PRIVACY POLICY 

Version 5.0 – August 13, 2026 

CONFIDENTIAL: The information contained in this document is the property of FMO & TD, except as specifically authorized in writing by FMO & TD. The holder of this document shall keep the information contained herein confidential and shall protect same in whole or in part from disclosure or dissemination to third parties.

1.0 OVERVIEW

1.1 Purpose

1.2 The Ten Principles of PIPEDA

1.3 Definitions

2.0  PURPOSES OF COLLECTING PERSONAL INFORMATION

3.0  CONSENT

4.0  LIMITED COLLECTION OF PERSONAL INFORMATION

5.0  LIMITING USE, DISCLOSURE AND RETENTION

5.1 Use of Personal Information

5.2 Disclosure and Transfer of Personal Information

5.3 Retention of Personal Information

6.0  ACCURACY

7.0  SAFEGUARDS

8.0  INDIVIDUAL ACCESS

9.0  COMPLAINTS / RECOURSE

10.0  CHANGES TO THIS POLICY; INTERPRETATIONS

11.0  CONTACT US

OVERVIEW 

1.1 Purpose

Formost mediaOne, FMO, and Taylor Demers, TD, provides computer devices, networks, and other electronic information systems to meet missions, goals, and initiatives and must manage them responsibly to maintain the confidentiality, integrity, and availability of its information assets. 

This policy governs the way FMO & TD collects, uses, maintains, and discloses personal information collected during our business activities. This privacy policy has been developed to comply with Canada’s Personal Information Protection and Electronic Documents Act ("PIPEDA"). PIPEDA sets out rules for the collection, use and disclosure of personal information during commercial activity as defined in the Act.

This policy will be reviewed on an annual basis and can be viewed on FMO’s & TD’s Payworks Documents. 

1.2 The Ten Principles of PIPEDA

The ten principles of PIPEDA that form the basis of this Privacy Policy are as follows:

1. Accountability: organizations are accountable for the personal information they collect, use, retain and disclose during their commercial activities, including, but not limited to, the appointment of a Compliance Officer.
2. Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection and can only be used for those purposes.
3. Consent: organizations must obtain an Individual’s express or implied consent when they collect, use, or disclose the individual’s personal information.
4. Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes.
5. Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes and must not be disclosed to third parties unless the Individual consents to the alternative use or disclosure.
6. Accuracy: organizations are required to keep personal information in active files accurate and up to date.
7. Safeguards: organizations are to use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure.
8. Openness: organizations must inform their clients and train their employees about their privacy policies and procedures.
9. Individual Access: an individual has a right to access personal information held by an organization and to challenge its accuracy if need be; and
10. Provide Recourse: organizations are to inform clients and employees of how to bring a request for access, or complaint, to the Information/Privacy Officer, and respond promptly to a request or complaint by the individual.

This Privacy Policy applies to FMO’s & TD’s employees, temporary employees, Contractors, and Third-Party Service Providers. FMO & TD ensures that all temporary employees, Contractors, and Third-Party Service Providers sign confidentiality agreements prior to any transfer of an individual’s personal information while providing the business loans, business development advice, and other related information and/or services.

1.3 Definitions

"Personal information" means any information about an identifiable individual. It includes, without limitation, information relating to identity, nationality, age, gender, address, telephone number, e-mail address, Social Insurance Number, date of birth, marital status, education, employment, health history, assets, liabilities, payment records, credit records, loan records, income and information relating to financial transactions as well as certain personal opinions or views of an Individual.

"Business information" means business name, business address, business telephone number, name(s) of owner(s), officer(s) and director(s), job titles, business registration numbers (GST, RST, source deductions), financial status. Although business information is not subject to PIPEDA, confidentiality of business information will be treated with the same security measures by FMO & TD staff, members, and Board members, as is required for individual personal information under PIPEDA.

"Database" means the list of names, addresses and telephone numbers of clients and individuals held by FMO & TD in the forms of, but not limited to, computer files, paper files, and files on computer hard drives.

"File" means the information collected while processing an application, as well as information collected/updated to maintain /service the account.

"Express consent" means the individual signs the application, or other forms containing personal information, authorizing FMO & TD to collect, use, and disclose the individual's personal information for the purposes set out in the application and/or forms.

"Implied Consent" means the organization may assume that the individual consents to the information being used, retained, and disclosed for the original purposes, unless notified by the individual.

2.0 PURPOSES OF COLLECTING PERSONAL INFORMATION

FMO & TD collects personal information about clients to enable us to serve them better and to develop our business and operations. More specifically, we collect, use, and disclose personal information for the following purposes:

• To establish, maintain and manage our client relationships to provide products and services that have been requested.
• To be able to inform clients of our products other than those that have been specifically requested, including sending information promoting other FMO & TD services.
• To be able to comply with client requests or inquiries.
• To establish and maintain commercial relationships including to issue invoices, administer accounts, collect, and process payments, and to fulfill contractual obligations.
• To understand and respond to client needs and preferences, including to contact and communicate with clients and to conduct surveys, research, and evaluations.
• To monitor quality control and respond to questions and concerns through correspondence with clients.
• As permitted by and to comply with any legal or regulatory requirements or provisions, including in relation to adverse event reporting
• For any other purpose to which employees give consent 

3.0 CONSENT

It is important that where we collect, use, or disclose your personal information we have your consent to do so. In general, we seek to obtain your express informed consent before collecting your information. 

Express consent can be given electronically or in writing. 

Subject to legal or contractual restrictions and reasonable notice, you may change or withdraw your consent at any time by contacting us at the address indicated below. 

In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products, services, or information that you requested or that could be offered to you. All communications with respect to such withdrawal or variation of consent must be in writing and addressed to us.

This Privacy Policy does not cover statistical data from which the identity of individuals cannot be determined. FMO & TD retains the right to use and disclose statistical data as it determines appropriate.

4.0 LIMITED COLLECTION OF PERSONAL INFORMATION

Personal information collected will be limited to the purposes set out in this Privacy Policy, FMO & TD applications, and/or other forms. It will not be disclosed for any other purpose than for which it was collected, without your consent. 

5.0 LIMITING USE, DISCLOSURE AND RETENTION

5.1 Use of Personal Information

Personal information will be used for only those purposes to which the individual has consented with the following exceptions, as permitted under PIPEDA:

• The organization has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial, or foreign law and the information is used for that investigation.
• An emergency exists that threatens an individual’s life, health, or security.
• The information is for statistical study or research.
• The information is publicly available.
• The use is clearly in the individual’s interest, and consent is not available in a timely way.
• Knowledge and consent would compromise the availability or accuracy of the information; and
• Collection is required to investigate a breach of an agreement.

5.2 Disclosure and Transfer of Personal Information

From time to time, we may use and disclose your personal information: for the purposes described in this Policy or for any additional purposes for which we have obtained your consent. We may share your personal information with our employees, contractors, consultants, and other parties who require such information to assist us with establishing, maintaining, and managing our relationship with you. We will never disclose your personal information for 3rd party purposes.

We may disclose your personal information to:

• Service providers, including an organization or individual retained by FMO & TD to perform functions on its behalf, such as marketing, data processing, document management and office services.

FMO & TD will ensure, by contractual or other means, that the third party protects the information and uses it only for the purposes for which it was transferred.

5.3 Retention of Personal Information

Personal information will be retained in files if the file is active and for such periods of time as may be prescribed by applicable laws and regulations.

6.0 ACCURACY

FMO & TD endeavors to ensure that any personal information provided by the individual in his or her active file(s) is accurate, current, and complete as is necessary to fulfil the purposes for which the information has been collected, used, retained, and disclosed. 

Individuals are requested to notify FMO & TD of any change in personal or business information.

Information contained in inactive files is not updated.

7.0 SAFEGUARDS

FMO & TD will use physical, organizational, and technological measures to safeguard personal information to only those FMO & TD employees, volunteers, or third parties who need to know this information for the purposes set out in this Privacy Policy.

Physical Safeguards: Access to the physical premises is controlled and monitored using CCTV. Data is stored in locked filing cabinets when not in use. Access to work areas where data may be in use is restricted to FMO & TD employees only and authorized third parties.

Organizational Safeguards: Access to personal information will be limited to approved personnel. Members of FMO & TD are not permitted to copy or retain any personal information on individuals or clients and must return for destruction all such information given to them to review once the purpose for being provided with this information has been fulfilled.

All employees of FMO & TD are required to sign a confidentiality agreement binding them to maintaining the confidentiality of all personal information to which they have access.

All inactive files or personal information no longer required are shredded prior to disposal to prevent inadvertent disclosure to unauthorized persons.

Technological Safeguards: Personal information contained in FMO & TD computers and electronic databases are password protected in accordance with FMO’s & TD’s Information Security Policy. Access to any of the FMO’s & TD’s computers is also password protected. FMO’s & TD’s Internet router or server has firewall protection sufficient to protect personal and confidential business information against virus attacks and "sniffer" software arising from Internet activity. Personal information is not transferred by e-mail or other electronic form.

8.0 INDIVIDUAL ACCESS

Upon written request, subject to certain exceptions, FMO & TD will inform our clients of the existence, use, and disclosure of their personal information and will give clients access to that information. 

Access requests should be sent to FMO & TD, using the contact information in the “Contact us” section of this Policy. 

When a client requests access to their personal information, we will request specific information from the client to enable us to confirm their identity and right to access, as well as to search for and provide the personal information that we hold about the client. 

FMO & TD reserves the right to charge a fee to access a client’s personal information to cover FMO’s & TD’s costs; we will advise clients of this fee in advance.

A client’s right to access personal information is not absolute. Applicable law or regulatory requirements may allow or require FMO & TD to deny a client access where access would inhibit the ability of FMO & TD to comply with a legal obligation; where it has already been destroyed due to legal requirements or because we no longer need it for our business purposes and where access would reveal personal information about a third party.

If FMO & TD cannot provide a client with access to their personal information, the client will be informed of the reasons, subject to any legal or regulatory restrictions. 

9.0 COMPLAINTS / RECOURSE

Clients are to advise FMO & TD if they believe that their personal information is inaccurate. 

Clients have the right to ask for it to be corrected or updated. FMO & TD will ask clients to provide documentation to support their request for correction or updating.

An individual who has a concern about FMO’s & TD’s personal information handling practices, a complaint, in writing, may be directed to the V.P. Technology & Compliance Officer.

Upon verification of the individual's identity, FMO’s & TD’s Information Security/Privacy Officer will act promptly to investigate the complaint and provide a written report of the investigation's findings to the individual.

Where the V.P. Technology & Compliance Officer decides that the individual's complaint is well founded, the V.P. Technology & Compliance Officer will take the necessary steps to correct the offending information handling practice and/or revise FMO’s & TD’s privacy policies and procedures.

Where the V.P. Technology & Compliance Officer determines that the individual's complaint is not well founded, the individual will be notified in writing. If the individual is dissatisfied with the finding and corresponding action taken by the V.P. Technology & Compliance Officer, the individual may bring a complaint to the Federal Privacy Commissioner at the address below:

Office of the Privacy Commissioner of Canada
30 Rue Victoria, Gatineau, 

QC K1A 1H3
Tel 1-819-994-5444

10.0 CHANGES TO THIS POLICY; INTERPRETATIONS

FMO & TD reserves the right to modify or supplement this Policy at any time. 

If any changes are made to FMO’s & TD’s use, collection or disclosure of your personal information that require your consent, we will not implement such changes until your consent has been obtained. This Policy does not create or confer upon any individual rights or impose upon FMO & TD any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. 

Should there be, in a specific case, any inconsistency between this Policy and Canada’s federal and provincial privacy laws, as applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

11.0 CONTACT US

FMO & TD has a responsible compliance with this Policy. Should you have questions about this Policy or collection, use and disclosure practices, you may contact:

Formost mediaOne

Attention: V.P. Technology & Compliance Officer

Address: 6 Kenview Blvd, Brampton, ON L6T 5E4

Email: InfoSec@fmo.ca

Taylor Demers 

Attention: V.P. Technology & Compliance Officer

Address: 8 Kenview Blvd, Brampton, ON L6T 5E4

Email: privacyofficer@taylor-demers.com