Privacy Officer

To confirm our commitment to privacy, GRM has appointed a qualified member of our senior management team as the Privacy Officer. The Privacy Officer is available to offer more information on our practices and policies, to ensure compliance by everyone at GRM and to rectify any complaints. The Privacy Officer can be contacted by mail at the following address:

Privacy Officer
Global Resource Management

Head Office
330 Bay Street, Suite 1400
Toronto, ON M5H 2S8.

GRM’s Privacy Officer will review any new processes, procedures or practices affecting the privacy of our employees, our suppliers and our clients to ensure they are compliant with our Privacy Policy.

GRM’s Privacy Officer commits to being aware and knowledgeable about any changes in the Canadian privacy legislation and to ensuring GRM consistently meets or exceeds the privacy requirements.

Information Protection, Identification and Consent

GRM maintains that it will identify the purpose(s) for collecting personal information and inform the affected individuals of the intended purpose. When the intended use for the collected information involves releasing it to an interested third party, GRM will ensure the individual grants consent before any information is released. Consent for these purposes can be either explicit or implicit depending on the sensitivity of the information.

GRM will only collect information for which there is an intended purpose. The collected information will only be used for the purposes stated. Should the information be necessary for purposes other than those stated, separate consent will be obtained. This is true for all situations except those where GRM has obtained general consent or where the particular use is required by law or the police for an investigation.

All third-party suppliers, vendors and clients to which personal information may be released will have been carefully screened to ensure their Privacy Policies meet or exceed the legislated requirements.

Retention and Safeguards

GRM has set mandatory retention time frame limits based on Employment and Labour Standards and will retain personal information only as long as is outlined in the applicable legislation. Third-party suppliers have been instructed to follow the same guidelines. In addition, the information, while retained, will be secured by appropriate safeguards relevant to the sensitivity of the information.

Accuracy

GRM will make every effort to ensure personal information remains current and is updated internally and with third-party suppliers in a timely manner. Individuals are expected to update GRM with any changes to their personal information. The information will only be updated when required for the intended, previously informed purposes.

Openness

GRM will provide further information about its policy or practices upon request. To access this information, please get in touch with the Privacy Officer by sending a request in writing to:

Privacy Officer
Global Resource Management

Head Office
330 Bay Street, Suite 1400
Toronto, ON M5H 2S8.

The information will be released within 30 days of receipt of the request.

Individual Access

Upon request, GRM will release the personal information retained by the organization to the individual that the information is about, along with the use and disclosure of any personal information.

Specific requests for information can be directed to the Privacy Officer at the following address: The GRM Group, 330 Bay Street, Suite 1400, Toronto, ON M5H 2S8. The information will be released within 30 days of receipt of the request.

Should GRM not be able to comply with the request for a justifiable reason, that reason will be given to the requestor.

GRM considers the following reasons justifiable reasons to refuse access to personal information:

• Solicitor-client privilege
• Litigation privilege
• Security and ongoing fraud investigations
• Proprietary or trade secret information
• Sensitive medical information that could be obtained through other means
• Requests that would prove prohibitively costly to provide
• Requests that could reasonably be expected to threaten the life or security of another individual

This list is not exhaustive and other reasons may be considered justifiable.

Cookies Policy

GRM (“GRM”, “we” or “us”) is committed to providing you with the best online experience while visiting the GRM.com website (the “Website”). To achieve this, we utilise our own and standard third-party cookies to obtain data about your online behaviour while you are on the Website, and we also track how often you visit the Website. The information we collect is anonymous and does not identify you as an individual, unless you provide us with your information by completing a form, replying to a survey, signing up for email alerts or through another Service offered on the Website.

If you do not wish to accept this Policy please do not continue to use the Website.

What we track

We do not use any intrusive cookies on the Websites to collect your personal information. We use industry-standard third-party cookies such as Google Analytics to track your behaviour online and gain statistical information at an aggregated level in the following ways:

We track the number of visits to the Website, where each visitor came from (i.e. the website you visited prior to coming to the Website) and where each visitor goes from the Website (i.e. the website you visit after leaving ours).

A cookie is stored on your device for no longer than two (2) years which is linked to your IP address. Cookies are small text files that your web browser stores on your device. This allows us to track whether you return to the Website.

How to manage cookies

If you do not wish us to track information through cookies you can configure your browser to reject cookies. If you wish to do so, please refer to your Internet browser’s user instructions to find out how to delete and reject cookies. Note that the rejection of cookies may impact your user experience on the Website and restrict you from utilising certain site functionality and Services.

Third-party cookies

Throughout your journey on the Website, you may also notice content from third parties such as, e.g., a map showing you the location of nearby GRM branches provided by Google through its Google Maps service. We may also offer you the opportunity to further engage with us and share information with others using social networks such as Facebook and Twitter. This content is added so we can keep you up to date with carefully selected information that you may find relevant or of interest, however, this can result in these third-party providers storing additional cookies on your device that we have no control over. Consequently, we suggest you check the websites of any such third parties and their privacy policies for more information about their cookies and how you can manage them.

The Website may contain links to third-party websites. If you follow a link to any of these third-party websites please note that these websites have their own privacy and cookie policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third-party websites.

Changes to this Policy

Any changes we may make to our Policy in the future will be posted on this page.

Challenging Compliance

Individuals of whom GRM holds personal information have the right to file a challenge about the company’s compliance with Privacy legislation. GRM will consider all requests seriously and will investigate any complaint thoroughly.

To file a challenge, please send all relevant details and specifics to GRM’s Privacy Officer at the following mailing address:

Privacy Officer
Global Resource Management
330 Bay Street, Suite 1400
Toronto, ON M5H 2S8
Canada

Last updated: August 31, 2023, Legal (Can)