GRT Privacy Policy
Introduction
Protecting the privacy and the confidentiality of personal information—over the Internet, on the telephone, or through our offices—has always been fundamental to the way GRT Holdings Ltd. (“GRT”) conducts its affairs. GRT operates on the basis of a Privacy Policy and related procedures that guide the handling of the personal information collected. This privacy statement has been created to demonstrate GRT’s firm commitment to protecting the privacy of its customers, partners and potential website visitors. This policy and related procedures are consistent with the Canadian Standards Association Model Code for the Protection of Personal Information (herein “CSA Model Code) and applicable privacy legislation.
Privacy Statement
This policy deals only with personal information handled by GRT. Personal information is information about an identifiable individual, excluding business contact information. The following explains how GRT handles personal information. GRT reserves the right to change this policy and it may be updated periodically. These changes may affect the use of personal information. Accordingly, please check for changes regularly.
Accountability
GRT is accountable for all personal information under its control. GRT’s Privacy Officer is the Chief Financial Officer who is designated as responsible for GRT privacy policy. The Privacy Officer can be reached by:
Email: kevin@grtenv.com
Any questions about GRT’s handling of personal information should be directed to the Privacy Officer. In cases where the question concerns an access request, individuals must follow the request process described under Accuracy of and Access to Personal Information Collected.
Purposes for Collection, Use and Disclosure of Personal Information
The purpose for which GRT collects personal information will be identified at or before the time the information is collected. Personal information may be collected for such purposes as:
administering customer services;
Sending newsletters or other relevant information;
GRT will not use personal information for any other purpose than identified at or before the time of collection.
Consent
GRT seeks consent for all personal information it collects, uses and discloses through information provided to individuals prior to collection, or at the time of collection. For information which is considered to be more sensitive, GRT will ask for a signature as a sign of consent.
If information is voluntarily provided, this is interpreted as consent to the collection, use and disclosure of personally identifiable information as described in this Privacy Policy. As required by the CSA Model Code, GRT will not use personal information for any purpose other than that for which consent has been provided. Should GRT require use of personal information for a new purpose, consent will be sought for that new use.
Limits for Collecting, Using, Disclosing and Keeping Personal Information
GRT does not collect, use or disclose personal information of individuals except when individuals give consent and provide the information on a voluntary basis. There may be occasions where more specific personal information is necessary for GRT to proceed with a request for information, or provide a product or service. In such cases, GRT will describe the information required. In all such cases, GRT limits the amount and type of information collected to only the personal information that is required to provide the individual with the requested information, product, or service. GRT collects only information that is voluntarily provided by the individual and undertakes that such information will be kept strictly confidential.
GRT may disclose personal information collected by it without the knowledge or consent of the individual, for example to its lawyers; for purposes relating to an investigation under, the enforcement of or the administration of a law or where required by law to disclose the information. GRT will not use or disclose personal information without the knowledge or consent of the individual except as authorized by applicable law.
GRT does not sell or trade any personal information with third parties. Information may be transferred to third parties where information processing is outsourced by GRT in the course of its activities or administrative procedures in specific cases. Some personal information collected by GRT is transferred to our service providers for processing and storage. Some of our service providers are located outside of Canada and accordingly your data may be processed and stored outside of Canada, and may be subject to the laws of the jurisdiction in which it is processed or stored.
Any personal information that GRT retains is kept in such a manner as to ensure its security and confidentiality at all times.
Safeguarding Personal Information
GRT respects the privacy of its customers, partners, potential website visitors and internet users and will protect that privacy as vigorously as possible. Personal information is stored in electronic and physical files that are secure. Security measures include secure locks on filing cabinets, and using industry standard techniques such as firewalls, encryption, intrusion detection and restricted access to computers. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while GRT strives to protect personal information, it cannot ensure or warrant the security of any information transmitted to it or received from it electronically. This is especially true for information transmitted via e-mail. GRT has no way of protecting that information until it reaches us. Once a transmission is received, GRT makes its best efforts to ensure its security on its servers. Internally, access to personal information is restricted to employees who need access to the information in order to do their jobs. These employees are limited in number, and are knowledgeable about and committed to our privacy policies.
Accuracy of and Access to Personal Information Collected
GRT makes every effort to keep personal information as accurate, complete, current and relevant as necessary for the identified purposes. GRT does not routinely update personal information.
GRT makes readily available to individuals its Privacy Policy and related procedures for managing personal information. Customer access to the Privacy Policy and related procedures is provided on GRT’s website and in written form. Any questions about the handling of personal information by GRT can be raised with the Privacy Officer.
At the written request of an individual, he or she may view or edit their personal information as collected by GRT. GRT will inform them of what personal information it has about the individual, what it is being used for and, in cases where it has been disclosed, to whom it has been disclosed. There may be exceptional circumstances as provided by the CSA Model Code under which GRT may not be able to give an individual access to personal information held about them by GRT. In this case GRT will explain the reason for this lack of access, as provided by the CSA Model Code.
To make a request, please send an email to our Privacy Officer at the address indicated above. In any written request, please include the following information:
Name
Contact details
Nature of the request, for example:
view and/or edit information
inquire regarding use and/or disclosure
GRT will reply to requests in no later than thirty days after receipt of the request, or if it is not able to respond within this time period, a notice of extension will be sent.
Questions
Any questions or comments about GRT’s handling of personal information should be directed to the Privacy Officer.
Use of GRT Website
GRT believes that online privacy is important to the success of the Internet and electronic commerce in general and is strongly committed to each visitor’s right to privacy. This statement sets forth GRT’s Privacy Policy for its website located at grtenv.com and describes the practices that GRT follows in respect to the privacy of the users of this site. By accessing and using materials from this website or sending or posting materials to it, you (the “user”) agree to the terms of this privacy commitment and to our practices to collect, use or disclose personal information.
This Privacy Statement may be updated periodically to reflect enhancements to the GRT website that may affect the use of personal information. Accordingly, please check back periodically.
Information on This Website
Information which includes all facts, data and other information, collectively the “Information” in the pages of this website is of a general nature, is intended only for informational purposes, is subject to change without notice, and is not intended to be relied on by visitors as binding legal advice on any particular matter.
Individual information provided to GRT to gain access to any feature of this website will not be sold or made available to any third party, except where information processing is outsourced by GRT in the course of its regular administrative procedures.
GRT reserves the right to perform statistical analyses of aggregated user behavior and characteristics, in order to measure interest in and use of the various sections of its site so as to improve design and navigation and to gather information for marketing purposes. Only aggregated data from these analyses, not individual data, will be used for this purpose.
“Cookies” are not attached to GRT’s website. A “cookie” is a piece of data that is stored on the hard drive of a computer that contains information about use of the website. Other websites may contain “cookies” that accumulate information about website use, for example a record of the websites that an individual has visited.
Accuracy of the Information on This Website
The information on GRT’s website is believed to be accurate, complete and current when posted, but GRT cannot guarantee that it will remain accurate or complete or that it will be current at all times.
GRT is not responsible for direct, indirect, special or consequential damages, regardless of the cause, arising out of the use of this website.
Accuracy of Information on Linked Websites
Through the links to other sites found on GRT’s website, the user may enter domains that are beyond the boundaries of GRT and, once there, GRT is not responsible for the privacy practices or the content of these websites. GRT has no control over the accuracy, completeness or relevance of the information on these sites and provides links to these sites solely for the information and convenience of visitors to our website.
Copying Information from This Website
The information on GRT website may be used or copied provided that it is used or copied accurately, or is used in its entirety and/or that the source of the information is clearly identified. Only a member of GRT may use the information for commercial purposes. GRT is not responsible for the way in which the information may be used or copied. GRT reserves the right to change, delete or add information at any time.