Privacy

For the purposes of this Privacy Policy, “Personal Information” shall mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address, telephone and fax numbers and e-mail address). In the course of its relationship with you, Mill Street will need to collect, use and sometimes, disclose various types of Personal Information for various purposes associated with the scope of the work as directed by you or your organization. You may be assured that Mill Street will only collect Personal Information that is necessary for the following purposes:

  • Establishing your identity: which may require you to provide name, address, employment/business information, legally mandated forms of identification.
  • Billing: which will include the collection of names, addresses, banking and/or financial details.
  • Provision of Services: which will include any Personal Information necessary to provide services requested by you or your organization. We may also analyze the Personal Information provided to us to offer you additional services. You may, at any time, advise us that you do not wish to receive such information from Mill Street.

LIMITING COLLECTION, USE, DISCLOSURE & RETENTION OF PERSONAL INFORMATION

Mill Street may collect your Personal Information in many forms (hard/soft copy, electronically, facsimile, telephone conversations/recordings, etc.), but will only do so by lawful means and only for necessary purposes that have been disclosed to you. Mill Street provides clients and others with general access to public web sites and restricted access to extranets. Our Web servers and authorized third party providers track general information about visitors such as their domain name, IP address and time of visit. Mill Street’s Web servers also collect and aggregate information regarding which pages are being accessed as well as information volunteered by visitors through online surveys or subscriptions to electronic newsletters. This information is used internally, only in aggregate form, to better serve visitors by helping us to:

  • Manage our sites
  • Diagnose any technical problems
  • Improve the content of our Web site

During the course of an individual’s use of the Internet, he or she will encounter “cookies” in the normal course. Cookies are small files or pieces of information that may be stored in a computer’s hard drive when an individual visits a web site. Mill Street uses cookies. Most Internet browsers are initially set to accept cookies. If you do not wish to accept cookies, you can set yours to refuse cookies or to alert you when cookies are being sent. Personal Information collected in any form will only be retained by Mill Street so long as it is required: a) for the purpose for which it was collected; b) to be retained by law; c) to address any issues that may arise at a later date. When your Personal Information is no longer required for these identified purposes, Mill Street uses secure procedures to destroy, delete, erase or convert the Personal Information into an anonymous form.

CONSENT

Your provision of Personal Information to Mill Street means that you agree and consent that we may collect, use and disclose your Personal Information under this Privacy Policy. If you do not agree with these terms, you are requested not to provide any Personal Information to Mill Street. Certain services can only be offered if you provide Personal Information to Mill Street. If you choose not provide us with any required Personal Information, Mill Street may not be able to offer you those services. Consent may be given in different ways such as: a) expressly by signing a document, agreeing through electronic means or verbally; or b) impliedly by providing the Personal Information voluntarily. There may be circumstances where you have provided Personal Information for an identified purpose, and Mill Street later needs to use that information for a different purpose. In such circumstances, Mill Street will seek your consent to use the information for the new purpose. Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where Mill Street must disclose information without consent. Such circumstances may include:

  • Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
  • Where Mill Street believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
  • Where it is necessary to establish or collect monies owing to Mill Street;
  • Where it is necessary to permit Mill Street to pursue available remedies or limit any damages that Mill Street may sustain; or
  • Where the information is public.
  • Where obliged or permitted to disclose information without consent, Mill Street will not disclose more information than is required.

You have the right to revoke your consent to the collection, use and disclosure of your Personal Information at any time. However, revocation of your consent may result in our inability to provide services to you. We will discuss with you the reason we need your Personal Information and why the revocation of your consent affects our ability to provide the service or product to you.

DISCLOSURE & SECURITY

Mill Street may disclose Personal Information to organizations that perform services for Mill Street. Personal Information will only be provided to such organizations if they agree by way of contractual or other arrangements to use such information solely to provide services to Mill Street and under the instruction of Mill Street and, regarding that information, to act in a manner consistent with the principles articulated in this Privacy Policy. Personal Information may also be subject to transfer to another organization in the event of a merger, change of ownership, obtaining insurance or financing. This will occur only if the parties have entered into an agreement under which the collection, use and disclosure of the information is restricted to those purposes that relate to the business transaction, including a determination whether or not to proceed with the business transaction, and is used by the parties to carry out and complete the business transaction. Mill Street has taken steps to maintain adequate physical, procedural and technical security regarding its offices and information storage facilities to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information (“Data Breach”). Mill Street further protects Personal Information by restricting access to those individuals that the management of Mill Street has determined need to know that information in order that Mill Street may provide its services. All Mill Street’s, employees, servants, and agents are provided with training on maintaining the confidentiality and protection of the Personal Information provided to Mill Street. No method of transmitting or storing data is perfectly secure. While the physical characteristics mail, telephone calls, faxes and transmissions over the Internet are different, each is susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted. In the unfortunate event of a Data Breach, Mill Street will attempt to contain the loss to the greatest extent possible and will comply with applicable breach notification requirements.

AMENDMENT OF THIS PRIVACY POLICY

This Privacy Policy is in effect as of July 24, 2015. Mill Street will from time to time review and revise its privacy practices and this Privacy Policy. In the event of any amendment, an appropriate notice will be posted on Mill Street web site. Policy changes will apply to the information collected from the date of posting of the revised Privacy Policy to Mill Street’ web site as well as to existing information held by Mill Street.