Privacy Policy

This Policy explains how STRATFORD ECONOMIC ENTERPRISE DEVELOPMENT CORPORATION (referred to as “we,” “us,” or “our”) collect, use, retain, share and delete (collectively, “process”) your Personal Information in the delivery of our services.

Please contact us at info@investstratford.com if you have any privacy questions.

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Please read through this Policy carefully so that you may decide to consent, refuse to consent, or later withdraw your consent to the processing of your Personal Information. By using our services, you agree to the processing of your Personal Information in accordance with this Privacy Policy. Please note that if you choose not to consent or you later withdraw your consent, we may not be able to provide you or continue providing you certain services or responses.

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1. What is Personal Information?

“Personal Information” is broadly defined to include all information that identifies or could reasonably be linked, directly or indirectly, with a particular individual. Personal Information could be as simple and direct as your name, but it could also be less explicit like how a certain individual interacted with a website or an advertisement.

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2. What Personal Information do we collect, and How and Why We Collect It?

We generally collect your Personal Information from three sources:

• through our websites located at: https://www.investstratford.com and http://www.stratfordperthbusiness.ca (our “Sites”);
• in person; and
• through other means, such as by phone.

We collect Personal Information directly from you for the following reasons and we use it the ways described below:

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3. Automated Collection of Data

We use cookies, clear GIFs, third-party analytics and other tracking mechanisms to track your use of our Site. As you use our Site, these tracking mechanisms may automatically collect information such as: your IP address, browser type and operating system; web pages you view; links you click; how you move through the Site including the length of time you use the Site or particular features or pages of the Site; and the referring URL, or the webpage that led you to the Site. We may combine this information with other Personal Information we collect about you for statistical purposes, for measuring effectiveness of advertising and for fraud detection.

(a) Cookies

Cookies are pieces of information that are transferred from websites to your computer’s local storage, and they may serve a variety of purposes. For example, cookies “remember” you when you return to a website and make your experience more user-friendly. Cookies identify which web pages are visited and how often. Cookies are also used to allow companies to better understand how their websites are used to improve their services.

How to disable or delete cookies

If you want to prevent your browser from accepting cookies, if you want to be informed whenever a cookie is stored on your computer or if you want to delete cookies from your computer, please make the necessary changes in your Internet browser settings. Please note that if you disable or delete cookies in your Internet browser settings, you might not be able to access important functions or features.

Below is a brief description of the different types of cookies we use, how we use those cookies and the potential impact to your experience if they are disabled:

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(b) Clear GIFs

Clear GIFs (a.k.a., web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your computer’s local storage. These “images” are automatically loaded to your browser/device when you visit our website or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. Clear GIFs allow us to record simple user actions related to our websites and to email communications received from us, to help us determine the usage and effectiveness of our site and communications. We might use clear GIFs to track the activities of our visitors and app users, help us manage content, and compile statistics about usage. We and our third-party service providers also might use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. These can be blocked either by using a third-party application such as Ghostery (https://www.ghostery.com), or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality).

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(c) Google Analytics

We also use automated devices and applications, such as Google Analytics (https://support.google.com/analytics/answer/6004245) (to opt out, go here (https://tools.google.com/dlpage/gaoptout) to evaluate usage of our Site. We use these tools to obtain aggregated statistical information about the use of our Site to help us improve our services, performance and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information that they collect about you on our Site with other information that they have collected about you from your use of other websites.

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(d) Third-Party Technology

Our Site also uses the social media plugins (“Plugins”) of the following social networks: of the following social networks: Facebook, Twitter (X), LinkedIn, YouTube, Instagram, and Pinterest, etc. If you are logged into a social network, these companies may record your visit to our Site. In addition, if you interact with the Plugins, your Personal Information may be directly transmitted to the respective social media company.

The Plugins’ collection and use of your Personal Information is not covered by this Privacy Policy. For more information, please consult the respective social media company’s Terms of Service and Privacy Policy.

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(e) Site Usage Data

This Site gathers traffic patterns, usage information, and other aggregated data This aggregate usage data does not identify you individually. We gather this information to evaluate our visitors’ preferences and the effectiveness of our Site. We may share anonymous, aggregated statistics about visitors to our Site with others outside our company, or we may allow third parties to collect aggregate data through our Site.

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4. How We Share Your Personal Information

We do not sell Personal Information, and we will not share your Personal Information, except:

(a) to third parties performing clearly defined sub-processing functions on behalf of us, including the following types of third parties:

• (such as analyzing data, providing marketing assistance, providing search results and links, or verifying data provided by you);

(b) where we are required by law to disclose Personal Information; in connection with
any legal proceedings or prospective legal proceedings;

(c) in order to establish, exercise, or defend our legal rights;

(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling. We will require any person or entity to whom we provide your Personal Information to agree to comply with our then current Privacy Policy. We will take reasonable commercial efforts to ensure that they comply with our Privacy Policy; and,

(e) in the event of a transfer of our ownership or assets, or our / a bankruptcy or any
of our affiliates.

We may also share your Personal Information with one or more of our respective subsidiary and parent companies and other affiliated legal entities and businesses who are under common corporate control. However, all of our parent, subsidiary, and affiliated legal entities and businesses that receive your Personal Information will comply with the terms of this Privacy Policy and all applicable data protection laws with respect to their use and disclosure of such Personal Information.

Personal Information may also be used for administrative services and shared with funding partners (i.e. Provincial Ministry of Economic Development Job Creation and Trade, City of Stratford) for the purpose of providing business consultation, economic development, financial assistance, and delivery feedback.

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5. How We Protect Your Information

To protect your Personal Information against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we and our sub-processors use appropriate physical, technical, and organizational security measures

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6. Your Privacy Rights

You have the following rights with respect to the Personal Information that we collect, use, or share:

To exercise your rights or to determine what rights you may have, you or your authorized agent may reach out to us by email to the email address noted above.

If you’re not satisfied with our response, you may complain to Privacy Commissioner of Ontario. You can find the contact information for the Commissioner under the “Contact” page on https://www.ipc.on.ca/en. If for whatever reason you’re unsure of how to contact the Privacy Commissioner, let us know, and we’ll endeavor to help you.

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7. Data Retention and Your Rights to Access and Correction

Depending on your request and the method of contact, we may ask you or your authorized agent for Personal Information that we consider necessary to verify your identity to prevent fraud. This information may include name, contact information, and information related to your relationship with us, but the specific information requested may differ depending on the circumstances of your request.

(a) Your Right to Access

The disclosure of information will be provided at a no cost to you.

We reserve the right to decline your request where the information requested:

• would disclose Personal Information of another individual or of a deceased individual;
• is subject to legal privilege;
• does not exist, is not held, or cannot be found by us, could reasonably result in serious emotional harm to the individual or another individual, or serious bodily harm to another individual; or,
• may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions.

In addition, we reserve the right to decline your request if the request is manifestly unfounded or excessive, and we quote you a reasonable fee for responding to your request, but you refuse to pay that fee.

Lastly, we also will not disclose the Personal Information where applicable law would bar such disclosure.

(b) Your Right to Update or Correct Your Information

You may in most cases correct or update your Personal Information by instructing us to do so on
your behalf.

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(c) Data Retention

We do not hold onto your data for forever. Instead, our default is to retain your Personal Information until it is no longer necessary for the purposes for which it was collected, or to comply with legal obligations.

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8. RESIDENTS OF THE EUROPEAN ECONOMIC AREA

In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European visitors, this Policy outlines the legal basis on which we process your Personal Information and provides other information required by the GDPR.

In addition to the common rights granted to all visitors of the Site who provide us with Personal Information, the GDPR provides the following additional rights to individuals in the European Economic Area:

• Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Information, as permitted by law.
• Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances.
• Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Information that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
• Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Information, as permitted by law.
• Right not to be subject to a decision based solely on automated processing (Art. 22 GDPR): You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or significantly affecting you, as permitted by law.
• Right to lodge a complaint before the Data Protection Authority (Art.77 GDPR): We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Information relating to you infringes applicable data protection laws.

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9. Withdrawing your Consent

Where you have provided your consent to the processing of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at the email address noted above. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. It may take up to 3 business days to fulfill your request. Please note that despite your withdrawal, we may continue to process your Personal Information (i) to the extent that we are contractually obligated to do so, (ii) to the extent necessary to enforce any contractual obligations you may have with us, and (iii) for any other legitimate purpose (including fraud prevention) permitted by applicable law.

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10. We May Change this Privacy Policy

In order to maintain or enhance our services it might be necessary to change this Privacy Policy from time to time. We reserve the right to modify this Privacy Policy at any time, subject to applicable data protection laws. Please visit the Site from time to time for information on updates to this Privacy Policy.

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