PRIVACY POLICY

Wheelhouse Strategic Marketing is committed to safeguarding the personal information entrusted to us by our clients. We manage your personal information in accordance with Alberta’s Personal Information Protection Act and other applicable laws. This Personal Information Protection Policy (the “Privacy Policy”) outlines the principles and practices we follow in protecting your personal information.

This Privacy Policy applies to Wheelhouse Strategic Marketing. This Privacy Policy also applies to any person providing services on our behalf.

What is personal information?

Personal information means information about an identifiable individual. This includes an individual’s name, address, phone number, age, sex, marital or family status, or employment details.

What personal information do we collect?

We collect only the personal information that we need for the purposes of providing services to our clients, including personal information needed to:

  • Open and manage client files;
  • Deliver requested products and services;
  • Enroll a client in a program;
  • Process email newsletter subscriptions;
  • Contact clients regarding appointments, services, promotions and other matters relevant to the services;
  • Follow up with clients to determine satisfaction with services;
  • Notify clients of upcoming events of interest;
  • Meet regulatory requirements

We normally collect client information directly from our clients. We may also collect your information from other persons with your consent or as authorized by law.

We inform our clients of the purposes for which we are collecting the information before or at the time of collecting personal information. However, we don’t provide this notification when a client volunteers information for an obvious purpose (for example, providing information in order to download products from our website).

Use of Service Providers outside Canada

Our service providers in the located in various countries may collect, use or disclose your personal information for the following purposes:

  • Open and manage client files;
  • Deliver requested products and services;
  • Enroll a client in a program;
  • Process email newsletter subscriptions;
  • Contact clients regarding appointments, services, promotions and other matters relevant to the services;
  • Follow up with clients to determine satisfaction with services;
  • Notify clients of upcoming events of interest;
  • Meet regulatory requirements

Consent

We will ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

We will ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent by checking a box on a form, or electronically (by clicking a button).

In cases that do not involve sensitive personal information, we may rely on “opt-out” consent. For example, our website uses the following cookies:

  • _session_id, unique token, sessional, to store information about your session (referrer, landing page, etc).
  • _secure_session_id, unique token, sessional

To “opt out”, you can check the appropriate box on our website or contact our Privacy Officer at hello@wheelhousemarketing.ca.

A client may withdraw consent to the use and disclosure of personal information at any time unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.

We may collect, use or disclose client personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory or is available in another public domain.

We understand the importance of protecting children’s privacy, especially in an online environment such as at our websites. Our website covered by this Privacy Policy is not intentionally designed for or directed at children 13 years of age or younger. It is our policy never to knowingly collect or maintain information about anyone under the age of 13. If you are the parent or guardian of a child and become aware that your child has provided us with personal information without your consent, please contact our Privacy Officer at hello@wheelhousemarketing.ca.

How do we use and disclose personal information?

We use and disclose client personal information only for the purpose for which the information was collected, except as authorized by law. For example, we may use client contact information to deliver goods. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary.

How do we safeguard personal information?

We make every reasonable effort to ensure that client information is accurate and complete. We rely on our clients to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases, we may ask for a written request for the correction.

We protect client personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.

We use appropriate technical and organizational measures to ensure a level of security appropriate to the risk and to safeguard your personal information in our possession. However, no data transmission over the internet is completely secure and no security and no security mechanism is impenetrable. Therefore, although we take steps to protect your personal information, we cannot guarantee the security of your personal information that we collect from you or the security of our servers or our website. By accessing our website, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.

We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.

We retain client personal information only as long as is reasonable to fulfil the purposes for which the information was collected for legal or business purposes.

We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed.

We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.

Access to records containing personal information

Clients of Wheelhouse Strategic Marketing have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.

If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.

You may make a request for access to your personal information in writing to our Privacy Officer. You must provide sufficient information in your request to allow us to identify the information you are seeking.

You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. You may also request a correction of an error or omission in your personal information.

We will respond to your request within 45 calendar days unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.

Miscellaneous

From time to time, we may make changes to this Privacy Policy to reflect, among other things, changes in the law or our data collection and use of practices and such modifications shall be effective when updated on our website. Your continued use of our website after a revised Privacy Policy signifies your acceptance of the revised Privacy Policy. It is important that you review this Privacy Policy regularly to ensure you are up to date with any revisions.

Questions

If you have questions or concerns about any collection, use or disclosure of personal information by Wheelhouse Strategic Marketing, or about a request for access to your own personal information, please contact our Privacy Officer in the first instance:

Kayley Brooks

Wheelhouse Strategic Marketing

hello[at]wheelhousemarketing.ca

If you are not satisfied with the response you receive, you may contact the Information and Privacy Commissioner of Alberta:

Office of the Information and Privacy Commissioner of Alberta

Suite 2460, 801 – 6 Avenue, SW

Calgary, Alberta T2P 3W2

Phone: 403-297-2728 Toll Free: 1-888-878-4044

Email: generalinfo[at]oipc.ab.ca

Website: www.oipc.ab.ca