Privacy Policy

Growth Associates* is committed to protecting the privacy and security of your personal information obtained by reason of your customer relationship with Growth Associates*. This policy explains the types of customer personal information we collect, how it is used, and the steps we take to ensure your personal information is handled appropriately.

What is personal information?

Personal information is information that refers to an individual specifically and is recorded in any form. Personal information includes such things as age, income, date of birth, ethnic origin, medical records and credit records. Information about individuals contained in the following documents is not considered personal information:

• Public telephone directories, where the subscriber can refuse to be listed
• Professional and business directories available to the public
• Certain public registries and court records
• Certain other publicly available printed and electronic publications.

Our commitment to your privacy is governed by the following privacy principles:

1. We obtain your consent to collect, use or disclose your personal information

Growth Associates* obtains your consent to collect, use or disclose your personal information. The method of obtaining consent is appropriate to the type of personal information being collected, used or disclosed:

• Growth Associates* will obtain your express consent (verbal, written or electronic agreement) to collect, use or disclose sensitive personal information.
• Growth Associates* will use implied consent to collect, use or disclose your personal information where one or more of the following apply
• A customer relationship already exists
• Express consent has previously been given
• Where the purpose of using the personal information is reasonably apparent to you

You can change your consent preferences at any time by contacting Growth Associates* by phone, email, mail or in person.

2. We limit collection of your personal information

Growth Associates* collects only the information required to provide products and services to you. If the personal information we require is collected for a reason other than to provide products and services your consent will be obtained before or at the time the information is collected. Growth Associates* will collect personal information only by clear, fair and lawful means. Examples of why we collect personal information include:

• Communicating with you generally
• Protecting against fraud or error
• Providing products and services requested by you
• Recommending products and services that Growth Associates* believes will be of interest and provide value to you
• To comply with legal and governmental requirements

3. We limit use, disclosure and retention of your personal information

Growth Associates* uses and discloses your personal information only for the purposes it was collected. Growth Associates* does not sell or rent personal information to any organization or person for any reason. We do not share your personal information with third party organizations except to offer you a product or service. If your personal information is shared with third parties, these third parties are bound by appropriate agreements with Growth Associates* to secure and protect the confidentiality of your personal information. We retain your personal information only as long as it is required for our business relationship or as required by federal and provincial laws.

4. We are open about our privacy and security policy

We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information. This policy and any related information is available at all times on our web site, www.growth-associats.ca under Privacy Policy or on request.

5. We provide access to your personal information stored by Growth Associates*

You can request access to your personal information stored by Growth Associates*.

You can contact us via email, telephone, mail or in person. Please see the contact us section below for further details. Upon receiving such a request, Growth Associates* will:

• Inform you about what type of personal information we have on record or in our control, how it is used and to whom it may have been disclosed.
• Provide you with access to your information so you can review and verify the accuracy and completeness and request changes to the information.
• Make any necessary updates to your personal information.

6. We respond to your questions, concerns and complaints about privacy

Growth Associates* responds in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures.

How to contact us:

• By calling us at (905) 688-2226
• By email to info@growth-associates.ca
• By mail to Growth Associates*, 184 King Street, St. Catharines, ON Canada, L2R 3J7