WEBSITE PRIVACY POLICY

Last Updated: July 1, 2019

Our Commitment to Privacy: matter architectural studio inc. (“matter”, “it”, “us” or “we”) is committed to protecting the privacy and confidentiality of personal information in its possession. This privacy policy is available from our website (“http://www.matterinc.ca”) and it explains how personal information is collected, used and disclosed concerning matter’s customers and other individuals. matter is committed to collecting, using and disclosing personal information responsibly and in accordance with this privacy policy.

If you do not consent to the collection, use and disclosure of your personal information in accordance with this privacy policy, do not provide matter with any personal information. It is important to note that some sections of this Website can only be used, and some of matter’s products and services can only be provided, if matter receives the appropriate and required personal information. Consequently, should you choose not to provide matter with the required personal information, matter may be unable to offer access to this Website, or products and services, to you.

matter does not knowingly or intentionally collect personal information from visitors who are under the age of thirteen (13). By using this Website or receiving any products of services from us, you represent and warrant that you are over the age of 18 and are lawfully able to accept this Agreement. If you do not have the capacity to enter into a legal agreement in the province, state, territory or country in which you reside, do not access or use the Website or receive any products or services from us unless your parent or guardian enters into this Agreement on your behalf and consents to your access to and use of the Website and any products or services we provide to you.

Accountability: matter has designated a Privacy Officer who is responsible for the creation, oversight and implementation of this Privacy Policy and procedures to protect personal information, for receiving your privacy-related questions, and for providing you with information about our privacy practices. Our Privacy Officer is also responsible for notifying you of any material changes to our privacy practices, by posting updated information on our Site.

You can contact our Privacy Officer:

info@matterinc.ca
Attention: Privacy Officer

Please contact our Privacy Officer to obtain further information about matter’s policies and procedures, to seek access to personal information matter may have about you, or if you have any unresolved inquiries or concerns. matter will respond to you and try to resolve your concerns. matter may need to ask you for personal information to verify your identity.

Personal Information: For the purposes of this privacy policy, the term “personal information” means any information that is defined to be personal information under applicable privacy laws. Usually, this refers to any information about an identifiable individual or any information that can be used to identify an individual. As an example, personal information may include any of the following: a person’s name, email address, residential address, telephone number, social media addresses, and in some cases, more sensitive information such as but not limited to gender, demographic information, family status, investment particulars, consumption preferences, business expenditures, credit score, accounting data, social security or social insurance numbers, bank account information, and payment card information.

In most circumstances, personal information does not include the business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information, such as information in a public directory, is not personal information under this privacy policy.

Purposes: matter may collect, use or disclose personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:

Limiting Collection: matter collects your personal information in accordance with this privacy policy. matter will try to limit the collection of your personal information to only the minimum amount of personal information required to fulfill the identified purposes, such as facilitating use of this Website, and provision of any products or services to you. However, in some instances we may provide you with the option of sharing additional personal information that will enhance your use of our Website and any products or services we provide to you.

Limiting Use, Disclosure and Retention: matter and its staff will use your personal information in accordance with this privacy policy. matter will not use or disclose personal information for purposes other than the purposes identified herein, or for purposes for which we have obtained your consent elsewhere.

We also ensure that only our employees, or third parties, responsible for the Website operations, or for providing you with any products or services, have physical or technical access to personal information and only where such access is required to perform work authorized by us.

matter will retain personal information only for the duration of your enrolment as a matter user unless otherwise required by our obligations to you, to third parties, or by law. Personal information will be retained in fully encrypted, secure and segregated databases. If you choose to withdraw from the Services, we will securely destroy your personal information in our possession and control within a reasonable period of time, unless we are required to retain such personal information longer to fulfill our obligations to you, to third parties, or by law. However, we may retain non-personally identifiable information indefinitely.

We retain all personal information provided by you on secure servers in Canada or in jurisdictions outside of Canada. Some of our third party partners and service providers may store data received from you (including personal information) on servers in Canada or in other jurisdictions outside of Canada. Data, including personal information, stored outside of Canada will be subject to the laws of the jurisdiction in which such data is stored.

By accessing our Website you consent to the storage of your personal information in Canada or outside of Canada and recognize that if your personal information will be subject to the laws of the jurisdiction in which such data is stored. This consent includes all personal information provided via the Website including any password protected portion of the Website. If access to our Website or use of any of our products or services are provided to you by one of our third party service providers, the third party service provider may have their own terms of use and privacy policies that will govern your relationship with such third parties. You are responsible for reviewing and agreeing to these terms of use and policies. If you do not agree with these terms of use or privacy policies you should not use the products or services offered by such third party service providers.

When matter data is viewed via a mobile device, some data is cached in the memory of the device. That data is deleted when the related application is closed and does not persist. If the application is put in the background without closing, the data may remain in the cache. We take no responsibility for any unauthorized viewing of this data by third parties.

When possible, matter will use non-identifiable, aggregate information (e.g. number of users and transactions) when providing information to any third party.

Consent: matter takes a consent-based approach to the collection, use and disclosure of personal information. We collect personal information directly from you and may collect personal information about you from other sources, such as websites having links to or from this Website, government ministries, departments or agencies, government registries, investigators, health institutions or organizations, insurance companies or financial institutions. We will only obtain personal information from such organizations (e.g., your bank or other third party service providers) when you provide us with the account numbers, passwords or other credentials required to retrieve the personal information, for the purpose of providing you with use of our Website or use of products or services we provide to you.

We use and disclose the personal information only as described in this policy, in accordance with other consents we receive from you, and in accordance with our Terms of Use.

Privacy legislation requires matter to obtain the consent of an individual to the collection, use or disclosure of personal information in many circumstances.

By providing your personal information to matter, you agree that matter may collect, use and disclose your personal information in accordance with this privacy policy and as otherwise permitted or required by law, and that matter may access, process and store your personal information in Canada or another jurisdiction.

When matter receives personal information from you for the purposes of providing you with use of this Website, matter’s products or services, or for other uses identified herein by matter, you are providing matter with consent as follows:

  1. to allow matter to deal with that personal information in a reasonable manner;
  2. to allow matter to provide your personal information to third parties it engages to provide or support matter’s Website, or to provide any products or services to you;
  3. to allow matter to collect your additional personal information from third party sources when you provide us with information required to retrieve your information from such third party sources;
  4. to allow matter to use and store your personal information for the purpose of providing you with the products and services you purchase from matter and to utilize this Website; and
  5. to allow matter to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your personal information by matter.

If you need to provide matter with personal information about other individuals, including but not limited to any of your employees, agents, contractors or representatives, you represent and warrant to matter that:

Providing matter with your personal information or the personal information of other individuals is always your choice. When you use this Website, request products and/or services from matter, utilize matter’s services, or register with this Website, matter asks that you provide information that enables matter to respond to your request and/or provide you with matter’s products or services. In doing so, you consent to matter’s collection, use and disclosure to appropriate third parties of such personal information for these purposes.

There are legal exceptions where matter will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if matter must comply with a court order or governmental order.

If matter sells its business or merges with another party, your consent will be implied to transfer your information to matter’s successor for the same purposes as set out in this privacy policy.

Disclosure of personal information: matter will only disclose your personal information for the purposes set out in this privacy policy.

matter will never sell your contact details to a third party. matter does not sell client lists or personal information to others. In providing matter’s products or services or access to matter’s Website, matter may need to disclose the personal information matter collects to other service providers or agents who perform various functions for matter, provided such suppliers agree to keep all personal information private, confidential and secure and to use the personal information only to carry out work on matter’s behalf.

In certain circumstances, matter may be required to provide personal information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstance matter may have a legal duty or right to disclose personal information without the individual’s knowledge or consent. Various government agencies such as the Canada Revenue Agency, Human Rights Commission, Ontario Ministry of Finance; Ontario Ministry of Labour, etc. and law enforcement, have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.

Privacy and Our Websites: Each time a visitor comes to the Website, matter’s web server may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities on matter’s Website and/or webpages linked thereto. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. matter may use this non-personal information to optimize matter’s Website, products and/or services.

matter may, from time to time, use “cookies” solely for security and authentication purposes. Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or services. At your option, you may turn off matter’s “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of matter’s Websites, products and/or services. To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser.

matter may, from time to time, engage third parties to assist with this Website, and such third parties may track your usage, locate your geographic position, collect personal information, send messages to you on behalf of matter, push notifications to you, and use “cookies”, as discussed herein.

By accessing and browsing matter’s Website, products and/or service(s), you agree that matter, or any third party it engages or that assists matter, may collect, use and disclose any information collected about you through matter’s Website, products and/or services or that you provide to matter through matter’s Website, products and/or services as described in this privacy policy.

matter’s Website, products and/or service(s) may contain links to other sites and may provide forms on behalf of other organizations. This privacy policy only applies to personal information that we collect, use and disclose. matter is not responsible or liable for the privacy practices of third parties, including any organizations on the behalf of which matter provides forms, and matter strongly recommend that you review a third party’s privacy policy before disclosing any personal information to the third party.

Retention and Destruction of personal information: The amount of time matter will retain personal information varies, depending on the use of this Website, the products or services matter has provided, and the nature of the personal information that matter holds. matter retains personal information for such period of time as is necessary for matter to maintain sufficient information so matter may respond to any issues that arise at a later date or as is required by law.

When personal information is no longer required by matter or by law, matter will either convert it into an aggregated non-identifying form or matter will appropriately destroy or erase the personal information in a manner that is in accordance with matter’s current policies and procedures.

If you are a member and at any point you decide that you no longer wish to participate as an matter member, your practice information record required for the Website will be deleted and a copy of such record will be stored offline in a secure archive in accordance with related laws. Should you reinstate your membership information from this record may be accessed and utilized by matter.

Safeguards: matter implements reasonable industry practices appropriate to the sensitivity of your personal information to protect matter’s systems and personal information under matter’s control against unauthorized access and use. We use administrative, technical, and physical safeguards to protect your personal information against loss, theft, and unauthorized access, use, disclosure, copying, modification, disposal, or destruction in accordance with applicable legal requirements and industry best practices.

For example, we implement encryption and security controls to protect against unauthorized access to personal information during electronic transmission, and we train our employees to follow privacy and security practices specific to the Services. We also undertake security assessments to ensure that we maintain strong security controls.

matter may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and matter does not have any control over such external servers or services.

Electronic Communications: Email is frequently matter’s preferred method of communicating with you and others, and, unless you object, matter may use unencrypted plain text or html-based emails or messages when communicating with you. These emails or messages, and other electronic means by which matter may communicate with you, may contain information that is confidential, unless you instruct matter not to send such information electronically. matter may communicate with you through other electronic means, in accordance with the contact information you provide to matter.

While matter makes every effort to secure all electronic communications within matter’s control, there are inherent risks involved with exchanging information electronically. For example, such information may be accidentally or deliberately intercepted by third parties. matter is unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.

matter will endeavour to be compliant with Canada’s Anti-Spam laws (“CASL”) in matter’s commercial electronic communication with you. Should you fail to provide matter with the requisite consent to send you commercial electronic messages, or withdraw such consent, matter may be unable to provide, or continue to provide, this Website or some of matter’s products and/or services that can only be provided if matter receives appropriate and required personal information. CASL consent can be provided or withdrawn at: info@matterinc.ca

An unsubscribe link will also be provided in our emails to you.

Keeping Information Accurate / Access and Correction: matter relies on you to ensure that the personal information you provide to us while using the Website or any products or services that we provide to, relating to yourself or any other individual, is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You must verify all information created from your use of the Services and we recommend that you consult an accounting professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk.

You are responsible for ensuring that that the information you have provided is truthful, accurate, reliable and complete.

It is important to matter that your personal information held by matter is accurate and complete. Having accurate information about you enables matter to give you better service. It also helps to ensure the accuracy of the information in our reports, displays, articles and support queries, you can help matter keep personal information up-to-date by keeping matter informed of any changes, such as a change of address, telephone number or any other circumstances.

With some exceptions, matter has the right to access, verify and amend the information matter has about you after matter has received your written request and authenticated your identity.

In some situations, matter may not be able to provide access to certain personal information as the right to access personal information is not absolute. If matter does not provide you with the requested information, matter will notify you in writing and explain matter’s reason(s) for not fulfilling your request.

Despite matter’s efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let matter know and matter will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from matter. matter will note errors, incomplete information or unresolved differences in information collected in any file it has relating to you.

You agree to indemnify and hold matter, its affiliates, subsidiaries, partners, service providers, suppliers and contractors and each of their respective officers, directors, agents, and employees, harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from the collection, use and disclosure of personal information relating to you or any individual that you provide to us, and any personal information relating to you that we obtain from third party sources in accordance with this privacy policy.

Withdrawal of Consent: At any time and without penalty, you can withdraw their consent to matter’s collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions, by emailing us at: info@matterinc.ca

Should you choose to withdraw your consent, matter may be unable to provide, or continue to provide, this Website or some of matter’s products and/or services that can only be provided if matter receives appropriate and required personal information. Consequently, should you choose not to provide matter with the required personal information, matter may be unable to offer this Website and such products and/or services to you.

You may, at any time, ask matter not to send you further marketing materials about matter’s products or services or if you do not wish to receive further invitations, you may unsubscribe or ask matter not to contact you for these purposes. You can also request that we close your account at any time, subject to reasonable notice and any legal and/or contractual restrictions, by emailing us at: info@matterinc.ca

Once your account is closed, all personal information relating to your account will be deleted from our databases. However, anonymous transactional data (which does not personally identify you or any of your employees, agents, contractors and representatives) will be retained in our database.

Withdrawing your consent will not prohibit matter from undertaking actions that matter has already taken based on your prior consent.

Openness: matter makes clear and transparent notice of its privacy practices, and this privacy policy is publicly available on our Website. This privacy policy describes the collection, use, disclosure, and protection of personal information and provides the contact information of our privacy officer.

matter will advise you at the first reasonable opportunity upon discovering or being advised of an incident whereby your personal information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by unauthorized persons or in an unauthorized manner.

Privacy Concerns: matter will respond to questions and concerns relating to matter’s personal information handling practices and this policy. Please direct such questions and concerns to our privacy officer with the following indication on the envelope, on the letter and/or in the email, as applicable – Attention: Privacy Officer

Individual Access: Upon request, we will inform you if we hold any personal information about you and provide you with access to this information, within a reasonable period of time, and as permitted in accordance with applicable laws. If we have any personal information about you, we will also tell you for what purposes it is used or disclosed, within a reasonable period of time, and as permitted in accordance with applicable laws.

You have a right to update any personal information that we hold about you. Should you wish to see the full contents of your personal information file, you must make a formal written request and mail it to our privacy officer with the following indication on the envelope and the letter – Attention: Privacy Officer. We will respond to you within a reasonable period of time, or let you know why there might be a delay.

Changes to this Privacy Policy: This privacy policy is effective as of July 1, 2019. matter reserves the right to change this privacy policy, and any of matter’s policies and procedures concerning matter’s practices for handling personal information, at any time and without any prior notice. If matter has modified or amended our privacy policy, matter will post the most current version on matter’s Website. Any changes that are made to this privacy policy will apply to both any personal information that matter holds prior to the effective date of the amended privacy policy and any personal information that matter collects on or after such effective date.

Successors and Assigns: matter’s successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this privacy policy.

© matter architectural studio inc., 2019.