Privacy Policy

DC Steel Ltd. and our corporate affiliates (the “Company”, “we”, “us”, “our”) respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services to you.  Based on applicable privacy and data protection principles common to Canada and other jurisdictions that we are subject to, we have developed this privacy policy (the “Policy”) to explain our practices for processing your personal information.  This Policy does not apply to our employees’ personal information or any de-identified or anonymized information. 

 

This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct, update and access your personal information that you provide as a user of DC Steel Admin, DC Steel Forms and such other related websites and applications as may be made available from time to time (collectively, the “Application”), excluding third party software, websites, or services that may interact with the Application (“Third-Party Services), and the services we provide through the Application (collectively with the Application and excluding any Third-Party Services, the “Service”). This Policy references the general Terms of Use for the Service available at http://www.dcsteel.ca/terms-of-use (the “Terms of Use”), and forms an integral part of those Terms of Use. All capitalized terms not otherwise defined herein have the meaning provided in our Terms of Use.

 

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or use any part of the Service or otherwise provide any personal information to us. 

1. Personal Information

For the purposes of this Policy, “personal information” means any identifiable information about an individual, including but not limited to an individual’s name, home address, telephone number, email address, except any other information otherwise exempted by the applicable laws of Canada.  For example, in Canada, personal information does not include any business contact information that is processed solely to communicate with that person about thier employment or profession. 

When you use our Service, we may collect the following personal information from you: 

  • Contact information such as name, mailing address, date of birth, SIN, phone number, email address, start date, benefit start date, emergency contact name, and emergency contact phone number;

  • Unique identifiers such as username, account number, and password; and

  • Referral information.

Your personal information may be collected when: 

  • for an account with us;

  • You provide us with your personal information through our website or application;

  • We collect data from third parties or publicly available sources.

We only collect personal information that we need.  We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Collection from Third Parties

We do not knowingly collect your personal information from third parties unless you consent or we are otherwise exempted, required or permitted by applicable laws to do so.  

If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected.

  

Links to Other Sites

To the extent that our Application contains links to Third-Party Services, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on Third-Party Services.

 

2. Purpose for Which Personal Information is Processed

We may process your personal information for the following purposes (the “Purposes”):

  • To verify and authenticate your identity;

  • To ensure that the Service is optimized for your use and benefit;

  • To analyze user experience and improve the Service;

  • To operate, maintain and provide to you the Service, including all features and functionality of the Application including the delivery of workplace health and safety information to work site management;

  • To communicate with you to provide you services, contacts, materials and recommendations for your needs as identified by you through phone, email, or the Application;

  • To carry out our obligations arising from any contracts entered into between you and us;

  • To comply with internal policies and procedures and other legal, accounting, or security requirements;

  • To share your personal information with our employees, contractors, consultants and other third party service providers such as application hosting providers, advertising agencies, payment processors or customer service agencies (“Third-Party Processors”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Service for your use and benefit. 

Please note that we may change or add Third-Party Processors at any time, in our sole discretion, either in Canada or elsewhere. We encourage you to reference this Policy from time-to-time, to obtain updated information. Given the nature of cloud services, personal information may be stored outside Canada, anywhere in the world, and may be accessible to foreign courts, law enforcement and national security authorities in the jurisdiction(s) where it is transferred or stored. 

We will only process your personal information for the Purposes for which we intend to process such information.  Otherwise, we will not process your personal information without your consent except where permitted by law.

3. Disclosure of Your Personal Information 

We may disclose your personal information for the Purposes as described in this Policy in the following ways: 

  • If you are using the Services in the course of your employment, to your employer; 

  • If you are using the Services in the course of an engagement as an independent contractor, to the party which engaged you to perform the services;

  • To our employees, contractors, and agents on an as-needed basis;

  • To our Third-Party Processors; and

  • To law enforcement, government or regulatory bodies, or other lawful authorities as required by law.

 

4. Legal Basis for Processing Your Personal Information 

Consent

We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested.  Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request.  Your consent can also be provided by your authorized representative.  Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed.  By using our Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected.  When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.

 

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Service or otherwise provide any personal information to us.  

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Application, (ii) deleting your account with the Application and stopping use of the Application, or (iii) opting out of the use of your personal information by contacting our Privacy Officer (see Section 9 below).   However, if you withdraw or change your consent, we may not be able to provide you with the Service.

Other Legal Bases 

Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable law.  

 

5. Security of Personal Information

The security of your personal information is important to us. We protect personal information using physical, technological and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.

 

However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

 

6. Requests for Access to and Correction of Personal Information

Applicable privacy laws allow individuals the right to access and request the correction of errors or omissions in their personal information that is in our custody or under our control. You may request access to and review of your personal information in our possession. However, access may be declined where permitted or required by applicable law.

 

You may request that we corrrect your personal information in our possession. We reserve the right not to change any personal information if we do not agree that it is inaccurate or outdated, but will append any alternative text the individual concerned believes appropriate.

 

If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal. 

 

7. Retention of Your Personal Information

We generally keep personal information for only as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate purposes.  More specifically, we retain personal information as long as necessary for the fulfillment of the identified Purposes for its collection or as otherwise necessary to comply with applicable laws or protect our interests. When personal information is no longer necessary or relevant for the identified Purposes, or is required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to personal information. 

 

8. Updates or Changes to this Policy

This Policy was last updated on March 8, 2022. We will occasionally update this Policy and revise the "last updated" date appearing in this paragraph. 

 

If we make any material changes we will either (a) notify you by email (sent to the email address listed in your account), or (b) provide a notice on the Application or otherwise through the Service before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes.  Your continued use of the Service signifies your acceptance of any changes to this Policy.

 

9. Contact Information for Privacy Officer

You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our Privacy Officer by emailing info@dcsteel.ca.

 

If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws.  Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.

End of Policy