Last Updated: November , 2021
Our Commitment to Privacy
Withe will never disclose, sell or lease to any third party any Personal Information that you provide to us, including through this website (the “Site”), without your permission, other than as described in this Policy, or unless we are required to do so by law. Notwithstanding this, this Site is hosted and administered by a third party. Accordingly, the Personal Information provided through this Site will be available to that third party for the limited purposes of hosting and administering this Site.
By providing us with your Personal Information and using our Site, you accept this Policy and consent to its terms, as well as any other terms that are described to you when your Personal Information is collected. If you do not consent, please do not use the Site or otherwise provide your Personal Information to us.
It is Withe’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.
We may modify, revise or update this Policy at any time by updating this posting. Each time you use the Site, the version of this Policy then posted will apply to that use, so you should check this page each time you use the Site.
What is Personal Information?
“Personal Information” is information about an identifiable individual. Personal Information includes but is not limited to your name, residential address, telephone number, fax number and e-mail address.
What Personal Information Do We Collect?
We may collect the following types of Personal Information about you:
- Your contact information (such as your name, the organization you are affiliated with, your residential address, telephone number, fax number and email address); and
- Your comments and questions.
Personal Information is collected by us when you provide it to us, such as when you provide us with your contact information or send us a question or comment through the Site, when you meet with us in person, or when you phone us with an inquiry.
We also collect other non-identifiable information that is recorded by the standard operation of our Internet servers on an anonymous basis, such as the operating system you are using, the sections of the Site you visit, and the Site pages read and images viewed.
This information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Site and system administration purposes; (ii) to improve the Site; (iii) to conduct internal reviews of the number of visitors to the Site; (iv) to help us better understand visitors’ use of our Site; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary.
When you view the Site, we may place a “cookie” on the hard drive of your computer which allows the Site to remember who you are. Cookies provide additional functionality to websites to better match users’ interests and preferences. With most Internet browsers, you can erase cookies from your computer hard drive, block the creation of cookies, or receive a warning before a cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.
Our Site may use web beacons. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, web beacons will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
For What Purposes Do We Collect Personal Information?
We collect and use Personal Information primarily for the purposes of:
- responding to your communications and inquiries;
- meeting legal, regulatory, audit, security, and financial requirements under federal and provincial laws;
- sending you press releases, marketing materials or information about scheduled events for which we have your consent to receive; and
- providing investors with information that they have requested about Withe.
We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information.
We will notify the individual from whom the information is collected of the purposes for which we are collecting the information. This notice will be provided at or before the time that we collect the Personal Information. Depending on the way in which Personal Information is collected, this may be done orally or in writing.
When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will communicate the new purpose prior to using the information for the new purpose, unless the new purpose is required or permitted by law.
Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.
Retention and Disposal of Personal Information
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education.
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.
Processing of Personal Information
Your Personal Information may be stored on servers located outside of Canada and as a result may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction.
Links to Other Websites
Our Site may provide links or references to websites operated by third parties. These third party websites are not governed by this Policy but by other privacy policies that may differ from our Policy. This Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies or actions of third parties. In visiting any third party websites, whether linked to this Site or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party website or any content in such website. We encourage you to review the privacy policies of each website visited before using those websites or disclosing any Personal Information to third parties.
Correcting Your Personal Information
We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information.
Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed.
Access to Personal Information
If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information.
You may contact our Privacy Officer at the contact information below to request access to Personal Information that we have about you. We will respond to requests within 30 days.
Questions and Further Information
We are accountable for all Personal Information in our custody and control and have designated a Privacy Officer, who is ultimately accountable for the handling of all Personal Information in our custody and/or control and for ensuring that the principles described in this Policy are being complied with.
We make information about our privacy policies and practices readily available. If you have any concerns, complaints, or if you would like further information regarding our privacy policies or practices, please contact our Privacy Officer at: firstname.lastname@example.org