Privacy Policy

Principle #1 — Leslie Lockhart International is accountable for your personal information in its possession or control.

Leslie Lockhart International is accountable for all personal information in its possession or control. This includes any personal information that Leslie Lockhart International has collected about site users, customers, and past customers (each, a “Leslie Lockhart International Stakeholder”), as either collected directly from such Leslie Lockhart International Stakeholder; “Leslie Lockhart International Website”(s); or other organizations (e.g., business partnerships that enrich the variety of service offerings, corporations, government entities, not-for-profit organizations, academic institutions). However, from time to time Leslie Lockhart International may collect, use and disclose personal information as the agent of other organizations, in which case, without limiting the obligations of Leslie Lockhart International to comply with applicable privacy laws, such other principal entities shall be accountable for such personal information.

Leslie Lockhart International has:

• established and put into effect policies and procedures aimed at properly protecting personal information; and
• educated its staff and volunteers regarding such policies and procedures and their roles and responsibilities in protecting personal information.

Principle #2 — Leslie Lockhart International identifies the purposes for which it collects personal information from you before it is collected.

We generally identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.

Some of the primary purposes for which we collect and use your Personal Information include:

• to provide services to you in your capacity as a Leslie Lockhart International Stakeholder;
• to complete a transaction with you when you purchase or use a product or service offered by us;
• to advise you of Leslie Lockhart International products or services that may be of interest to you;
• to send you electronic Leslie Lockhart International newsletters that may be of interest to you or to which you have subscribed, and to better understand which articles are of interest to you;
• to conduct research and analytics for purposes that include but are not limited to better understanding Leslie Lockhart International Stakeholders, allowing Leslie Lockhart International Stakeholders to provide feedback on products and services, and producing data analytics and statistical reports;
• to present non-Leslie Lockhart International content and advertising that is customized to your interests;
• to respond to inquiries you submit;
• to establish and manage your Leslie Lockhart International Website account(s);
• to customize the content presented to you when using a Leslie Lockhart International Website;
• to utilize certain Leslie Lockhart International Website services; and
• to report usage of a Leslie Lockhart International Website – the reports may be used by Leslie Lockhart International, and individual(s) designated as group administrator(s).

We may also use your Personal Information as otherwise permitted or required by law. We will always seek your consent if we want to use your personal information for purposes other than for those set out in the latest version of the Privacy Policy or to which you have previously agreed.

Principle #3 — Leslie Lockhart International obtains your consent before collecting personal information from you.

We will not sell, trade, rent or license personal information that you provide to us.

We explain your options and obtain your implicit or explicit consent at the time of or prior to collecting, using or disclosing your Personal Information. We will always collect your Personal Information by fair and lawful means (for example, when you complete an application form or purchase a product or service from us). We may collect Personal Information about you from Leslie Lockhart International Website(s), and other institutions, organizations and third parties we choose to partner with. We also collect your Personal Information where we have obtained your consent to do so or as otherwise permitted or required by law.

We will generally obtain your consent electronically on our site. However, it may also be obtained in writing or verbally. In determining the appropriate form of consent, we will consider the sensitivity of and reasonable expectations regarding the personal information. Where is it reasonable to do so, or permitted by law, we may rely on implied consent.

Except as required to process a transaction, to maintain records of Leslie Lockhart International or as required or permitted by applicable law, providing us with your personal information is voluntary. You may withdraw or modify your consent at any time, subject to legal and contractual restrictions, provided that reasonable notice is given to us. If you withdraw your consent to receive information regarding certain products, publications, services or events being offered by us, you may not be made aware of same. Refusal or withdrawal of consent from use of personal information by Leslie Lockhart International Website(s) may result in our being unable to provide you with Leslie Lockhart International Website services.

From time to time, Leslie Lockhart International Website site and service updates are emailed to users. If you do not wish to receive such mailings, you may request to be removed from this electronic mailing list at any time by contacting us (see contact information under Principle #8). You should understand, however, that if you are removed from the mailing list you may not be made aware of the status or availability of certain Leslie Lockhart International Website services.

Personal Information is any information that is identifiable to you. This information may include, but is not limited to, your name, mailing address, phone numbers, email address, identification numbers, credit card numbers, banking information, and creditor information. Personal Information, however, generally does not include information that Leslie Lockhart International collects, uses or discloses solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession such as the individual’s name, position name or title, work address, work telephone number, work fax number or work electronic address.

Principle #4 — Leslie Lockhart International discloses your personal information only for purposes for which it has consent, or as permitted or required by law. Leslie Lockhart International retains personal information only as long as necessary to fulfill those purposes.

We identify to whom, and for what purposes, we disclose your Personal Information, at the time of or prior to collecting such information from you and obtain your consent to such disclosure. For example, we may:

1. transfer your Personal Information to our volunteers, for the purposes of the volunteers performing volunteer functions;
2. transfer your Personal Information to third party service providers with whom we have a contracted agreement that includes appropriate privacy standards, such as service providers that provide communication services support or data storage or processing – for the purpose of, for example, providing user or customer benefits, facilitating commercial transactions with us or offering educational programming;
3. disclose your Personal Information to such persons and for such purposes for which you provide your consent;
4. disclose your Personal Information as otherwise permitted or required in the case of an emergency where the life, health or security of an individual is threatened; and
5. disclose your Personal Information as otherwise permitted or required by law.

We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law.

All personal information destroyed or erased from our records is done so securely with due regard to the sensitivity of the information.

From time to time we may disclose or hold your Personal Information outside of Canada, and while outside of Canada it may be subject to access by regulators in accordance with the laws of those jurisdictions.

Principle #5 — Leslie Lockhart International endeavours to keep accurate, complete, and up-to-date, personal information in its possession or control, to the extent required to meet the purposes for which it was collected.

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible based on information provided to us by you. We expect you, from time to time, to supply us with written updates to your Personal Information, if applicable. In the case of Leslie Lockhart International Stakeholders, Personal Information may be updated by contacting us directly (see contact information under Principle #8).

Principle #6 — Leslie Lockhart International protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information. You can visit our Leslie Lockhart International Website(s) without telling us who you are or revealing any information about yourself, including your email address. However, our web server may collect the IP address and domain you used to access our Leslie Lockhart International Website(s), the type and version of web browser and operating system you are using, the number, duration and frequency of visits to our Leslie Lockhart International Website(s) and the Website you came from and visited next. This anonymous information cannot be traced to a specific individual User – it is used by us simply for the purposes of analytics – for example, to measure the number of visits, average time spent, page views, most popular preferences and other statistics about visitors to the Leslie Lockhart International Website(s) and to determine the characteristics in which users use our Leslie Lockhart International Website(s) and services. We may use this data to monitor Leslie Lockhart International Website performance for systems administration purposes, to make Leslie Lockhart International Website(s) easier and more convenient to use, to improve our services and to track information in aggregate form (e.g. how many visitors use Leslie Lockhart International Website(s)). This helps us better understand our Leslie Lockhart International Website(s) traffic, visitor behavior and the impact of campaigns, content and email-driven traffic. By having access to such deeper data insights, we are able to measure, re-evaluate content offerings, map customer buying journeys and provide you with a more personalized visitor site experience, enabling demographic and interest reporting.

We make use of Google Analytics. A description of how Google Analytics collects and processes data is set out in “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).

Please note that we have also implemented the following specific Google Analytics Advertising Features:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• Google Analytics Demographics and Interest Reporting
• Integrated services that require Google Analytics to collect data via advertising cookies and identifiers

We use cookies, that is, small files that your Web browser places on your computer’s hard drive, to remember a User’s code, subscriptions, and preferences while the User is using Leslie Lockhart International Website(s), to facilitate navigating different pages on Leslie Lockhart International Website(s), to personalize the users experience when returning to Leslie Lockhart International Website(s), to monitor progression through Leslie Lockhart International Website(s), to identify opportunities to improve the user experience, and to customize ads you see when visiting Leslie Lockhart International Website(s), and third party sites. Also, as a result of us enabling the Advertising Reporting Features, in addition to collecting the information it normally does, Google Analytics collects information via its Google advertising cookies: see https://support.google.com/analytics/answer/2444872#web.

Should you wish to opt out of the Google Analytics advertising features, you may do so at https://tools.google.com/dlpage/gaoptout/.

Our Leslie Lockhart International Website(s) contains security mechanisms that protect against the loss, the misuse and the modification of information under our control.

Our Leslie Lockhart International Website(s) may provide links to third party web sites. Our Privacy Policy does not extend to these third party web sites and it is recommended that Users read the privacy policies of these web sites. We are not responsible for the content of, or the privacy practices employed by, third party web sites.

Please note that it is your responsibility to protect your user id and password information. If this information is disclosed the privacy of your information cannot be assured.

Principle #7 — Leslie Lockhart International is open about the procedures it uses to manage personal information.

Up-to-date information on Leslie Lockhart International’s Privacy Policies can be obtained by contacting us directly (see contact information under Principle #8).

Principle #8 — Leslie Lockhart International responds on a timely basis to requests from Leslie Lockhart International Stakeholders about their personal information, which Leslie Lockhart International possesses or controls.

We will generally make available to you any Personal Information that we have collected about you, utilized or disclosed, upon your written request, to the extent permitted or required by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes.

You can at any time, challenge the accuracy or completeness of the Personal Information we have which is related to you. Where we validate your identity, and you successfully demonstrate the inaccuracy or incompleteness of your Personal Information, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

If you are unsure whether we have a record containing your personal information and would like to confirm what personal information we have, please contact us directly (see contact information below) with your request, identifying all email addresses which you may have given us.

We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests or as otherwise required or permitted by law. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

We will not assess any costs to you for access to your Personal Information or to our Privacy Policies or Practices without first providing you with an estimate of the approximate costs, if any. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such information shall be used only for this purpose.

All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and Practices, should be forwarded as follows:

By mail:
Attn: Leslie E. Lockhart
Leslie Lockhart International
15 Place Leclerc
Kirkland, Quebec
H9J 2Z9

By e-mail: leslie@leslielockhartinternational.com with the subject line PRIVACY

All privacy related complaints will be acknowledged, recorded, investigated and responded to in accordance with applicable law. We will inform you of the relevant procedures when you make an inquiry or lodge a challenge or complaint.

Last revised: 01 September, 2017