Privacy Policy
Introduction
At Steer Technologies Inc d/b/a Argo Co. [1] [2] (“Argo”, “we”, “us” or “our”), we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Argo and its affiliates collect from or about you on or through our website, [insert domain name] (the “Website”), as well as how we use and to whom we disclose that information. This Privacy Policy forms part of our Terms of Service, available at [insert link]. Please review this entire document carefully.
By accessing or using our Website, you consent to our collection, use, and disclosure of your personal information as described in this Privacy Policy. You can withdraw your consent at any time, however, if you choose to do so, we may not be able to provide you with the services and communications that are available through the Website.
This Privacy Policy is effective for Canada
Argo is subject to the Personal Information Protection and Electronic Documents Act (Canada) and applicable Canadian provincial privacy legislation. Privacy laws vary by jurisdiction. You acknowledge and agree that access to the Website and the services that are available through the Website are provided via the Internet and that your information, including personal information, may be transferred across national borders and stored or processed in accordance with the terms and conditions of this Privacy Policy.
This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be consistent with privacy requirements for all jurisdictions.
[Note: This privacy policy has been prepared for compliance with Canadian laws, excluding Quebec. If you want the privacy policy to be compliant with Quebec law a French translation will need to be prepared and a civil law review is recommended. This cannot be completed within the requested timeline pre-launch. Please note that the website itself would need to be made available in French as well to achieve compliance with French language laws in Quebec.]
What personal information do we collect?
We collect and maintain different types of personal information in respect of the individuals with whom we interact. This personal information may include, but is not limited to, your contact and identification information, such as your name, address, telephone number, email address, and IP address.
How do we collect personal information?
As a general rule, Argo collects personal information directly from you. In other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions). From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Other information that is collected when you use the Website
In addition to the personal information described above, we automatically collect certain device and statistical information to make our Website work better for you. For example, we collect the network connection, the device domain used to access our Website, the operating system on your device, your device settings, the type and version of your browser, crash data, other unique device identifiers, the mobile application or website you came from to access the Website, the page you entered and exited at, any searches, pages or advertising within our Website that is viewed by that IP address and what country you are from. We use this information to monitor the performance of our Website (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our Website.
Our Website uses cookies and other technologies that are similar to cookies (“Cookies”). A Cookie is a small file of letters and numbers that we may set on your device to store and sometimes track information about you. Cookies and similar technologies we use are designed for “analytics”. This allows us to distinguish you from other users of the Website. This helps us to provide you with a good experience when you use the Website and allows us to improve our Website.
Most internet browsers allow you to remove or manage Cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your internet browser or visit https://www.aboutcookies.org/how-to-control-cookies/. Please note that disabling our Cookies may result in your inability to take full advantage of all of the features of our Website.
Why do we collect personal information?
We only collect information from you that is necessary to provide you with the services and communications available through our Website and which enables us to manage, maintain, and develop our operations. For example, we collect information in order to:
- establish, maintain and manage our relationship with you, including by contacting you, so that we may provide you with any services or communications (e.g., our newsletter or investor presentation) that you have requested;
- allow you to participate in, subscribe to or otherwise receive services and communications from us;
- be able to comply with your requests (e.g., if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
- understand your preferences and tailor communications and services to you and to send you information about Argo and its affiliates’ portfolios, news, media coverage, events, filings and investor matters, as applicable;
- protect Argo against error, fraud, theft and damage to our Website, assets or other properties;
- conduct analysis and evaluations to understand usage and trends to improve our Website, services, communications and operations;
- enable us to comply with applicable laws or regulatory processes; and
- any other reasonable purpose to which you consent.
By consenting to our collection, use, and disclosure of your personal information through our Website you allow us to fulfill the purposes for which we collect your personal information.
When we collect your information for research and development purposes, we ensure that any information used for our analysis and reports will be de-identified, anonymized, or aggregated in a manner that will not identify you.
We will collect your express consent prior to sending you any commercial electronic messages, unless an exception to obtaining your opt-in consent applies under Canada’s Anti-Spam Legislation. You will have the opportunity to opt-out of receiving commercial electronic messages at any time by following the unsubscribe mechanism included in our commercial electronic messages or by contacting our Privacy Officer.
How do we use your personal information?
We may use your personal information:
- as permitted or required by applicable law or regulatory requirements;
- for the purposes described in this Privacy Policy; and
- for any additional purposes for which we have obtained your consent to use your personal information.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When do we disclose your personal information?
We may disclose your personal information to our affiliates, our respective employees, contractors, consultants, service providers and other parties who require such personal information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, we may use third party service providers to assist us with our marketing and advertising activities and communications and these service providers may send you communications on our behalf.
Personal information may also be disclosed or transferred to another party during the course of, or upon completion of, a change in ownership of, or the grant of a security interest in, all or a part of Argo or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.
Finally, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of Argo’ regular reporting activities under applicable law to protect the rights and property of Argo;
- during emergency situations or where necessary to protect the safety of a person or group of persons; and
- for any additional purposes for which we have obtained your consent to disclose your personal information.
Since we may share your personal information with third parties, as described in this Privacy Policy, your personal information may be collected, used, processed, stored or disclosed outside of your jurisdiction of residence. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction. If you would like further information about our policies and practices regarding the third parties (including our service providers) with whom we disclose your personal information and how these third parties collect, use, disclose and store personal information, please contact our Privacy Officer using the contact details below.
By providing your personal information to us, you consent to our disclosure of this information to our service providers (and other third parties) as described in this Privacy Policy, including those that may be located outside of your jurisdiction of residence, for the purposes of processing your personal information on our behalf, providing services to us or to you, and for the other purposes described in this Privacy Policy.
Your consent is important to us.
It is important to us that we collect, use, and disclose your personal information only when we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
We will usually seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. If you withdraw or vary your consent, we may not be able to provide you with the communications and/or services you request through our Website. For example, if you would like to receive our newsletter, but are not willing to provide your email address, we will not be able to fulfil your request.
Unless you advise us otherwise, through the access and use of our Website, services and communications, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.
How is your personal information protected?
Argo will endeavour to maintain commercially reasonable physical, technical and procedural safeguards that are appropriate based on the sensitivity of the personal information. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.
The security of your personal information is important to us. Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
Updates to your personal information.
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.
Access to your personal information.
You can ask to access the personal information that we have received from or possess about you. If you want to review, verify, or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased, or anonymized in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
Retention of personal information.
We don’t keep your personal information forever. We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.
Links to third-party websites.
Our Website may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Argo is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.
Revisions to this Privacy Policy.
Argo may make changes to this Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our Website.
If we make any material changes, we will notify you as required by law, but encourage you to check back often for updates. Your continued use of the Website after an update or amendment to this Privacy Policy means that you consent to the collection, use, and disclosure of your personal information as described in the updated Privacy Policy.
Interpretation of this Privacy Policy.
Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy does not create or confer upon any individual any rights or impose upon Argo any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
Questions or concerns?
If you have any questions about this Privacy Policy or concerns about how we handle your personal information, please contact our Privacy Officer in writing or by e-mail. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction. We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:
or at:
545-101 King St W. Toronto, ON M5V 1M1, Canada