At McCoy Global Inc. (“McCoy” or “we”), we are committed to maintaining the security, confidentiality and privacy of your personal information.
McCoy has developed this Policy in compliance with the Personal Information Protection Act (“PIPA”) of Alberta, the location of McCoy’s corporate head office. Where applicable, McCoy also complies with:
(a) the Canadian federal Personal Information Protection and Electronic Documents Act with respect to Canadian operations of McCoy Global Inc.;
(b) GDPR with respect to operations related to residents of the of the EU
a) “Personal Information” means any information about an identifiable individual (for example, name, age, home address and phone number, social insurance number, marital status, income, or credit history). Personal Information does not include contact information (described below) when that contact information is used for contacting an individual in their capacity as an employee of an organization.
b) “contact information” means information of corporate or commercial entities, or business contact information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.
c) “Privacy Officer” means the individual designated responsibility for ensuring that McCoy complies with this Policy.
2. Scope of this Policy
This Policy addresses the ways in which McCoy collects, uses and discloses Personal Information. McCoy is committed to ensuring the accuracy, confidentiality, and security of
your Personal Information and allowing you to request access to, and correction of, your Personal Information.
a) Customers: This Policy applies generally to McCoy’s customers and website visitors, and customers who use online services that McCoy provides.
3. Collecting Personal Information
As part of our business activities, we may collect some or all of the following information from you, either directly or from various other sources:
• your name, address, home and mobile telephone numbers, home e-mail address;
• information about products and services you have obtained through McCoy.
McCoy will obtain your consent to collect, use or disclose Personal Information except where McCoy is authorized or required by law to do so without your consent. For example, we may collect, use or disclose Personal Information without your knowledge or consent if the information is publicly available, we are obtaining legal advice, or we reasonably expect that obtaining consent would compromise an investigation or proceeding. Other exceptions may also apply.
Consent can be provided expressly, impliedly, orally, in writing, electronically, through an authorized representative.
Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), you can withhold or withdraw your consent in writing at any time. Your decision to withhold or withdraw consent may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist you in making your decision.
The purposes for collecting Personal Information are usually obvious at the time of collection, and in those cases, you provide your Personal Information for those purposes. Otherwise, McCoy will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection. We generally collect Personal Information for the following purposes:
• To verify identity;
• To verify creditworthiness;
• To report to and obtain reports from credit bureaus;
• To identify customer preferences;
• To open and manage an account with McCoy;
• To deliver requested products and services;
• To ensure a high standard of service to our customers;
• To retain a contractor or agent who will perform services for us on an outsource or contract basis.
6. Using and Disclosing Personal Information
McCoy will only use or disclose your Personal Information where necessary to fulfill the purposes identified at the time of collection or as indicated in this Policy.
McCoy will not use or disclose your Personal Information for any additional purpose unless McCoy obtains consent to do so, or as authorized or required by law.
McCoy will not sell customer lists or Personal Information to other parties.
McCoy may share Personal Information subject to confidentiality obligations in the course of business transactions such as mergers, acquisitions or asset sales of an affiliate, subsidiary or division, as permitted by applicable law.
McCoy does not use Personal Information to make automated decisions.
7. Retaining Personal Information
If McCoy uses your Personal Information to make a decision that directly affects you, McCoy will retain that Personal Information for at least one year so that you have a reasonable opportunity to request access to it. Otherwise, McCoy will retain your information only as long as is reasonable to fulfill the identified purposes or a legal or business purpose.
Individuals situated in the European Union (EU) have a right to have their Personal Information erased from McCoy’s systems, upon request and in limited circumstances. Where legally permissible, we will take reasonable steps, including technical measures to erase such Personal Information held by McCoy.
Individuals situated in the EU also have a right to request that their Personal Information is ported to another service provider upon request. Where legally permissible, McCoy will take reasonable steps, including technical measures to port the Personal Information held by McCoy.
8. Ensuring Accuracy of Personal Information
McCoy will make reasonable efforts to ensure that Personal Information we are using or disclosing is accurate and complete. In most cases, we will rely on you to ensure that information is current, complete and accurate.
You may request correction to your Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought. A request to correct Personal Information should be forwarded to McCoy’s Privacy Officer.
If you demonstrate the inaccuracy of Personal Information, McCoy will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year. If the correction is not made, we will note your correction request in the file.
9. Securing and Storing Personal Information
McCoy makes reasonable security arrangements to protect your Personal Information from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
Your personal information may be transmitted through, stored or processed in countries other than your home country, in which case the information is bound by the laws of these countries. These countries may include, but not limited to:
• United States of America
• EU member states
• United Arab Emirates
McCoy continually reviews and updates its security policies and controls as technology changes to ensure ongoing Personal Information security.
McCoy will take reasonable steps, through contractual or other reasonable means, to ensure our contractors, suppliers and others whom we ask to assist in providing goods and services implement a comparable level of Personal Information protection.
Note that confidentiality and security may not be assured when information is transmitted through e-mail, Internet or wireless communication. McCoy will not be responsible for any loss or damage suffered as a result of breach of security or confidentiality when you transmit information to us by e-mail or other Internet or wireless communication, or when we transmit information by such means.
10. Providing Access to Personal Information
You have the right to access your Personal Information held by McCoy, subject to limited exceptions as provided by law.
A request to access Personal Information must be made in writing on forms provided by McCoy and must provide sufficient detail to identify the Personal Information being sought. Requests to access Personal Information should be forwarded to the Privacy Officer.
We will make the requested information available within a reasonable time period (as required by law), or provide written notice of an extension where additional time is required to fulfill the request.
McCoy may charge a minimal fee for providing access to Personal Information. Where a fee may apply, we will inform you of the cost and request further direction from you about whether or not to proceed with the request.
If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal and the available recourse, all as provided by law.
11. Responding to Personal Data Breaches
A ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed. In the event of a personal data breach, in certain circumstances we are legally obliged to report the breach to the appropriate and relevant privacy commissioner or data protection authority. In accordance with privacy legislation, we will also notify the individuals directly affected by the breach, as appropriate in the circumstances.
12. Job Applicants
If you have applied for a job with McCoy, McCoy can collect, use or disclose Personal Information that is reasonably related to the hiring decision without your consent, so long as the collection, use and disclosure is reasonable. Information that is related to your hiring decision may include your qualifications, experience, knowledge, skills and education, and references.
If you submit an application for a specific position, McCoy will retain your application as set out in Section 7. If you submit an application generally (i.e., not for a posted job opening, and not when requested by McCoy), McCoy will: (i) keep your application reasonably secure, if McCoy decides to keep your application on file; (ii) securely destroy your application, if McCoy decides that your application is not suited for McCoy’s current employment needs; and (iii) retain your application for at least one year if McCoy uses it to make a decision that directly affects you.
13. Google Analytics
Google Analytics employs cookies to define user sessions, which allows for the collection of data about how visitors are using the websites. Google Analytics uses only first-party cookies for data analysis. This means that the cookies are linked to a specific website domain, and Google Analytics will only use that cookie data for statistical analysis related to your browsing behavior on that specific website. According to Google, the data collected cannot be altered or retrieved by services from other domains.
If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit Google Analytics.
14. Changes to this Policy
McCoy reserves the right to change this Policy from time to time. The current version will be made posted to our sites and will apply to any collection, use or disclosure of Personal Information after posting of the revised Policy.
15. Questions and Complaints
McCoy’s Privacy Officer is responsible for ensuring McCoy’s compliance with this Policy. You should direct any complaints, concerns or questions regarding McCoy’s compliance in writing to the Privacy Officer.
McCoy Privacy Officer
Suite 201, 9910 39th Ave NW
Edmonton, AB T6E 5H8