Privacy Statement

ORION is committed to preserving your privacy and maintaining the accuracy, integrity, confidentiality and availability of your Personal Information. This Privacy Policy sets out the policies and procedures regarding ORION’s collection, use, retention and disclosure of Personal Information.

Scope of Policy

This Privacy Policy applies to Personal Information we collect, use, retain and/or disclose in the course of commercial activities. As used in this policy, “Personal Information” means information about an individual who is identifiable by us through use of that information alone or in conjunction with other information that is available to us. In this Privacy Policy, “Personal Information” does not include information that is exempted under applicable privacy legislation, such as certain business contact information and certain publicly available information. In addition, this Privacy Policy does not apply to information about our employees, officers and directors and our related practices, which are covered by internal ORION human resources policies.C

Collection of Personal Information

We collect Personal Information in order to provide use of information technology and telecommunications infrastructure and services to our constituents, to administer our constituent accounts and contracts, to establish and manage constituent relationships and other commercial relationships, and to comply with regulatory and legal requirements. As well, we collect Personal Information to provide our constituents with information related to developments in technology, security and administration through training, seminars, white papers, and information circulars.

When you retain ORION’s services, register with us to receive content or attend an event, communicate with us through any means such as by email or through any of our websites, you are giving us information that we collect. That information may include Personal Information such as your IP address, name, physical address, email address, phone number, and other details including demographic information.

By giving us this information, you consent to your information being collected, used, disclosed, and stored by us, only as described in this Privacy Policy.

If reasonably possible and appropriate, we will collect your information directly from you or from third parties acting on your behalf, such as your employer, where the requisite consent to do so has been obtained or as otherwise permitted by law. From time to time you may provide us with the Personal Information of individuals other than yourself. You agree to obtain, prior to disclosing such information to us, the consent of such individuals to the disclosure, and subsequent use by us, of such Personal Information, in accordance with this Privacy Policy, unless otherwise permitted by law.

How We Collect Your Personal Information

We collect your Personal Information only by lawful means and only with your consent or as required or permitted by law. Whenever reasonably possible and appropriate, we collect your Personal Information from you directly or from persons whom you have requested to provide us with information.

How We Use Your Information

We may use your Personal Information for the following purposes:

  • to provide services to you, your employer or your organization
  • to negotiate and arrange to provide services to you;
  • to develop our services;
  • to inform you of services and information we think you may be interested in procuring;
  • to manage our business, including fulfilling contractual obligations and auditing our operations;
  • to provide information to representatives and advisors to help us comply with legal, accounting, regulatory or security requirements;
  • to evaluate constituent satisfaction;
  • for security and emergency purposes; and
  • as otherwise permitted by law.

Disclosure of Your Personal Information

We will only disclose your Personal Information for purposes related to our provision of services to you, your employer or your organization, or with your express consent, or if required or authorized by law. For example, we may disclose your information:

  • when disclosure to third parties assists us in providing you the services that you have requested;
  • when necessary to collect outstanding accounts or to assess eligibility for credit; or
  • when necessary to comply with laws or regulations.

Information from Your Use of this Website

We may collect internet log information about how and when you use our websites. This information may include, without limitation, your IP address and location data, weblogs, time, date, browser used, referring web addresses, other communication data, searches conducted and pages visited.

To ensure that our websites are optimized for ease of use, we or our service provider(s) may use cookies to collect information about your language preferences, when you visit the site, your browser type and version, and other similar information. These cookies are intended to optimize your experience as a user of the website.

Cookies are files that store information on your hard drive or browser. They are used to collect information about how visitors use the website. They collect information in an anonymous form, including where visitors come to the website from and the pages they visit.

We may use cookies to track the pages that you visit on our website and your related preferences. We use the information to compile reports and to help us improve our websites.

If you do not want cookies sent to or stored on your system, most Internet browsers will allow you to delete or block cookies from your computer hard drive, prevent them from being stored or signal a warning before a cookie is stored. You should refer to your browser instructions or help screen to learn more about these functions. However, please note that if you use your browser settings to delete or block cookies you may not be able to access all or parts of our websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our website. If you continue to use the website, you agree to our use of cookies.

Consent

We may obtain your consent to our collection, use and disclosure of your Personal Information either expressly, for stated purposes, or impliedly when the purposes are indicated by the relevant circumstances or follow logically from other stated purposes. By providing us with Personal Information, you consent to the collection, use and disclosure of information relating to providing our services, managing our relationship with you, administering our business and as permitted or required by law, in accordance with this Privacy Policy.

We will seek your consent before using Personal Information for any purpose beyond the scope of your original consent. You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice.

For example, if you no longer wish to receive promotional information from us about our services, including by email, please click the “unsubscribe” link, if available in an email from us, email your request to unsubscribe@orion.on.ca, or contact us in any of the ways listed below under “Questions or Concerns”.

Accuracy of Your Information

We use reasonable efforts to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. In order to help us maintain and ensure that your Personal Information is accurate and up to date, you must inform us, without delay, of any change in the information you provided to us.

Security of Your Personal Information

We take not less than reasonable steps to protect your Personal Information from loss, unauthorized access, modification or disclosure. In addition, we implement physical and technological safeguards including locks, security software, passwords and firewalls to prevent unauthorized access.

The transmission of information via the internet is not completely secure. Although we will use not less than reasonable efforts to protect your Personal Information, we cannot guarantee the security of your Personal Information that is transmitted to or from us or our website; any transmission is at your own risk.

Information Transferred to Service Providers

When we transfer your Personal Information to a third party to provide administrative and other services, we use appropriate measures to ensure that the third party will only use your Personal Information to perform the services we have specified and handle your Personal Information in accordance with standards no less stringent than those set out in this Privacy Policy and the Canadian laws applicable to us.

We may use third party service providers located outside of Canada, specifically in the United State of America. As such, any Personal Information you provide to us may be stored and processed on computers operated by service providers outside of Canada and may be accessible by law enforcement authorities and others in such foreign jurisdiction pursuant to its laws. By providing any type of Personal Information to us, you acknowledge and agree that this information may be stored or used outside of Canada as described in this paragraph.

ORION may bring Personal Information of EU residents to Canada in accordance with this Privacy Policy relying on the EU’s Decision 2002/2/EC. If we transfer any such Personal Information to a third-party processor located in the United States, we will obtain their assurances that they are subject to the EU-US Privacy Shield or the equivalent.

For EU Residents

While we do not currently target our services to constituents outside of Canada, we may collect some personal information about residents of the European Economic Area (“EEA”). For the benefit of such individuals, we handle their personal data in accordance with applicable EU data protection laws and regulations, including the EU GDPR. Subject to certain exemptions set out in the GDPR, as an EU resident you have the following rights in relation to the Personal Information we hold about you:

  • The right to access and inspect your personal information or to be provided with a permanent copy of the information being held about you;
  • The right to request the correction of any inaccuracies in your personal information or where the accuracy of information is disputed, to add additional information or to give notice that you dispute the accuracy of the information content;
  • The right to request the erasure of your personal information, particularly where the continued processing of the information is no longer necessary;
  • The right to object to the processing of your personal information, particularly where there are no longer sufficient legitimate grounds for us to continue processing the information;
  • The right to restrict processing, data portability and the right to appeal any automated decision making or profiling; and
  • The right to complain to a data protection regulator about our processing of your personal information.

It is important to note that the rights set out above are not unconditional and the specific circumstances of the processing being undertaken by us will determine if these rights may be exercised. Further information concerning these rights and their application can be obtained by residents of the EEA by contacting us at the address provided below.

If you are a resident of the EEA, our legal basis for collecting and using the personal information described in this privacy policy will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you where the processing is in our legitimate commercial interests which are not overridden by your protection interests or fundamental rights and freedoms. Typically, our legitimate interests include: providing our services, facilitating our security safeguards, administering our business and defending legal claims.

If you use our services, we may need your personal information to perform a contract with you. In some limited cases, we may be under a legal obligation to collect, use or disclose your personal information, such as disclosure required by court order.

Where we rely specifically on express consent to collect and process your personal information, you are not obliged to provide your consent and you may subsequently withdraw your consent once it has been provided. It should be noted however that this may limit your experience with our resources and services.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the address provided below.

Social Media Features

Our website may include social media features, such as LinkedIn, the Facebook Like button and widgets, such as the “Share This” button or interactive mini-programs on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with such a feature are governed by the privacy policy of the organization providing it.

Links to Third-Party Sites

Our websites may include links to other, third party websites, whose privacy practices may differ from ours. If you submit Personal Information to any of those third party websites, your information is governed by their privacy policies and we do not accept any responsibility or liability for such third party sites. Please check the privacy policies published on any third-party sites which you may access through our website before submitting Personal Information to them.

Access to Your Personal Information

You may ask for access to any Personal Information that we hold about you. You also may ask how we collected the information, how we are using it, and to whom we have disclosed it. In certain circumstances we may be unable to provide access to some or all of the information that we hold about you. If we are unable or not permitted by law to provide you with access, we will provide you with an explanation and indicate further steps which are available to you.

Changes to this Privacy Policy

We regularly review this Privacy Policy and may amend it from time to time.

Questions, Concerns, Access to Information

If you have any questions or concerns or wish to obtain further information about our Personal Information policies and procedures, or if you wish to access your Personal Information or change any consent regarding our use or disclosure of your Personal Information, please contact us at the address set out below:

Gabrijela Jevtic, VP of Finance
privacy@orion.on.ca