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Last updated: 2023-12-19

  1. Introduction

Bespoke Adjusting & Claims Management Inc. (“Bespoke“, “We“, “Us” and “Our”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

  • How we collect, use, disclose, and protect the personal information of our customers and website users (“you“).
  • Describes the types of information we may collect from you or that you may provide when you visit the website bespokeadjusting.ca (our “Website“).
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

  • On this Website.
  • In email, text, and other electronic messages between you and Bespoke, whether through this Website or otherwise.
  • When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully to understand our policies and practices for collecting, processing, disclosing, storing and deleting your personal information. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (please refer to the section of this policy titled “Changes to Our Privacy Policy”). Your continued use of the Website after we make changes to this policy indicates that you accept and consent to those changes, so please check the policy periodically for updates.

This policy does not apply to personal information we receive from one of our clients in terms of delivery of our claims adjusting, claims administration and related services, or to personal information we collect in conjunction with the delivery of any such services.  The receipt, collection, validation, updating, processing, disclosure, storage, retention, disposal and other handling of any personal information in such circumstances will be in accordance with the underlying contractual terms of our agreement with such client as well as applicable privacy laws.

  1. Information we collect about you

We collect and use several types of information from and about you, including:

  • Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, and any other identifier we may use to contact you (collectively, “personal information“).
  • Business-related information, namely information that related to your business duties, including:
    • title;
    • duties;
    • business address;
    • business email address; and
    • business telephone number.
  • Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature or the number of users viewing and/or downloading specific content.
  • Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
  • Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
  1. How we collect information about you

We use different methods to collect your information, including through:

  • Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
  • Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other similar tracking technologies.
  • Third parties or publicly available sources, for example, our business partners.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of inquiring about the Website, and its services and content, or about another matter. We may also ask you for information when you report a problem with the Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research and quality assurance purposes.
  • Your search queries on the Website.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioural tracking on the Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioural tracking.

The information we collect automatically is statistical data and does not include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.
  • Monitor your authorized or unauthorized display, reproduction, distribution and/or use of Website content.

:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, please refer to the section of this policy titled “Choices About How We Use and Disclose Your Information.”
  • Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear GIFs, pixel tags, and single-pixel GIFs) that permit Bespoke, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  1. How we use your information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present the Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
  • To provide you with notices about any subscription you have purchased, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
  • To monitor our users’ and customers’ compliance their respective contractual obligations.
  • To monitor infringement of our intellectual property rights.
  • To notify you about changes to the Website or any products or services we offer or provide though it.
  • To improve the Website, products or services, marketing, or customer relationships and experiences.
  • To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
  • For any other purpose to the extent permitted by applicable privacy laws.

We may also use your personal information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, use the unsubscribe mechanism at the bottom of our e-mails. For more information, please refer to the section of this policy titled “Choices About How We Use and Disclose Your Information.”

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

  1. Disclosure of your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Bespoke’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Bespoke about our customers and users is among the assets transferred. Disclosure of personal information may also be made in the stages leading up to completion of such matters including, without limitation, in conjunction with the undertaking of due diligence by proposed purchasers, co-venturers or other interested parties.
  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, please refer to the section of this policy titled “Choices About How We Use and Disclose Your Information.
  • To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • In any manner, in any situation and for whatever purpose permitted by applicable privacy laws.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
  • To enforce or apply the Terms and Conditions of Use for the Website (which can be accessed and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bespoke, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  1. Transferring your personal information

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information, procuring services and/or content through the Website or otherwise interacting with the Website, you consent to this transfer, storage, or processing.

  1. Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, please refer to the section of this policy titled “Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
  • Promotional Offers from Bespoke. If you have opted in to receive certain emails from us but no longer wish to have your email address or other contact information used by Bespoke to promote its own or third parties’ products or services, you can unsubscribe This opt-out does not apply to information provided to Bespoke as part of any service purchase, service experience, or other transactions.
  1. Data security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

 

  1. Data retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

  1. Minors

Our Website is not intended for individuals who have not reached the age of majority in the jurisdiction in which they reside (“Minors”). Minors may not access the Website and should not provide Bespoke or its service providers with any personal information. We do not knowingly collect personal information from Minors. If you are a Minor, do not use this Website or provide any information on this Website or on or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If you believe we might have any information from or about a Minor, please contact us at .

  1. Accessing and correcting your personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [email protected] to request access to, and/or correct any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information to the extent permitted by applicable privacy laws, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to any of your personal information or choose to exercise our right not to provide you with access to any of your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include, without limitation:

  • Information protected by solicitor-client privilege.
  • Information that is part of a formal dispute resolution process.
  • Information that is about another individual that would reveal their personal information or confidential commercial information.
  • Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected].

  1. Withdrawing your consent

Where you have provided your consent to the collection, use, and transfer 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 [email protected]. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service and your continued access to and use of the Website and related services and content may be limited or prevented. We will explain the impact to you at the time to help you with your decision.

  1. Changes to our privacy policy

It is our policy to post any changes we make to our privacy policy on this page. .

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

  1. Contact information and challenging compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer

[email protected]

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.