Aspen Valuation Privacy Policy
Aspen Valuations Privacy Policy
Aspen Valuations Inc. (“Aspen”) recognizes the importance of protecting personal information and an individual’s right to privacy. This policy outlines the framework of Aspen’s policies and procedures regarding its collection, use, retention, and disclosure of personal information in respect of its clients and others and supplements, where applicable, our professional obligations of confidentiality and solicitor/client privilege. This Privacy Policy does not apply to personal information about employment candidates or our employees, partners, or contracted staff, which is dealt with separately.
Our privacy policies and procedures only apply to personal information about identifiable individuals. They do not apply to business information. Personal information does not include the name, title, business address or telephone number of an employee of an organization. In the context of this policy, the term “clients” includes all current, former, and prospective clients.
Why Do We Collect Personal Information?
Generally, we collect personal information in order to provide valuation services to our clients, to establish and manage client relationships and other commercial relationships, and to comply with regulatory requirements. As well, we collect personal information to provide our clients with newsletters. We also collect personal information to evaluate client satisfaction.
What Personal Information Do We Collect?
Personal information that we collect includes:
- contact information
- financial information
- information relating to a client’s legal issues
- information about others collected in the course of representing a client, such as a client’s employees, other parties to a transaction or lawsuit, or witnesses
- information regarding visitors to our offices
- information that you have consented to us collecting, or information that we are otherwise permitted by law to collect.
How Do We Collect Your Personal Information?
We collect your personal information only by lawful and fair means and only with your consent or as required or permitted by law. Whenever possible and appropriate, we collect your personal information from you directly or from persons whom you have requested to provide us with information. Sometimes we may collect information about you from other sources such as financial institutions, insurance companies, witnesses in litigation matters, other parties involved in your transaction or file, government agencies or registries, employers (if we are acting for you at your employer’s request), accountants or other professional advisors, and credit bureaus.
How Do We Use Your Information?
We may use your personal information for the following purposes:
- to provide valuation and related services
- to manage our business, including fulfilling contractual obligations and auditing our operations
- to evaluate client satisfaction
Disclosure of Your Personal Information
Subject to our professional obligations of confidentiality, Aspen will only disclose your personal information for purposes related to its providing services to you, or with your express consent, or if required or authorized by law. For example, we may disclose your information:
- at your request
- when necessary to collect outstanding accounts
- when necessary to comply with court orders, regulatory rules (including the rules of applicable provincial law societies)
- when we reasonably believe that a third party requesting your personal information is your agent
In addition, we may disclose your personal information to third parties if we merge or reorganize. We may disclose your personal information before and after a transaction. However, if the transaction is completed, we will require the third party to provide a comparable level of protection for your personal information. If the transaction is not completed, we will require the third party to destroy securely, or to return to us, any records containing your personal information.
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 as required by law 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. Please note, however, that withdrawing consent may affect our ability to serve you and maintain our relationship.
For example, if you no longer wish to receive our publications or receive information about our services, including by email, please send an e-mail message to: connect@aspenval.com stating you no longer wish to receive communications about Aspen.
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.
Additional terms applicable to data subjects in the European Union
If you are in the European Union, please note that this section applies to our processing of your personal data in addition to the other terms of this Privacy Policy. Any reference to “personal information” in this Privacy Policy should be understood as referring to “personal data”, defined under the General Data Protection Regulation (“GDPR”) as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Aspen collects personal data about you. Aspen as data controller processes your personal data in compliance with the requirements of the GDPR, as amended from time to time.
Legal bases upon which we process your Personal Data
We only process your personal data:
- with your consent;
- for performing the services you have requested from us or, upon your request, to take the steps necessary to provide you with such services; or
- in the furtherance of our legitimate interests in maintaining business relationships and communicating with you as a business contact, about Aspen’s activities and services. We consider that our legitimate interests are in compliance with the GDPR and your legal rights and freedoms. You have the right to object to any of this processing and, if you want to, please contact our Privacy Officer at the contact details indicated below.
Retention of your personal information
We only retain your personal data for as long as necessary to fulfill the purposes identified in this Privacy Policy or as long as required for our legal or business purposes.
Additional data subject rights
In addition to the rights described above under “Access to Your Personal Information”, you may in some cases ask us to delete your personal data. You can also object to certain personal data about you being processed and request that processing of your personal data be limited. Please note that the limitation or deletion of your personal data may mean we will be unable to provide the services described above. You also have the right to receive your personal data in a machine-readable format and have the data transferred to another party responsible for data processing. If you disagree with how we process your Personal Data, you are also entitled to report this to the competent supervisory authorities in the European Union.
Changes to this Privacy Policy
We regularly review our privacy policies and procedures. Therefore, we may amend this Privacy Policy from time to time. The most current version of our Privacy Policy will be posted on our website at https://www.aspenval.com. Regardless of any changes we make to our Privacy Policy, we will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information, or as otherwise required or permitted by law, unless you have given your express consent for us to do otherwise.
Questions or Concerns
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 connect@aspenval.com. We will treat all privacy concerns seriously. We will investigate any concern and seek to resolve it within a reasonable time.