SMG Privacy Statement

Safe Management Group (SMG) websites are maintained by Safe Management Group Inc., 345 Lakeshore Road East, Suite 506, Oakville Ontario, L5J 1J5.

SMG (referred to herein as “SMG”, “we”, “us” or “our”) strives to ensure it meets privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation. The purpose of this statement is to inform our customers and other individuals we deal with (“you” or “your”) how we collect, use, disclose and protect your personal information. In particular it applies to our practices with respect to personal information of consumers of our products and visitors to our websites. SMG reserves the right to change this policy.

 

Collection of Information

SMG recognizes the importance of protecting the privacy of your Personal Information. Personal Information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This statement applies to our collection, use and disclosure of Personal Information in Canada. This statement does not apply to information about our employees or to information that is not personal information. SMG only collects Personal Information that is voluntarily provided to SMG by you so that we can serve your needs and our legitimate business purposes.

 

How We Use Personal Information

We may use your Personal Information to:

  • process and review your order;
  • conduct a credit check with your consent;
  • perform our business operations, including processing and servicing your orders and accounts, including fulfilling purchases and billing, collecting payment and accounting for those purchases;
  • responding to questions or enquiries;
  • to send newsletters or other announcements and commercial offerings we think may interest you;
  • sending order confirmations and status reports and promotional information about products and special offers;
  • keeping your credit card on file for future purchases, unless you tell us not to;
  • sending you communications on behalf of third parties that we think may offer goods or services that may be of interest to you, unless you tell us not to;
  • unless you tell us not to, providing your contact particulars (e-mail and postal address) to other marketers of products or services;
  • marketing the goods and services we provide;
  • managing, administering, collecting or otherwise enforcing accounts;
  • maintaining business records including records concerning purchases and payments on your account, and generally managing and administering our business;
  • meeting legal, regulatory, insurance, security and processing requirements; and
  • otherwise with your consent or as permitted or required by law.

 

Disclosure of Personal Information

SMG discloses Personal Information in the following circumstances:

    • to manage and administer customer accounts, including to process credit cards or other forms of payment;
    • to manage our business, including to enforce our user agreements;
    • as permitted by law to protect the rights, property or safety of SMG or its employees, representatives, agents and affiliates;
    • to enforce any debts that you may owe to us;
    • with your consent, to conduct credit checks from time to time;
    • with your consent, to other marketers of products or services, including online marketers;
    • as otherwise provided for in “How we use your Personal Information” above; and
    • as necessary to meet legal, regulatory, insurance, audit, processing and security requirements, as permitted or required by law (such as where we are required to do so by subpoena, court order, warrant or legally permitted inquiry by a government agency), or with your consent.

 

Service Providers. Personal Information may also be transferred to third party agents or service providers we engage to provide various services such as: hosting and maintaining our websites, ad-serving (placing third party ads on our sites), providing merchandise you purchase; mailing; providing services you use on our websites; managing our internal operations such as data analysis, site activity data collection and e-mails; customer service and fulfillment vendors; and call centre, administrative, billing or other processing services on our behalf. Some or all of our services may be provided through facilities located in the U.S. or elsewhere outside of Canada. We take reasonable measures to ensure that your Personal Information that may be collected, used, disclosed or otherwise processed by these service providers or our affiliates is protected and not used or disclosed for purposes other than as directed by SMG, but SMG and our service providers and affiliates may in some circumstances be subject to legal requirements in foreign jurisdictions, such as lawful requirements to disclose personal information to government authorities in those countries.

 

Business Transactions. Personal Information may be used by SMG and disclosed to parties connected with the contemplated or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of SMG or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include:

  • permitting those parties to determine whether to proceed or continue with the transaction
  • fulfilling reporting, inspection or audit requirements or obligations to those parties
  • permitting the use and disclosure of your Personal Information by those parties (for example, assignees) for substantially the same purposes as described in this Privacy Statement.

 

External Sites. SMG may place advertisements or other promotional offers from select companies on our websites, in our e-mails or in our mailings. When you choose to purchase these products or accept these promotional offers, you may link to these businesses’ websites or otherwise be asked to give them Personal Information, or we may send them your Personal Information if you have provided it to us for that purpose. These businesses operate independently from SMG. Any Personal Information that you provide to such external sites is no longer controlled by us or our Privacy Policy.

We may use third-party advertising companies to place ads on our sites. These companies may employ cookies and action tags (also known as “single pixel gifs” or “web beacons”) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is generally not personally identifiable (unless, for example, you provide Personal Information to them through an ad or e-mail message). If you choose to provide your Personal Information to these third party sites, we encourage you to read these businesses’ privacy policies to determine how they will collect, use or disclose your Personal Information.

If you enter our website from the site of one of SMG’s partners, our system will recognize the path you have taken. SMG may advertise on such partners’ sites or we may enter into a promotional partnership with them. We track the number of visitors to see the success of our online marketing or promotional campaign. These partners will not collect your Personal Information, unless you are notified in advance, if you have given it to them separately, or have consented to give it to them through us. In cases where such partners have access to your information, we contractually bind them to handle it in accordance with their posted privacy statements.

 

Consent

Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of Personal Information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with Personal Information, we will assume that you consent to our collection, use and disclosure of your Personal Information for the purposes identified or described in this Privacy Policy, if applicable, or purposes identified at the time of collection. You may withdraw your consent to our collection, use and disclosure of Personal Information at any time, subject to contractual and legal restrictions and reasonable notice. For example, you cannot withdraw consent to our use of your Personal Information necessary for us to collect a debt that you owe us. Note that if you withdraw your consent to certain uses of your Personal Information, we may no longer be able to provide certain of our products or services to you.

 

Security

We protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and mandataries of SMG who require access to your Personal Information in order to fulfil their job requirements will have access to your Personal Information.

 

Technology

We use encryption technology to help to safeguard your transactions. The technology used is SSL (Secure Socket Layer), which is supported by all web browsers that are version 4.0 or newer. Your Personal Information, including your credit card information, is encrypted as it travels over the Internet. When we receive your Personal Information, it is stored on restricted-access computers. Please be careful whenever sending Personal Information to us via any contact features on our websites or by e-mail. For example, do not send us your account password or credit card information via these methods, as they are not a secure means of transferring information. Our employees with access to your Personal Information are trained to follow specific practices concerning its proper handling. We have designed our websites not to display your full credit card information.

Your account is password-protected. You must use your password to submit an order or view your Personal Information in your account. Our sites are designed to sign you out automatically if your session remains inactive for a period of time. Currently that period of time is 20 minutes. If you share a computer, we recommend that you always sign out before leaving it unattended.

 

Technical Information

When you visit our websites, we may collect technical information that does not, by itself, identify a specific individual. This information may include, for example, the address (or “URL”) of the website that you came from before visiting our site, which pages you visit on our site, which computer platform, monitor, web browser and related software and settings you used to view our site and any search terms you have entered on our site or a referral site. This technical information is aggregated and used to measure and improve the effectiveness of our site. We may collect your IP (Internet Protocol) address and/or domain name to help diagnose problems with our server, administer our site, or see where our site traffic is coming from. We may also collect other information via our site, such as site usage activity and preferences, also known as demographic or profile data.

We may use “cookies” (described in more detail below) and clear GIFs on our site or in our e-mail communications with you to enhance the functionality of our site and to make your transactions and other activities more customized, convenient and efficient. We may use cookies, for example, to remember user preferences, show you new products based on your preferences, alert you to new site features, to minimize the need for you to re-enter information, and to store information about your activities on our site and other technical information. Cookies and/or clear GIFs may be placed by or third party service providers, who provide these services on our behalf.

We may also use your Personal Information in order to help improve our products or for marketing and promotional purposes. SMG will not release, sell, rent, or trade your Personal Information to any third party without your written consent.

Test results and certificates issued or denied from the online training modules may be shared with the online client’s employer or institution of employment exclusively.

The SMG website requires the use of Internet browser cookies to facilitate processing, to validate user access rights upon login, and to facilitate the user’s experience on the website. These cookies are session based and expire when the Internet browser is shut down. SMG does not use Internet browser cookies for any other purpose. Cookies are small pieces of information that we may send through your browser or other software to your hard drive. A cookie lets us recognize you and provide a more meaningful and personalized shopping experience when you come back to our site.

Most web browsers are set to accept cookies automatically, but you can change this setting. However, you may need to leave your cookies “on” in order to take full advantage of the features of our site. If your cookies are “off”, see your browser’s “help topics” to learn how to change the setting. Additionally, in the event that we use Flash cookies, your Flash layer can be set to accept, reject or delete them.

Users should be reminded that any Personal Information that is voluntarily posted by a user to a public area of our website (for example, a posting to a bulletin board or chat room) might be collected and used by others. We cannot prevent such uses.

SPECIAL NOTICE TO PARENTS: We have no intention of seeking Personal Information about minors (children under age 13) who visit SMG websites. The same privacy policies will apply to that information. In addition, if we can identify a user as a minor, the Personal Information will not be used for further marketing and promotion. We encourage you to ask your children to seek your permission before providing information about themselves or their family over the Internet.

SPECIAL NOTICE TO CHILDREN: Ask your parent or guardian for permission before you send any Personal Information over the Internet.

 

Contacting Us

This Privacy Statement refers in various places to you contacting us in order to:

1) receive information or special offers

2) withdraw your consent to our retention, use and disclosure of your Personal Information

3) access or correct your Personal information

4) receive a copy of the most current version of this Privacy Policy

5) communicate any questions, comments, or concerns about this Privacy Policy or the information practices of SMG.

 

You may contact us for any of these by:

1) writing to us, attention: Privacy Officer, Safe Management Group Inc., 349 Lakeshore Road East, Suite 506, Oakville, Ontario L6J 1J5

2) calling 905-849-0967 and 1-866-554-5001 .

3) sending us an e-mail to smg@safemanagement.org

4) faxing us at 905-849-1442, attention Privacy Officer, SMG

5) as otherwise specified in this Privacy Policy.

 

Requests regarding access to or correction of Personal Information must be made in writing.