Privacy Policy

BY USING THIS WEBSITE, YOU CONSENT TO THE COLLECTION AND USE OF INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. YOU ALSO ACKNOWLEDGE THAT SWD MAY PERIODICALLY CHANGE, MODIFY, ADD OR REMOVE OR OTHERWISE UPDATE THIS PRIVACY POLICY AT ITS DISCRETION, WITHOUT PRIOR NOTIFICATION.

SWD respects and is committed to protecting privacy and safeguarding the Personal Data entrusted to us by visitors of our website.

updated May, 2018

Collection of Personal Information

The term “Personal Information” as used in this Privacy Policy refers to information that can be used to identify you as an individual, including for example your name, e-mail address, mailing address, or telephone number. Generally, we will only collect and process your Personal Information as described in this Privacy Policy or otherwise with your consent. However, we reserve the right to conduct additional processing to the extent permitted or required by law or in support of any legal or criminal investigation.

Privacy Policy

SWD is committed to maintaining the accuracy, confidentiality and security of your Personal Information. As part of this commitment, SWD has built our Privacy Policy on the values set by the Canadian Standards Association’s Model Code for the Personal Information Protection and Electronic Documents Act (PIPEDA).

Identifying Purposes

We may collect and use Personal Information to provide you with products or services, bill you for products and services you request, respond to inquiries or comments, market products and services which may be of interest to you, or communicate with you for other purposes to which you consent either implicitly or expressly.

SWD shall specify orally, electronically or in writing the identified purpose(s) to you at or before the time personal information is collected. On request, persons collecting Personal Information shall explain these identified purposes or refer to the designated individual in control of the Privacy Policy.

It is your choice to submit Personal Information to us through the website. Generally, when you voluntarily provide us with your Personal Information, we will assume you consent to our collection, use and disclosure of that information for the purposes identified at the time of collection.

Non-Disclosure

We will not use or disclose your Personal Information for purposes other than those identified in this Privacy Policy or at the time of collection. We will not sell, share, or otherwise distribute your Personal Information to third parties except as provided in this Privacy Policy. Personal Information may be transferred to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed. These third parties have contracted with us to only use Personal Information for the agreed upon purpose, and not to sell your Personal Information to third parties, and not to disclose it to third parties except as may be required by law, as permitted by us or as stated in this Privacy Policy.

Personal Information collected from you may also be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat Personal Information in accordance with this Privacy Policy. Also, Personal Information may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

Consent

Knowledge and consent are required for collection, use or disclosure of Personal Information except where required or permitted by law.

Under certain circumstances, Personal Information may be collected, used or disclosed without your knowledge or consent. These circumstances include but may not be limited to:

  • when clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when an individual is a minor, seriously ill or mentally incapacitated;
  • when the consent of the individual may defeat the purpose of collecting the information, such as a breach of an agreement or a contravention of federal or provincial law;
  • when there is an emergency where the life, health or security of an individual is threatened; and
  • when disclosure is to a lawyer representing SWD, to collect a debt, to comply with a subpoena, warrant or other court order, or otherwise required by law.

Reasonable efforts shall be made in obtaining your  consent to ensure  you are advised of the purpose for which the information will be used or disclosed. Purposes will be stated in a manner that can be reasonably understood by you.

In determining the appropriate form of consent,  we will take into account the sensitivity of Personal Information and reasonable expectation.

In general, the use of SWD products or services by you constitutes implied consent for the collection, use or disclosure of personal information for all identified purposes.

Consent may be withdrawn at any time subject to legal or contractual restriction and reasonable notice.

Limiting Collection, Disclosure, and Retention of Information

We only collect Personal Information deemed necessary by the company. All information collected will be by fair and lawful means. SWD may also collect Personal Information from other sources or third parties that represent they have the right to disclose the information.

In certain circumstances, Personal Information may be collected, used or disclosed without the knowledge and consent of the individual.

SWD may disclose customer’s Personal Information to:

  • credit grantors or reporting agencies;
  • a person who, in reasonable judgment of SWD is seeking the information as an agent of the customer; and
  • a company involved in supplying the customer with related services.

SWD may disclose Personal Information regarding its employees:

  • for normal personnel and benefits administration;
  • in the context of providing references regarding current or former employees in response to requests from prospective employers; or
  • where disclosure is required by law.

Personal Information is not used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law and is retained only as long as necessary for the fulfillment of those purposes. SWD shall maintain reasonable controls, schedules and practices for information and records retention and destruction. Information no longer necessary or relevant for identified purposes or required by law to be retained shall be destroyed, erased or made anonymous.

Accuracy

Personal Information maintained shall be as accurate, complete and up-to-date as necessary for the purposes for which it is used and maintained with sufficient accuracy and completeness to minimize the possibility that inappropriate information may be used to make a decision.

SWD will update Personal Information necessary to fulfill the identified purposes or upon notification by the individual.

Security Safeguards

We take reasonable steps to protect your Personal Information using physical, electronic and organizational security measures appropriate to the sensitivity of the information. To ensure the security and confidentiality of Personal Information that we collect online, we use data networks protected, by industry standard firewall and password protection.

In the course of handling your Personal Information, we use appropriate security measures to protect against such risks as loss, unauthorized access, disclosure, copying, use, modification or destruction regardless of the format in which it is held and use care in disposing or destroying personal information to prevent unauthorized parties from gaining access to the information.

Access to Personal Information is restricted to those employees who have a need to use the data and who have been trained to handle such data properly and observe strict standards of confidentiality.

Website Personal Information

Cookies

We may collect and process information about your visit to this website, such as the pages you visit, the website you came from and some of the searches you perform. Such information is used by us to help improve the contents of the site and to compile aggregate statistics about individuals using our site for internal, market research purposes. In doing this, we may install “cookies” that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. A “cookie” is a small piece of data which is sent to your browser and stored on your computer’s hard drive.

You can set your browser to notify you when you receive a “cookie,” this will enable you to decide if you want to accept it or not; however, if you do not accept you may not be able to use all functionality of your browser software. We may obtain the services of outside parties to assist us in collecting and processing the information described in this section.

Google Analytics

We may use Google Analytics for integrating and optimizing web pages where appropriate. “Google Analytics” is a service offered by Google Inc. (“Google”) that generates detailed statistics about a website’s traffic and traffic sources and measures conversions and sales. Google Analytics uses “cookies” stored on your computer to help analyze how users use our website.

The information generated by the cookies about your use of our website, including your IP address, will be transmitted to and stored by Google on servers in the United States. The IP address, however, will be shortened before being sent to Google and Google can then not use it any more to identify you or your computer. Only in exceptional cases the full IP address will be transmitted to and shortened by Google in the US.

On behalf of us, Google will use the information generated by the cookies for the purpose of evaluating the use of our website, compiling reports on website activity providing us with these reports for analytical purposes.

Google may transfer this information to third parties in case of a statutory obligation or if a third party processes data on behalf of Google.

You may prevent or stop the installation and storage of cookies by your browser settings by downloading and installing the free Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout?hl=en. We inform you that in such case you may not be able to wholly use all functions of the website.

By using our website you consent to the processing of any Personal Information Google will collect on you in the way and for the purpose as described above.

Links to other sites

This Privacy Policy applies only to this website, and not to websites owned by third parties. We may provide links to other websites which we believe may be of interest to our visitors. We aim to ensure that such websites are of the highest standard. However, due to the nature of the internet, we cannot guarantee the privacy standards of websites to which we link or be responsible for the contents of sites other than this one.

Openness Concerning Policies and Practices

SWD will make specific information regarding its policies and practices relating to the management of Personal Information available to you.

All information about policies and practices will be easy to understand including:

  • contact information for the person/s accountable for the privacy code and to whom inquiries or complaints may be forwarded;
  • the means of gaining access to personal information held by the Company; and
  • a description of the type of personal information held by the Company.

Your Access to Personal Data

SWD shall inform you of the existence, use, and disclosure of Personal Information request and shall provide access to that information except in certain circumstances. You have the ability to challenge the accuracy and completeness of the information and have it amended as appropriate.

Under certain circumstances, access to all the personal information held about a customer or employee may be restricted and the reason for denying access will be provided. Examples of reasons for full access denial are but are not limited to:

  • if doing so would reveal Personal Information about a third party or could reasonably be expected to threaten the life or security of another individual;
  • if disclosure would reveal confidential commercial information;
  • if information is protected by solicitor-client privilege; or
  • if information was collected in relation to the investigation of a breach of an agreement or contravention of a federal or provincial law.

On request, SWD shall provide an account of the use and disclosure of Personal Information and a list of potential organizations to which it may have disclosed Personal Information about the individual.

In order to safeguard information, you will be required to provide sufficient identification information to permit access to your file. Any such information shall be used only for this purpose.

Personal Information found to be incorrect or incomplete shall be promptly corrected. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, SWD will inform third parties having access to the Personal Information in question of any amendments or unresolved differences.

 Challenging Compliance

You shall be able to address a challenge concerning compliance with the above principles to the person accountable for compliance with the SWD Privacy Code. Procedures for addressing and responding to all inquiries or complaints about the Company’s handling of personal information shall be maintained. You shall be informed about the existence of these procedures and the availability of the complaint procedure.

The person accountable for compliance may seek external advice where appropriate before providing a final response to individual complaints.

All complaints concerning compliance shall be investigated. If a complaint is found to be justified, appropriate measures to resolve the complaint including, if necessary, amending policies and procedures. The complainant will be informed of the outcome of the investigation regarding the complaint.

For further inquiries contact:

Andrea Villeneuve
PO Box 61068
RPO Grant Park
6000-1120 Grant Avenue
Winnipeg, MB R3M 3X8
andrea@swd.ca