Last Modified: December 2023
In this Policy, “personal information” means identifying information, such as your name, home address or contact information (including home telephone number and personal e-mail address). Please note that not all information that you share with us is considered personal information: for example, business contact information is not considered personal information.
We comply with all applicable privacy legislation, including the Personal Information Protection Act (British Columbia) (“PIPA”), and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) as is appropriate in the circumstances.
What Personal Information We Collect
We may collect and process personal information through our Website, in the course of providing our Services and during interactions such as newsletters, seminars etc. We collect your personal information in various ways, including through direct interactions with you through forms or correspondence, and through automated technologies, such as cookies, as you navigate our Website. The type of information we may collect includes:
- Personal information such as first and last name;
- Contact information physical address, email address and telephone number;
- Biographical information such as job title, employer, photograph and video or audio content;
- Marketing, communication preferences and related information such as feedback and survey responses;
- Billing and financial information such as billing address, bank account and payment information;
- Services information such as details of services that we have rendered to you;
- Recruitment information such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment or association to or with us;
- Website usage and other technical information such as details of visits or information collected through cookies, your interaction with our online advertising and content and other tracking technologies;
- Information provided to us by or on behalf of our clients or generated by us in the course of providing our Services, which may, where relevant, include special categories of personal information (such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sexual orientation, etc.);
- Identification and other background verification data such as a copy of driver’s licence, passports or utility bills or evidence of beneficial ownership or the source of funds to comply with anti-money laundering laws and collected as part of our client acceptance and ongoing monitoring procedures;
- Any other personal information provided. Please note that if you provide personal information to us about other people (such as your customers, directors, officers, shareholders or beneficial owners), you must ensure that you have given those individuals an appropriate notice that you are providing their information to us and have obtained their consent to that disclosure; and
- Where applicable, records of consent given to us (date, time, means of consent), in circumstances where such consent is need for the processing of personal information.
When an individual visitor accesses our Website, we may use a browser feature called a ‘cookie’ to collect information such as the type of internet browser and operating system the visitor uses, the domain name of the site from which the visitor came, date and duration of the visit, the number of visits, the average time spent on our Website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor, to our computers each time our Website is visited. Unless a visitor specifically informs us (e.g. by sending us correspondence from our Website), we will not know who the individual visitors are.
Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. If you are using our Website and have not set your browser to reject cookies, you are considered to have consented to their use. If you refuse to accept cookies please note that you may have difficulty using certain features of our Website.
Note that we may also collect non-personal information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
How We Use Your Personal Information
Personal information collected by us is used only for the purposes described in this Policy, or for other purposes which are disclosed to you and to which you consent.
We may use your personal information in a variety of ways. Specifically, we may use your personal information:
- To provide our Services and to conduct our business, to administer and perform our services, including to carry out our obligations arising from any agreements entered into between you and us;
- To respond to requests for information or enquiries from visitors to the Website;
- To facilitate use of the Website and to ensure content is relevant and to ensure that content from the Website is presented in the most effective manner for you and for your device;
- For marketing and business development purposes – to provide details of new services, legal updates and invitations to seminars and events where an individual has chosen to receive these;
- For research and development purposes (including from a security perspective) – analysis in order to better understand our clients’ services and marketing requirements and to better understand our business and develop our services and offerings;
- To fulfil our legal, regulatory, or risk management obligations – to comply with our legal obligations (performing client due diligence/“know your client”, anti-bribery, sanctions or reputational risk screening, identifying conflicts of interests);
- To fight against fraud and/or other relevant background checks, notably as may be required by applicable law and regulation and/or best practice at any given time (if false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them);
- To enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties;
- To ensure that we are paid – to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings); and
- To reorganize or make changes to our business – In the event that we undergo a reorganization (for example if we merge, combine or divest a part of our business), we may need to transfer some or all of personal information to the relevant third party (or its advisors) as part of any due diligence process or transfer to that reorganized entity or third party your personal information for the same purposes as set out in this Policy or for the purpose of analyzing any proposed reorganization.
In addition to the identified purposes described in this Policy, we may use personal information and share it with other organizations with whom we have a commercial relationship to measure the use of our Website, to improve the functionality and content of our Website and to facilitate usage by visitors.
How We Disclose and Share Your Personal Information
We disclose may personal information:
- to third parties, where disclosure is necessary to provide legal services to you, including foreign agents, government, regulatory agencies, or law firms retained to act on your behalf, experts, consultants or as part of a proposed or actual transaction, such as a financing or other business transaction;
- to our service providers, inside or outside Canada, who assist us with marketing or other services, including mailing or payment processing services. We use reasonable measures to require our service providers to use your personal information only to perform the applicable services;
- where we are required or authorized by law to do so, for example, where the rules of court require us to provide personal information to the opposite side and the court in a litigation matter, where we are required to respond to a government or regulatory request, or where a court issues a subpoena or order;
- to third parties, where it is necessary to collect fees, for instance, to a financial institution or collection agent;
- to anyone who we reasonably believe is your agent;
- to third parties where you have instructed us to disclose your personal information to such parties;
- to our insurers or regulatory agencies (including our governing law societies) to comply with our professional and ethical obligations related to the practice of law;
- in accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MT+Co.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MT+Co. about our customers and users is among the assets transferred;
- if we believe disclosure is necessary or appropriate to protect the rights, property or safety of MT+Co., our customers, or others, including where necessary for the purpose of fraud protection and credit risk reduction; and
- where you consent or as otherwise permitted or required by law.
We may transfer personal information that we collect or that you provide as described in this Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this Policy.
Where We Store and How Do We Transfer Your Personal Information
Your personal information is stored in secured locations and on servers controlled by us located either at our offices or at the offices of our service providers. When we transfer your personal information to a third party to provide administrative and other services, we use appropriate measures to ensure that the third party will only use your personal information to perform the services we have specified. The global nature of our business sometimes requires us to use administrative service providers who may be located outside of Canada. Accordingly, your personal information may be transferred outside of Canada. We require that our service providers privacy and security standards be consistent with or no less protective than this Policy and in compliance with all applicable Canadian legislation. By submitting your personal information or engaging with our Website, you consent to this transfer, storage, or processing.
How We Secure Your Personal Information
The security of your personal information is very important to us. We have policies and procedures in place to protect your personal information from loss, unauthorized access, modification or disclosure. In addition, we operate out of secure premises and have implemented technological safeguards including security software, passwords and firewalls to prevent unauthorized computer access.
Please note that no method of transmitting or storing information is completely secure. While we take appropriate measures to protect your personal information, there is always a risk that it may be lost, intercepted or misused. We may exchange electronic versions of documents and e-mails with you using commercially available software that is vulnerable to attack by viruses and other destructive electronic programs. We cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be virus free. We make no warranty with respect to the integrity of any electronic communications between us and you or with respect to the security of any such communication and you consent to our exchange of electronic communications, including confidential documents, unencrypted. If you believe personal information has been compromised, please contact us as set forth in the “Contact Us” section.
How Long We Store Your Personal Information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Consent and Control Over Your Personal Information
It is important to us that we collect, use or disclose your personal information only where we have your consent to do so or as provided in this Policy. Depending on the sensitivity of the personal information, your consent may be express, implied or deemed. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you. If you choose to provide any personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this Policy.
Consent to the collection, use and disclosure of personal information by us may be implied by the fact that you have engaged us to provide Services, where the collection, use and disclosure of personal information relates to the performance of those Services. If you provide personal information about another person to us, we assume you have the consent of that individual to enable us to collect, use or disclose their information as described in this Policy.
If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered.
We may also collect, use or disclose your personal information without your consent, for example, to collect a debt you owe to us or to comply with applicable laws or court orders.
We assume, unless you advise us otherwise, that by receiving a copy of this Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your personal information as explained in this Policy.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer (see Contact Us). Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide some or all of our Services.
Under certain circumstances, and in accordance with applicable data protection laws, you have the you may have the following rights:
- Access: entitled to ask if we are processing information and, if we are, request access to personal information. Subject to applicable law and, where applicable, payment of a possible fee, this enables the individual to receive a copy of the personal information we hold and certain other information about him or her or it;
- Accuracy: we are required to take reasonable steps to ensure that the personal information in our possession is accurate, complete, not misleading and up to date; and
- Correction: entitled to request that any incomplete or inaccurate personal information we hold be corrected.
We reserve the right to make changes to this Policy at our sole discretion at any time without notice to you. We will post a notice on our Website homepage if we make material changes to how we treat our users’ personal information, however we encourage you to check this Policy as it exists at the time, each time you use our Website.
Please send any questions, comments, and requests regarding this Policy and our privacy practices to:
MT+Co. Privacy Officer
300 - 638 Smithe Street
Vancouver, BC V6B 1E3
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this Policy, and with applicable privacy laws. To discuss these procedures, please contact our Privacy Officer using the contact information listed above.