BlackShire Group (or “BlackShire”) recognizes the importance of protecting personal and financial information when users visit the website or download a mobile application created or commissioned by BlackShire (each a “Website” or “App” and together “Website and App”). This Policy including the Cookies Policy is designed to help users understand the information collection practices on a Website and App owned or operated by or on behalf of BlackShire, including (but not limited to) www.blackshire.com/ca. Information collected on our Website and App is collected by BlackShire Group but may be shared with other entities within the BlackShire group of companies as set out below. Contact information is included in this Policy and on the Website.
We are committed to:
- protecting the personal information provided to us;
- informing users how the information gathered about them is used; and
- ensuring that users know the circumstances under which BlackShire may disclose usersr personal data
This Policy covers the privacy and data protection policies on the Website and App, and should be read in conjunction with any other applicable policies, terms, and conditions in place between users and BlackShire.
Changes to this Policy
This Policy is dated August 2018.
Contact the Team
For any questions or complaints about this Policy, or the privacy-related practices of BlackShire or its service providers (including information regarding our policies and practices relating to services providers located outside of Canada), please contact us:
- through users usual contact or at Corporate Secretary, c/o BlackShire Group, 150 York Street, Suite 1008, Toronto, Ontario, M5H 3S5; or
- by email at firstname.lastname@example.org
Data Protection and Privacy
Information collection and use
In the password protected section of the Website or App, or as a visitor who has entered the Website or App via a click through link in an email which has been sent, information about users, including information about the pages visited, the documents downloaded and other information which can help BlackShire personalize future interactions and communications may be collected. Any information collected about users from this Website and App may be associated with other identifying information that BlackShire has about users for the purposes set out above.
Users may contact BlackShire to:
- request that BlackShire amend, rectify, delete or update the personal data held about a user;
- amend or update user choices around processing (i.e., in relation to marketing);
- request access to, or a copy of, personal information held by BlackShire.
Where users would like to request access to or receive a copy of all personal information held, such request should be in writing (email or post), addressed to “Access Request” c/o the Corporate Secretary at the contact information above and should contain as much information as possible to facilitate our dealing with this request.
BlackShire generally records certain usage information, such as the number and frequency of visitors to the Website and App. This information may include the websites that users access immediately before and after users visit to the Websites and Apps, the Internet browser users are using pages requests, operating system, average time spent on the Website, and users IP address. If BlackShire uses such data at all it will be on an aggregate basis, and will not be disclosed to third parties for any information that could be used to identify users personally. BlackShire uses this information to help understand the Website activity, and to monitor and improve the Website.
Sharing user information with Service Providers (including other BlackShire companies)
Users personal data may be collected and processed on our behalf for the purposes above:
- By any of the companies within the BlackShire Group; or
- By a third party service provider engaged by us for these purposes
For example, BlackShire may use service providers to send email or other communications that are tailored to user interests and host, manage, and analyze data. BlackShire companies and service providers engaged may be based in countries outside of Canada. As such, users personal information may be maintained and processed by its affiliates and other third party service providers in Canada, United States, United Kingdom, European Union, Israel or other international jurisdictions in countries having different standards of protection for personal information. BlackShire service providers will be required by the Company to protect user information in accordance with applicable data protection and/or privacy laws and not use the information for any purpose other than providing the service to the Company.
Compliance with Laws
Users personal information will be held and processed by BlackShire in accordance with applicable data protection and/or privacy laws. BlackShire and its service providers will not provide any personal information to any other persons, except if it or its service providers are required to make disclosures by any applicable law (which may include lawful access by U.S. or foreign courts, law enforcement and other governmental entities), any government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding or as otherwise required or permitted by applicable law.
E-mail and Marketing
BlackShire does not sell its clients’ personal information, nor will it provide users personal information to third parties for their marketing purposes without users consent. BlackShire will not send users e-mail messages without first receiving users permission, unless it relates to servicing users account or unless users have consented to receiving electronic delivery of fund documents as part of the E-Delivery service. It is BlackShire policy to include instructions for unsubscribing from these permission-based programs in each message.
If users consent to receive push notifications through an App, BlackShire will send push notifications to users mobile device notifying users of new articles or other content available through the App. The push notifications may be tailored based on users interests and content that users have viewed on the App. If users do not want to continue to receive push notifications users can always withdraw user consent by changing user settings via the settings page of users mobile telephone.
Disclosure to Third Parties
BlackShire has implemented reasonable physical, technical and administrative safeguards in an effort to protect personal information in its custody and control from theft, loss and unauthorized access, use, disclosure. BlackShire recommends that users do not send any personal information via non-secure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure. BlackShire protects users personal information when users transact business on our Website and App by requiring the use of a browser software program that supports industry standard SSL encryption with 128- bit key lengths. The “128-bit” designation refers to the length of the key used to encrypt the data being transmitted, with a longer key representing a higher level of security.
What are Cookies?
Cookies are small text files that are stored in users computer’s memory and hard drive, in users mobile device or tablet when users visit certain web pages. They are used to enable websites and applications to function or to provide information to the owners of a website, application, or other third parties which receive data obtained from that website or application. When users visit any web site or use an application, it may store or retrieve information on users browser, mostly in the form of cookies. This information might be about users, users preferences or users device and is mostly used to make the site work as users expect it to. The information is used to provide users with a more personalized web or application experience.
- Analytical purposes: BlackShire or third parties may use analytical cookies on the Website and App. Analytical cookies allow it to recognize, measure and track visitors to its Websites and Apps and compile a record of this usage information (including areas visited and links clicked). This helps BlackShire to improve and develop the way its Websites and Apps work, for example, by determining whether site visitors can find information easily, or by identifying the aspects of our Websites and Apps that are of the most interest to them in order to provide articles and content that are tailored to their interests and preferences.
- Usage preferences: Some of the cookies on BlackShire Websites and Apps are activated when visitors to its sites make a choice about their usage of the site. BlackShire’s Websites and Apps then ‘remember’ the settings preferences of the user concerned. This allows it to tailor aspects of the sites to the individual user.
- Functional purposes: Functional purpose cookies store information that is needed by applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.
Users Cookie Preferences:
Cookies are necessary in order for users to be able to make full use of BlackShire’s Websites and Apps. In addition, cookies help BlackShire provide users with personalized features on our Websites and Apps. If users wish to remove cookies set by the Websites and Apps from users browser in the future, users may delete them. The instructions for removing cookies from users computer or mobile device depend on the operating system and web browser users use. If users choose to disable cookies, some of BlackShire’s Website’s functionality might be impaired.
Local Flash Storage
On certain areas of the Websites and Apps, BlackShire includes content designed for display using Adobe Flash Player, such as animations, videos and tools. Local flash storage (often referred to as “Flash cookies”) can be used to help improve experience as a user. Flash storage is retained on users device in much the same way as standard cookies, but is managed directly by users Flash software.
If users wish to disable or delete information stored locally in Flash, please see the documentation for users Flash software, located at www.adobe.com. Please note that, if users disable Flash cookies, some site functionality may not work.