Privacy Policy

TBA Privacy Policy – English

September 2020

TBA PRIVACY POLICY

TBA is committed to your right to privacy. Reference to “TBA” “we,” “us” or the “Company” is a reference to Transworld Business Advisors of Ontario and the relevant affiliates or subsidiaries involved in the data processing activity.

This Privacy Policy (“Privacy Policy”), forms part of our terms and conditions applicable to you, and governs the data collection, processing, use, transfer and disclosure made by us (or by anyone on behalf of us) in connection with: (i) visitors to our website: www.tworld.com/Ontario (respectively, “Visitor” and “Website”); (ii) the services provided by TBA pursuant to the suite of TBA agreements entered into with you; (iii) transactions made by you with TBA (“Client”); and (iv) other related services and applications (collectively, “Services”).

If you choose to use the Services, interact with the Website, or provide data to us otherwise, you explicitly agree to the use of such data in accordance with this Privacy Policy. You may not use the Website and/or Services or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Policy shall not be construed in any manner to derogate from the terms and conditions of the Website, or any other agreement or understanding between TBA and you.

The English language version of this Privacy Policy shall be controlling in all respects and shall prevail in case of any inconsistencies or discrepancies with translated versions of this Privacy Policy (including any related documents).

THE HIGHLIGHTS:

• You are not required by law to provide us with any Personal Data (defined below). Sharing Personal Data with us is entirely voluntary.  However, certain Personal Data is required for us to provide the Services to you.  If you do not provide such Personal Data, we will not be able to provide the Services to you.
• Our Website and Services are intended for Users over the age of 16, or equivalent minimum age for either providing consent to processing of Personal Data or using the Services in the relevant jurisdiction. Users under such age are not permitted to use the Services. If you are under such age you should cease to use the Services immediately. In certain jurisdictions using the Services may be restricted for Users under the age of 21.
• In certain jurisdictions you may be entitled under applicable law to request review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.
• We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances as specified herein.
• If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please send us an email to: tbaontario@tworld.com.

1.         What is Personal Data, and what data is collected about me by TBA?

“Personal Data” or “Personal Information” (will be referred together as “Personal Data”), means any information about an identifiable individual or that identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, online identifiers, IP address, billing information, information concerning households, devices etc.

“Non-Personal Data”, means non-identifiable aggregated data, such as technical data transmitted by the user’s device and aggregated use of the website. This data is not used to identify individuals.

Personal Data is only used for the limited purposes necessary to conduct the consulting activity as described in the TBA suite of documents entered into with you.

In addition, we may use certain of the above-mentioned Personal Data in order to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity theft and any other misuse of the Services and to enforce our rights against you, as well as to protect the security or integrity of our databases and Services. Such processing is based on out legitimate interests or based on legal obligation.

We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Website or collected by us, please inform us immediately.

Non-Personal Data

Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Website and Services, including among others, in order to measure and understand the level of engagement to our Services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services and features.

2.         Will TBA Share My Personal Data With Others?

WE DO NOT SELL OR RENT ANY OF YOUR PERSONAL DATA TO NON-AFFILIATED THIRD PARTIES FOR THEIR MARKETING PURPOSES.

Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and Services for our Users and Merchants.

We share Personal Data only under the following limited circumstances:

• With partners who are an integral part of our Services.
• With trusted third parties who assist us in operating the Services and conducting our business. Such as service providers who provide us with fraud prevention services, Client support call center services, debt collection agencies, account maintenance, marketing services, survey services and platforms, and technology services.
• With our affiliates and connected companies, such as subsidiaries to provide you with information about products and services that we or they believe may be of interest to you.
• For personalizing your experience of the Services.
• As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about the products, services and communications.
• Credit bureaus and collection agencies to report account information, as permitted by law.
• To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization or similar event.
• Other third parties with your consent or direction to do so.

3.         Any transfer of Personal Data originating outside of Canada shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.

If you would like to receive more information about our practices and policies with respect to our use of service providers and the jurisdictions in which they are located, please get in touch with us using the contact information provided below.

4.         Will I receive promotional materials from TBA?

We may send Users of the Services or Users who provided us with their consent with information on new products, features, activities, services and periodic announcements or newsletters. You may opt-out any time from such communications by either sending us an email to: tbaontario@tworld.com asking to opt-out.

5.         Users rights with respect to Personal Data

Subject to applicable law requirements, we will provide individuals with the opportunity to exercise their rights regarding their Personal Data. Individuals’ principal rights under data protection and privacy laws may include (you may have some or all of these rights depending on your jurisdiction):

• the right to confirm whether or not we process your Personal Data;
• the right to access your Personal Data and being provided with a copy of the Personal Data that we hold.
• the right to rectification of your Personal Data;
• the right to erasure of your Personal Data.
• the right to restrict processing of your Personal Data.
• the right to object to processing of your Personal Data;
• the right to data portability.
• the right to complain to a supervisory authority (in the event that you are a European Economic Area (“EEA”) resident); and
• the right to withdraw consent.

6.         How does TBA protect my data?

TBA implements measures to reduce the risks of loss of information and unauthorized access or use of information. We adopt appropriate and generally accepted data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed and you cannot reasonably expect that the Service and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse.

7.         Data Retention

Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.

HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: (i) directly from you, for example, when you fill our any of our forms; (ii) automatically when you visit our Website; (iii) from third-party business partners such as analytics providers.

USE OF PERSONAL INFORMATION

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry.
• To provide, support, personalize, and develop our Website and Services, as well as improve our Website and Services.
• For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Site Services.
• For testing, research, analysis, and product development, including to develop and improve our Website and Services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the Consumer Protection Act, 2002.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, disposition, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING AND SELLING DATA

We may disclose your Personal Information to a third party only for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

CONTACT US

If you have any questions about this Privacy Policy, you may contact us as follows:

By sending us email at: tbaontario@tworld.com

By regular mail at: 3280 Bloor Street West, Suite 1140, Centre Tower, Toronto, Ontario, Canada, M8X 2X3