which allow an Individual to share information with other Individuals on the Site, such as message boards, user reviews, or similar functions. These features may permit an Individual to publish Personal Information about him or herself or about another individual, although Highness does not encourage any Individual to share any Personal Information publicly online. By submitting such information, the Individual represents:
- that the Individual consents to its collection, retention, and public disclosure by Highness in accordance with this Privacy Protection Policy; and
- that the Individual has obtained the same consent from any other Individual whose Personal Information is being posted, as applicable.
Highness does not monitor, or moderate information submitted or posted by the users of the Site and accepts no responsibility or liability for any content, including without limitation, Personal Information, posted in this way.
It is important for Highness to keep client information accurate in order to provide quality service and minimize the potential for misuse. We strive to keep client information correct, complete and up-to-date. Clients may be contacted periodically to ensure information is accurate on file. Clients are requested to advise Highness of any changes to client information, as Highness is not liable for errors that cannot be corrected without client input. Should an inaccuracy be found, we will act efficiently to correct it at no cost to the client.
If an Individual believes that his or her Personal Information has been posted by a third party without consent, that Individual should contact Highness at email@example.com to notify us so that the complaint may be investigated and the content removed if it is appropriate to do so.
Our Site, like many other websites, uses passive-tracking technologies such as “Cookies”. “Cookies” are small bits of information that are transferred to and stored in separate files within your computer or phone’s browser and are used on this Site to collect information. A cookie will not collect any information that is not otherwise provided to us. Cookies allow a Site to identify repeat visitors through an ID number cached in that computer. Cookies can be disabled or cleared using the tools of any web browser. Individuals should consult the instructions in their own web browser to learn about the options to disable cookies.
B. Personal Access
Individuals are entitled to access and review their Personal Information held by Highness. However, an Individual’s right to access is not absolute and may be subject to legal restrictions such as if providing access to the personal information would impede a criminal investigation or result in the disclosure of other protected information.
Highness may also deny an Individual’s request to access if granting access would have an unreasonable impact on other people’s privacy or where the requested information cannot be severed from the balance of the record in which it is contained. Access will not be provided to information that has been destroyed or is too costly to retrieve. We will make a reasonable effort to respond within a reasonable timeframe to all such requests for access and revision and either provide access to the Personal Information or, if permissible, explain why access is denied.
It is important for Highness to maintain accurate Personal Information about an Individual in order for us to provide efficient and effective delivery of information. Individuals may contact the Privacy Officer using the contact information provided above to modify or correct any Personal Information that Highness holds about them.
Highness will respond to requests for access in writing within 30 days of receipt. Corrections will be made within a reasonable timeframe.
Requests for access to Personal Information should be made to firstname.lastname@example.org .
C. Disclosure of Personal Information General
To provide our Services, Highness may need to disclose Personal Information to certain third-party agents or service providers. Personal Information may also be provided to Highness’s professional advisors in connection with our business operations, for example, where Highness’s business undergoes a fundamental business change such as a sale, financing, merger, or a transfer of all or a portion of our business or assets. In any such case, Highness shall ensure that any such parties accessing your Personal Information have appropriate safeguards in place to reasonably ensure the protection of your Personal Information.
Highness shall not otherwise disclose Personal Information to third parties for commercial or other reasons, except as may be specifically required to comply with applicable laws. Except as may be specifically provided in this Privacy Protection Policy, Highness will obtain an Individual’s consent prior to disclosing any Personal Information or otherwise using Personal Information for purposes other than those for which it was explicitly or implicitly given.
DISCLOSURE IN COMPLIANCE WITH LAW
Highness may also disclose Personal Information to establish or exercise our legal rights or defend against legal claims or in connection with an emergency that warrants use or disclosure of the information.
It may also be necessary for Highness to disclose Personal Information to law enforcement officials, regulatory bodies, government agencies; law enforcement agencies; securities commissions; law societies; other self-regulatory organizations (SRO’s); or under a court order. Express consent will not be required if needed for: audit, statistical or record-keeping purposes; a legal reason or request by securities or legal regulatory authorities or SRO; to collect a debt owed by the client; to a legal professional for the purposes of obtaining legal advice; and pursuant to a court order. Should Highness be asked to produce confidential information by any such entity, we will comply. In some cases, Highness may provide information on its own initiative if there are reasonable grounds to believe crime or a violation of applicable regulation is involved.
Such Personal Information includes:
- the client’s given name, surname, date of birth and gender; and/or
- contact information including the client’s mailing address, phone number, and email address, as applicable.
USE OR DISCLOSURE FOR RESEARCH PURPOSES
In order to improve our processes and Services, Highness may from time to time make use of aggregated and non-identifying information (Aggregated Data) for research purposes. Such purposes include, without limitation, better understanding the needs and wants of our clients and users. Highness may disclose such Aggregated Data, which will not personally identify any Individual, to our affiliates, agents, service providers and business partners for these purposes.
D. Retention and Security
Client information will only be used for the purposes for which it was collected. Highness may share client information with authorities for regulatory or tax reporting purposes. Information may also be shared with legal bodies, SROs and other authorities for reasons previously discussed. Client information may also be shared with external service providers or strategic partners/affiliates (upon verbal consent by the client).
Highness will not retain any Personal Information longer than is necessary to fulfill the purpose(s) for which the Personal Information was provided or as may be required by any federal or provincial record keeping requirements, whichever is longer. This may involve the retention of your Personal Information for a period exceeding your actual relationship with Highness. Once your Personal Information is no longer required to fulfill the stated purpose or to comply with applicable laws, it will be either destroyed or rendered anonymous.
We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical and technical safeguards.
Threats to Personal Information include loss, misuse, theft, inadvertent disclosure, and improper modification. At all times, Highness employs reasonable physical, technical, organizational, and digital precautions to safeguard your Personal Information. Highness restricts access to Personal Information to authorized personnel who are appropriately trained to handle Personal Information.
E. Opt Out
Canada’s Anti-Spam Legislation (CASL) regulates commercial electronic messages, including without limitation, emails, newsletters, updates, and offers and text messages (a CEM). In compliance with CASL, Highness will not send CEMs without the express or implied consent of an Individual. Any Individual who wishes to revoke their consent may opt out of receiving future CEMs by following the conspicuous unsubscribe mechanism contained in each CEM in accordance with CASL or by contacting the Privacy Officer as described above. Any such opt-out will not apply to any communications that are required by law.
F. Links to Other Websites
G. Social Media
As part of the Services we offer, Individuals can interact with Highness through various social media platforms such as LinkedIn. Although these platforms are a unique and interactive way to communicate with all types of users, all communications on these third-party platforms are public and not subject to this Privacy Protection Policy. As a result, Highness cannot protect the information, including Personal Information, which an Individual chooses to post on such third-party platforms.
Please ensure that you read and respect the guidelines for each of these third-party platforms.
Updates to this Privacy Protection Policy
Please check back periodically for updates.