We take steps at Clearbridge to ensure we meet privacy principles and requirements. As a result, we respect your personal information under applicable Canadian privacy legislation. The purpose of this statement is to inform our website visitors how we collect, use, disclose and protect your personal information. 

Personal information is information about an identifiable individual. The individual is more particularly described under applicable privacy legislation. Therefore, this statement applies to our collection, use and disclosure of personal information in Canada.

Personal Information We Collect

Clearbridge and its agents and representatives collect personal information in several circumstances. In addition, personal information we collect may include:

• Contact Information: Name, address, telephone number, cellular number, email address and other contact information.
• Financial Information: Credit card numbers, bank name, billing address, transaction, and purchase history.
• Usage Information and History: IP addresses, support ticket history, email correspondence, visit history to www.clearbridge.ca and related websites.
• Such other information we may collect with consent or as permitted or required by law.

Use of Personal Information

Clearbridge uses personal information for the following purposes:

• For billing purposes. This includes managing, administering, collecting, or otherwise enforcing accounts.
• For general administrative purposes. This ensures compliance with legal, regulatory, insurance, security, and processing requirements.
• For customer relations purposes.  We may contact customers to ensure their satisfaction with our services.
• Otherwise with consent or as permitted or required by law.

Disclosure of Your Personal Information

Clearbridge discloses personal information only as necessary. This allows us to meet legal, regulatory, insurance, audit, processing, and security requirements. This occurs with your consent, or as the law permits or requires.

In addition to the above, personal information may be disclosed to our affiliates for internal audit, management, billing, or administrative purposes.

As such, in no event will Clearbridge disclose any personal information about any customer to any third party without the customer’s express written consent.

Clearbridge has taken security measures to ensure customer information is protected against loss, alteration, or misuse. These measures include strong database encryption, archive encryption and the use of secure protocols. The security protocols that may be used include SSL when transmitting confidential information over the Internet.

Service Providers

Personal information, NOT including financial information, may also be transferred to third-party agents or service providers. Additionally, we engage with them to provide technical support on our behalf. Some of which may be located outside of Canada.

We take reasonable measures to ensure that your personal information that may be collected, used, disclosed or otherwise processed by these service providers on our behalf is protected.

In addition, we ensure your personal information is not used or disclosed for purposes other than as directed by Clearbridge. This is subject to legal requirements in foreign jurisdictions applicable to those organizations. For example, lawful requirements to disclose personal information to government authorities in those countries.

Business Transactions

Clearbridge may use personal information and disclose it to parties connected with the contemplated or actual financing, securitization, insuring, sale, assignment or other disposals of all or part of Clearbridge or our business or assets. This is for the purposes of evaluating and/or performing the proposed transaction. These purposes may include:

• Permitting those parties to determine whether to proceed or continue with the transaction.
• Fulfilling reporting, inspection or audit requirements or obligations to those parties.
• Permitting the use and disclosure of your personal information by those parties (for example, assignees) for the same purposes as described in this privacy statement.
• Our website/the Internet.
• Customer IDs and passwords.

Customer identification numbers and passwords that Clearbridge has issued, are the responsibility of the customer to keep safe and confidential. Customers must ensure that only authorized personnel access their accounts. If for any reason you are concerned about this, please contact us.

Site Visitors

Clearbridge collects information about visitors to its websites such as length of visit, the pages visited and the referrer. Clearbridge may also use “cookies” to help track sessions or for other administrative purposes. This information is for internal use only and helps Clearbridge to improve its customer service and marketing strategies.

Your Consent

Consent to the collection, use and disclosure of personal information may be given in several ways. Consent can be expressed (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information). It can also be implied (for example, when you provide information necessary for a service you have requested).

You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information. Furthermore, you have not withdrawn your consent for an identified purpose, such as by using an “opt-out” option provided, if any.

Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Similarly, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information. The purposes are identified or described in this privacy statement, if applicable, or otherwise at the time of collection.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice.

Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services.

Clearbridge collects, uses, and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use, or disclose personal information without your consent. For example, to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

Security

We protect your personal information using physical, electronic, or procedural security measures. Our process is appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Authorized employees and agents of Clearbridge who require access to your personal information to fulfill their job requirements may have access to your personal information.

Access, Corrections and Contacting Us

Clearbridge may establish and maintain a file of your personal information for the purposes described above. If you wish to request access or correction of your personal information in our custody or control, you may contact us via this website. Your right to access or correct your personal information is subject to applicable legal restrictions. If you wish to make inquiries or complaints or have other concerns about our personal information practices, you may contact us via this website, or telephone us at +1 (778) 383-6726.

Privacy Statement Changes

This privacy statement may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals in advance, if necessary. If you are concerned about how your personal information is used, you should contact us as described above or check back at our website periodically to obtain a current copy of this statement.

This privacy statement has been updated 08/31/2022.