PRIVACY POLICY

It is ONR’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 privacy policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This privacy policy has a limited scope and application. Consequently, the rights and obligations contained in this privacy policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this privacy policy applies to you, please contact our Privacy Compliance Officer for more information.

WHAT IS PERSONAL INFORMATION?

For the purposes of this privacy policy, personal information is any information about an identifiable individual, other than an individual’s business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

• contact and identification information, such as your name, address, telephone number and e-mail address;
• product and service related information concerning the products and services that we provide to you;
• personal information related to the services that you seek from us; and
• business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feedback and information requested by or provided to you.

 

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities.

ONR is a digital research firm focused on delivering results to empower business decisions: we seek to understand consumers. As such, our activities include, among other things, carrying out market surveys As such, ONR may also collect personal information from individuals participating in and / or impacted by these activities.

As a general rule, ONR collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

OUR WEBSITE

We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We may use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our other business purposes, such as: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our website. Your IP address may be used to ensure that we do not receive multiple survey responses from the same IP address.

In connection with the foregoing, we may place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs. It also allows us to optimize your survey experience. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.

In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by:

• applying for a position with ONR through our website; or
• by corresponding with a representative of ONR via e-mail using the hyperlinks created for that purpose.

Our website may contain links to other websites that may be subject to less stringent privacy standards. If you click on a link to such a third party website, a third party may also place a cookie on your hard drive. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. OnR is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Finally, we may use third party analytics tools to help us measure traffic and usage trends for our website. These tools may use cookies and other technologies to collect information about your use of our website, and collect information sent by your device or our website. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, better understand your online activity, and assists us in improving our website.

For example, we use Google’s Universal Analytics to better understand who is using our website and how people are using it. Google may use cookies, pixel tags and other technologies to collect and store information such as website pages visited, places where users click, time spent on each website page, IP address, type of operating system used, location-based data, device ID, search history, and phone number. We use this information to improve our website and as otherwise described in this privacy policy. Please see
http://www.google.com/policies/privacy/partners for information about how Google Analytics uses this information, visit 
https://tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on, and visit 
http://www.google.com/settings/ads to adjust the settings for your Google account.

WHY DO WE COLLECT PERSONAL INFORMATION?

OnR collects personal information to enable us to manage, maintain, and develop our operations, including for example:

• to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
• to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;
• to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
• to carry-out surveys for the purposes of better understanding you;
• to administer contests and award prizes in connection with same;
• to fulfil honorariums;
• to create Aggregated Information (as defined below) for the purposes of: (i) meeting our clients’ requests; and/or (ii) developing new or improving existing products and services;
• to be able to comply with your requests;
• to protect OnR against error, fraud, theft and damage to our goods and property;
• to enable us to comply with applicable laws or regulatory process; and
• any other reasonable purpose to which you consent.

We may share Aggregated Information with third parties for the purposes of managing, maintaining, and developing our operations. For the purpose of this privacy policy, “Aggregated Information” arises from the compilation, combination and/or analysis of information from multiple sources on an aggregated basis (so as to prevent identification of personal information relating to any one individual) in order to identify or create, for example, trends, benchmarks, reports, summary metrics, predictive algorithms, products and/or services.

HOW DO WE USE AND DISCLOSE YOUR PERSONAL INFORMATION?

We may use and disclose your personal information:

• as permitted or required by applicable laws or regulatory requirements;
• for the purposes described in this privacy policy; and
• for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

 

We may also use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including: (i) third parties that provide services to us; (ii) third parties that assist OnR in the provision of services to you; and (iii) third parties whose services we use to conduct our business.

For example, we may share your personal information from time to time with our third party information technology, data processing and payment processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.

In addition, personal information may be disclosed or transferred to another party during the course of the grant of a security interest in OnR’s assets, or completion of, all or a part of OnR through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this privacy policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of OnR’s regular reporting activities to its affiliates;
• to protect the rights and property of OnR;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent.

 

YOUR CONSENT IS IMPORTANT TO US

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this privacy policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

CHOICE / OPT-OUT

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Compliance Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Compliance Officer. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this privacy policy.

HOW IS YOUR PERSONAL INFORMATION PROTECTED?

OnR endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: for example, unauthorized access use, or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of your personal information at any time.

The security of your personal information is important to us, please advise our Privacy Compliance Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

UPDATING YOUR PERSONAL INFORMATION

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

ACCESS TO YOUR PERSONAL INFORMATION

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Compliance Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Compliance Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

INQUIRIES OR CONCERNS?

If you have any questions about this privacy policy or concerns about how we manage your personal information, please contact our Privacy Compliance Officer by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

PRIVACY COMPLIANCE OFFICER

We have appointed a Privacy Compliance Officer to oversee compliance with this privacy policy. The contact information for our Privacy Compliance Officer is as follows:

OnR
9120 Leslie Street, Suite 106
Richmond Hill, Ontario
L4B 3J9 Canada
Attention: Privacy Compliance Officer

E-mail: privacycompliance@onrcx.com

REVISIONS TO THIS PRIVACY POLICY

OnR from time to time, may make changes to this privacy policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this privacy policy on our website (at www.onrcx.com), and we encourage you to refer back to it on a regular basis.

This privacy policy was last updated on May 25, 2018.

INTERPRETATION OF THIS PRIVACY POLICY

Any interpretation associated with this privacy policy will be made by our Privacy Compliance Officer. This privacy policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.

This privacy policy does not create or confer upon any individual any rights, or impose upon OnR any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this privacy policy and Canada’s federal and provincial privacy laws, as applicable, this privacy policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

It is OnR’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 privacy policy covers only those activities that are subject to the provisions of US and Canada’s federal and provincial privacy laws, as applicable.

This privacy policy has a limited scope and application. Consequently, the rights and obligations contained in this privacy policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this privacy policy applies to you, please contact our Privacy Compliance Officer for more information.

WHAT IS PERSONAL INFORMATION?

For the purposes of this privacy policy, personal information is any information about an identifiable individual, other than an individual’s business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

• contact and identification information, such as your name, address, telephone number and e-mail address;
• product and service related information concerning the products and services that we provide to you;
• personal information related to the services that you seek from us; and
• business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feedback and information requested by or provided to you.

 

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities.

OnR is a digital research firm focused on delivering results to empower business decisions: we seek to understand consumers. As such, our activities include, among other things, carrying out market surveys As such, OnR may also collect personal information from individuals participating in and / or impacted by these activities.

As a general rule, OnR collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

OUR WEBSITE

We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We may use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our other business purposes, such as: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our website. Your IP address may be used to ensure that we do not receive multiple survey responses from the same IP address.

In connection with the foregoing, we may place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs. It also allows us to optimize your survey experience. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.

In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by:

• applying for a position with OnR through our website; or
• by corresponding with a representative of OnR via e-mail using the hyperlinks created for that purpose.

Our website may contain links to other websites that may be subject to less stringent privacy standards. If you click on a link to such a third party website, a third party may also place a cookie on your hard drive. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. OnR is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Finally, we may use third party analytics tools to help us measure traffic and usage trends for our website. These tools may use cookies and other technologies to collect information about your use of our website, and collect information sent by your device or our website. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, better understand your online activity, and assists us in improving our website.

For example, we use Google’s Universal Analytics to better understand who is using our website and how people are using it. Google may use cookies, pixel tags and other technologies to collect and store information such as website pages visited, places where users click, time spent on each website page, IP address, type of operating system used, location-based data, device ID, search history, and phone number. We use this information to improve our website and as otherwise described in this privacy policy. Please see http://www.google.com/policies/privacy/partners for information about how Google Analytics uses this information, visit https://tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on, and visit http://www.google.com/settings/ads to adjust the settings for your Google account.

WHY DO WE COLLECT PERSONAL INFORMATION?

OnR collects personal information to enable us to manage, maintain, and develop our operations, including for example:

• to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
• to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;
• to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
• to carry-out surveys for the purposes of better understanding you;
• to administer contests and award prizes in connection with same;
• to fulfil honorariums;
• to create Aggregated Information (as defined below) for the purposes of: (i) meeting our clients’ requests; and/or (ii) developing new or improving existing products and services;
• to be able to comply with your requests;
• to protect OnR against error, fraud, theft and damage to our goods and property;
• to enable us to comply with applicable laws or regulatory process; and
• any other reasonable purpose to which you consent.

We may share Aggregated Information with third parties for the purposes of managing, maintaining, and developing our operations. For the purpose of this privacy policy, “Aggregated Information” arises from the compilation, combination and/or analysis of information from multiple sources on an aggregated basis (so as to prevent identification of personal information relating to any one individual) in order to identify or create, for example, trends, benchmarks, reports, summary metrics, predictive algorithms, products and/or services.

HOW DO WE USE AND DISCLOSE YOUR PERSONAL INFORMATION?

We may use and disclose your personal information:

• as permitted or required by applicable laws or regulatory requirements;
• for the purposes described in this privacy policy; and
• for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

 

We may also use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including: (i) third parties that provide services to us; (ii) third parties that assist OnR in the provision of services to you; and (iii) third parties whose services we use to conduct our business.

For example, we may share your personal information from time to time with our third party information technology, data processing and payment processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.

In addition, personal information may be disclosed or transferred to another party during the course of the grant of a security interest in OnR’s assets, or completion of, all or a part of OnR through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this privacy policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of OnR’s regular reporting activities to its affiliates;
• to protect the rights and property of OnR;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent.

 

YOUR CONSENT IS IMPORTANT TO US

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this privacy policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

CHOICE / OPT-OUT

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Compliance Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Compliance Officer. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this privacy policy.

HOW IS YOUR PERSONAL INFORMATION PROTECTED?

OnR endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: for example, unauthorized access use, or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of your personal information at any time.

The security of your personal information is important to us, please advise our Privacy Compliance Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

UPDATING YOUR PERSONAL INFORMATION

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

ACCESS TO YOUR PERSONAL INFORMATION

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Compliance Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Compliance Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

INQUIRIES OR CONCERNS?

If you have any questions about this privacy policy or concerns about how we manage your personal information, please contact our Privacy Compliance Officer by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

PRIVACY COMPLIANCE OFFICER

We have appointed a Privacy Compliance Officer to oversee compliance with this privacy policy. The contact information for our Privacy Compliance Officer is as follows:

OnR
9120 Leslie Street, Suite 106
Richmond Hill, Ontario
L4B 3J9 Canada
Attention: Privacy Compliance Officer

E-mail: privacycompliance@onrcx.com

REVISIONS TO THIS PRIVACY POLICY

OnR from time to time, may make changes to this privacy policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this privacy policy on our website (at www.onrcx.com), and we encourage you to refer back to it on a regular basis.

This privacy policy was last updated on May 25, 2018.

INTERPRETATION OF THIS PRIVACY POLICY

Any interpretation associated with this privacy policy will be made by our Privacy Compliance Officer. This privacy policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.

This privacy policy does not create or confer upon any individual any rights, or impose upon OnR any rights or obligations outside of, or in addition to, any rights or obligations imposed by US and Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this privacy policy and US and Canada’s federal and provincial privacy laws, as applicable, this privacy policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

It is OnR’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 privacy policy covers only those activities that are subject to the provisions of European privacy laws.

This privacy policy has a limited scope and application. Consequently, the rights and obligations contained in this privacy policy may not be available to all individuals or in all jurisdictions.

This privacy policy sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this privacy policy carefully. When using our website, this privacy policy should be read alongside the website terms and conditions.

ABOUT ONR

In this privacy policy references to “we” or “us” or “OnR” refer to OnResearch Inc., a company incorporated in Canada.

In order to provide our services, we will collect and use information about individuals. This will sometimes involve individuals based in Europe. We are the controller of all personal information we process pursuant to the products and services we provide and we are responsible for complying with data protection laws.

We have appointed a Privacy Compliance Officer to oversee compliance with this privacy policy. If you have any questions about how we collect, store or use your personal information, you may contact our Privacy Compliance Officer using the details set out in the “Contact us” section.

What Is Personal Information?

Personal information means any information relating to an identified or identifiable natural person.

OUR PROCESSING OF YOUR PERSONAL INFORMATION

We collect varying information about you and use it for different reasons according to the relationship we have with you. For example, we will collect different personal information depending on whether you are a business contact at one of our clients or where you are a respondent to a survey.

Where you provide personal information to us about other individuals (for example, information about your household composition) we will also be controller of and responsible for their personal information. You should refer them to this notice before providing personal information to us on behalf of others.

Our legal grounds

We may process your information for a number of different purposes. For each purpose we must have a “legal ground” for this processing.

Personal information

 

We will rely on the following legal grounds when we process your personal information:
Appropriate business need	We have an appropriate business need to use your personal information for example because it is necessary for our everyday business operations and activities, to facilitate the provision of market research services to our clients, to maintain management information or to monitor usage of the OnR website. When using your personal information for these purposes, we will always consider your rights and interests in privacy and whether they outweigh our interests in using your personal information for these purposes. We have implemented a procedure to assist us with this assessment.
Legal or regulatory obligation	We have a legal or regulatory obligation to use such personal information. For example our regulators require us to hold certain records of our dealing with you.

 

Sensitive personal information

When purpose involves the processing of information that is classed as “sensitive personal information”, (this includes information to health and criminal convictions) we must have an additional “legal ground”.

 

We will rely on the following legal grounds when we process your sensitive personal information:
Consent	You have provided your explicit consent to our use of your sensitive personal information. In some circumstances, we may need your consent to process sensitive personal information. For example where we are conducting research on personal health topics.

 

Nature of our relationship with you

In order to make this notice as user friendly as possible we have split it into different sections which detail the information about the types of personal information we are likely to collect and use about you in different circumstances. Please read below to see details of these different types of relationship that best describes your relationship with us.

Our relationship with you

Where you are a participant in our market research

This section will apply if you respond to one of our surveys or otherwise participate in our market research.

Where you are a participant in our market research

In most cases where you participate in market research with or through OnR, your responses will be held by OnR against a unique identification number rather than your name or other identifying details. As such in most cases, although OnR may collect personal information, OnR will not usually be able to connect this information to a named individual.

In those cases where the nature of the market research means you are identifiable (e.g. because there is a prize draw for entry), the personal information we collect will be limited to:

• Contact and identification information, such as your name, address, telephone number and e-mail address.
• Personal information you provide in your responses to our market research (e.g. if you write in personal information in response to an open ended question).

 

However, any information required to link you to your survey responses will be deleted once any prize has been administered, and the responses will then just be retained against a unique identification number.

Where you start a survey but do not complete or submit it, any information you have provided will be automatically deleted.

Where you participate in market research through our website you should also see the “Our website” section.

How will we collect your personal information?

As a general rule, OnR collects personal information directly from you but in some circumstances the personal information that we collect about you is held by and received from a third party.

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. (e.g. our panel providers). Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

What will we use your personal information for?

 

Purpose for processing	Legal grounds for using your personal information	Legal grounds for using your sensitive personal information
To carry-out surveys for the purposes of better understanding you.	Appropriate business need (to provide market research services to our clients)
To administer contests and award prizes in connection with same.	Appropriate business need (to provide market research services to our clients)
To fulfil honorariums.	Appropriate business need (to provide market research services to our clients)
To create Aggregated Information for the purposes of: (i) meeting our clients’ requests; and/or (ii) developing new or improving existing products and services.	Appropriate business need (to provide market research services to our clients)	Consent
To be able to comply with your requests.	Appropriate business need (to manage requests that come into the business)
To protect OnR against error, fraud, theft and damage to our goods and property.	Appropriate business need (to protect against error, fraud, theft and damage to goods and property).
To enable us to comply with applicable laws or regulatory process.	Legal or regulatory obligation.

 

Aggregated Information

In most cases we will not share raw response data with our clients. However we will share Aggregated Information with third parties for the purposes of providing market research services and managing, maintaining, and developing our operations. For the purpose of this privacy policy, “Aggregated Information” arises from the compilation, combination and/or analysis of information from multiple sources on an aggregated basis (so as to prevent identification of personal information relating to any one individual) in order to identify or create, for example, trends, benchmarks, reports, summary metrics, predictive algorithms, products and/or services.

Where we do share raw response data this data is shared in an anonymised form.

In addition, personal information may be disclosed or transferred to another party during the course of the grant of a security interest in OnR’s assets, or completion of, all or a part of OnR through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this privacy policy, unless you consent otherwise.

Where you are a business contact at one of our clients

This section will apply if you are a broker doing business with us, an appointed representative or other business partner such as an introducer or supplier.

What personal information will we collect?

 

• Contact and identification information, such as your name, address, telephone number and e-mail address.
• Product and service related information concerning the products and services that we provide to you.
• Personal information related to the services that you seek from us.
• Business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feedback and information requested by or provided to you.
• We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities.

 

How will we collect your personal information?

As a general rule, OnR collects personal information directly from you but in some circumstances the personal information that we collect about you is held by and received from a third party.

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

What will we use your personal information for?

Purpose for processing	Legal grounds for using your personal information	Legal grounds for using your sensitive personal information
To establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested.	Appropriate business need (to use your details to provide market research services).	No sensitive personal information processed.
To be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services.	Appropriate business need (to use your details to provide market research services).	No sensitive personal information processed.
To be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services.	Appropriate business need (to use your details to procure services for our business).	No sensitive personal information processed.
To be able to comply with your requests.	Appropriate business need (to manage requests that come into the business).	No sensitive personal information processed.
To protect OnR against error, fraud, theft and damage to our goods and property.	Appropriate business need (to protect against error, fraud, theft and damage to goods and property).	No sensitive personal information processed.
To enable us to comply with applicable laws or regulatory process.	Legal or regulatory obligation.	No sensitive personal information processed.

Who will we share your personal information with?

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including: (i) third parties that provide services to us; (ii) third parties that assist OnR in the provision of services to you; and (iii) third parties whose services we use to conduct our business.

In addition, personal information may be disclosed or transferred to another party during the course of the grant of a security interest in OnR’s assets, or completion of, all or a part of OnR through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this privacy policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of OnR’s regular reporting activities to its affiliates;
• to protect the rights and property of OnR;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent.

 

Where you are a user of the OnR website

If you use our website, this section will be relevant to you and sets out our uses of your personal information.

What personal information will we collect?

 

• General information submitted via the website, for example where you provide your details in the contact section such as your name, contact details and company name.
• Information such as IP address and browsing history obtained through our use of cookies. You can find more information about our use of cookies in the “Our website” section.

 

How will we collect your personal information?

We will collect your information directly from our website.

What will we use your personal information for?

 

Purpose for processing	Legal grounds for using your personal information	Legal grounds for using your sensitive personal information
To respond to any enquiries you have submitted.	Appropriate business need (to respond to your enquires).	No sensitive personal information processed.
To monitor the use of and improve our website (as set out in more detail in the “Our website” section).	Appropriate business need (to monitor and improve our website).	No sensitive personal information processed.
To protect OnR against error, fraud, theft and damage to our goods and property.	Appropriate business need (to protect against error, fraud, theft and damage to goods and property).	No sensitive personal information processed.
To enable us to comply with applicable laws or regulatory process.	Legal or regulatory obligation.	No sensitive personal information processed.

 

Who will we share your personal information with?

From time to time, we may share your personal information with:

• Third party service providers that we engage to undertake or assist with analytics activities.

 

OVERSEAS TRANSFERS

Information collected and processed by OnR is stored on our servers based in Toronto, Canada. Therefore, where you are based within the EEA and you deal with use as a client or you participate in our market research or access our website your personal information will be transmitted to Canada.

In addition, we may share your personal information from time to time with our third party information technology, data processing and payment processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.

WHAT MARKETING ACTIVITIES DO WE CARRY OUT?

Where you are a business contact at one of our clients we may use your personal information to provide you with details of our services which may be of interest to you.

We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to opt out of marketing, you may do so by clicking on the “unsubscribe” link that appears in an email or responding to the email with the subject “unsubscribe” (we will confirm in each email how to unsubscribe) or telling us when we call you. Otherwise you can always contact us using the details set out in “Contact us” section to update your contact preferences.

Please note that, even if you opt out of receiving marketing messages, we will still send you service related communications where necessary.

HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

We will only keep your personal information for the minimum periods required in order to fulfil the relevant purposes set out in this privacy policy. We are also required to keep certain information in order to comply with our legal and regulatory obligations.

The exact time period will depend on your relationship with us and the type of personal information we hold. Our headline retention periods are:

 

Datatype	Retention period
Raw response data	7 years
Aggregate response data	7 years
Business contact records	7 years

 

These are subject to some exceptions where we have a legal requirement or compelling business reason to keep them for longer.

AUTOMATED PROCESSING

We do not currently undertake any automated decision making. We will let you know if this position changes.

YOUR RIGHTS

Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in the “Contact us” section.

Please note in some cases we may not be able to comply with your request (for example, where there is a conflict with our own obligations to comply with other legal or regulatory requirements). However, we will always respond to any request you make and if we can’t comply with your request, we will tell you why.

 

Your rights include:
The right to access your personal information	You are entitled to a copy of the personal information we hold about you and certain details of how we use it. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. Your information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible. Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
The right to rectification	It is important that the information contained in our records is both accurate and current and we take reasonable steps to ensure that the information we hold about you is accurate and complete. However if your personal information happens to change during the course of our relationship or you think the information we hold about you is inaccurate or out of date, you can ask us to update it.
The right to erasure	In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or where you withdraw your consent. However this will need to be balanced against other factors. For example, we may have legal and regulatory obligations which mean we cannot comply with your request.
The right to restriction of processing	In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.
The right to data portability	In certain circumstances, you have the right to ask that we transfer personal information that you have provided to us to another third party of your choice.
The right to data object	Where we rely on an appropriate business need to process your personal information you have the right to request that we stop processing your information for a particular purpose unless we can demonstrate there is a compelling business need or if it is necessary in connection with a legal claim.
The right to object to marketing	You can ask us to stop sending you marketing messages at any time. You can do this either by clicking on the “unsubscribe” button in any email that we send to you or you can contact us using the details set out in “Contact us” section Please note that even if you opt out of receiving marketing messages, we may still send you service related communications where necessary.
Rights relating to automated decision-making	Should we start doing so you would have the right to request human intervention in any decision.
The right to withdraw consent	For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.
The right to lodge a complaint with the ICO	You have a right to complain to the data protection supervisory authority in your jurisdiction, if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations. Making a complaint will not affect any other legal rights or remedies that you have.

 

HOW WE PROTECT YOUR INFORMATION

OnR endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: for example, (i) unauthorised access, use or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of your personal information at any time.

The security of your personal information is important to us, please advise our Privacy Compliance Officer immediately of any incident involving the loss of or unauthorised access to or disclosure of personal information that is in our custody or control.

OUR WEBSITE

We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We may use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our other business purposes, such as: (i) customising certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our website. Your IP address may be used to ensure that we do not receive multiple survey responses from the same IP address.

Cookies

In connection with the foregoing, we may place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie also allows us to track your visit to the website so that we can better understand your use of our website so that we can customise and tailor the website to better meet your needs. It also allows us to optimise your survey experience. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.

In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by:

• Applying for a position with OnR through our website;
• By corresponding with a representative of OnR via e-mail using the hyperlinks created for that purpose.

Our website may contain links to other websites that may be subject to less stringent privacy standards. If you click on a link to such a third party website, a third party may also place a cookie on your hard drive. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. OnR is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Third party analytics

Finally, we may use third party analytics tools to help us measure traffic and usage trends for our website. These tools may use cookies and other technologies to collect information about your use of our website, and collect information sent by your device or our website. This information may be used to, among other things, analyse and track data, determine the popularity of certain content, better understand your online activity, and assists us in improving our website. For example, we use Google’s Universal Analytics to better understand who is using our website and how people are using it. Google may use cookies, nixel tabs and other technologies to collect and store information such as website pages visited, places where users click, time spent on each website page, IP address, type of operating system used, location-based data, device ID, search history, and phone number. We use this information to improve our website and as otherwise described in this privacy policy. Please see:

http://www.google.com/policies/privacy/partners for information about how Google Analytics uses this information, visit:
https://tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on, and visit:
http://www.google.com/settings/ads to adjust the settings for your Google account.

CONTACT US

If you have any questions about this privacy policy or concerns about how we manage your personal information, please contact our Privacy Compliance Officer by telephone, in writing or by email. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you are entitled to make a complaint to the data protection supervisory authority in your jurisdiction (as set out in the “Your rights” section).

The contact information for our Privacy Compliance Officer is as follows:

OnR
9120 Leslie Street, Suite 106
Richmond Hill, Ontario
L4B 3J9 Canada
Attention: Privacy Compliance Officer

E-mail: privacycompliance@onrcx.com

REVISIONS TO THIS PRIVACY POLICY

OnR from time to time, may make changes to this privacy policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this privacy policy on our website (at www.onrcx.com), and we encourage you to refer back to it on a regular basis.

This privacy policy was last updated on May 25, 2018.