Updated November 12, 2018
Waterloo Region Economic Development Corporation (“Waterloo EDC”, “Website”, “we” or “us”) know that you care about how the personal data we receive about you is used and shared, and we take your privacy seriously. This Privacy Policy describes Waterloo EDC’s privacy practices in relation to information that we collect through our Website operated by us from which you are accessing this Privacy Policy, through our social media pages located at https://twitter.com/waterlooedc, https://www.youtube.com/channel/UCvpiFm69hy63roe3JDD_bgA, and https://www.linkedin.com/company/waterlooedc/ (collectively, the “Social Media Pages”), and other services provided by us both online and offline; as well as through email messages that we send to you that link to this Privacy Policy (collectively, including the Website and the Social Media Pages). “You” or “user” refers to any individual who visits or otherwise uses the Website.
This Privacy Policy does not apply to the practices of third parties that Waterloo EDC does not own or control, or to individuals that Waterloo EDC does not employ or manage.
Waterloo EDC’s privacy policy applies only to those sites operated by Waterloo EDC. Waterloo EDC does not control the privacy practices of external sites. Before submitting personal information, each individual should carefully review the privacy policies and practices of this site.
1. What types of information does Waterloo EDC collect?
- Personal Data. “Personal Data” is information that, directly or indirectly, identifies you or another individual and which may include: name, title, company name, job function, industry, postal address, telephone number, email address, browser and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers in connection with the Website, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
- Other Information. “Other Information” is any information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Website and for other purposes described below.
2. How does Waterloo EDC collect information?
We and our service providers collect Personal Data and Other Information in a variety of ways, including:
- Through the Website: We collect information through the Website, e.g., when you download content, have a conversation with live chat, register for a webinar, contact us, subscribe to our email newsletter, or register to use our Website.
- Offline: We collect information from you offline, such as when you have a conversation with one of our team members during phone calls or meetings.
- Through You: Waterloo EDC collects information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Data, this information does not personally identify you or any other user of the Website.
- Information From Other Sources: In order to enhance our ability to provide relevant marketing and services to you, we obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
- Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Website you are using. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. Waterloo EDC uses IP Addresses to calculate usage levels of the Website, help diagnose problems with its servers, administer the Website, and for monitoring the regions from which you navigate to Waterloo EDC’s Website.
- Through Cookies and Other Similar Technologies: “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Website. When you visit our Website, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse our Website and enhance the level of services and functions provided. We also use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Website and other websites. To do so, these companies may place or recognize a unique cookie or similar on your browser. Waterloo EDC recognizes automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions. Please review our Cookies Policy for more information.
- By Aggregating Information: Aggregated Personal Data does not personally identify you or any other user of the Website (for example, we may aggregate Personal Data to calculate the percentage of our users who live in a particular city).
3. How does Waterloo EDC use personal data?
We use Personal Data:
- To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our services and the Waterloo Region.
- To send administrative information to you, for example, information regarding the Website and content, and changes to our terms, conditions, and policies.
- To send you marketing communications, including via email in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
- To personalize your experience on the Website by presenting content and materials tailored to you.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new content, enhancing, improving or modifying our Website and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. We will collect and use your Personal Data where the processing is in our legitimate business interests, such as for direct marketing and sales of Waterloo Region industries, lifestyle and real estate to prospective Business-to-Business (B2B) customers. Our legal basis for processing Personal Data in certain circumstances will also be based on your consent to do so or where we need the Personal Data to perform a contract with you or in order to enter into a contract with you. In some cases, we may also have a legal obligation to collect Personal Data from you.
If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
4. How will Waterloo EDC share personal data it receives?
Third-Party Business Partners:
Waterloo EDC partners with local Economic Developers and a variety of local businesses to market or sell services, real estate, businesses, or products. We may disclose Personal Data to our partners for the purposes described above or to have them further assist you in your business relocation or expansion needs.
Agents and Service Providers:
We contract with other companies and people to perform tasks on our behalf and share your Personal Data with some of them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing on our behalf. Examples include analyzing data, providing marketing assistance, engaging technical support for our services, providing customer service, and performing analysis related to our services. We also provide your Personal Data to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Data.
Waterloo EDC Blog and Social Media Pages:
Personal Data may also be disclosed by you through the Website, social media, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Waterloo EDC Blog, at https://blog.waterlooedc.ca and the Social Media Pages). This information can appear in public ways, such as through search engines or other publicly available platforms, and can be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.
Profiling and Automated Decision-making:
Waterloo EDC combines data obtained by the methods described in Section 2 to help us determine what services might be of interest to you and when you might be ready to relocate or expand your business based on repeated interaction with Waterloo EDC websites, emails, and content. Waterloo EDC marketing and business development personnel are involved in this process and no automated decisions are made that would result in legal effects or similarly significantly affect an individual.
5. How does Waterloo EDC use and disclose Other Information?
We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we would use or disclose it in the same way that we use and disclose Personal Data.
In some instances, we may combine Other Information with Personal Data (such as combining your name with the name of your organization). If that combination permits you to be identified, we will treat the combined information as Personal Data for as long as it is combined.
6. How does Waterloo EDC secure Personal Data about me?
We use third parties to safeguard all and protect Personal Data within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your information has been compromised), please immediately notify us in accordance with the “Questions, Concerns and Complaints” section below.
7. How can I access, correct, amend or remove information about me?
If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Data about you that has been collected and stored by Waterloo EDC, or have it transferred to another organization, please notify us at marketing@waterlooedc.ca so that we may consider and respond to your request in accordance with applicable law. If you would like to object to the processing of your Personal Data for direct marketing purposes, please use the mechanisms outlined in Section 9 (“What Choices Do I Have?”).
For your protection, we only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we need to verify your identity before implementing your request. We will respond to your request within 30 days.
Please note that we need to retain certain information for recordkeeping purposes.
8. For how long will Waterloo EDC retain my Personal Data?
We will retain your Personal Data for a period of time consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements.
9. What choices do I have?
You can always opt not to disclose information. However, if you elect to do so, we will likely be limited in responding to your inquiry or providing services to you.
You can opt-out of receiving marketing messages from Waterloo EDC by unsubscribing through the unsubscribe or opt-out link in an email, or by sending an email to marketing@waterlooedc.ca. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages.
10. Can children use Waterloo EDC’s Website?
The Website is not intended for minors under the age of 18. Waterloo EDC does not knowingly or specifically collect information about minors under the age of 18 and believes that children of any age should get their parents’ or legal guardians’ consent before providing any Personal Data. If you believe that we have mistakenly or unintentionally collected such information, please notify us at marketing@waterlooedc.ca so that we can delete the information from our servers.
11. Third Party Sites
The Website permits you to link to other websites on the Internet through direct links or through applications such as “share” or “like” buttons, and other websites likewise may contain links to the Website. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Privacy Notice. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information is collected and used by them.
Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Google, LinkedIn, Microsoft, Twitter or any other social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Data you disclose to other organizations through or in connection with the Website or the Social Media Pages.
12. International transfer of data
Your Personal Data may be stored and processed in any country where we use third party service providers or targeting, and by using the Website or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including the United States, Australia, Germany, Ireland, Israel, Japan, and the UK, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. Where required, we put in place a solution to ensure that Personal Data transferred outside of the EEA is subject to adequate protection, namely the European Commission Standard Contractual Clauses.
European Economic Area (EEA) Notice
If you are located in a country in the European Union (EU) and utilize our Website which is offered to EU residents, or if we collect, track, use or process in some other way your Personal Data collected from you or through your use of our Website, or we transfer that personal information, we will do so in accordance with this Privacy Policy, and in compliance with applicable requirements of the General Data Protection Regulation (EU 2016/679) (GDPR).
Transfers of Personal Information
Waterloo EDC collects Personal Data and is responsible for your personal information, which Waterloo EDC processes and stores in the region selected by the Customer.
The European Commission has decided that Canada ensures an adequate level of protection of individuals’ personal information. Waterloo EDC may use the following safeguards when transferring your personal information to a country, other than the Customers selected region, that is not within the EEA:
(a) Only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal information;
(b) Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU.
Opt-in
If you are an EU resident, we may only collect your data using cookies and similar devices on our Website, and then track and use your personal information where you have first consented to that. We will not automatically collect personal information from you as described above unless you have consented to us doing so. If you consent to our use of cookies and similar devices, you may at a later date disable them. In order to disable cookies please see our Cookies Policy.
Your Legal Rights
Under certain circumstances, you may have rights under the data protection laws in relation to your personal information, including the right to:
- Request access to your personal information
- Request correction of your personal information
- Request erasure of your personal information
- Object to processing of your personal information
- Request restriction of processing your personal information
- Request transfer of your personal information
- Right to withdraw (revoke) consent
If you wish to exercise any of these rights, please contact marketing@waterlooedc.ca to find out more information about what we may need from you and the time in which we should respond.
13. Questions, concerns or complaints
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information as a data Controller, please contact marketing@waterlooedc.ca.
Because email communications are not always secure, please do not include sensitive information in your emails to us.
Waterloo EDC will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
You may have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
14. Copyright, Trademark and Visual Identity
All contents of Waterloo EDC’s online site is Copyright © 2017 Waterloo EDC. All rights reserved.
The Waterloo EDC Logo is a registered trademark of Waterloo EDC. Any reproduction of the Logo without Waterloo EDC’s expressed permission is prohibited.
15. Personal and Non-Commercial Use Limitation
Unless specifically authorized by Waterloo EDC, you may not modify, copy, distribute, transmit, display, perform, reproduce, publish, licence, create derivative works from, transfer, or sell any information, software, products or services obtained from this Website.
16. No Unlawful or Prohibited Use
As a condition of your use of Waterloo EDC’s websites, you warrant to Waterloo EDC that you will not use these websites for any purpose that is unlawful or prohibited by this Privacy Policy.
Will you sell or share my personal information?
Waterloo EDC will never sell your personal information. Waterloo EDC may be required to disclose your personal information; however we will only ever do so as required by law.
Do you collect non-identifying information?
Yes, Waterloo EDC collects non-identifying information including:
- Your internet protocol (I.P.) address;
- The type of web browser you have used to access the site;
- The date and time of your visit;
- Any documents you have downloaded from the library; and,
- Any videos or pages you have viewed.
How is this non-identifying information used?
The non-identifying information is used for statistical reporting purposes and to understand how site visitors are using the site. This information will be used to guide enhancements to the tools, services and information available on our website. This information will not be combined with any other information or service to determine your browsing habits on other websites, or to identify you personally.
Advice received via this website should not be relied upon for personal, medical, legal or financial decisions and you should consult an appropriate professional for specific advice tailored to your situation.
Waterloo EDC and/or its respective suppliers may make improvements and/or changes to our online sites at any time. Waterloo EDC and/or its respective suppliers make no representations about the suitability, reliability, timeliness, and accuracy of the information, software, products, services and related graphics contained on this website for any purpose. All such information, software, products, services and related graphics are provided “as is” without warranty of any kind. Waterloo EDC and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, software, products, services and related graphics, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement.
In no event shall Waterloo EDC and/or its suppliers be liable for any direct, indirect, punitive, incidental, special, consequential damages or any damages whatsoever including, without limitation, damages for loss of use, data or profits, arising out of or in any way connected with the use or performance of our online sites, with the delay or inability to use our online sites, the provision of or failure to provide services, or for any information, software, products, services and related graphics obtained through our online sites, or otherwise arising out of the use of our online sites, whether based on contract, tort, strict liability or otherwise. If you are dissatisfied with any portion of our website, or with any of these terms of use, your sole and exclusive remedy is to discontinue using our website or online account.
Governing Law and Jurisdiction
All matters relating to your access to, or use of, Waterloo EDC’s websites shall be governed by the statutes and laws of the Province of Ontario.