Wingborn Ltd. is committed to protecting the personal information that we collect, use and disclose in the course of providing services to our clients in accordance with all applicable privacy legislation. This Privacy Policy sets out in general terms how we collect, use, disclose and protect the personal information of our clients, other individuals and our web site users (“you”).

Personal Information

Privacy legislation in Canada defines “personal information” broadly as any information about an identifiable individual. In general, personal information does not include business contact information, including your name, title or position, business or business e-mail address, telephone or facsimile number.

Accountability

Wingborn Ltd. is responsible under applicable privacy legislation for the personal information in our possession or control. This includes personal information we receive directly, such as from individual clients or other individuals, and personal information we receive indirectly from clients or others. We have established policies and procedures with the objective of protecting personal information and have appointed a Privacy Officer to oversee privacy matters for our firm. Our Privacy Officer can be reached at [email protected].

What Personal Information Do We Collect?

The types of personal information we may collect about you include your name and business contact information, billing and account information, and other information incidental to the provision of services by our firm. Examples of the types of personal information we may collect include information about directors, officers and employees of a client or other party and information about shareholders, security-holders, investors, potential investors or buyers, business partners, targets, individuals, clients, or other parties who are individuals.

Our Purposes for Collecting, Using or Disclosing Personal Information

General

Wingborn Ltd collects, uses and discloses personal information for the primary purpose of providing our clients with professional consulting services, including for the following purposes:
• to estabish and manage client relationships;
• to share personal information wqith third parties in the context of providing our clients with the best possible service related to the project that has been undertaken (i.e. product sourcing, project writing);
• to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, evaluate credit standing, and to fulfill contractual obligations;
• to contact and communicate with clients and other individuals for the purpose of conducting market research, and evaluating client service and satisfaction;
• to maintain, develop and manage our document management, knowledge-management and precedent systems and databases;
• to consider the admission of individuals as employees and members of the firm;
• to develp and manage our business and operations;
• to detect and protect against error, negligence, breach of contract, fraud, theft, and other illegal activity, and where necessary to meet our insurance requirements; and as permitted by, and to comply with, applicable legal or regulatory requirements or provisions.

Web site

Cookies

Cookies are small data files that are sent to your browser and stored on your computer’s hard-drive when you visit certain web sites in order to “track” your visit to the site. Wingborn Ltd. may, from time to time, collect non-personal information about you and your use of the site though the use of cookies. We do not match or correlate this information with any personal information that you submit on the web site. Some browsers can be set to reject all cookies; if you choose to modify your browser in this manner, all features of the web-site will remain available to you. We use cookies to analyze web-site usage. This information is used for no other purpose.

On-line Communications

In order to provide our web site users with information or requested services, visitors may voluntarily submit personal information to us for such purposes as subscribing to or downloading publications, participating in surveys or asking a question. We use the personal information you provide only for the purpose for which you have provided it. If a subscriber or visitor has subscribed or attended a seminar or other event in the past, we may combine the information with information submitted on the web site. We provide an on-going opportunity to unsubscribe or opt-out of contact by the firm by telephoning our privacy officer.

E-Mail Communications

We may send e-mail communications to clients, subscribers or other individuals in our contact database to advise of information relevant to our clients and to develop our business. Each e-mail includes an opt-out feature and instructions on how to un-subscribe if you do not wish to receive future e-mails from Wingborn Ltd. for these purposes.

Links

Our web site may present links to other web sites. You should be aware that operators of linked web sites may also collect your personal information and information generated through the use of cookies when you link to their web sites. Wingborn Ltd. is not responsible for how such third parties collect, use or disclose your personal information, so it is important to review their privacy policies before providing them with your personal information.

Service Providers

To the extent we enter into arrangements with service providers, agents and contractors to store, handle or process personal information on our behalf, such as for data processing, document storage software support and office services, our policy will be to require such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them.

Consent

We will obtain a client’s consent to the collection, use and disclosure of personal information about the client, and the consent of other individuals where required by applicable privacy legislation. We assume that an individual has consented to our reasonable collection and use of personal information consistent with the purposes for which the information was given, when the individual initiates contact with us or voluntarily provides personal information to us. We do not collect, use or disclose personal information without consent unless authorized or required by law to do so.

Limited Collection, Use and Disclosure and Retention

We collect personal information by fair and lawful means and, wherever appropriate, directly from the individual. Wherever possible, we limit the amount of personal information we collect, use or disclose to that necessary and appropriate to operate our business. We limit the personal information we collect and use for client relationship and development purposes to contact information and information about preferences provided by the individual. Our records are stored with safeguards against inappropriate or unauthorized access (see Safeguards).

Accuracy of Information

In order to provide clients or subscribers with a professional level of service and to maintain appropriate contact preferences, we may ask you to update your personal information, contact information or preferences from time to time, and we provide an ongoing opt-out opportunity by link or hard copy with notices. Clients are encouraged to contact their representative at Wingborn Ltd. to update the personal information we maintain in our client files.

Safeguards

We protect personal information in our files and document management systems from loss, misuse, unauthorized access and alteration by using physically secure facilities, password protection, standard security practices and tools and well-defined internal policies and practices.

Access to Your Personal Information

Individual clients may review any personal information concerning themselves we have on file in our offices by contacting their Wingborn Ltd. representative. Individuals who are not clients may request access to personal information we hold about them by written request to:

Privacy Officer
Wingborn Ltd.
3-350 174 St.
Surrey, BC V3Z 2N8

or

via our e-mail contact form.

We will provide access to such personal information, subject to exceptions stipulated or required by applicable privacy legislation. Examples of such exceptions include information protected by privilege; or information about another individual where disclosure would reveal confidential commercial information. If you are concerned about the access we have provided or wish to advise us of inaccuracies in the information, you may contact our Privacy Officer using our e-mail contact form.

Challenging Compliance with this Privacy Policy

Wingborn Ltd. will respond to complaints from individuals or questions about our compliance with this policy and with applicable privacy laws. We will investigate and attempt to resolve all complaints. To challenge our compliance with this policy please contact our Privacy Officer at the co-ordinates listed above.

If you have any questions or concerns about your privacy and our role in protecting it, please contact our Privacy Officer.
We reserve the right to change our Privacy Policy at any time by posting a new Privacy Policy on our web site.

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