Privacy Policy

Matrix360 has a focus on both privacy and data security. We recognize that the information being trusted and held by Matrix360 is sensitive and it is treated as such. With user privacy and data security in mind we created the following Privacy Policy for our services and programs.

Our Commitment and Legal Obligation

Matrix360 is committed to safeguarding the personal information entrusted to us by our employees, clients, candidates, partners, guests and website visitors. We manage your personal information in accordance with Freedom of Information and Protection of Privacy Act (FIPPA), Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s Anti-Spam Laws (CASL) and other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information. This policy applies to Matrix360 Inc. and its subsidiaries, Matrix Search Group Limited. The policy also applies to any person providing services on our behalf. A copy of this
policy is provided to any clients, candidates, partners, guests, and website visitors on request.

Matrix360 has a focus on both privacy and security. We recognize that the information being held by Matrix360 is sensitive and it is treated as such. With user privacy and security in mind we created the following principles for Matrix360.

• We will never sell or rent your personally identifiable information to third parties for any purposes
• We will never share your contact information with another user or third party without your written consent
• All personally identifiable information you provide will be secured using industry standard protocols and technology
• Users have the ability to change what is public but the default setting should err on the side of less public disclosure rather than more

What is Personal Information?

Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, professional position title, company information, age, race, ethnicity, sex, marital or family status, an identifying number, financial information, educational history, etc.

What Personal Information We Collect?

Matrix360 collects only the personal information that is specifically authorized by law, or where the collection is necessary for the purposes of providing services and programs to our clients and candidates. We collect personal information directly from you, unless another manner of collection is authorized by clients or law, including personal information needed to:

• open and manage a program or service
• deliver and administer requested programs or services
• enroll client(s) or candidates(s) in programs or services
• manage and conduct data gathering through surveys, polls and newsletters
• contact clients about appointments, events, programs and services
• follow up with clients and candidates to determine satisfaction with programs and services
• notify clients and candidates of upcoming events, programs or services of interest

Candidates: If you choose to declare yourself as a candidate or submit materials and information in order to be considered for general talent opportunities, we will register your information in our confidential applicant tracking system (ATS) database and may contact you regarding other opportunities in the future.

The information collected from you as a candidate, may include contact information (name, address, telephone number, email address); personal history (resumes, education and employment history, work or job interests, reference and background checks); and other information reasonably linked to any talent management services offered (preferences, choice of contact methods, etc.).

We may collect similar information from other sources, such as from references candidates provide or from corporate referrals but we will not collect information that is not reasonably required for the purpose of any talent management services.

Please advise us in writing if you do not wish to have your information saved. We respect the privacy and confidentiality of your personal information and appreciate your agreement in allowing us to collect, use, and disclose information that is incidental to processing your application.

We understand you may choose to refuse or withdraw consent to the collection, use and release of your personal information and you may notify us of this choice in writing by submitting a request to info@matrix360.ca or david@matrix360.ca and we will record and respect your choices. Please be aware that this may result in our inability to represent you to our clients as a candidate for both current and future opportunities.

Clients: As clients who have retained Matrix360 for any talent management or workplace strategy services or programs, we will act in the capacity as a partner during the course of service we provide and any information or data gathered in the context of the services we deliver will be subject to the conditions outlined in this privacy policy and to the privacy laws and any applicable laws of Canada.

Requests to access information should be directed to info@matrix360.ca or david@matrix360.ca and we will provide the information as required by law. You can help us maintain the accuracy of your information by notifying us of any changes to your information.

We inform our clients and candidates, before or at the time of collecting personal information, of the purposes for which we are collecting the information. However, we don’t provide this notification when client(s) or candidate(s) volunteers information for an obvious purpose (for example, producing a credit card for an in-store purchase when the information will be used only to process the payment).

We may only use personal information for the purpose it has been collected, or for a consistent purpose, unless another use is specifically authorized at law. We retain your personal information only as long as required for the purposes it was collected. For candidates and clients that would be for as long as you are seeking talent management services and wish to remain on our systems or as long as legally required by statute or contract.

Consent

We ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

In cases where we collected personal information before January 1, 2004, we assume your consent to our use and, where applicable, disclosure for the purpose for which the information was collected.

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will ask clients to provide their consent verbally (in person, by telephone), in writing (by signing a consent form, by checking a box on a form, or electronically by clicking a button).

A client may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain programs and services if we do not have the necessary personal information.

We may collect, use or disclose client personal information without consent only as authorized by law or by you. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public directory.

How Do We Use and Disclose Your Information?

We use and disclose client and candidate personal information only for the purposes for which the information was collected, except as authorized by law or you. For example, we may use client and candidate contact information to deliver programs or services.

From time to time, we use third party service providers to deliver some of our services and programs. We share with these service providers only that information which is required to perform our services, and each service provider is required by contract to abide by the Privacy laws of Canada, the United States of America (USA) and European Union to secure the information we provide.

As a requirement of providing our services, from time to time we will store and process your personal information in Canada or in the USA, using USA based third party service providers in accordance with the privacy laws governing Canada and the USA.

The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary. If we wish to use or disclose your personal information for any new business purpose, we will ask for your written consent. We will not share your personal information with any other third parties without your written consent, unless required by law or a duly authorized legal process, such as a court order.

How Do We Safeguard Your Information?

Matrix360 takes every reasonable effort to ensure that client and candidate information is accurate and complete. We rely on our clients to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible.
In some cases, we may ask for a written request for correction.

We protect client personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.

We will notify the Office of Privacy Commissioner of Canada, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.
We retain client and candidate personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.

We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We destroy personal information records within 36 months of our program or service completion.

We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.

Access to Records Containing Personal Information

Clients of Matrix360 have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the Freedom of Information and Protection Privacy Act and Personal Information Protection and Electronic Documents Act to refuse to provide access to information that would reveal personal information about another individual.

Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.

If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.

You may make a request for access to your personal information by writing to david@matrix360.ca. You must provide sufficient information in your request to allow us to identify the information you are seeking.

You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. For personal information collected before January 2004, if we do not have a record of disclosures, we will provide information about any disclosure of your information that is likely to have occurred.

You may also request a correction of an error or omission in your personal information.

We will respond to your request within 45 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.

Security

Matrix360’s security practices are continually evolving to ensure that the integrity and confidentiality of information and systems are maintained and adhered to. We up-to- date security safeguards, secure data networks with appropriate firewalls and password protection to protect our networks and website from misuse, alteration, copying disclosure, destruction, monitoring or unauthorized sharing of information and damage. Our safeguards include the use of security software and encryption protocols and involve physical, technical and procedural controls to protect information behind the firewall.

We maintain the security of your personal information through access control, logical security (security of applications, hardware and data), and physical security of our facilities. In addition, we strive to keep your personal information accurate through processes and policies that maintain the accuracy of recorded information.

From time to time, we may provide information to third party service providers who process information on our behalf to help deliver some of our internal business operations such as email distribution, surveys, IT services and customer service. We only utilize third party service providers when we are satisfied that adequate levels of privacy and data protection are in place to protect any personal information held in that facility, country or that the service provider acts at all times in compliance with applicable privacy laws. We only partner with third party service providers who ensure that any personal information handled in other countries receives the same level of protection and privacy as it is given in Canada. When disposing of sensitive information, we utilize a secure third party for processing.

Website Privacy

When web guests visit our website www.matrix360.ca, our web server may automatically record certain anonymous technical information regarding your visit such as: the internet domain for your internet service provider, your IP address, the time when you visited the website, the pages that were accessed. This information is only used to identify server issues and assist us to administer our website.

Cookies: Cookies are small text files that your computer hard drive stores when visiting certain websites. These files are then used by website operators to help identify if you revisit the site. Our firm does not collect personal information about you and your use of our website through cookies.

Links: From time to time we include links to our partners, clients, and community associations websites for your information. Such third party websites may have different privacy policies and practices and we do not endorse nor assume responsibility or liability for these websites. Please verify privacy policies before you submit any personal information to them.

Email and Marketing Communications

From time to time, we may send marketing, special events, newsletters or promotional emails to you containing information we believe may be useful, such as information about our services, programs or those of our partners, community associations with whom we have relationships. You may unsubscribe at any time or communicate your preferences regarding certain types of communication.

Application Online and Manual Application Forms

Matrix360 offers clients the possibility on the website to contact us using online application forms and manual application forms. We process the information provided by clients in the application forms to process your application. Where applicable, we also store the information for evidence purposes for any establishment, exercise or defense of legal claims or in order to meet statutory document retention obligations.

When the application forms on our website are used certain information, for example your IP address, is for technical reasons sent to our server by the browser used on your device. We process this information in order to provide the application forms on our website and to ensure the security of the IT infrastructure used to provide the application form.

It is our policy to comply with the legislation within each jurisdiction in which we operate, as well as with applicable data privacy regulations for clients outside of Canada.

Child Protection

We do not offer services to, or target, persons under the age of 18. In compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), we will purge any information we receive from people we believe to be children under 18 from our database and cancel the corresponding accounts. We only offer services to persons under the age of 18 with parental or guardian written permission for our Matrix Real Reach Program. We follow the strictest guidance and compliance with Personal Information Protection and Electronic Documents Act (PIPEDA).

Changes to this Privacy Policy

Matrix360 may update this privacy policy. In the event there are significant changes to our Privacy Policy and its affects to your personally identifiable information, we will display a notice on our website: www.matrix360.ca. If you continue to use our services or programs after notice of changes have been sent to you or published on our website, you hereby provide your consent to the changed practices.

Who To Contact For Questions, Inquiries and Complaints

If you have a question or concern about any collection, use or disclosure of personal information by Matrix360 Inc, or about a request for access to your own personal information, please contact:

David Bendea, Director of Partnerships & Communications
150 King Street West, Suite 360 Toronto, Ontario M5H 1J9

Email: david@matrix360.ca

If you are not satisfied with the response you receive, or to obtain any information about the Personal Data Protection and Electronic Documents Act (PIPEDA) or privacy laws in general, please contact Office of the Privacy Commission of Canada (OPC):

Office of the Privacy Commission of Canada (OPC)

30 Victoria Street Gatineau, Quebec K1A 1H3

You can also contact your Provincial or Territorial Privacy Commissioner’s office for
more information:

• Alberta
  Office of the Information and Privacy Commissioner of Alberta
• British Columbia
  Office of the Information and Privacy Commissioner for British Columbia
• Manitoba
  Manitoba Ombudsman
• New Brunswick
  Office of the Integrity Commissioner for New Brunswick
• Newfoundland and Labrador
  Office of the Information and Privacy Commissioner for Newfoundland and Labrador
• Northwest Territories
  Information and Privacy Commissioner of the Northwest Territories
• Nova Scotia
  Office of the Information and Privacy Commissioner Nova Scotia
• Nunavut
  Information and Privacy Commissioner of Nunavut
• Ontario
  Office of the Information and Privacy Commissioner of Ontario
• Prince Edward Island
  Office of the Information and Privacy Commissioner (Prince Edward Island)
• Quebec
  Commission d’accès à l’information du Québec
• Saskatchewan
  Saskatchewan Information and Privacy Commissioner
• Yukon
  Yukon Information and Privacy Commissioner