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Privacy Policy

August 6, 2015 – Version 1.2
 

Purpose.

This Privacy Policy (the “Policy”) governs all aspects of how Tiffin Media Inc. (“Tiffin”, “We”, and “Us”) collects, uses, maintains and discloses personal information from all users (“Users”, “You” and “Your”) of the Grapple website (“Site”) and all Services (“Services”) offered by Tiffin. The privacy of Users is very important to Us and We are committed to protecting the confidentiality of all information entrusted to Us by You. Tiffin complies with the requirements of the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”).
 

Tiffin values the privacy of their customers.

Tiffin is committed to protecting the confidentially of all information entrusted to it by Users. All content contained on the Site is intended only for people 18 years of age and over and Tiffin does not knowingly collect or use Personal Information from anyone under the age of 18.
 

Information that Tiffin collects.

Tiffin, from time-to-time, may collect personally identifiable information (“Personal Information”) from Users. This may include name, address, jurisdiction of practice, and email address that you provide, and any correspondence that you have with Tiffin that occurs by way of telephone, email, online chat, web-based email forms and/or support tickets that are generated for the purpose of communicating and/or resolving any issues related to the Services. Tiffin also collects additional usage information (“Additional Usage Information”) that is collected electronically about how Users use the Site (e.g. by tracking the number of unique pageviews received by the pages of the website, or the domains from which Users originate) or via cookies that can be used to identify the User should they visit the website again. Additional Usage Information collected may include other information about your visits to our website. For example, we may collect information about your computer, such as your IP address (a number assigned to your computer whenever you surf the World Wide Web); the type of Internet browser you are using; the type of computer operating system you are using; or the domain name of the website from which you linked to our websites. This Additional Usage Information will not be linked to your Personal Information and will only be collected in the aggregate in connection with all the users of our website for planning, forecasting and/or evaluation purposes. As such, please note that this Policy does not cover aggregated data from which the identity of an individual cannot be determined. Tiffin retains the right to use anonymous aggregated data in any way that it determines appropriate.
 

Credit Card and Payment Information

Tiffin uses Beanstream Internet Commerce Inc. (“Beanstream”) to process payments on the Site.  For information on how Beanstreams collects, maintains and uses your Personal Information, please see their Privacy Policy here.  Please note, that Tiffin does not have access to your credit card information submitted through the Site.
 

Your Consent

Your provision of Personal Information to Tiffin means that you agree and consent that Tiffin may collect, use and disclose your Personal Information in accordance with this Policy. If you do not agree with these terms, you are requested not to provide any Personal Information to Tiffin. Tiffin services can only be offered if you provide Personal Information to Tiffin. Consequently, if you choose not to provide us with any required Personal Information, Tiffin will not be able to offer you certain services.
 
If you do not wish to receive information regarding the products and services offered by Tiffin send an e-mail to the address listed at the end of this policy
 

How Tiffin uses Personal Information

Tiffin may, from time-to-time, use Personal Information collected to: (i) provide Users with a product or service that has been requested; (ii) contact Users directly regarding products and services offered by Tiffin; (iii) understand User preferences in order to enhance Users' experience with Tiffin; (iv) research the effectiveness of the website and the marketing, advertising and sales efforts of Tiffin; and (v) for the collection of account receivables owed by Users to Tiffin.
 
Tiffin does work closely with the Google Advertising Network to present Tiffin advertisements throughout the Google Advertising Network to Tiffin customers. Users may opt out of this program at any time by visiting - http://www.google.com/privacy/ads/ and selecting ‘Opt Out’.
 
Tiffin’s use of Personal Information is limited to these purposes. Unless permitted by law, no Personal Information about a User is collected, without first obtaining the consent of the individual to the collection, use and dissemination of that information.
 

Disclosure of Personal Information

Tiffin will never disclose your Personal Information without consent except pursuant to the requirements of Section 7(3) – Disclosure without knowledge or consent – of PIPEDA and Division 1 – Protection of Personal Information – of PIPEDA, in which circumstances Tiffin may be obligated to disclose information without consent. Where obligated or permitted to disclose information without consent, Tiffin will not disclose more information than is required or requested.
 
Personal Information may also be subject to transfer to another company in the event of a change of ownership of all or part of Tiffin. This will occur only if the parties have entered into an agreement under which the collection, use and disclosure of such information is restricted to those purposes that relate to the business transaction, including a determination whether or not to proceed with the business transaction, and is to be used by the parties to carry out and complete the business transaction.
 

Maintenance, Retention and Security of Personal Information

Tiffin retains Personal Information about Users as long as Tiffin believes it is necessary to fulfill the purpose for which it was collected. Personal Information about Users that is maintained on our systems is protected using industry standard security measures and Tiffin compiles with the security safeguards principal of Schedule 1, Clause 4.7 of PIPEDA. However, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure and transmission of information over the Internet is susceptible to possible loss, misrouting, interception and misuse.
 

Access to Personal Information

Tiffin provides individuals with access to Personal Information held about them and complies with the individual access principal of Schedule 1, Clause 4.9 of PIPEDA.
 
Pursuant to Schedule 1, Clause 4.9.5 of PIPEDA, an individual may also request that Tiffin delete an individual’s Personal Information from Tiffin’s system and records. However, due to technical constraints and the fact that Tiffin backs up its systems, Personal Information may continue to reside in Tiffin’s systems after deletion for some time. Individuals, therefore, should not expect that their Personal Information would be completely removed from Tiffin’s systems in response to an accepted request for deletion.
 
Tiffin reserves the right to decline access to Personal Information where disclosure of the information requested is not required, as per Division 1, Clause 9 of PIPEDA.
 
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure, pursuant to the principal in Schedule 1, Clause 4.9.4 of PIPEDA. Where information will be disclosed, Tiffin will endeavour to provide the information in question within a reasonable time and no later than thirty (30) days following the request. Tiffin will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, Tiffin will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information.
 
To guard against fraudulent requests for access, Tiffin will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
 

Amendment of Tiffin practices and this Policy

This statement is in effect as of September 1, 2014. Tiffin will from time to time review and revise its privacy practices and this Policy. In the event of any amendment, an appropriate notice will be posted on this website. Policy changes will apply to the information collected from the date of posting of the revised Policy to Tiffin’s website as well as to existing information held by Tiffin.
 

Questions

If you have any questions about the privacy practices of Tiffin, or you wish to access your Personal Information, please contact:
 
Legal and Compliance
Tiffin Media Inc.
180 Dundas Street West
Suite 2601
Toronto, Ontario
M5G 1Z8
 
E-mail: rohit@grapplelaw.ca

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