Privacy Policy

Accountability

D. Toma Professional Corporation is responsible for the personal information under our control and has designated a Privacy Officer who is accountable for compliance with our Privacy Policy. We also require that comparable protection of personal information is in place with any third parties used by us to process such information. Questions can be directed to D. Toma Professional Corporation's Privacy Officer as indicated below:

Purpose

We recognize the importance of your privacy and the sensitivity of personal information. D. Toma Professional Corporation is providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information.

Scope

This Privacy Policy applies to Personal Information that is collected by D. Toma Professional Corporation in the course of our business, including on the D. Toma Professional Corporation website ("Site"), blogs, and other online or offline services (together with any and all future online and offline services managed by or on behalf of D. Toma Professional Corporation, the "Services"). This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. All individuals whose responsibilities include the collection of Personal Information on behalf of D. Toma Professional Corporation are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally in the jurisdictions where our clients and Site visitors reside.

Transparency/Notice

Types of Personal Information We Collect

We use the term "personal information" to mean any information that can be used to identify an individual. Our primary goals in collecting personal information are to both provide and improve our Services, to provide professional services to you, and to allow you to enjoy and easily navigate our Site with the most accurate and relevant information to you and/or your organization. The types of Personal Information we may collect (directly from you or from a Third-Party sources) and our privacy practices depend on the nature of the relationship you have with D. Toma Professional Corporation and the requirements of applicable law. Some of the ways that we may collect Personal Information include:

• directly to D. Toma Professional Corporation through your engagement of our Services (offline),
• through the distribution of requested reference materials,
• resumes, work history information, or application forms, submitted to us
• when you contact us for further information
• via surveys, quizzes, or benchmarking surveys
• via registration for events, courses and conferences (online or offline),

As you navigate the Site, certain limited technical information may also be collected about your visit through the privacy-focused analytics described below.

How We Use Your Information

All the personal information we hold about you will be processed by us in North America and no third parties will have access to your personal data unless there is a legal obligation for us to provide them with this. We have set out below the legal bases for us to process your data:

• Some of our processing is necessary for compliance with a legal obligation.
• We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with providing you with services.
• We will also communicate with you information about other services we can offer you and update you about our activities.
• Where your information is used other than in accordance with one of these uses, we will first obtain your consent to that use.

User Data obtained by the Site is used for internal business purposes of D. Toma Professional Corporation and in connection with a visitor's request. This data is not shared with others for unrelated purposes unless stated in this Privacy Policy or otherwise communicated to the Site visitor.

D. Toma Professional Corporation's intention is not to seek any sensitive information through our Site unless legally required for recruiting purposes.

D. Toma Professional Corporation makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the Site has collected excessive information, we encourage the visitor to contact us at ​ to raise any concerns.

Except for instances where visitors explicitly choose to receive specific D. Toma Professional Corporation marketing or other informational materials, D. Toma Professional Corporation will not use personal data collected from our Site to distribute marketing or informational materials.

Consent

By continuing to use the Site and by providing any personal data (including sensitive personal data) to us via the Site or email addresses provided on the Site, visitors are consenting to our use of your personal data as set out in this Privacy Policy.

Cookies and Analytics

Our Site is designed to operate with minimal tracking technologies. We do not use advertising or targeting cookies, social media widgets, or cross-site tracking on the Site.

• Essential technologies. The Site may use technologies that are strictly necessary for its operation and security, such as automated bot-protection checks on our contact form.
• Analytics. We use Fathom Analytics, a privacy-focused analytics service, to understand overall traffic to the Site (such as which pages are visited and how often). Fathom does not use cookies and does not collect or store personal information about individual visitors. More information is available in Fathom's privacy policy at usefathom.com/privacy.

Because our analytics are cookieless, the Site does not present a cookie consent banner. If we introduce technologies that require consent in the future, we will update this Privacy Policy and request consent where required by applicable law.

Third Parties

D. Toma Professional Corporation will only disclose Personal Information to third parties under the following circumstances:

• when explicitly requested by the client/user/visitor
• when required to deliver publications or reference materials requested by the client/user/visitor
• when required to facilitate conferences or events hosted by a third party
• when required to meet any other request of a client/user/visitor.

Categories of third parties that D. Toma Professional Corporation may share personally identifiable information with include federal, provincial, and local government entities.

The Site does not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and D. Toma Professional Corporation does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Data Retention

D. Toma Professional Corporation retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether D. Toma Professional Corporation is storing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. You may send an email to ​ or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by D. Toma Professional Corporation. Please include your full name, email address associated with your Account, and a detailed description of your data request.

Although D. Toma Professional Corporation makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which D. Toma Professional Corporation is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual's privacy in the case in question or where it is commercially proprietary. If D. Toma Professional Corporation determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, D. Toma Professional Corporation will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Security and Safeguards

D. Toma Professional Corporation takes reasonable measures to ensure that your personal information is kept secure and prevent unauthorized access, modification or disclosure. Among the reasonable steps taken to protect your information are:

• Physical premises security;
• Restricted file access to personal information;
• Deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
• Internal password and security policies.

Human Resources Data

With regard to Personal Information that D. Toma Professional Corporation receives in connection with the employment relationship, D. Toma Professional Corporation will use such Personal Information only for employment-related purposes. If D. Toma Professional Corporation intends to use this Personal Information for any other purpose, we will notify the Individual and provide an opportunity to opt-out of such uses.

Onward Transfer

D. Toma Professional Corporation does not disclose your personal information to any third party to enable them to market their products or services. For example, we do not sell or provide our client mailing lists to suppliers or other clients. Under certain circumstances, D. Toma Professional Corporation will disclose your personal information; for example:

• If we engage a third party to provide services to us;
• Where it is necessary to establish or collect payment;
• If the information is already publicly known.

Whenever we disclose your personal information to third parties for the purpose of providing services to us, we require such parties to maintain levels of confidentiality and security that are equivalent to our own practices.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, D. Toma Professional Corporation will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

Data Transfers

All Personal Information collected via or by D. Toma Professional Corporation may be stored anywhere in the world, including but not limited to, Canada, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to D. Toma Professional Corporation, you consent to the storage of your Personal Information in these locations.

Opt-Out Procedures

YOU HAVE THE RIGHT TO OPT-OUT OF RECEIVING INFORMATION FROM D. TOMA PROFESSIONAL CORPORATION.

In accordance with the Canadian Anti-Spam Legislation, we must offer all email recipients the option to block future emails from D. Toma Professional Corporation. We provide that option in the footer of every email whether it is promotional in nature or related to the execution of engaged Services. Please note that if you decide not to provide us with the Personal Information that we request, or decide to opt-out of communications, we may not be able to provide you Services.

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to D. Toma Professional Corporation's storing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by contacting ​ or clicking on the Unsubscribe option in the footer of every email.

About this Document

This Privacy Policy spells out the responsibility of D. Toma Professional Corporation and your rights as a client or other individual regarding the collection, use and disclosure of your personal information.

This Privacy Policy is subject to any amendments which will be posted on D. Toma Professional Corporation's website and will also be available from D. Toma Professional Corporation's Privacy Officer.