Policy Name: Privacy Policy
Effective Date: September 19, 2018
Version History: Adopted on September 19, 2018 Revision Date: December 2019

Wayfinder has adopted a Code of Business Conduct (Code) that reflects Wayfinder Corp. and its subsidiaries’ (Wayfinder’s) commitment to

Definition and Overview

Wayfinder Corp. is committed to protecting the privacy and security of your Personal Information (defined below). This Privacy Policy describes how Wayfinder Corp. and its subsidiaries, affiliates and related entities (collectively, “Wayfinder” "we" or "us") collect and use Personal Information. Wayfinder follows the guidance of the Alberta Personal Information Protection Act (“PIPA”) and other relevant federal and provincial privacy legislation, as applicable. We will only use your Personal Information in accordance with this Privacy Policy and PIPA unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. “Personal Information” is a broadly defined term that includes information that is reasonably capable of identifying a particular individual either alone or when combined with information from other available sources. Personal Information includes employee’s Personal Information such as information required to process payroll, but it does not include business contact information or work product information.

Some examples of Personal Information are:

  • Personal contact information such as name, personal number and home address, excepting information on a business card;

  • Government identification (social insurance number, drivers’ license number);

  • Financial information such as bank account or income details;

  • Personal characteristics such as age, gender, disability;

Consent

We will get consent for the collection, use, or disclosure of Personal Information about an individual, unless otherwise permitted by the Act. Wayfinder will get your consent to collect, use, or disclose your Personal Information, except where we are legally authorized or required by law to do so without consent.

Depending on the transaction, consent may be obtained orally, in writing or electronically and may be an opt-out (check box) consent. Consent may also be implied or explicit, depending on the sensitivity of the Personal Information.

You may withdraw consent to collect, use or disclose your Personal Information at any time by giving Wayfinder reasonable notice, unless withdrawing consent would frustrate our performance of a legal obligation. If you chose to withdraw your consent, Wayfinder may be unable to provide you with the goods or services requested.

In an employment relationship, we can collect, use, or disclose employee information without consent if it is reasonable for the purposes of establishing, managing, or terminating an employment relationship between you and Wayfinder.

Information We Collect

The information we collect about you depends on our relationship with you, but may include your name, contact information, personal employee information, information about how you use our products and services, and information about your preferences, demographics, and interests.

We only collect information that is required for, or related to, providing products and services, establishing, managing and terminating an employment or contractual relationship and conducting business by providing you with requested products and services. Generally, we collect business information, not personal information.

For online visitors, we may collect information such as your IP address, the type of your operating system, the time and duration of your visit to our sites, Internet locations you came from, and the web pages you visit within

Collection, Use and Disclosure of Personal Information

We will not collect, use, or disclose Personal Information except for the identified purposes for collection, unless we have received additional consent or the processing is authorized without consent. We will use Personal Information in accordance with this Policy, your consent and PIPA. We will disclose Personal Information where authorized by PIPA or required by law (for example, in the event of a court order, subpoena, or search warrant).

Protection and Retention of Personal Information

We will take appropriate measures to safeguard your Personal Information electronically with password protection on all of our computers and electronic devices. We will safeguard our passwords and the electronic storage of your data, which will all be maintained in Canada. Any Personal Information in hard copy, which is minimal, is stored in locked cabinets at the applicable Wayfinder worksite. Access to locked cabinets is restricted. Only those Wayfinder employees who have a true business need to collect, use or disclose your Personal Information will have access to it and will treat it confidentially in accordance with this Policy and PIPA.

We will securely destroy or anonymize Personal Information once it is no longer necessary to fulfil the identified purposes or any other legal or business purposes, unless it is necessary to retain the Personal Information for legal or business purposes. Generally for legal purposes we store data for six years from the date of collection or last use, whichever is later.

Accuracy and Access

Wayfinder will make reasonable efforts to ensure that the Personal Information we collect, use, or disclose is accurate and complete. Individuals may request that Wayfinder correct any errors or omissions in their Personal Information that is under our control and, if we are satisfied that the request for correction is reasonable, we will correct the Personal Information.

You have a right to access your own Personal Information, including information about the way in which your Personal Information is being or has been used or disclosed. You can make this request to the Wayfinder Privacy Officer, whose contact information is below. A minimal fee may be required in advance of disclosure. We will respond to your request for Personal Information by providing the Personal Information or an explanation of why we cannot provide the Personal Information within 30 days of the request, unless a time extension is granted under PIPA.

Contacting Us

If you have questions about this Policy or our collection, use, disclosure or retention of your Personal Information, you should contact the Wayfinder Privacy Officer:

Darren Mitchell, Privacy Officer

dmitchell@wayfindercorp.com

Additionally, you may contact the Office of the Information and Privacy Commissioner of Alberta https://www.oipc.ab.ca