2. Personal Information
Personal information is information about an identifiable individual. Personal information does not include aggregated information that does not allow an individual to be identified. An individual’s business contact information, such as his or her name, title, business address, business telephone and business facsimile numbers, are not considered to be personal information.
3. Privacy Principles
Principle 1 – Accountability
Principle 2 – Identifying Purposes for Collection of Personal Information
Sutton Fair shall identify the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which Sutton Fair collects, uses or discloses of personal information are described in section 4 below.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of his or her personal information, except where inappropriate or as permitted by law. In obtaining consent, Sutton Fair shall use reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information will be used or disclosed. In determining the appropriate form of consent, Sutton Fair shall take into account the sensitivity of the personal information and the reasonable expectations of a reasonable person. Consent shall not be obtained through deception. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Sutton Fair will advise the individual of the implications of such withdrawal.
Principle 4 – Limiting Collection of Personal Information
Sutton Fair shall limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by Sutton Fair. Personal information shall be collected by fair and lawful means, and not by misleading or deceiving individuals about the purpose or which information is being collected.
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Sutton Fair shall not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Sutton Fair shall retain personal information only as long as necessary to fulfill the identified purposes.
Principle 6 – Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Sutton Fair shall update personal information about individuals as and when necessary to fulfill the identified purposes or upon notification by the subject individual. Sutton Fair will not routinely update personal information, unless such process is necessary to fulfill the identified purposes.
Principle 7 – Security Safeguards
Sutton Fair shall protect personal information by security safeguards appropriate to the sensitivity of the information. Sutton Fair shall use reasonable efforts and security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction. Sutton Fair shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the limited purposes for which it is to be used.
Principle 8 – Openness Concerning Policies and Practices
Sutton Fair shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. Sutton Fair shall make information about its personal information policies and practices available on the Sutton Fair website at www.Suttonfair.com and upon request to the Chief Privacy Officer via the contact information provided below.
Principle 9 – Individual Access to Personal Information
Upon written request from an individual pursuant to Principle 8, Sutton Fair shall inform the individual of the existence, use, and disclosure of his or her personal information and, subject to certain exceptions, shall give the individual access to that information. If access is denied, Sutton Fair shall notify the requesting individual in writing, give reasons for the denial, and inform the individual of the recourses open to him or her. If access is granted, Sutton Fair shall afford the requesting individual a reasonable opportunity to review the personal information collected by Sutton Fair. Personal information will be provided in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. Sutton Fair may extend such 30 day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Sutton Fair or the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 – Challenging Compliance
4. Identified Purposes for the Collection, Use and Disclosure of Personal Information
Sutton Fair and its agents, affiliates and service providers may collect, use and/or disclose your Personal Information for the following purposes:
(a) to consider whether Sutton Fair or any of its affiliates should establish or continue a commercial or franchise relationship with existing or potential exhibitors, including without limitation, to evaluate credit standing and to match credit bureau or credit reporting agency information, to check references and confer with banking institutions;
(b) to establish and maintain commercial or franchise relations with exhibitors, customers, suppliers, financial institutions, and affiliates, and to provide ongoing products and services, administer accounts, make and receive payments, engage in leasing arrangements (including without limitation, with M.T. Leasing Inc.), and fulfill contractual obligations;
(c) to understand and respond to franchisee and customer needs and preferences, including to communicate with exhibitors and customers and to conduct surveys and promotions;
(d) to develop, publish and distribute our franchise newsletters, press releases, marketing and advertising media, and other Sutton Fair branded products and services, in any format or media;
(e) to develop, enhance, market, sell, provide and inform you of Sutton Fair’s products and services;
(f) to develop, enhance, market, sell, provide and inform you of products and services of third parties, including our affiliates and franchise suppliers, with whom Sutton Fair and/or its exhibitors have a commercial relationship;
(g) to manage and develop Sutton Fair’s and its affiliates’ businesses and operations;
(h) in the course of conducting regular human resources operations, compensation, tax and benefits administration, including for the purposes of establishing, managing or terminating an employment or consulting relationship, to administer corporate travel, and to obtain and provide references regarding prospective, current or former personnel and exhibitors;
(i) to update and verify our databases and information provided by third parties;
(j) to monitor communications to ensure the consistency and quality of the products and services of Sutton Fair, its affiliates, exhibitors, suppliers, and other third parties with whom Sutton Fair has a commercial relationship;
(k) to detect and protect Sutton Fair, its affiliates, exhibitors and other third parties against error and fraud and other illegal activity, and to audit compliance with Sutton Fair’s corporate policies and contractual obligations;
(l) to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Sutton Fair or its affiliates or exhibitors;
(m) as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
(n) for any other purpose to which you consent.
In addition to the purposes identified above, Sutton Fair may collect, use or disclose personal information from or to an organization or individual (including an affiliate):
(1) who, in the reasonable judgment of Sutton Fair, is providing or seeking the information as an agent of the subject individual;
(2) retained by Sutton Fair to perform functions on its behalf or to provide services to Sutton Fair, provided such organization or individual does not collect, use or disclose the personal information for any purpose other than to perform such functions or provide services to Sutton Fair;
(3) where the subject individual consents to such collection, use or disclosure, or as required or permitted by law.
5. Privacy and our Websites
Online Communications – In order to provide you with a product, service or information, you may voluntarily submit personal information to us for purposes such as submitting a franchise application, obtaining information, corresponding with us, and participating in contests and surveys. We may combine and store personal information about your use of our websites and the online information you have provided with certain other online and offline information we may have collected.
E-Mail Communications – Occasionally, Sutton Fair may send you e-mail communications with information that may be useful to you, including information about the products and services of Sutton Fair, its affiliates and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from Sutton Fair. However, if you are a franchisee, customer, supplier or otherwise have a commercial relationship with Sutton Fair, to ensure that you receive important information, you agree that we may send you non-marketing related information when necessary.
Links – Our websites may contain links to other websites which are provided to you as a convenience only. You are advised that other third party websites may have different privacy practices than Sutton Fair, and Sutton Fair has no responsibility for such third party websites.
Date last revised: March, 2012
Description of Revision: New draft
7. Further Information
For more information on Sutton Fair’s privacy practices or if you have questions or concerns about your privacy, you can contact us through the Sutton Fair website at www.Suttonfair.com or by phoning the office at (905) 722-3165. Our office representatives will assist you in resolving the situation. If you still have unsolved concerns with respect to the treatment of your personal information by Sutton Fair, you may address these concerns to the Chief Privacy Officer at:
Sutton Fair Chief Privacy Officer
P.O. Box 460, Sutton, ON, L0E 1R0 Canada