Ashford House is committed to maintaining the security, confidentiality and privacy of your Personal Information.
“Personal Information” means any information about an identifiable individual (for example, name, age, home address and phone number, social insurance number, marital status, income, or credit history). Personal Information does not include contact information (described below) when that contact information is used for contacting an individual in their capacity as an employee of an organization.
“Contact information” means information of corporate or commercial entities, or business contact information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.
“Privacy Officer” means the individual designated responsibility for ensuring that Ashford House complies with this Policy.
2. Scope Of This Policy
This Policy addresses the ways in which Ashford House collects, uses and discloses Personal Information, including Personal Information on [Name of Organization’s Website] (the “Website”). Ashford House is committed to ensuring the accuracy, confidentiality, and security of your Personal Information and allowing you to request access to, and correction of, your Personal Information. This Policy applies generally to Ashford House customers and Website visitors, and customers who use online services that Ashford House provides.
3. Collecting Personal Information
As part of our business activities, we may collect some or all of the following information from you:
- Name, address, home and mobile telephone numbers, home e-mail address;
- Usernames and passwords you create to access our online services.
Ashford House also operates [name of website]. Ashford House reserves the right utilize a “cookie” or similar technology for the purposes of recording the individuals who visit our site. Information collected may include visitor IP address, date and time of visit to the website, webpage and documents downloaded, and previous website visited. Information is used for statistical purposes and to improve functionality of the website. By visiting the website, you are voluntarily providing your consent to the collection of the information specified in this paragraph.
Ashford House will obtain your consent to collect, use or disclose Personal Information except where Ashford House is authorized or required by law to do so without your consent. For example, we may collect Personal Information without your consent if it is permitted by a statute of Alberta or Canada, it is reasonable for the purposes of an investigation or legal proceeding, or the collection is necessary to collect a debt owed to us. Other exceptions may also apply.
Consent can be provided expressly, impliedly, orally, in writing, electronically, or through an authorized representative.
Subject to certain exceptions (e.g., withdrawal of consent would frustrate the performance of a legal obligation), you can withhold or withdraw your consent in writing at any time. Your decision to withhold or withdraw consent may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist you in making your decision.
The purposes for collecting Personal Information are usually obvious at the time of collection, and in those cases, you provide your Personal Information for those purposes. Otherwise, Ashford House will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection. We generally collect Personal Information for the following purposes:
- To verify identity
- To open and manage an account with Ashford House
- To deliver requested products and services
- To retain a contractor or agent who will perform services for us on an outsource or contract basis.
6. Using And Disclosing Personal Information
Ashford House will only use or disclose your Personal Information where necessary to fulfill the purposes identified at the time of collection or as indicated in this Policy.
Ashford House will not use or disclose your Personal Information for any additional purpose unless Ashford House obtains consent to do so, subject to certain exceptions. Exceptions may include instances where the use and disclosure is authorized or required by a statute of Alberta or Canada, is reasonable for the purposes of an investigation or legal proceeding, or is necessary to respond to an emergency.
7. Retaining Personal Information
Ashford House will retain your information only as long as is reasonable to fulfill the identified purposes or a legal or business purpose.
Individuals situated in the European Union (EU) have a right to have their Personal Information erased from Ashford House’s systems, upon request and in limited circumstances. Where legally permissible, we will take reasonable steps, including technical measures to erase such Personal Information held by Ashford House.
Individuals situated in the EU also have a right to request that their Personal Information is ported to another service provider upon request. Where legally permissible, Ashford House will take reasonable steps, including technical measures to port the Personal Information held by Ashford House.
8. Ensuring Accuracy Of Personal Information
Ashford House will make reasonable efforts to ensure that Personal Information we are using or disclosing is accurate and complete. In most cases, we will rely on you to ensure that information is current, complete and accurate.
You may request correction to your Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought. A request to correct Personal Information should be forwarded to Ashford House’s Privacy Officer.
If you demonstrate the inaccuracy of Personal Information, Ashford House will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year. If the correction is not made, we will note your correction request in the file.
9. Securing and Storing Personal Information
Ashford House makes reasonable security arrangements to protect your Personal Information from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
Your personal information may be transmitted through, stored or processed in countries other than your home country, in which case the information is bound by the laws of these countries. These countries may include, but not limited to:
- United States of America
Ashford House will take reasonable steps, through contractual or other reasonable means, to ensure our contractors, suppliers and others whom we ask to assist in providing goods and services implement a comparable level of Personal Information protection.
10. Providing Access To Personal Information
You have the right to access your Personal Information held by Ashford House, subject to limited exceptions as provided by law.
A request to access Personal Information must be made in writing on forms provided by Ashford House and must provide sufficient detail to identify the Personal Information being sought. Requests to access Personal Information should be forwarded to the Privacy Officer.
We will make the requested information available as required by law, or provide written notice of an extension where additional time is required to fulfill the request.
Ashford House may charge a fee for providing access to Personal Information. Where a fee may apply, we will inform you of the cost and request further direction from you about whether or not to proceed with the request.
If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal and your ability to seek a review of the decision from the appropriate supervisory authority.
11. Responding To Personal Data Breaches
A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information or data transmitted, stored, or otherwise processed. In the event of a personal data breach, in certain circumstances we are legally obliged to report the breach to the relevant privacy commissioner or data protection authority. In accordance with privacy legislation, we will also notify the individuals directly affected by the breach, as appropriate in the circumstances.
12. Google Analytics
Google Analytics employs cookies to define user sessions, which allows for the collection of data about how visitors are using the websites. Google Analytics uses only first-party cookies for data analysis. This means that the cookies are linked to a specific website domain, and Google Analytics will only use that cookie data for statistical analysis related to your browsing behavior on that specific website. According to Google, the data collected cannot be altered or retrieved by services from other domains.
If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit Google Analytics.
13. Changes To This Policy
Ashford House reserves the right to change this Policy from time to time. The current version will be posted to our Website and will apply to any collection, use or disclosure of Personal Information after posting of the Policy.
14. Questions and Complaints
Ashford House’s Privacy Officer is responsible for ensuring Ashford House’s compliance with this Policy. You should direct any complaints, concerns or questions regarding Ashford House’s compliance in writing to the Privacy Officer.
12026 107 Ave NW Edmonton, AB T5H 0Z2
Revised February 2023.