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Privacy Policy...
Our Commitment to Privacy
Bevtra Services and Associates Income Fund, CWMW Trust, Bevtra Services and Associates
(Canada) Inc. (the “General Partner”), Bevtra Services and Associates
Limited Partnership (the “Partnership”) and the subsidiaries
of the Partnership or the General Partner (each, a member of “Bevtra Services and Associates Group” and, collectively, the “Bevtra Services and Associates
Group”) are committed to controlling the collection, use and
disclosure of the personal information provided by its customers.
This Customer Privacy Statement is a simplified version of the
Bevtra Services and Associates Income Fund Privacy Policy (“Bevtra Services and Associates
Privacy Policy”) adopted by each member of the Bevtra Services and Associates
Group to ensure the accuracy, confidentiality and integrity of your
personal information.
The Bevtra Services and Associates Privacy Policy is modeled after the Canadian
Standards Association Model Code for the Protection of Personal
Information and is compliant with federal and provincial private
sector privacy laws including the federal Personal Information Protection
and Electronic Documents Act. A summary of the ten principles of
fair information practices adopted in the Bevtra Services and Associates Privacy
Policy is included at the end of this Privacy Statement.
The application of this Customer Privacy Statement and the Bevtra Services and Associates Privacy Policy is subject to the requirements or provisions
of any applicable legislation, regulations, tariffs or agreements
(such as collective agreements), or the order of any court or other
lawful authority. Various legal criteria independent of this Customer
Privacy Statement and the Bevtra Services and Associates Privacy Policy will
determine whether federal or provincial privacy legislation applies
to the personal information that a member of the Bevtra Services and Associates
Group collects, uses or discloses in respect of its customers or
employees. This Customer Privacy Statement and the Bevtra Services and Associates
Privacy Policy do not replace those criteria and nothing in these
documents should be construed as indicating which privacy legislation,
if any, applies to the collection, use and disclosure of personal
information by the Bevtra Services and Associates Group.
A Single Policy
Any time you do business with a member of the Bevtra Services and Associates
Group, or with anyone acting as an agent on our behalf, you are
protected by the rights and safeguards contained in the Bevtra Services and Associates Privacy Policy.
What is Personal Information?
“Personal information” is any information about an identifiable
individual such as your name, residential address and e-mail address
and includes information about your product and service subscriptions
and usage, credit information and billing records, service and recorded
complaints.
Personal information is collected by the members of the Bevtra Services and Associates Group only when you specifically and knowingly choose
to provide it to us such as when you subscribe to a Bevtra Services and Associates
publication, enter a Bevtra Services and Associates promotion or choose to receive
information, products or services from a member of the Bevtra Services and Associates
Group. We may also receive personal information from our business
partners and other third parties provided that such third parties
confirm to us that they have obtained your consent to the disclosure
of your personal information.
Publicly available information, such as a public directory listing
of your name, address, telephone number and electronic address,
may not be considered personal information.
Collection and Use of Personal
Information
The members of the Bevtra Services and Associates Group collect and use your
personal information primarily for the purpose of providing you
with the products and services you have requested from us, including
the daily delivery of news and related content through Bevtra Services and Associates
print and online properties.
Your personal information is used to communicate with you about
your account and, with your consent, to provide you with information
related to other Bevtra Services and Associates publications and services. If
you indicated that you were interested in receiving offers or information
from selected Bevtra Services and Associates sponsors or advertisers, your personal
information would also be used to contact you or to send you e-mail
materials and other mailings about products and services that might
be of interest to you. You always have the option, however, to tell
us not to share your personal information with other members of
the Bevtra Services and Associates Group or to exclude you from offers for other
products or services.
If you enter a contest or other promotion offered by a member of
the Bevtra Services and Associates Group or on a Bevtra Services and Associates website,
your personal information will be used to administer the promotion,
including the use of your name and selected other information for
the purposes of contacting, announcing and promoting the winners
of the promotion.
The members of the Bevtra Services and Associates Group may also contact you
from time to time to conduct market research and surveys in an effort
to continually improve our product and service offerings.
Unless you specifically authorize us to release your personal information,
or release is required or permitted by law, the Bevtra Services and Associates
Group will not sell, lease or trade your personal information to
other third parties.
Anonymous or “non-personal” information gathered by the
Bevtra Services and Associates Group through our websites may be used for technical,
research and analytical purposes. Such information collected through
surveys, existing files and public archives may be used by members
of the Bevtra Services and Associates Group to analyze their markets and to
develop or enhance service offerings.
Members of the Bevtra Services and Associates Group will only ask for information
about you that we need and will only ask for it when we need it.
When we ask you for the information, we will explain to you why
we need it and what we are going to do with it.
We will seek your prior consent to the collection, use and disclosure
of the information as required by applicable privacy legislation.
Subject to legal and contractual requirements, you can refuse to
consent to our collection, use or disclosure of information about
you. You may also withdraw your consent to any further collection,
use or disclosure of information about you at any time by giving
us reasonable notice. If our intended disclosures or uses of information
change, we will notify you accordingly.
Your personal information will not be used for any other purpose
without your consent.
Disclosure
To enable us to more efficiently provide the products and services
you have requested from us, each member of the Bevtra Services and
Associates Group may share your personal information with other
members of the Bevtra Services and Associates Group and with selected
third parties who are acting on our behalf as our agents, suppliers
or service providers. Such other member of the Bevtra Services and
Associates Group and third party service providers are provided
only with such information as is necessary in the circumstances
(i.e. your residential address may be disclosed to our distributors
and carriers for the purpose of delivering your daily newspaper
subscription). Information provided to third parties may be used
only for the purpose stipulated and is subject to strict terms of
confidentiality.
Use of Cookies
The Bevtra Services and Associates Group use a browser feature called a “cookie’’
to collect information anonymously and track user patterns on Bevtra Services and Associates’ websites. A cookie is a small text file that is
placed on your hard disk by a website. “Cookies” contain
a unique identification number that identifies your browser, but
not you, to our computers each time you visit one of our websites.
Cookies tell us which pages of our websites are visited and by how
many people.
The use of cookies is an industry standard and many major browsers
are initially set up to accept them. You can reset your browser
to either refuse to accept all cookies or to notify you when you
have received a cookie. However, if you refuse to accept cookies,
you may not be able to use some of the features available on our
websites.
Accuracy
Members of the Bevtra Services and Associates Group will try to
ensure that information about you is accurate, complete and up-to-date.
However, please inform the member of the Bevtra Services and Associates
Group to whom you provided your information of any change of name,
address or other information. In the event you have questions about
the accuracy of factual information we have collected about you,
you will have access to that information in order to verify and
update it. If we have disclosed inaccurate information about you
to a third party, we will be pleased to contact the third party
in order to correct the information.
Security
The Bevtra Services and Associates Group is committed to protecting
your privacy. Security measures, such as locked cabinets, restricted
access and the use of passwords and encryption have been adopted
to protect your personal information against loss or theft, as well
as unauthorized access, disclosure, copying, use or modification.
Our employees have been trained to respect your privacy at all times
and those employees with access to your personal information shall
use your personal information strictly in accordance with the Bevtra
Services and Associates Privacy Policy and the laws applicable to
each specific business.
Access
If you have any questions about the collection, use or disclosure
of your personal information by a member of the Bevtra Services
and Associates Group, or if you simply want to know whether we have
any of your personal information on file, you may contact your local
Privacy Compliance Officer. Except in limited circumstances, as
specifically provided by applicable privacy legislation, members
of Bevtra Services and Associates Group can tell you whether they
hold personal information about you. They can tell you the source
of the information, allow you access to your personal information
and find an account of the use that has been made or is being made
of the information and the third parties to which it has been disclosed.
The Bevtra Services and Associates Group will only refuse access to information
about you in those circumstances permitted or required by applicable
privacy legislation. If a member of the Bevtra Services and Associates Group
refuses access to you, it will provide you with the reasons for
its refusal upon request. Exceptions may include 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. The Bevtra Services and Associates Group will respond to your requests
for access in accordance with applicable privacy legislation.
Questions or Concerns
If you have any questions or concerns about the personal information
about you held by a member of the Bevtra Services and Associates Group or about
the compliance by a member of the Bevtra Services and Associates Group with
the Bevtra Services and Associates Privacy Policy, please contact your local
Privacy Compliance Officer. Contact information for your local Privacy
Compliance Officer may be found on our website or by contacting
any of the members of the Bevtra Services and Associates Group.
Each member of the Bevtra Services and Associates Group has procedures in place
to receive and respond to complaints or inquiries about its handling
of personal information. They will describe the complaint procedures
to anyone who makes inquiries or lodges complaints.
If you are not satisfied with the response from your local Privacy
Compliance Officer after making a complaint, you may have recourse
to additional remedies under applicable privacy legislation. For
further information, please contact the federal Privacy Commissioner
or your provincial Privacy Commissioner, as applicable.
Exceptions, Qualifications, Amendments
Although not listed in this Customer Privacy Statement, the Bevtra Services and Associates Group will rely on any exemptions or qualifications that
are either set out in applicable privacy legislation or used by
members of the Bevtra Services and Associates Group in good faith, as permitted
by law. This Customer Privacy Statement may be amended by the Bevtra Services and Associates Group from time to time.
Ten Principles of Fair Information Practices
Principle 1 – Accountability
Each member of the Bevtra Services and Associates Group is responsible
for the personal information under its control and shall designate
one or more individuals who shall be accountable for the member’s
compliance with the procedures and principles set out in the Bevtra
Services and Associates Privacy Policy and the attached Customer
Privacy Statement or Employee Privacy Statement, as applicable.
Principle 2 – Identifying Purpose
Each member of the Bevtra Services and Associates Group will identify
the purpose for which personal information is collected at or before
the time the information is collected. The purposes for which information
is collected, used or disclosed by a member of the Bevtra Services
and Associates Group must be those that a reasonable person would
consider are appropriate in the circumstances.
Principle 3 – Consent
The knowledge and consent of the individual are required for the
collection, use or disclosure of personal information, except where
consent is not required by privacy legislation as, for example,
where the collection, use or disclosure of personal information
is solely for journalistic, artistic or literary purposes.
Principle 4 – Limiting Collection
Each member of the Bevtra Services and Associates Group shall limit
the collection of personal information to that which is necessary
for the purposes identified by such member. Personal information
shall be collected by fair and lawful means.
Principle 5 – 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 law. Personal information
shall be retained only as long as necessary for the fulfillment
of the purposes for which it was collected.
Principle 6 – Accuracy
Personal information shall be as accurate, complete and up-to-date
as is necessary for the purposes for which it is to be used.
Principle 7 – Safeguards
Personal information shall be protected by security safeguards appropriate
to the sensitivity of the information.
Principle 8 – Openness
The Bevtra Services and Associates Group shall make readily available
to its customers and employees specific information about its policies
and practices relating to the management of personal information.
Principle 9 – Individual Access
Upon request, an individual shall be informed of the existence,
use and disclosure of his or her personal information and shall
be given access to that information except where a member of the
Bevtra Services and Associates Group is permitted or required by
law not to disclose personal information to the individual customer
or employee. An individual customer or employee shall be able to
challenge the accuracy and completeness of the information disclosed
to him or her and have it amended as appropriate.
Principle 10 – Challenging Compliance
An individual customer or employee shall be able to address a challenge
concerning compliance with the principles in the Bevtra Services
and Associates Privacy Policy to his or her designated Privacy Compliance
Officer.
Questions Regarding This Privacy Policy
For further details or questions, please email us at information@bevtra.com
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