WHAT PERSONAL INFORMATION DO WE COLLECT?
Personal information is information about an identifiable individual, as defined in applicable Privacy Laws. Generally speaking, personal information does not include:
- anonymous or aggregated information that does not allow an individual to be identified;
- information regarding companies and other “legal persons”; or
- business contact information such as your name, title or position, business address, telephone number or fax number, or business email address.
The types of personal information that AMI may collect from you from time to time include: your name, home address, home telephone number, personal email address, your forwarding address (e.g. during a vacation), previous address(es), personal billing and account information (such as credit card or bank account number), your mailing preferences, delivery instructions, and customer service preferences. In addition, from time to time, we may ask you to provide us with more detailed information regarding your interests, occupation and background. For example, we sometimes ask our customers to complete surveys in order to get a better sense of who they are and what issues, products or services may be of interest to our clients.
THE PRIVACY PRINCIPALS AMI FOLLOWS
AMI collects, uses and discloses your personal information by employing “fair information practices” as described in the following ten privacy principles and embodied in Privacy Laws:
- Accountability: AMI is responsible for personal information under its control and as a result has designated an individual as the person who is accountable for AMI’s compliance with the ten principles (“Privacy Officer”). As such:
- accountability for AMI’s compliance with the principles rests with the Privacy Officer, even though other individuals within AMI may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within AMI may be delegated to act on behalf of the Privacy Officer;
- the identity of the Privacy Officer designated by AMI to oversee AMI’s compliance with the principles shall be made known upon request; and
- AMI is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. AMI shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
- Identifying Purposes: In general, AMI collects, uses and discloses personal information about you in order to provide our customers with our services. More specifically, AMI collects, uses and discloses your personal information for the following purposes:
- to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual and legal obligations;
- to develop and manage our business and operations. This may include the sharing of personal information by and between AMI personnel and affiliated companies, and with third party service providers and agents, for such purposes;
- to detect and protect AMI and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with AMI’s policies and contractual and legal obligations;
- to distribute our newsletters and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers;
- to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving AMI;
- to understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
- to develop, enhance, market, sell or otherwise provide AMI’s products and services;
- to market, sell or otherwise provide products and services of third parties with whom AMI has a commercial relationship;
- as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
- for any other purpose to which you consent. AMI will collect, use and disclose only that personal information necessary for the purposes that have been identified.
NOTE: In certain circumstances under Privacy Laws, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information.
- Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by AMI. Information shall be collected by fair and lawful means and may be collected from other sources including but not limited to credit bureaus or other third parties who represent that they have the right to disclose the information. In most cases, collection shall be pursuant to appropriate contractual arrangements.
- Limiting Use, Disclosure, and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by Privacy Laws. Personal information shall be retained only as long as necessary for the fulfillment of those purposes or as required by law. AMI may collect from and/or disclose your personal information to:
- a person who, in the reasonable judgment of AMI, is providing or seeking the information as your agent;
- any of the companies and business entities that form part of AMI;
- an organization or individual retained by AMI to perform functions on its behalf, such as contractors, consultants, auditors, software developers (including web-site developers and hosts), data processing, document management and office services;
- an organization or individual retained by AMI to evaluate your creditworthiness or to collect debts outstanding on an account;
- a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;
- our auditors and professional advisors;
- another person or corporation as part of conducting business together or pursuant to the sale of all or substantially all of AMI’s assets or shares related to one or more specific lines of business, subject to the other person or corporation agreeing to manage personal information in accordance with Privacy Laws;
- another company or person for the development, enhancement, marketing or provision of any of AMI’s products or services;
- an agent or third party retained by AMI in connection with AMI’s administration or the provision of AMI’s products or services;
- credit grantors and reporting agencies; and k) a public authority or agent of a public authority, if in the reasonable judgment of AMI, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of this information. Except as permitted in this principle, AMI does not provide or sell its customer lists to any outside company for use in marketing or solicitation.
- Accuracy: Personal information shall be as accurate, complete, and up-to-date as it is possible. AMI will update personal information as and when necessary to fulfill the identified purposes or upon notification from you. AMI will not routinely update personal information, unless such process is necessary to fulfill the identified purposes. If ever your contact and/or other personal information changes, please contact us so that we can update our records.
- Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. The security safeguards are designed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. The methods of protection include:
- physical measures, such as locked filing cabinets and restricted access to offices;
- organizational measures, such as security clearances and limiting access on a “need-to-know” basis; and
- technological measures, such as the use of passwords, firewalls and encryption.
- the information made available shall include:
- the name or title, and the address, of the Privacy Officer to whom complaints or inquiries can be forwarded;
- the means of gaining access to personal information held by AMI;
- a description of the type of personal information held by AMI, including a general account of its use;
- a copy of any brochures or other information that explain AMI’s policies, standards, or codes; and
- what personal information is disclosed to third party organizations, including affiliated companies, and the purpose for such disclosure; and
- Individual Access: Upon request, subject to certain exceptions under Privacy Laws, AMI shall inform you of the existence, use, and disclosure of your personal information and shall provide access to that information. You may challenge the accuracy and completeness of the personal information and have it amended as appropriate.
NOTE: In certain situations, under Privacy Laws, AMI may not be able to provide access to all of your personal information it holds. The reasons for denying access will be provided to you upon request. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
PRIVACY AND OUR WEBSITE
Links – Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices, and be subject to different terms of service and use, than AMI, and AMI has no responsibility for such third party websites regarding its privacy policies or its content generally.
TRANSFER OF PERSONAL INFORMATION TO SERVICE PROVIDERS OUTSIDE OF CANADA