Altus has appointed a Chief Privacy Officer who is responsible for:
overseeing Altus’s compliance with the privacy principles in the Act; and
adopting policies, practices and procedures to give effect to the principles, including developing information and informing staff about Altus’s policies, practices and procedures.
The Act states that every organization must comply with the following obligations of privacy protection:
Limiting use, disclosure and retention;
Individual access; and
Personal Information means information about an identifiable individual, including but not limited to data such as race, ethnic origin, age, financial history and personal opinion. It does not include the name, title or business address or business telephone number of an employee of an organization.
Consent – Altus cannot collect, use or disclose personal information without the knowledge and consent, whether implicit or explicit, of an individual. Exceptions for the collection and use of personal information without consent are described in the Act.
Collection of Personal Information
We may also collect personal information to allow us to manage and develop our business and operations, including: informing you of, and supplying you with investor relations information other than that which you specifically requested; enabling Altus to comply with applicable law or regulatory requirements; and any other reasonable purpose to which you consent.
Personal information we receive from you may be collected by us either directly from you or may be obtained from one of our third party service providers who has collected the information from you on our behalf. These service providers may include providers of news wire services, transfer agents or financial institutions.
We also may automatically collect general anonymous information related to your use of our website, such as the date and time you visit the site, and the pages you visit on the website. In addition, we collect “cookie” information from your browser to identify your computer and provide us with a record of your visits to our website. The technology used to gather “cookie” information is provided by the Internet browser you use, and may be turned off by using your browser preference buttons. This statistical information helps us to understand how our websites are used (e.g., identifying which pages or sections are most popular and the peak activity times), which assists us in planning for future improvements to the website to better meet our guest’s needs.
Purposes of Collecting Personal Information
to inform you of, and supplying you with, investor relations information other than that which you specifically requested;
to comply with your requests;
to enable Altus to comply with applicable law or regulatory requirements; and;
any other reasonable purpose to which you consent.
You may refuse or withdraw your consent to our use of your personal information as explained under “Consent” below. Before using your personal information for any purpose other than those listed in (i) to (iv) above, Altus will explain that purpose to you and seek your consent.
Disclosure of Your Personal Information
All third parties will be asked to sign a Non-Disclosure Agreement, prior to their receipt of any personal information. The use, disclosure and retention of the personal information by the permitted third party is also governed by the Act and a statement of compliance with the Act will be required from such third parties prior to their receipt of the personal information.
we are required to do so by legal or regulatory requirements;
the information is publicly available or it is part of Altus’s regular reporting activities;
it is necessary to protect the rights and property of Altus;
emergencies occur or where the use is necessary to protect the safety of a person or group of persons;
the information is public personal information;
it is required by employees, contractors, consultants and other parties (including other organizations included in the term Altus), who require the information to assist us to establish, maintain and manage our relationship with you, including, for example, third parties that provide services to us or on our behalf or third parties that collaborate with Altus in the provision of services to you;
we have obtained your consent (see “Consent” below).
Consent and Opting-Out
Our collection, use or disclosure of your personal information requires your consent. Depending on the nature and sensitivity of your personal information, your consent to the collection, use and disclosure of such information may be express and positive (which may be oral, in writing or electronic) or implied (such as by using our products or services or by not responding to our offer to remove your personal information from our marketing lists), in which case we assume that you consent. Consent may be given by your authorized representative. You may withdraw your consent at any time as long as you give reasonable notice of withdrawal.
Withdrawal or refusal of consent is subject to legal and contractual restrictions. Altus can collect, use or disclose your personal information for legal, security or certain processing reasons when authorized by law. For example, we must provide your personal information in response to a search warrant or other legally valid enquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law.
If you prefer to be removed from the investor relations mailing lists used to supply you with investor information, you have the opportunity to opt-out by contacting us in the manner set out below. You are free to opt-out from our investor relations lists at any time, allowing a reasonable time for withdrawal. By opting out you may limit our ability to offer you certain investor information, services or benefits.
Security of Personal Information
We will maintain your personal information in secure data storage to safeguard it from unauthorized access, use or disclosure. We will maintain the strict confidentiality of all personal information collected, and will only disclose such information to employees and service providers of Altus who require such information for the purposes set out above. We have entered into agreements with our service providers to safeguard the personal information in their possession. We will only keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law.
We will keep personal information that is in our possession or control accurate, complete and up to date as is necessary for the purposes for which it is used. The Act prevents the routine updating of personal information unless such updates are necessary for the purposes initially agreed to be the individual.
Third-Party Website Links
Accessing Your Personal Information
You have the right to reasonable access to your personal information in our possession or control and to request rectification of any personal information that may be obsolete, incomplete or incorrect. To assist your request, you can obtain the Access to Personal Information Request form from us by writing to the Privacy Officer at the address below, or you can make the request by letter or telephone if you prefer. We may charge you an administration fee for providing access to your file in accordance with the nature of your request. Normally, we will respond to access or rectification requests within 30 days.
How to Contact Us
Altus Group Limited
33 Yonge Street, Suite 500
Toronto, ON M5E 1G4 Canada