What is Personal Information?
“Personal Information” is any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address). This Policy does not cover business contact information or aggregated data from which the identity of an individual cannot be determined. Nagel retains the right to use business contact information and aggregated data in any way that it determines appropriate.
Why Nagel May Collect Personal Information
Nagel uses Personal Information to:
(a) Establish a commercial relationship with you;
(b) Provide you with our products and services;
(c) Provide you with ongoing customer service;
(d) Provide you with information about our products and services;
(e) Process payments for products and services;
(f) Meet legal and regulatory requirements; and
(g) Such other purposes consistent with these purposes.
How Nagel Collects and Uses Personal Information
Nagel collects, uses and discloses Personal Information for purposes that are considered reasonable in the circumstances and only Personal Information that is required to support providing products or services to our clients. We only use fair and lawful methods to collect Personal Information. Our use of Personal Information is limited to the purposes described in this Policy. Nagel does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.
When Nagel May Disclose Your Personal Information
Nagel may disclose your Personal Information to:
a) Individuals or organizations who are our advisers or service providers; and
b) Individuals or organizations who are, or may be, involved in
(i) a transfer of all or part of the assets or business of Nagel;
(ii) maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems; or
(iii) a corporate re-organization of Nagel.
When sensitive Personal Information is provided to Nagel, we will only disclose that information if it is necessary to provide you with our products or services.
Where Nagel discloses Personal Information to organizations that perform services on our behalf, we require the service providers to use the information solely for the purpose of providing services to Nagel, our clients or the person concerned. We expect service providers to have appropriate safeguards to protect Personal Information.
There are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where Nagel is obliged to disclose information without consent. These circumstances may include:
a) Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
b) Where Nagel believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
c) Where it is necessary to establish or collect monies owing to Nagel;
d) Where it is necessary to permit Nagel to pursue available remedies or limit any damages that we may sustain; or
e) Where the information is public.
Where obliged or permitted to disclose information without consent, Nagel will only disclose information that is required.
Unless permitted by law, we do not collect, use or disclose Personal Information, without obtaining your consent.
In providing Nagel with Personal Information on or through our website or by other means, such as by email, by completing forms or by using links provided on our website, you consent to the collection, use and disclosure of that information. Where appropriate, specific authorization or consent may be obtained.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us on our “Contact Us” page. Your withdrawal of consent to our collection, use and disclosure of your Personal Information may affect our ability to provide goods or services to you. We will inform you of the consequences of the withdrawal of consent.
Nagel endeavours to ensure that Personal Information is as accurate, current and complete as necessary for the purposes for which we use the information. If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the information. When necessary, we use best efforts to inform third parties who were provided with Personal Information about the inaccuracies.
We only keep Personal Information for as long as it is required. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.
We destroy, delete, erase or convert your Personal Information into an anonymous form when it is no longer required by Nagel.
Protection of Personal Information
Nagel endeavours to maintain appropriate physical, procedural and technical security so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.
Access To Your Personal Information
Nagel permits the reasonable right of access and review of your Personal Information. We will provide the information in question within a reasonable time, generally no later than 30 days following your request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections. We will provide information from our records in a form that is easy to understand.
Nagel reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate. Nagel reserves the right to decline to provide access to Personal Information where the information requested:
a) Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm Nagel or the competitive position of a third party;
b) Would interfere with contractual or other negotiations of Nagel or a third party;
c) Is subject to solicitor-client, litigation or other legal privilege;
d) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
e) Does not exist, is not held, or cannot be found by Nagel;
f) May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
g) May be withheld or is requested to be withheld under applicable legislation.
Where information cannot be disclosed, we will provide reasons for non-disclosure. There is no charge for verifying or correcting your information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.
Resolving Your Privacy Concerns
In the event of questions about: (i) access to your Personal Information; (ii) our collection, use, or disclosure of Personal Information; or (iii) this Policy; please contact Nagel through our “Contact Us” page.