PRIVACY POLICY

Contents

This Privacy Policy describes the principles the Company will use to protect the privacy of personal information in its possession. It addresses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines the customers’ rights in respect of this information.
This Privacy Code does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. The Company does, however, protect the confidentiality of such information in accordance with applicable law and our own policies.

Personal Information Protection Principles

1. Accountability

The Company is accountable for the protection of all personal information within the organization’s possession or control, including any personal information that has been transferred to a third party for regulatory, legal or processing purposes. The Company will require a comparable level of protection of this information from its third party relations.
The Company shall designate one or more persons who are accountable for compliance with the following principles and who shall have overall responsibility for our protection of personal information and for the Company’s compliance with this Privacy Policy.

2. Identifying Purposes

Personal information that the Company collects from customers includes:

• the customer’s name and address and other contact information;
• facts about consumption, both historic and current;
• facts about payment for services, including general financial information;
• credit and reference information;
• computer and browser information such as screen resolution, version of browsers, operating systems, etc.

When an individual uses a service, the Company will make the individual aware of the purposes for which the Company is requesting the personal information. If the Company identifies other purposes for which the personal information may be used, the Company will seek the individual’s consent prior to such use. The Company will advise that it is the individual’s right to refuse permission for the Company to use personal information for any new purposes.
Additional purposes for collecting personal information may be identified to an individual before or at the time of collection. However, at a minimum the Company will collect personal information for the following purposes:

• to establish and maintain effective communication and provide on-going service;
• to bill and collect for payment of services;
• to establish and maintain responsible commercial relations with customers and provide them with ongoing service;
• to understand customer needs and eligibility for products & services;
• to recommend particular products & services to meet customer needs;
• to develop, enhance, market or provide products and services;
• to manage and develop The Company’s business and operations, including personnel and employment matters; and
• to meet legal, regulatory and settlement requirements.

3. Consent

The Company will obtain consent before or when it collects, uses or discloses personal information about an individual. An individual can provide consent to the collection, use and disclosure of personal information about them expressly or implicitly. The Company will collect, use or disclose personal information without an individual’s consent only in limited circumstances as permitted by law. Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of personal information about them at any time. If you do receive an unwanted email or other message from the Company, you can simply send an email to contact@makeitright.ca and request that your email address not be retained.
All existing customers have been or will be informed of what types of personal information have been collected, the purpose for the collection and the procedures available for contacting the Company with any inquiries.

4. Limiting Collection and Information About Children

The Company limits the amount and type of personal information it collects to that which is necessary or appropriate for the purposes indicated in principle # 2. Each affiliate of the Company will be responsible for its own collection, use and disclosure of information. Personal information will be collected by the Company using procedures which are fair, transparent and lawful.
The Company has no intention of collecting personally identifiable information from anyone under the age of 18. When the Company becomes aware that personally identifiable information from a child under 18 has been collected without such child’s parent or guardian’s consent, it will use all reasonable efforts to delete such information from its records.

5. Limiting Use, Disclosure and Retention

The Company will only use the personal information for the purpose for which it was collected as identified in principle #2, unless consent is given by the individual to use or disclose it for another purpose.
The Company treats your personal information as confidential and does not disclose it to third parties or use it without your written consent, except where such personal information is require to be disclosed to third parties under certain circumstances. When personal information is provided to third parties, the Company provides only that information which is (a) in accordance with principle #2; (b) in accordance with your agreement otherwise provided to disclose such information; or (c) that is required in the circumstances. Information provided to third parties is provided only for the purpose stipulated and except for information provided in accordance with law, such information is subject to specific confidentiality obligations. Companies to whom the Company may provide information must ensure that their employees who have access to your personal information agree to comply with the Company’s privacy standards.
Third parties include:

1. An agent acting on behalf of the Company, such as a company hired to perform installation or maintenance on our behalf;
2. A collection agency, for the express purpose of the collection of past due bills;
3. Law enforcement agencies, in emergencies, for internal security matters, or where required by court order or search warrant;
4. Billing, settlement or market operation purposes.

The Company may engage employees, contractors, and other companies or third parties to perform work that involves access to personal information. In any case, the Company will take reasonable steps to ensure that such parties are required to keep the information confidential and not to use it in any way other than as is necessary to perform their work for us.
The Company may disclose summary information obtained by combining data from many accounts, provided that the information has been sufficiently aggregated such that any personal identifiers cannot reasonably be identified.

6. Accuracy

In order to ensure the reliable delivery of service and the correct billing, the Company will use reasonable efforts to keep all personal information accurate, complete and up to date.
Individuals may challenge the accuracy and completeness of personal information about them and have it amended, as appropriate.

7. Cookies

A cookie is a small non-executable file that is stored on your hard drive for the purpose of identifying your computer. While it is possible to navigate and use the Company website by having your browser’s Internet security set such that it will not accept cookies, your online experience may be greatly reduced, and you may not be able to access the full functionality of the Company website.
The Company only uses session cookies at www.makeitright.ca and www.holmeshomes.ca. Session cookies are active only during the period you are logged on to the Company website, and are removed when you leave. They help us track the sections of the website that you use to allow us to make improvements in keeping with observed user preferences.
The Company also allows other companies, called third-party ad-servers or ad-networks, to present advertisements within our web pages. Because your web browser must request these advertising banners from the ad network’s website, these companies can send their own cookies to your cookie file, just as if you had requested a web page from the site. The Company only authorizes our third-party ad-servers to employ anonymous cookies for ad delivery and anonymous targeting. Our third-party ad servers do not collect, nor do we give them access to, any personally identifying information about you.
Third-party ad-servers may use permanent cookies. Permanent cookies remain on your hard drive until you remove them through your browser’s Internet security settings. Permanent cookies are used to store user preferences such as preferred language and thus eliminate your having to make the same entries on each visit.

8. Safeguards

In executing its responsibilities with respect to the confidentiality of personal information, the Company will employ a number of safeguards, appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, for example, restricted access to offices, security clearances and limiting access on a “need to know” basis and use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.

9. Openness and Updates

The Company will make its policies and practices relating to the protection of personal information available to its customers. The information will be available in a format that is easy to understand.
If The Company decides to change its privacy policy, it will post those changes to this privacy statement, the homepage, and other places it deems appropriate so that you are aware of what information we collect, how The Company uses it, and under what circumstances, if any, The Company will disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If The Company makes material changes to this policy, it will notify you here, by email, or by means of a notice on its homepage.
The Company publishes its privacy policy on its web site. Any material change to The Company’s privacy policy will be prominently noted in the published policy. In addition, you may contact The Company with any question or concern you may have by emailing the Privacy Officer at privacy@makeitright.ca. Questions or concerns may also be mailed to the Company at P.O. Box 40581, 5230 Dundas Street West, Etobicoke, Ontario, M9B 6K8.

10. Individual Access

Any customer of the Company can have access to the personal information about them that the Company has in its possession or control. Any customer may request that their personal information be amended for purposes of accuracy and completeness.
Customers can make their requests via email at contact@makeitright.ca or in writing to the attention of the Privacy Officer to P.O. Box 40581, 5230 Dundas Street West, Etobicoke, Ontario, M9B 6K8. The Company will attempt to respond to any individual’s request in a timely and efficient manner.

11. Challenging Compliance

Any customer of the Company may challenge the Company’s compliance with this
Privacy Policy by contacting the Company directly. The Company has policies and procedures to receive, investigate and respond to individuals’ complaints and questions. If the customer is not satisfied with the way the Company has responded to a complaint, the customer can contact the Privacy Commissioner of Canada.

12. Other important information

This web site may contain links from and to other sites. The Company does not endorse or otherwise accept responsibility for the content or privacy policies of those web sites, and encourages you to read the privacy policies of any web site you visit.
The Company web site is maintained in Canada. By using this web site, you authorize the export of any personally identifiable information you submit to us, as well as the non-personal information collected by this site, to Canada, and its storage and use as specified in this policy.
If you have submitted personally identifiable information to the Company via email and would like that information to be removed from our database, please send an email to support@makeitright.ca and request that your information be removed.