Vrume Privacy Policy


We recognize the importance of privacy and the sensitivity of personal information. We are committed
to protecting any personal information we hold. This Privacy Policy outlines how we manage personal
information and safeguard privacy.

YOUR PRIVACY RIGHTS: All businesses engaged in commercial activities must comply with the Personal
Information Protection and Electronic Documents Act, and the Canadian Standards Association Model
Code for the Protection of Personal Information, which it incorporates.
WHY DO WE NEED PERSONAL INFORMATION? We need personal information for a variety of reasons,
including maintaining communications with clients and maintaining client records.
WHAT PERSONAL INFORMATION DO WE COLLECT? Personal information is any information that
identifies you, or by which your identity could be deduced. The type of information we collect can
include client names, birth dates, places of birth, addresses, phone numbers, email address, corporate
associations and positions held, employment and business information and bank account information.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION? Wherever possible we collect your personal
information directly from you.

CONSENT: In many cases we shall ask you to specifically consent, if we collect, use, or disclose your
personal information. Normally, we ask for your consent in writing, but in some circumstances, in many
cases accept your oral consent. Sometimes, your consent may be implied through your conduct with us.
If you are a client you are deemed to consent to our collecting and maintaining personal information
about you as required for us to complete our work for you.

USE OF YOUR INFORMATION: We use your personal information to provide services to you, to
administer our databases and to include you in any direct marketing activities. If you tell us that you no
longer wish to receive information about our services, we will not send any further material.
We do not disclose your personal information to any third party to enable them to market their
products and services.

Circumstances where we may disclose your personal information include: when we are required or
authorized by law to do so, for example if a court issues a subpoena; when you have consented to the
disclosure; when the services we are providing to you requires us give your information to third parties
your consent will be implied, unless you tell us otherwise; where it is necessary to establish or collect
fees; if we engage a third party to provide administrative services to us (like computer back-up services
or archival file storage) and the third party is bound by our privacy policy; if the information is already
publicly known.

UPDATING YOUR INFORMATION: Since we use your personal information to provide services to you, it is
important that the information be accurate and up-to-date. If any of your information changes, please
inform us.

IS MY PERSONAL INFORMATION SECURE? We take all reasonable precautions to ensure that your
personal information is kept safe. Among the steps taken to protect your information are: premises
security; restricted file access to personal information; deploying technological safeguards like security

software and firewalls to prevent hacking or unauthorized computer access; internal password and
security policies.

ACCESS TO YOUR PERSONAL INFORMATION: You may ask for access to any personal information we
hold about you. Summary information is available on request. More detailed requests which require
archive or other retrieval costs may be subject to disbursement fees.
CORRECTING ERRORS: If we hold information about you and you can establish that it is not accurate,
complete and up-to-date, we will take reasonable steps to correct it.

CAN I BE DENIED ACCESS TO MY PERSONAL INFORMATION? Your rights to access your personal
information are not absolute.

We may deny access when: denial of access is required or authorized by law; information relates to
existing or anticipated legal proceedings against you by us; when granting you access would have an
unreasonable impact on other people's privacy; when to do so would prejudice negotiations with you;
to protect our rights and property; where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request to correct information, we shall explain why.
We do not use your Social Insurance Number as a way of identifying or organizing our information about

CAN I REQUEST ANONYMITY? Whenever it is legal and practicable, we may offer the opportunity to deal
with general inquiries without providing your name (for example, by accessing general information on
our website). The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires us to
confirm the identity of all new clients. It may also require us disclose information to FINTRAC in relation
to certain large cash transactions.

CREDIT BUREAUS: To help us make credit decisions about clients, prevent fraud, check the identity of
new clients and prevent money-laundering, we may on occasion, request information about you from
the files of consumer reporting agencies. If you are our client ask to become our client you are deemed
to consent to our collecting credit information about you from consumer reporting agencies.
COMMUNICATING WITH US: You should be aware that e-mail is not a 100% secure medium, and you
should be aware of this when contacting us to send personal or confidential information.

CHANGES TO THIS PRIVACY POLICY: Since we regularly review all of its policies and procedures, we may
change our Privacy Policy from time to time. Changes will be posted on this website. You should check
back from time to time to verify if there have been any changes.
REQUESTS FOR ACCESS: If you have any questions, or wish to access your personal information, please
write to us at

Platform @ The Junction.
5 Edinburgh Rd S
Guelph, Ont
N1H 5N8, Canada
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at

112 Kent Street,
Ottawa Ontario, K1A 1H3

EMPLOYMENT INQUIRIES: If you apply to us for a job, we need to consider your personal information as
part of our review process. We normally retain information from candidates after a decision has been
made unless you ask us not to retain the information. If we offer you a job which you accept, the
information will be retained in accordance with our privacy procedures for employee records.

WEB SITE: Our website contains links to other sites, which are not governed by this privacy policy. On
our website, like most other commercial websites, we may monitor traffic patterns, site usage and
related site information in order to optimize our web service. We may provide aggregated information
to third parties, but these statistics do not include any identifiable personal information.