Our Privacy Policy

Halmyre Strategies Inc. is committed to maintaining the privacy of your Personal Information. Our collection, use, and sometimes disclosure of your Personal Information is essential to our ability to offer you high-quality marketing information, products, services, and events. 

1.0 Scope of This Privacy Policy

1.1 This Privacy Policy explains the privacy principles which we will follow when we collect, use, and sometimes disclose your Personal Information. We are accountable for all Personal Information under our control. Our Privacy Officer, who may be contacted at privacy@halmyre.com, is accountable for our compliance with this Privacy Policy.

2.0 Changes To This Privacy Policy

2.1 It is important that you review this Privacy Policy periodically as it may change from time to time. Each change to this Privacy Policy that we make will become effective at the time that we post our changed Privacy Policy on this website (“Website”). So please review this Privacy Policy from time to time to see what’s changed – since these changes will apply to you.

3.0 What Is Personal Information?

3.1 Personal Information is information about an identifiable information that is subject to protection under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).

4.0 Why Do We Collect Your Personal Information? 

4.1 Subject to our obtaining your Consent in accordance with Section 6 of this Privacy Policy, we will collect your Personal Information for the following purposes (“Identified Purposes”):

•   To better understand your marketing needs and preferences;

• To communicate with you directly by telephone, e-mail, or other means, through our website(s), and through social media regarding our business, products. services, webinars, and events;

• To inform you of information, products, services, webinars, and events that may be of interest to you;

• To recommend specific products, services, webinars, and events to you;

• To provide our products, services, webinars, and events to you;

• To enter into legal and contractual relationships with you;

• To manage, operate, improve, and expand our business and its operations (including for the purposes described in Section 9 of this Privacy Policy);

• To develop new products, services. webinars, events, websites, and social media presence, as well as to improve our existing products, services. webinars, events, website(s), and social media presence; 

• To meet our legal and regulatory obligations; and

• To assert and enforce our legal rights and remedies, including initiating or defending against legal proceedings.

We may use third parties, including CRM and email services, to communicate directly with you for the Identified Purposes.

We will never sell to any third party any of your personal Information which we have collected from you.

5.0 How Do We Use Your Personal Information?

5.1 We will limit our use of your Personal Information to the Identified Purposes.

6.0 Obtaining Your Consent

6.1 Subject to certain exceptions, we must obtain your consent before collecting, using, or disclosing your Personal Information (“Consent”). PIPEDA sets out various exceptions to this requirement, such as when legal, medical, or security reasons make it impossible or impracticable to obtain Consent.  We can obtain your Consent, which can be implied or express, in a number of ways. 

6.2 For example, each time that you visit or use this Website, provide information to us by mail, e-mail, telephone, facsimile, electronic, or other means, provide your business card to any of our employees or representatives, order or purchase any of our products or services from us, or interact with us on or through Social Media, your consent will be implied. 

6.3 In certain cases, we may require you to provide your express Consent by completing and sending to us one of the online forms posted on this Website or through other means. For example, we will require your express consent to attend one of our webinars, to obtain articles, materials, or presentations from us, or to attend one of our events.

6.4 You may withdraw your Consent at any time, subject to legal or contractual restrictions, by providing reasonable notice to us, You may do by contacting us by e-mail at privacy@halmyre.com or by mail addressed to Halmyre Strategies Inc., 110 George Henry Blvd, Unit #49, Toronto ON Canada M2J 1E7. Attention: Privacy Officer. In such event, we will inform you of the implications of your withdrawing your Consent. 

6.5 You may also unsubscribe from any marketing communications that we may send to you by e-mail by clicking on the "unsubscribe" link located on the bottom of our e-mail.

6.6 In certain circumstances, we may seek your Consent with respect to our use or disclosure of your Personal Information after your Personal Information has been collected. 

6.7 For example, when Personal Information collected by us is to be used for a new purpose not previously identified by us, we will identify the new purpose prior to our using your Personal Information for the new purpose. Unless the new purpose is authorized by PIPEDA, we will also obtain your consent before your Personal Information is used by us for the new purpose.

7.0 How Do We Collect Your Personal Information? 

7.1 We may collect Personal Information about you by passive or automated means when you visit our Website, when you complete and submit an online form contained on our Website, when you interact with us directly by telephone, e-mail, at an event, on social media, or by other means, or when you provide your business card to any of our employees or representatives. 

7.2 Sometimes, we may also collect or receive Personal Information about you from our service providers such as Hubspot and Mailchimp, from our related companies, from our advertisers, from our marketing partners, and from other third parties. Unless we obtain your Consent in accordance with Section 6 of this Privacy Policy with respect to such Personal Information, we will only use and/or disclose such Personal Information in accordance with the terms of the privacy consent that you granted to such third party.

7.3 We, along with our service providers, related companies, advertisers, and marketing partners may use “cookies”, “Web beacons”, JavaScript, and other tracking technologies which enhance your user experience when visiting our Website. We may also use other technology to assist third parties advertise to you when your visit or use other websites or mobile applications. 

7.4 Cookies are small pieces of information which are placed in your internet browser. They identify you when your visit our Website. This helps customize your user experience on our Website.

7.5 You can control how cookies and similar technologies track and log data about your internet use and deliver personalized ads to you on our Website and other websites. These controls include:

• Browser App And Device Settings

Managing the settings of your browsers, apps and devices, including preferences for how your content and information are stored;

• Flash Cookies

Managing flash cookies (which are used to display personalized ads) by clicking:

https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html

• Third-Party Data Collectors

Communicating directly with third parties that may collect data on a website that you visit, such as:

Linkedin: https://www.linkedin.com/help/linkedin/answer/62931?lang=en

Google:  https://www.adobe.com/privacy.html

Adobe:  https://www.adobe.com/privacy.html

Facebook:  https://www.facebook.com/privacy/policy

Twitter:  https://twitter.com/en/privacy

• Security Software 

Purchasing software that can be installed install on your devices to limit third parties’ ability to track your browsing activity;

• Digital Advertising Alliance 

Visiting https://optout.aboutads.info to learn more about personalized advertising and how to opt out of it through your browser with companies in the Digital Advertising Alliance;

• Do-Not-Track Requests.

Enabling your browser’s Do Not Track (“DNT”) function to automatically request website DNT requests are only honored by some advertisers and websites. Our Website does not respond to DNT requests.

7.6 If you restrict the use of cookies and other technologies, certain web services may not work properly. For example, if you restrict personalized advertising, you will still receive advertisements but they will not be personalized based on your browsing activity.

7.7 If you access our Website through a mobile device or a mobile application, you may be asked to share your precise geo-location information with us. This may assist us to customize your user experience related to our Website.

7.8 If you interact with us on or though Social Media, we may collect, use, and disclose Personal Information related to you, your friends, your contacts, your connections, people you follow, people who follow you, your posts, and your preferences.

7.9 We may also use technology on our Website to collect, determine, and analyze generic information regarding Website user trends, user movement across our Website, demographic information about users of our Website, key elements which users of our Website select or click on, and to look up internet addresses on the internet to determine general geographic trends of parties using our Website. This information will be generic information concerning usage of our Website – not Personal Information.

7.10 Lastly, we may also combine your Personal Information with that of other individuals to create aggregate data which we may use to improve our Website, to improve our products, services, website, and events, and to develop new products, services, websites, webinars, and events. Aggregate data is general information about groups of users but not about you as an individual.

8.0 Collection Of Personal Information By Third Parties Through Our Website

8.1 We may authorize third parties to place advertisements, links, media, and other notices on our Website. These parties may use various technologies to collect Personal Information. 

8.2 Since we will not have custody of such Personal Information, the collection, use, and disclosure of such Personal Information will be governed solely by the privacy policy of each such third party rather than this Privacy Policy.

9.0 Reasons That We May Disclose Your Personal Information 

9.1 Subject to our obtaining your Consent in accordance with Section 6 of this Privacy Policy, we may disclose your Personal Information to third-party contractors, advisors, consultants, representatives, and service providers (“Service Providers”) that we retain to assist us to manage, operate, improve, and expand our business. This may include Service Providers that we have engaged to: 

• Supply products and services to us;

• Perform business related functions on our behalf;

• Provide customer, financial, technical, and operational support to us; 

• Operate our computer, telephone, e-mail, and other electronic systems;

• Host and operate our website(s), webinars, forums, social media, and online communities;

• Operate and maintain databases for us;

• Conduct research and analytics for us;

• Create and supply media and content to us; 

• Conduct or support our marketing activities (through e-mail, websites, webinars, social media, and other advertising platforms);

• Send or support online or mobile advertising for us;

• Fulfill orders and user requests for us; 

• Process payments for us; 

• Assert and enforce our legal rights and remedies, including initiating and defending against legal proceedings;

• Otherwise support our business, operations, products, services, webinars, and events.

9.2 If we disclose any of your Personal Information to any of our Service Providers which are located outside of Canada, your Personal Information will be protected by safeguards which meet Canadian privacy standards. However, your Personal Information may be subject to the laws of the country within which such Service Provider is located. As a result your Personal Information may be accessible to law enforcement and national security authorities of that jurisdiction.

9.3 We may also disclose your Personal Information to our related companies, advertisers, and marketing partners in order for them to inform you of information, products, services, websites, webinars, and events that may be of interest to you, to recommend specific products, services, websites, webinars, and events to you, and to provide their products, services, websites, webinars, and events to you.

9.4 Finally, we may disclose your Personal Information:

• To a government institution or other organization if reasonably necessary in order to establish your identity, or to investigate the contravention of any law or agreement;

• To an appropriate public authority in an emergency involving imminent danger to life or property.

• As otherwise authorized or required by law.

10.0 Limiting Collection of Your Personal Information

10.1 Our collection of your Personal Information will be limited to the Identified Purposes. 

11.0 Limiting Use, Disclosure And Retention of Your Personal Information

11.1 Except with your Consent, as authorized by PIPEDA, or as required by law, Personal Information which we have collected from you shall only be used and/or disclosed by us for the Identified Purposes.

11.2 We will retain your Personal Information only for as long as is necessary to fulfill the Identified Purposes. Where we no longer require your Personal Information to fulfill the Identified Purposes, it will be destroyed, erased, or made anonymous except where it forms part of aggregated statistical data where your individual information cannot be traced back to you.

12.0 Accuracy

12.1 Personal Information which we collect from you shall be as accurate, complete, and up-to-date as is necessary for the Identified Purposes.

13.0 Safeguards

13.1 Personal Information which we collect from you shall be protected by security safeguards appropriate to the sensitivity of the information collected. 

13.2 We use a variety of security technologies and procedures to help protect the Personal Information which we have collected from unauthorized access, use or disclosure. We secure the Personal Information which we collect on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

14.0 Openness

14.1 Upon request, we will make available to you specific information about our policies and practices relating to the management of Personal Information under our control.

15.0 Individual Access

15.1 Upon our receipt from you of your written request, we will, subject to PIPEDA, inform you of the existence, use, and disclosure by us of any of your Personal Information which we have collected from you. You may also challenge the accuracy and completeness of any of your Personal Information under our control and have it amended as appropriate. 

15.2 We will respond to your written request within a reasonable period of time. Generally this will be within thirty (30) calendar days of our receipt of your written request.

15.3 Please note however that, in certain circumstances, we may not be able to provide access to all of your Personal Information which we possess. 

15.4 In providing an account of third parties to which we may have disclosed your Personal Information, we will attempt to be as specific as possible. However, where it is not possible to provide a list of specific organizations to which we have actually disclosed your Personal Information, we will provide a list of organizations to which we may have disclosed Personal Information about you.

15.5 Our response will usually be provided at no cost to you. However, we reserve the right, depending upon the nature of the request and the Personal Information involved, to charge you our costs to process each of your requests.

15.6 In any case where there may be a cost charged by us to process a request made by you, we will notify you in advance. If we do so, the identified costs must be paid to us by you in advance of our beginning to process such request.

15.7 If you successfully demonstrate to us the inaccuracy or incompleteness of any of your Personal Information under our control which has been collected by us, we will amend your Personal Information under our control as required.

16.0 Challenging Compliance

16.1 We will investigate all written privacy complaints which we receive from you related to Personal Information about you which we have collected.

16.2 If you wish to make a privacy complaint related to your Personal Information which we have collected, please include on your complaint your name, email address, and telephone number where we may contact you. Please send your complaint to our privacy officer at privacy@halmyre.com.

16.3 If we find your complaint to be justified, we will take such action as is appropriate to comply with PIPEDA and this Privacy Policy.

17.0 Questions About This Privacy Policy