What is Personal Information?
The term “personal information” refers to any information about an identifiable individual or any information that allows an individual to be identified. In general, personal information does not include business contact information, such as your name, title or position, business address, nor your business email, telephone or fax number in your capacity as an employee of an organization. During your relationship with BANKRUPTCY LETHBRIDGE, you may be asked to provide certain personal information concerning you and/or other individuals (such as family members, employees, officers, directors, shareholders, business partners, customers, creditors, suppliers, etc.) Examples of such information include an individual’s name, date of birth, home address, financial and credit information, billing and account information and other information relating to the provision of services by BANKRUPTCY LETHBRIDGE.
Purposes for Collection of Personal Information
BANKRUPTCY LETHBRIDGE collects, uses and discloses personal information for the purposes identified at the time of collection, or as otherwise permitted or required by applicable law, including for the following purposes:
to comply with any and all obligations imposes upon BANKRUPTCY LETHBRIDGE pursuant to the Bankruptcy and Insolvency Act of Canada;
to comply with our professional responsibilities and obligations, including the rules regarding client identification and verification;
administrative, management and business purposes, such as to issue invoices, administer accounts, collect and process payments, fulfill contractual obligations, and audit our business obligations;
to establish and manage estate relationships, including considering whether to establish such a relationship;
to maintain proper information management systems and databases;
for any other purpose for which BANKRUPTCY LETHBRIDGE has your consent.
What we Collect, Use and Disclose
BANKRUPTCY LETHBRIDGE strives to limit the extent of the personal information we collect to what is necessary and appropriate for the identified purposes. We will not use or disclose your personal information for purposes other than for which it was collected, except with your consent or as may be permitted or required by law.
Although BANKRUPTCY LETHBRIDGE maintains server logs and Web logs which automatically collect and log all incoming traffic to our Website, including your Internet Protocol (IP) address, BANKRUPTCY LETHBRIDGE makes no attempt to link these addresses with the identity of individuals visiting our site.
Any personal information you do provide to BANKRUPTCY LETHBRIDGE is protected under the federal Personal Information Protection and Electronic Document Act (PIPEDA) and/or other provincial Personal Information Protection Act(s). This means that, at the point of collection, you will be informed that your personal information is being collected, the reason or purpose for which it is being collected, and that you have a right of access to the information.
Website Visitor information is not disclosed to anyone except our Trustee, employees or agents who need the information, e.g. to respond to a request from you.
Consent to Collect, Use and Disclose
BANKRUPTCY LETHBRIDGE will not collect, use or disclose personal information without the consent of the individual(s) concerned unless we are permitted to or required to do so by law. We generally do not obtain the consent of the individual(s) concerned in the following circumstances:
if a client provides personal information to us about a third person for purposes of our obligation(s) pursuant to the Bankruptcy and Insolvency Act of Canada;
when information is being collected for the prevention or detection of fraud or for law enforcement, where seeking the consent of the individual may defeat the purpose of collecting the information; and
if legal, medical or security reasons make it impossible or impractical for us to seek consent.
Withdrawal of Consent to Use and Disclosure
In some jurisdictions or provinces, you may withdraw your consent to the use and disclosure of your personal information, or limit certain uses and disclosures. To do that, please contact our Privacy Officer, utilizing the contact information identified in subsequent sections of this policy.
Disclosure of Your Personal Information
Our Trustees, employees and agents are subject to and maintain professional and ethical standards, and, as such, BANKRUPTCY LETHBRIDGE will not disclose personal information unless our client has provided consent or we are permitted or required to do so by law.
Subject always to our professional obligations, and only for the purposes of providing bankruptcy and financial services, BANKRUPTCY LETHBRIDGE may disclose personal information to third parties (including adverse parties and their counsel, experts, witnesses, service providers) in the context of bankruptcy proceedings and business transactions.
BANKRUPTCY LETHBRIDGE may also disclose your personal information to your authorized agent or representative, and BANKRUPTCY LETHBRIDGE may also disclose personal information as otherwise required or permitted by applicable law.
BANKRUPTCY LETHBRIDGE may disclose your personal information to a government or regulatory entity that has asserted its lawful authority to obtain such information, or where BANKRUPTCY LETHBRIDGE has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to protect BANKRUPTCY LETHBRIDGE’s rights and property. If BANKRUPTCY LETHBRIDGE is involved in a merger or other reorganization, BANKRUPTCY LETHBRIDGE may disclose your personal information to the resulting entity.
BANKRUPTCY LETHBRIDGE does not sell or exchange for consideration, any personal information it holds.
Securing and Storing Personal Information
BANKRUPTCY LETHBRIDGE may store and process your personal information at BANKRUPTCY LETHBRIDGE’s offices in Canada, or elsewhere. To help protect the confidentiality of your personal information, BANKRUPTCY LETHBRIDGE employs security safeguards that are customary in the financial industry, and appropriate to the sensitivity of the information, including physical, organizational and technological measures. Examples of such measures include restricted access to file storage, limiting access to information on a “need-to-know” basis, using passwords and well-defined internal policies and practices.
To the extent BANKRUPTCY LETHBRIDGE employs third-party service providers to store, handle or process information on our behalf (e.g. data processing or office services), we will use contractual and other means to provide a comparable level of protection while the information is being stored, handled or processed by them.
How to Access Personal Information
You may request access to your personal information and/or information about BANKRUPTCY LETHBRIDGE’s collection, use and disclosure of information by contacting our Privacy Officer in writing, at the addresses identified below.
c/o Bankruptcy Lethbridge
9415 98 Avenue NW
Edmonton, Alberta T6C 4P6
Attention: Privacy Officer
PRIVATE AND CONFIDENTIAL
Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is precluded from disclosure by law.
If you have not received a satisfactory response to your privacy concerns after contacting our Privacy Officer, you may direct your question or complaint to any of the following:
Canadian Association of Insolvency and Restructuring Professionals:
Office of the Superintendent of Bankruptcy Canada:
Office of the Privacy Commissioner of Canada:
Accuracy of Personal Information
You can help BANKRUPTCY LETHBRIDGE maintain the accuracy of your information by notifying BANKRUPTCY LETHBRIDGE of any changes to your personal information.
If you have any inquiry or complaint that relates to BANKRUPTCY LETHBRIDGE’s policies or procedures relating to the handling of personal information, we invite you to contact our Privacy Officer.
WHAT ARE COOKIES?
Cookies are very small, completely safe and secure text files which are downloaded to your computer or mobile device when you visit a website or application. Your web browser (e.g. Safari, Internet Explorer, Google Chrome or Mozilla Firefox) then sends these files back to the website or application every time you return so that your user personal settings can be recognized. Cookies are useful, helping website developers and companies to improve your website browsing experience. Some cookies are strictly necessary to enable you to move around the site or to provide certain basic features. Others are used to monitor and improve our website’s functionality and performance.
We do not sell or share any information collected by cookies, nor do we disclose the information to unauthorized third parties, except where required by law (for example to government bodies and law enforcement agencies).
WHAT COOKIES WE USE ON OUR WEBSITE
Anonymous Analytics Cookies: Analytics provide us with key information about anonymous user behaviour. Whenever a user visits our website, web analytics software provided by a third party generates an anonymous analytics cookie. These help us find out whether or not you have visited the BANKRUPTCY LETHBRIDGE website before, how many individual unique users visit the site, what pages they look at most frequently etc.
Social Website Cookies: The BANKRUPTCY LETHBRIDGE website allows you to share content on social media networks like Facebook and Twitter. This functionality is enabled via the use of third party cookies. In this case, privacy implications vary and depend on the privacy settings you have chosen when registering with the social media sites. Our site enables sharing through Facebook, Google, Twitter and ShareThis.
Session Cookies: Session cookies are used for users’ movement through the website. They allow you to proceed through many pages of the BANKRUPTCY LETHBRIDGE site quickly and easily without having to authenticate or reprocess each new area you visit. Session cookies are not stored on your computer and they will expire when you close your web browser.
HOW YOU CAN CONTROL COOKIES
If you wish to restrict or block web browser cookies on your device, you can do this in your browser settings.