Privacy Policy

INTRODUCTION

RONCO is committed to protecting the personal information that we collect, use and disclose in the course of providing business services and running our manufacturing operations, in accordance with all applicable regulatory requirements, including applicable privacy legislation, and consistent with our professional obligations. We have professional and ethical obligations to maintain information we have received within our client relationships in confidence. This Privacy Policy supplements our professional obligations of client confidentiality and sets out in general terms how we collect, use, disclose and protect the personal information of our clients, other individuals, and our web site users (“you”).

“PERSONAL INFORMATION”

Privacy legislation in Canada defines “personal information” broadly as any information about an identifiable individual. In general, personal information does not include business contact information, including your name, title or position, business, telephone, or facsimile number.

ACCOUNTABILITY

RONCO is responsible under applicable privacy legislation for the personal information in our possession or control. This includes personal information we receive directly, such as from individual clients or other individuals, and personal information we receive indirectly from clients or others. We have established policies and procedures with the objective of protecting personal information and have appointed a Privacy Officer to oversee privacy matters for our firm. Our Privacy Officer can be reached at privacyofficer@roncosafety.com.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The types of personal information we may collect about you include your name and contact information, including email, billing and account information, business partners, targets, competitors or customers of clients, and other information incidental to our business.

OUR PURPOSES FOR COLLECTING OR USING PERSONAL INFORMATION

GENERAL

RONCO collects and uses personal information for the following purposes:

• To establish and maintain commercial relationships with customers, including to issue invoices, administer accounts, collect and process payments, evaluate credit standing, and to fulfil contractual obligations;
• To contact and communicate with prospects and customers for the purpose of conducting market research, and evaluating customer service and satisfaction;
• To distribute our marketing materials and offers to individuals who subscribe to our mailing lists;
• To maintain, develop and manage our document management and knowledge-management systems and databases.
• To develop and manage our business and operations.

PUBLICATIONS AND SEMINAR PROGRAMS

Our Contact Management System uses the contact information of those who subscribe through our web site. Our marketing programs draw on a contact database of primarily business contacts that may also include individuals. We provide an opportunity to any contact to unsubscribe or opt-out of contact by accessing our web page or e-mailing to unsubscribe@roncosafety.com.

WEBSITE

Cookies – Cookies are small data files that are sent to your browser and stored on your computer’s hard-drive when you visit certain web sites to “track” your visit to the site. RONCO may, from time to time, collect non-personal information about you and your use of the site though the use of cookies. We do not match or correlate this information with any personal information that you submit on the web site. Some browsers can be set to reject all cookies; if you choose to modify your browser in this manner, all features of the website will remain available to you. We use cookies for language preference purposes and to analyze web-site usage. This information is used for no other purpose.

On-line Communications – To provide our web site users with publications, information or requested services, visitors may voluntarily submit personal information to us for such purposes as subscribing to or downloading publications, participating in a seminar or other event, participating in surveys, or asking a question. We use the personal information you provide only for the purpose for which you have provided it. If a subscriber or visitor has subscribed or attended a seminar or other event in the past, we may combine the information with information submitted on the web site. We provide an on-going opportunity to unsubscribe or opt-out of contact by the firm by accessing our website, or by e-mail at unsubscribe@roncosafety.com.

E-Mail Communications – We may send e-mail communications to subscribers or other individuals in our contact database to distribute publications or to advise of offers, events or seminars. Each e-mail includes an opt-out feature and instructions on how to un-subscribe if you do not wish to receive future e-mails from RONCO for these purposes.

Links – Our web site may present links to other web sites. You should be aware that operators of linked web sites may also collect your personal information and information generated through the use of cookies when you link to their web sites. RONCO is not responsible for how such third parties collect, use, or disclose your personal information, so it is important to review their privacy policies before providing them with your personal information.

SERVICE PROVIDERS

To the extent we enter into arrangements with service providers, agents, and contractors to store, handle or process personal information on our behalf, such as for data processing, document storage software support and office services, our policy will be to require such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them.

CONSENT

We obtain your consent to the collection, use and disclosure of personal information where required by applicable privacy legislation. We assume that an individual has consented to our reasonable collection and use of personal information consistent with the purposes for which the information was given when the individual initiates contact with us or voluntarily provides personal information to us.

We do not collect, use, or disclose personal information without consent unless authorized or required by law to do so, such as in the following circumstances:

• Where a court order or subpoena is issued, or under applicable rules of production, a regulatory or other body with jurisdiction to compel production so requires.
• If we are investigating the breach of an agreement, a legal duty or contravention of a law and obtaining consent would compromise the investigation or the accuracy of the information.
• If we are required to disclose personal information to a lawful authority.
• As otherwise authorized by law.

LIMITED COLLECTION, USE AND DISCLOSURE AND RETENTION

We collect personal information by fair and lawful means and, wherever appropriate, directly from the individual. Wherever possible, we limit the amount of personal information we collect, use or disclose to that necessary and appropriate to provide our business services and to operate our business. This information is stored with safeguards against inappropriate or unauthorized access (see Safeguards).

ACCURACY OF INFORMATION

In order to provide subscribers with a professional level of service and to maintain appropriate contact preferences, we may ask you to update your personal information, contact information or preferences from time to time, and we provide an ongoing opt-out opportunity by link or hard copy with all publications, invitations, and notices.

SAFEGUARDS

We protect personal information in our files and document management systems from loss, misuse, unauthorized access, and alteration by using physically secure facilities, password protection, standard security practices and tools and well-defined internal policies and practices.

ACCESS TO YOUR PERSONAL INFORMATION

You may review any personal information concerning yourself that we have on file in our offices by written request to privacyofficer@roncosafety.com. We reserve the right to change our Privacy Policy at any time by posting a new Privacy Policy on our web site.