Updated as of January 2, 2018
Table of Contents
- General overview
- Type of personal information we collect and how we use the personal information
- When we share personal information
- Where we store and process personal information
- How we secure personal information
- How long we keep personal information
- Your right to access and correct your personal information
- Cookies and similar technologies
- Interest-based advertising (IBA)
- Opting out of IBA
- Advertising on mobile devices
- Do not track
- Connecting via social networks
- Links and connections to third-party services
- Children’s privacy
- How to contact us
1. General overview
First Reference Inc. (“First Reference”) recognizes the importance of an individual’s right to keep personal information private. First Reference is committed to the responsible handling and protection of personal information. Personal information means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
First Reference’s business involves the placement and licensing of our products and services on a business-to-business basis. As such, business information is preferred over personal information for all business-to-business transactions.
3. Type of Personal Information we Collect and how we use the Personal Information
First Reference collects personal information from you, for example, if you register for an event, request information, purchase a licence to use one of our services or products, or request customer or technical support. We may ask you to provide information such as your name, address, phone number, email address, user name and password, and information about your device. Not all of the personal information First Reference holds about you will always come directly from you. It may, for example, come from your employer, other organizations to which you belong, or a professional service provider such as your tax or accounting professional or lawyer, if they use our services or products. We also collect personal information from third parties such as our partners, service providers, and publicly available websites, to offer services or products we think may be of interest and to help us maintain data accuracy and provide and enhance the services or products.
In addition, our servers, logs, and other technologies automatically collect certain information to help us administer, protect, and improve our services and products; analyze usage; and improve users’ experience. We share personal information with others only as described in this policy, or when we believe that the law permits or requires it.
Occasionally we collect and process what may be considered sensitive personal information.
Sensitive personal information is a subset of personal information and is generally defined as any information related to trade union membership and gender. In some instances, sensitive personal information may also include precise geolocation information, financial and bank account numbers, or unique identifiers.
For example, if you purchase a license from us or subscribe to our services or products, we will collect payment information, such as financial or bank card information, and other information necessary for us to process the transaction. If you or your service professional uses our policy generating software, we will collect some company and employee information. Some of our services and products will ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the service or product. We may also collect information such as a government-issued identification number if you use our elearning, training or workflow software. Information that is considered sensitive under applicable law will be handled in accordance with such laws.
We process personal information for these services and products for business-related purposes
- Account setup and administration: We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, newsletters and service-related information.
- Personalization: We use personal information to deliver and suggest tailored content such as news, research, reports, and business information and to personalize your experience with our services and products. Some of our services and products will ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the service or product. If you agree to share your precise geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online.
- Marketing and events: We use personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important service and product information related to your accounts and subscriptions.
- Surveys and polls: If you choose to participate in a survey or poll, any personal information you provide may be used for marketing or market research purposes.
- Research and development: We use personal information for internal research and development purposes and to improve and test the features and functions of our services and products.
- Hosted services: Some of our services and products provide data and document storage as an integral part of the product or solution offering. Documents and data stored by our customers may contain business and employee personal information in forms, payroll and financial data -related documents, for example. Any information stored by or on behalf of our customers is controlled and managed by and only made accessible to those customers or others our customers may authorize from time to time. Our access to this information is limited to First Reference personnel with a critical business reason, such as technical support. Please click here to learn more about where we process and store information.
- Legal obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, or those of other persons.
4. When we share personal information
First Reference shares or discloses personal information when necessary to provide services or products or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We may occasionally share non-personal, anonymized, and statistical data with third parties. Below are the parties with whom we may share personal information and why.
- Within First Reference: Our business that serves businesses across Canada are supported by a variety of First Reference teams and functions, and personal information will be made available to them if necessary for the provision of services and products, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and contractors are required to follow our privacy and security policies when handling personal information.
- Our business partners: We occasionally partner with other organizations to deliver co-branded services or products, provide content, or to host events, conferences, and seminars. As part of these arrangements, you may be a customer of both First Reference and our partners, and we and our partners may collect and share information about you. First Reference will handle personal information in accordance with this policy, and we encourage you to review the privacy statements of our partners to learn more about how they collect, use, and share personal information.
- Our third-party service providers: We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfill the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfillment and delivery. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
- Third parties for legal reasons: We will share personal information when we believe it is required, such as:
- To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.
- In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
- To protect our rights, users, systems, and services.
- E-recruitment partners: If you register as a user of our e-recruitment services in order to apply for employment, your personal information, including any sensitive personal information you provide, will be made available to the organization to which you have applied. In order to consider an application fully, your personal information may be forwarded to an organization’s global offices.
5. Where we store and process personal information
First Reference has networks, databases, servers, systems, support, and help desks located in Ontario. We collaborate with third parties such as cloud hosting services, suppliers, and technology support located around the world to serve the needs of our business, workforce, and customers. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within First Reference or to third parties in areas outside of your Canada, province and territory. The areas in which these recipients are located will vary from time to time, but may include the United States, Europe, Canada and other countries where First Reference uses contractors or third party licences.
When we transfer personal information from the European Economic Area to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. In other words, your rights and protections remain with your data. For example, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it. If you would like to know more about our data transfer practices, please contact our Privacy Officer.
6. How we secure personal information
First Reference takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.
- Policies and procedures
- We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data
- We have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets
- We place appropriate restrictions on access to personal information
- We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely
- We conduct Privacy Impact Assessments in accordance with legal requirements and our business policies
- Training for employees and contractors
- We require privacy, information security, and other applicable training on a regular basis for our employees and contractors who have access to personal information and other sensitive data
- We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions
- Vendor risk management
- We require, through the use of contracts and security reviews, our third-party vendors and providers to protect any personal information with which they are entrusted in accordance with our security policies and procedures
7. How long we keep personal information
First Reference with the collaboration of the Privacy Officer retains personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, First Reference takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need personal information, we securely delete or destroy it.
8. Your right to access and correct your personal information
We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.
- Access to personal information: If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
- Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by using the “My Account” or “Contact Us” options within the relevant service or product.
- Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or visit the applicable “My Account” preference center. Information related to controlling cookies can be found here, and information related to Interest-Based and Mobile Advertising can be found here.
- Filing a complaint: If you are not satisfied with how First Reference manages your personal data, you have the right to make a complaint to a data protection regulator such as the Privacy Commissioner of Canada or of a particular province or territory.
You can also first contact our Privacy Officer at:
First Reference Inc,
50 Viceroy, Unit 1
Email Privacy Officer
9. Cookies and similar technologies
- What is a cookie?
A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.
- Types of cookies and why we use them
- Absolutely necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, services you have asked for, like adding items to an online shopping cart, cannot be provided.
- Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies don’t collect information that personally identifies you and only collect aggregated and anonymous information. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.
- Functionality cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites.
- Targeting and advertising cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.
- Managing cookies
You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.
We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:
- Other tracking technologies
- Local shared objects/Flash cookies: Flash cookies, also known as local shared objects, are designed to support browser content supported by Adobe® Flash. They are usually used to enable ads and video content on websites. Like other cookies, they will store information on your device, some of which will be specific to the Flash-enabled content. Flash cookies can only be deleted within Adobe Flash rather than via your browser. Please refer to the following help page for information on how to manage your privacy settings and deletion of Flash cookies.
- Web beacons: Our web pages may contain electronic images known as web beacons (also called single-pixel gifs and transparent graphic images) that we use to help deliver cookies on our sites, count users who have visited those sites, deliver services, and analyze the effectiveness of our promotional campaigns, for example. We may also include web beacons in our marketing email messages or newsletters to determine whether an email is opened or if links are clicked.
- Web server & application logs: Our servers automatically collect certain information to help us administer and protect the Services, analyze usage, and improve users’ experience. The information collected includes:
- IP address and browser type
- Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
- Device operating system and other technical facts
- The city, state, and country from which you access our website
- Pages visited and content viewed, stored, and purchased
- Information or text entered
- Links and buttons clicked
- URLs visited before and after you use our Services
10. Interest-based advertising (IBA)
Interest-based advertising (IBA) allows us to deliver targeted advertising to users of our services and products. IBA works by showing you advertisements that are based on the type of content you access or read. For example, as you browse our services and products, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests. For more information about IBA, please visit: http://www.iab.net/public_policy/behavioral-advertisingprinciples.
11. Opting out of IBA
If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive marketing or advertising when you are using our services or products. It just means that we will not use information collected about you for IBA and that any advertising you see will not be customized or relevant to you. You can exercise your online advertising choices at http://optout.aboutads.info or by clicking the AdChoices icon in an ad and following the instructions. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative’s (NAI) Opt Out Tool (http://www.networkadvertising.org/choices). Remember, if you delete cookies, use a different device, or change web browsers, you may need to opt out again.
12. Advertising on mobile devices
Mobile devices have an identifier that gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. Another tool you can use to control advertising on your mobile device is the AppChoices App: http://youradchoices.com/appchoices. You may also choose to turn off location tracking on your mobile device. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising. You may still see the same number of ads but they may be less relevant because they will not be based on your interests.
13. Do not track
Some browsers transmit Do Not Track (DNT) signals to websites. Due to the lack of a common interpretation of DNT signals throughout the industry, First Reference does not currently alter, change, or respond to DNT requests or signals from these browsers. We will continue to monitor industry activity in this area and reassess our DNT practices as necessary.
14. Connecting via social networks
Some of our services or products may include social networking features, such as the Facebook® “Like” button and widgets, “Share” buttons, and interactive mini-programs. Additionally, you may choose to use your own social networking logins from, for example, Facebook or LinkedIn®, to log into some of our services or products. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the services or products and do not participate in social sharing on the services or products.
15. Links and connections to third-party services
Our services or products may contain links to and may be used by you in conjunction with third-party apps, services, tools, and websites that are not affiliated with, controlled, or managed by us. Examples include Facebook, LinkedIn, Twitter® and, third-party apps like voice software and readers. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to these third-party services.
16. Children’s privacy
First Reference provides information solutions for professionals, and our services or products are generally not aimed at children. If, however, we collect and use information about children, such as to develop an educational resource, we will comply with industry guidelines and applicable laws.
17. How to contact us
We understand that you may have questions or concerns about this policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:
First Reference Privacy Officer:
Email to Privacy Officer
50 Viceroy, Unit 1
Marketing preferences and services support:
To update your account information or email marketing preferences, or for technical support or other help with your products or services, please visit the “My Account” or use the “Contact Us” option for the relevant service or product or contact customer service.