Introduction

This Privacy Policy governs our dealing with "personal information". Personal information means any information about an identifiable individual including information such as age, gender, family status, health, home address and home phone number. Personal information does not include business information such as the name, title, business address, or telephone number of an employee of an organization.

Accountability

We are responsible for all personal information in our possession or control. This would extend to information to which third parties who provide goods or services to our firm (such as our accountants, security and maintenance persons, information technology advisors, delivery persons, temporary personnel, web site managers, cleaners, and bankers) may have access. We restrict such access to such third parties as much as is reasonably possible.

Why we collect Personal Information

The primary purposes for which we collect, use and disclose personal information is to serve our customers or potential customers, to market our services and other purposes which would be considered related or otherwise reasonable in the circumstances. For example, we primarily collect, use and disclose personal information for the following reasons:

• to evaluate customer needs with regards to school uniform matters
• to process transactions on behalf of our customer
• to permit us to market or promote our services to customers or prospective customers

We also collect, use and disclose personal information for secondary purposes such as:

• to invoice customers, process or collect accounts
• to provide mailings, or invitations to special events
• to communicate new developments at our firm in matters of interest to our customers or prospective customers
• to assess and evaluate the performance of our staff and services

If we were to sell our business or to merge with another entity that other party would want to perform a due diligence investigation of our firm, including its records to ensure the accuracy of the information we have provided and the viability of the business. This would likely include our accounting and service files. Before we would permit this disclosure, we would obtain an agreement from such third party to keep all personal information confidential.

If we plan to use or disclose personal information we have collected for a purpose not previously identified, we will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the personal information has been collected before use or disclosure.

Consent

Generally all personal information is held in strict confidence and we will obtain consent, either express or implied, to use or disclose personal information about an individual unless otherwise permitted or required by law. The way in which we seek consent, including whether it is express or implied, will vary depending upon the sensitivity of the information and the reasonable expectations of the individual. Provided that we are informed of same, an individual can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. There are some circumstances where we are permitted or required under law to collect, use or disclose personal information without the knowledge or consent of the individual. These circumstances include: personal information which is publicly available as defined by the regulation; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to act in respect to an emergency that threatens the life, health or security of an individual; and for debt collection.

Safeguarding

We will take appropriate steps to ensure adequate safeguards are in place to protect the personal information which we obtain. Our safeguards include ensuring the paper information is stored in a supervised or secure location, restricted access to our offices and that electronic information is also secure with restricted third party access and through the use of passwords. Our staff is trained to ensure that they are aware of the sensitivity of such information and that they will collect, use and disclose personal information only as necessary to perform their duties and in accordance with this policy. Our third party contractors or agents who have access to personal information will be required to confirm that they follow appropriate privacy practice.

Retention

While we do not intend to keep personal information for longer than is reasonable, we do keep personal information for some time so that we are able to answer questions about our services and to account to regulatory authorities. Normally we close customer files after a matter is completed and no further services anticipated and thereafter the file is generally destroyed after seven (7) years. Our accounting and financial files are normally kept for a minimum of seven (7) years. We destroy paper files with personal information by shredding or discarding it in garbage receptacles; we destroy electronic information by deleting it.

Openness and Access

With some exceptions, we will give you access to the personal information we retain about you upon request. We will need to confirm your identity before providing such access. We ask that you provide any request or identify any problem relating to such personal information in writing. We will respond within 30 days with the information requested or if this is not possible we will advise you of the reason. Exceptions may include information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record.

Correcting personal information

Amendments

Questions

Any questions or complaints about our Privacy Policy can be directed to our Privacy Officer:

Attention: Privacy Officer

Halpern’s Ltd.
2785 Skymark Ave., Unit 17
Mississauga, ON
L4W 4Y3

Tel: 905-361-1112
Fax: 905-361-1204
Toll Free Tel: 1-866-409-0409
Toll Free Fax: 1-877-409-0400
E-mail: info@halperns.ca