PRIVACY CODE

Earning your trust.

We believe that an important part of respecting privacy is to be clear about how we handle customers' personal information, and to make information about our approach easily accessible.

We have developed our Privacy Code which sets out the general principles that govern the collection, use and disclosure of our customers' personal information.

Privacy Code

At The Gold Continent, we have a long-standing policy of protecting the privacy of customers and team members in all of our business operations. The Gold Continent Privacy Code is a formal statement of the principles and guidelines that govern how The Gold Continent protects personal information of its customers (subject to the exclusions noted here and below under scope) and team members. It is based on and incorporates the ten fair information principles. Read legal footnote 1 that form the basis of all applicable privacy legislation in Canada, including Part 1 of the Personal Information Protection and Electronic Documents Act (Statutes of Canada 2000).

The Gold Continent Privacy Code was originally published in 2020: we regularly review it to ensure that it reflects legislative and technological changes and that it continues to reflect our practices and commitments.

Privacy Code: 10 Guiding Principles

Principle 1 – Accountability.


The Gold Continent is responsible for personal information under its control and shall designate one or more persons who are accountable for The Gold Continent's compliance with the following principles. 1.1 Responsibility for ensuring compliance with the provisions of the The Gold Continent Privacy Code rests with the senior management of The Gold Continent, which shall designate one or more persons to be accountable for compliance with the Code. Other individuals within The Gold Continent may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information. 1.2 The Gold Continent shall make known, upon request, the identity of the person or persons designated to oversee The Gold Continent' compliance with the The Gold Continent Privacy Code. 1.3 The Gold Continent is responsible for personal information in its possession or control. The Gold Continent shall use appropriate means to provide a comparable level of protection while information is being processed by a service provider or partner (see Principle 7). 1.4 The Gold Continent shall implement policies and procedures to give effect to the The Gold Continent Privacy Code, including: - Implementing procedures to protect personal information and to oversee The Gold Continent's compliance with the The Gold Continent Privacy Code; - Establishing procedures to receive and respond to inquiries or complaints; - Training and communicating to team members about The Gold Continent's policies and practices; - Developing public information to explain The Gold Continent' policies and practices.




Principle 2 – Identifying purposes for collection of personal information.


The Gold Continent shall identify the purposes for which personal information is collected at or before the time the information is collected. The Gold Continent collects certain information about our subscribers that form the basis for the records that can be used to formlaize assets or used immediately with corporate enterprises to conduct certain transactions. We collect personal information and that which is related to your Property or Business to create records of those assets.
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Principle 3 – Obtaining consent for collection, use or disclosure of personal information.


The knowledge and consent of a customer or team member are required for the collection, use, or disclosure of personal information, except where not required by applicable privacy legislation. The Code does not require consent for the collection, use or disclosure of information about a customer or team member that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act or provincial privacy legislation, where applicable. 3.1 In obtaining consent, The Gold Continent shall use reasonable efforts to ensure that a customer or team member is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated so that it is reasonable to expect that the customer or team member would understand the nature, purpose and consequences of granting consent. 3.2 Generally, The Gold Continent shall seek consent to use and disclose personal information at the same time it collects the information. However, The Gold Continent may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose. 3.3 The Gold Continent will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service if such collection, use or disclosure is required to fulfill the identified purposes. 3.4 In determining the appropriate form of consent, The Gold Continent shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and team members. 3.5 In general, the use of products and services by a customer, or the acceptance of employment or benefits by a team member, constitutes implied consent for The Gold Continent to collect, use and disclose personal information for all identified purposes. 3.6 A customer or team member may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and team members may contact The Gold Continent for more information regarding the implications of withdrawing consent.




Principle 4 – Limiting collection of personal information.


The Gold Continent shall limit the collection of personal information to that which is necessary for the purposes identified by The Gold Continent. The Gold Continent shall collect personal information by fair and lawful means. 4.1 The Gold Continent collects personal information primarily from its customers or team members. 4.2 The Gold Continent may also collect personal information from other sources including credit bureaus, employers or personal references, publicly available sources or other third parties who properly represent that they have the right to disclose the information.




Principle 5 – Limiting use, disclosure, and retention of personal information.


The Gold Continent shall not use or disclose personal information for purposes other than for identified purposes, except with the consent of the individual, for exceptions set out in legislation, or as required by law. The Gold Continent shall retain personal information only as long as reasonably necessary for the fulfillment of those purposes.




Principle 6 – Accuracy of personal information.


Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. 6.1 Personal information used by The Gold Continent shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or team member. 6.2 The Gold Continent shall update personal information about customers and team members as and when reasonably necessary to fulfill the identified purposes or upon notification by the individual.




Principle 7 – Security safeguards.


The Gold Continent shall protect personal information by security safeguards appropriate to the sensitivity of the information. 7.1 The Gold Continent shall employ appropriate security measures to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. 7.2 The Gold Continent shall protect personal information shared with service providers and partners by a variety of means, including by contractual agreements stipulating the confidentiality, privacy and security of the information and the purposes for which it is to be used. 7.3 All of The Gold Continent's team members with access to personal information shall be required to appropriately respect the confidentiality and privacy of that information. 7.4 The Gold Continent will store and process personal information in Canada or other countries. In either case, the personal information is protected with appropriate security safeguards, but may be available to foreign government agencies under applicable law.




Principle 8 – Openness concerning policies and practices.


The Gold Continent shall make readily available to customers and team members specific information about its policies and practices relating to the management of personal information. 8.1 The Gold Continent shall make information about its policies and practices easy to understand, including: - The title and address of the person or persons accountable for The Gold Continent's compliance with the The Gold Continent Privacy Code and to whom inquiries or complaints can be forwarded; - The means of gaining access to one's own personal information held by The Gold Continent; - A description of the type of personal information held by The Gold Continent, including a general account of its use. 8.2 The Gold Continent shall make available information to help customers and team members exercise choices regarding the use of their personal information and the privacy-enhancing services available from The Gold Continent.




Principle 9 – Customer and team member access to personal information.


The Gold Continent shall inform a customer or team member of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer or team member shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.




Principle 10 – Challenging compliance.


A customer or team member shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for The Gold Continent's compliance with the The Gold Continent Privacy Code. 10.1 The Gold Continent shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and team members about The Gold Continent's handling of personal information. 10.2 The Gold Continent shall inform its customers and team members about the existence of these procedures as well as the availability of complaint procedures. 10.3 The Gold Continent shall investigate all complaints concerning compliance with the The Gold Continent Privacy Code. If a complaint is found to be justified, The Gold Continent shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or team member shall be informed of the outcome of the investigation regarding his or her complaint.