Introduction

​​Stratking Marketing is committed to maintaining the privacy, security and accuracy of the personal and business information we collect, use and disclose in accordance with applicable legislation. We may be required to collect information of a personal nature including lifestyle or financial situation of our respective clients, employees or representatives (each an “individual”).

Stratking Marketing(“Company”) is aware of the sensitivity of such information and will ensure that it is kept strictly confidential. The purpose of this policy is to confirm, formalize and promote the protection of personal and business information in possession and control of the Company with respect to it’s Business and Individual clients.

A. General Policy

1. ​Personal or Business information
   Personal or Business Information is defined as being any information concerning an individual or Business and allowing the identification of him or her or the Business. Personal and Business information has to be protected regardless of its characteristics or its form whether written, graphic, audio, visual, computerized or any other form.
2. Purposes of Information Collection
   The Company shall identify the purposes for which personal and business information is collected at or before the time of collection. Persons mandated by the Company to collect information or persons who collect information that is submitted to the Company, are required to explain to the concerned individuals or businesses the purposes for which the information is being collected.

   ​Information will generally be collected from individuals or businesses through the various forms. The sole objective of the information collected from the individuals or businesses will be to provide the products or services requested and to respond to their needs or the Company’s needs for the duration of their relationship with the Company.

3. Consent​​
   ​Where the Company collects personal information from an individual or business, the Company informs them of the purposes for the collection of the information and obtains their consent at or before the time of collection, as well as when a new use is identified. Every person or business must be informed of any further collection, use or communication of the information about them and provide express consent for these purposes. The Company seeks express written consent in order to collect, use or disclose personal or business information through different forms used by the Company. Where appropriate in the circumstances, the Company may accept a verbal or implied consent.
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   ​Consent must be given by the individual or business or an authorized representative such as a legal guardian or a person having power of attorney. Any person or business may withdraw their consent at any time, subject to legal or contractual restrictions.

   The Company must inform the person or business of the consequences of such withdrawal, including the possibility that the Company may not be able to provide a product or the inability to process a request. The Company may have to collect, use or disclose information without the individual or business knowledge or consent for legal, medical or security reasons. The Company may also be required to disclose information to regulatory institutions and public bodies having the authority to investigate.

4. Limitations to Collection, Use, Disclosure and Retention
   ​The Company must always proceed by fair and lawful means in the collection, use, disclosure or retention of information. The Company must not collect, use or disclose information except with the consent of the individual or business or as required by law. The Company must limit the amount and type of information collected to that which is necessary to fulfil the purposes identified. The Company shall only collect personal or business information from the concerned party unless this party allows the Company to collect it from a third party.
   ​Personal information held by the Company is only accessible to parties having authority to access such information. They use such information only to the extent necessary in the discharge of their duties for and on behalf of the Company.

   The Company shall retain personal or business information only as long as necessary for the fulfilment of the purposes for which it was collected and the information must be destroyed in accordance with the law and Company’s guidelines with respect to the retention of files. The Company shall occasionally share information concerning individuals or businesses with suppliers or agents to ensure the management of the selected products or to provide the required services. These suppliers or agents shall have to commit themselves to comply with privacy legislation before any communication of information.

5. Accuracy​
   ​The Company shall endeavor to ensure that personal or business information is as accurate and complete as necessary for the purposes for which it is to be used. The Company shall not routinely update such information, unless such a process is necessary to fulfil the purposes for which the information was collected. If ever your contact and/or other personal or business information changes, please feel free to contact us, so that we can update our records.
6. Accountability
   ​The Company is responsible for personal and business information in its possession or control, including information that has been transferred to a third party for processing. The Company requires such third party to keep personal information under strict standards of privacy and protection. The Company shall ensure that each department has implemented procedures to apply the principles of this policy. The Company shall adequately inform and train its employees on the Company’s policies and procedures with respect to the protection of information.
7. Safeguards
   ​The Company has implemented and continues to implement appropriate safeguards with the purpose that personal or business information remains strictly confidential and that it is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. In addition, your information is only made available to our employees and service providers who have a “need to know” in order to offer you our services or otherwise fulfil the purposes identified in Section 3 above.
8. Request for Access to Information or Amendments
   ​The Company’s policies and procedures concerning the protection of personal or business information shall be readily available to it’s clients. The Company must inform an individual of the existence, use, and disclosure of his or her personal information and his or her right to access the information. The Company shall respond to an individual’s request for information on himself or herself, within a reasonable time. An individual may challenge the accuracy and completeness of personal information and have it amended as appropriate. The Company shall respond to an amendment request within a reasonable time. Any request for access to information or request for amendment must be sent to the following address:

   Stratking Marketing
   Hudson’s Bay Centre
   2 Bloor Street East, Suite
   Suite 3500
   Toronto, Ontario,
   M4W 1A8
   Canada

9. Complaints and Concerns
   ​The Company’s employees and representatives are trained to address clients’ questions or concerns relating to personal or business information. If the employee or representative dealing directly with the customer did not satisfy such concern, he or she may contact the President at the address provided in section 8 of this Policy. If a customer wants to make a complaint concerning the protection of personal or business information, he or she may provide a complaint in writing to the President at the address provided in section 8 of this Policy.

   ​The President will respond to such a complaint within 10 business days. For a justified complaint, the Company will make the appropriate corrections and modify its practices and procedures if necessary.