Collection, Use and Disclosure of Personal Information
"Personal information" refers to an identifiable individual's information when used or revealed in the process of commercial activity, conducting businesses or providing services and products, excluding a person's business title and business contact information.
Personal information includes:
- Contact information, such as name, home address, phone number and email details
- Social Insurance Number, ID card number and other government ID numbers
- Copies of agreements you enter into with Skyton
- Information you provide Skyton, such as preferences, identities of associates, comments and feedback
- Financial information, including credit details.
Skyton uses the information for business and client relationships, including, but not limited to:
- Building and managing a business relationship in order to provide you with the products and services you request
- Communicating with you in the way you request
- Sharing information, with your permission, with third parties representing you
- Reviewing services and products provided to you in order to understand your requirements and make improvements
- Protecting Skyton and its assets from error, damage, theft and fraud
- Complying with legal and statutory requirements
- Safeguarding Skyton's confidential information
- Reasonable requirements related to the management of Skyton's business and its relationship with the client
Your personal information is shared with Skyton employees, contractors, consultors, auditors and other parties, including Skyton subsidiaries and companies affiliated with Skyton Group, who need your personal information to advance Skyton's business relationship with you. These include third-party collaborators, contractors and services.
At any time you can withdraw or limit your consent, under the legal and contractual terms agreed with Skyton as a result of our business relationship. You are obliged to provide reasonable notice and to notify Skyton of the withdrawal or limitation of consent in writing to our Privacy Officer.
Skyton sometimes needs and reserves the right to disclose personal information without consent, including, but not limited to, in the event of:
- A threat to your health or safety
- An investigation or proceeding
- A legal requirement or authorization
- A requirement by warrant, subpoena, court order or request from another body authorized to demand the personal information
- Investigation of an offence by a public body
- A request from a lawyer representing Skyton
- An emergency
- Public availability of the personal information
Accuracy and retention of information
Skyton is committed to ensuring that any personal information it owns is as accurate, comprehensive and up-to-date as necessary for the purpose. Please notify Skyton as soon as possible if your information changes or you have reason to believe the personal information Skyton possesses is inaccurate. Please make any verification and correction requests in writing to Skyton Capital. In the event that Skyton turns down a request to change personal information, we will instead attach the requested information to the record as an alternative text.
Your personal information is retained only as long as it is needed for the purpose it was originally given, and to be able to provide your with product and service information that may interest you. The length of time Skyton keeps information on record varies depending on the content of the information and the related service or product. Retention may continue beyond the end of the business relationship, but only as long as it is necessary to comply with laws and regulations, and to respond to issues that may arise later. The information will be destroyed, erased or made anonymous, so that it cannot be identified with you individually.
Safeguarding Personal Information
Skyton promises to do make every effort to protect your personal information. We put in place physical, technical and procedural protections to safeguard personal information relative to its sensitivity. These measures intend to protect your personal information from loss and unauthorized access, use, copying alteration and disclosure.
Access to Your Personal Information
You may request to see your personal information Skyton keeps on record. Make all requests in writing to Skyton, and we will strive to provide access as soon as reasonably possible, or within the time period required by law. In the event of requests, we reserve the right to confirm your identity and rights to access information by requesting specific personal information from you. We also reserve the right to charge a fee for access to personal information, of which Skyton will notify you at the time or shortly thereafter.
Skyton may refuse access to personal information in circumstances including, but not limited to, requests that would necessitate:
- Personal information and opinions of other individuals
- Disclosure of confidential business information, such as trade secrets
- Violation of lawyer-client privilege
- Excessive burden, cost or effort disproportionate to the value of the information
- Risk of harm to the health, safety, life or emotional well-being of the individual or another person
- Interference with or harm to law enforcement functions, activities, investigations, or those of other regulatory bodies authorized by statutory law
- Violating laws forbidding disclosure of information
- Or where information cannot be found or does not exist
Skyton will provide reasons when a request for information is declined.
Interpretation of This Policy