This Privacy Policy sets out the policies and practices of Hugessen Consulting Inc. (“Hugessen”, “we”, “us” or “our”) with respect to the collection, use, disclosure, and handling of the personal information of our website users, clients, and clients’ personnel or prospective personnel (“you” or “your”).
Hugessen is committed to respecting privacy rights. Hugessen will only collect, use, disclose, or otherwise handle personal information in accordance with this Privacy Policy and applicable Canadian privacy laws.
In this Privacy Policy, “personal information” means information about an identifiable individual, as further defined under applicable Canadian privacy laws.
1. General
This Privacy Policy explains:
- what personal information we collect and why we collect it;
- how we use your personal information;
- who we share your personal information with;
- the choices you have to access and update your personal information; and
- your additional privacy rights based on where you reside.
During the course of providing our services to our clients (the “Services”), we may collect or obtain personal information about our clients and any of our client’s personnel or prospective personnel. We may also collect personal information from users when they visit our website (the “Website”).
We may collect or obtain your personal information when you give it to us (e.g., through your direct interactions with us), through third parties who have the right to disclose this information to us (e.g., our clients that provide us with the personal information of their personnel or prospective personnel) or because it is publicly available.
Hugessen may update this Privacy Policy from time to time. We will notify you of any amendments to this Privacy Policy by updating the “Last Updated” date at the top of this Privacy Policy. It is your responsibility to check this Privacy Policy from time to time to ensure that you are up to date with any changes. Subject to applicable laws, the most current version of this Privacy Policy will govern Hugessen’s use of your personal information. By continuing to use the Services and/or access the Website after changes are made to this Privacy Policy, you agree to be bound by the revised terms.
In addition, you can obtain a current copy of this Privacy Policy by contacting Hugessen’s Privacy Officer (see Section 9 for further information regarding contacting Hugessen’s Privacy Officer).
2. Consent
We may obtain your consent to collect, use, disclose, and otherwise handle your personal information through the following methods:
- Direct Interactions: We may obtain your consent (either expressly or implied) through our direct interactions with you.
- From our Clients: When clients provide us with the personal information of their personnel or prospective personnel in connection with the use of our Services, these clients are responsible for specifying the purposes for which the personal information will be processed by us and for obtaining the necessary consent for us to process such personal information in accordance with this Privacy Policy.
- From Publicly Available Sources: Hugessen may utilize publicly available information (such as that required by regulatory requirements, legal processes and voluntary disclosure) in providing work for clients or doing research to help further Hugessen’s intellectual capital.
By providing your consent in accordance with any of the above methods, you, in each case, consent to the collection, use, disclosure, and otherwise handling of your personal information for the purposes identified in and in accordance with this Privacy Policy, and for the purposes identified to you prior or at the time you provided the personal information. If you do not agree with this Privacy Policy or the manner in which your personal information may be used under this Privacy Policy, you should not use the Services or Website.
You may, subject to legal and contractual restrictions and reasonable notice, at any time withdraw your consent to the collection, use, disclosure and otherwise handling of your personal information. If you wish to withdraw your consent, please contact us (as set out in Section 9). Please note that revoking your consent may result in you not being able to access or utilize the Website and/or the Services.
3. Collection and Use of Personal Information
A. Information We Collect
Hugessen collects the following categories of personal information:
(a) Contact Information. We may collect your mailing address, email address, and telephone number.
(b) Biographical Information. We may collect your name, age, date of birth, employment and education details, and qualifications.
(c) Financial Information. We may collect information about the compensation offered or provided by organizations to individuals.
(d) Job Performance Evaluations. We may collect information about performance evaluations of individuals by organizations.
(e) Device and Website Information. When you visit the Website, we automatically collect certain information about your device, including, information about your web browser, operating system, Internet Protocol (IP) address, Internet service provider, the date and time you visited our Website, and certain cookies that are installed on your device (collectively, “Device Information”). Additionally, when you visit the Website, we collect information about the individual web pages that you viewed, your searched pages, what websites or search terms referred you to our Website, and information about how you interact with the Website (collectively, “Website Information”).
(f) Other Personal Information. We may collect other personal information that is identified to you at or before the time of collection.
B. How We Collect Information
Hugessen collects personal information using the following methods:
(a) Direct Interactions. We may collect personal information directly from any of the following:
- our clients;
- our client’s personnel or prospective personnel; or
- individuals of interest relating to a client engagement.
For example, clients may, among other things, provide us with personal information about their personnel or prospective personnel during the course of an engagement. We may also collect personal information when we interview individuals or perform evaluations.
(b) Automated Technologies or Interactions. As you interact with the Website, we may automatically collect Device Information and Website Information through the following technologies:
- “Cookies” are data files that are placed on your computer or mobile device and often include an anonymous unique identifier. For more information about our use of cookies, please see Section 6;
- “Log files” track actions occurring on the Website, and collects data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you visit the Website.
C. How We Use Personal Information
Where applicable, Hugessen may use your personal information for the following purposes:
(a) to perform the Services in accordance with any agreement between us and our clients (each, a “Client Agreement”);
(b) to facilitate communication between you and Hugessen;
(c) to analyze how the Website and the Services are being used, and to improve performance and functionality of the Website and the Services;
(d) to investigate and resolve complaints;
(e) to detect, prevent or mitigate security or technical issues relating to the Website and/or the Services;
(f) to enforce agreements relating to the Services;
(g) to protect our interests, including establishing, exercising and defending our legal rights and claims;
(h) to prevent fraud, cooperate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities;
(i) for any other purpose for which you have provided your consent or as otherwise set forth in this Privacy Policy; or
(j) as otherwise permitted by law.
Hugessen may also use the personal information that it collects, when the personal information has been anonymized, for the purpose of improving the Services.
4. Disclosure of Personal Information
Except as permitted by law, we will disclose personal information in accordance with this Privacy Policy or as otherwise identified to you prior to or at the time your personal information is collected. When we disclose personal information, we take appropriate precautions, including: (i) limiting its disclosure to what is reasonably required for the purposes set out in this Privacy Policy; and (ii) requiring our service providers to handle personal information in a manner that is consistent with this Privacy Policy.
Hugessen may disclose your personal information as follows:
(a) as expressly provided in the applicable Client Agreement;
(b) to third party service providers or agents who provide services to or on behalf of Hugessen, as further detailed below;
(c) to law enforcement agencies for the purposes of investigating fraud or other offences, in connection with the prevention or investigation of suspected fraudulent activities or harm to individuals or property, to establish or exercise our legal rights or defend against legal claims, or in connection with an emergency that warrants use or disclosure of the information;
(d) to regulatory authorities, as required or permitted by applicable law;
(e) to legal, financial, insurance, and other advisors or in connection with the sale, reorganization, or management of all or part of our business or operations; and
(f) as consented by you from time to time, including to fulfill any other purposes that are identified at the time your personal information is collected.
Hugessen may use third party service providers located in Canada and the United States of America to provide certain services that support the Website and/or the Services. The services provided by our third party service providers may include, among other things, the following: (i) storage and hosting services; (ii) website development services; (iii) information technology support services; and (iv) analytics services. We may disclose your personal information to such service providers as needed for them to perform the services they are providing to us. To the extent that your personal information is provided to any third party service provider by us, such service provider will only use or otherwise process your personal information in a manner that is consistent with this Privacy Policy.
5. Storage, Security, and Retention
A. Storage
Hugessen makes use of third party service providers to store personal information on its behalf. Hugessen, through its third party service providers may store or otherwise process personal information using servers or other facilities located in Canada and the United States of America.
However, the government, courts, law enforcement, security, or regulatory agencies of the United States of America may be able to obtain access to or disclosure of personal information as permitted by the laws of the United States of America. By agreeing to this Privacy Policy, you are acknowledging and agreeing that governments, courts, law enforcement or regulatory agencies of the United States of America may be able to access your personal information and accept that such foreign laws may not provide the same level of protection as do the laws in Canada.
B. Security
Hugessen uses reasonable efforts to safeguard personal information against loss, misuse, and unauthorized alteration with security measures appropriate to the sensitivity of the information, including through the use of physical, organizational, and technological measures. However, it is important to remember that no method of transmitting or storing data is completely secure, and therefore we cannot ensure, warrant or guarantee the security of any such information.
C. Retention
We retain personal information only for as long as necessary to serve the purposes for which it was collected, or as otherwise required or permitted by applicable law. Our retention standards are consistent with these retention requirements.
In accordance with applicable law and our internal policies, we destroy, erase or anonymize personal information when we no longer need to retain it. Additionally, for personal information collected pursuant to a Client Agreement, we will destroy or erase such personal information in accordance with the applicable client’s written direction.
Please note that our use, disclosure or other handling of anonymized information is not subject to this Privacy Policy.
6. Cookie Policy
Our Website may use cookies. Cookies are tiny elements of data that are sent to your browser when you visit any of our websites. Cookies are stored by your browser and allow us to recognize you when you return to any of our websites. We and our business partners, marketing partners, or service providers may place cookies on our websites for marketing purposes, to remember your preferences, and to authenticate you.
Cookies uniquely identify your device or user account associated with the website. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies, you may not be able to take advantage of all the features that may be offered on our Website. For more information about cookies please visit https://www.aboutcookies.org.
7. Access, Corrections and Complaints
A. Access and Corrections
If you send our Privacy Officer a written request (please see Section 9 for more information about how you can contact our Privacy Officer), we can tell you what personal information about you we have and how we use and disclose such information.
We can give you access to your personal information, with certain exceptions permitted by law. You may verify the accuracy and completeness of your information and request changes, if appropriate. There may be a minimal charge for the retrieval of your personal information that you request. We will inform you if there is a charge.
We can assist you in identifying the appropriate means to have correction(s) made to your personal information and, where appropriate, we will attempt to correct any personal information which we may have given to a third party.
Conditions for Access/Corrections:
You will be required to provide sufficient proof of your identity to permit us to provide the information you have requested.
If you are an employee of a client, Hugessen may, in accordance with applicable law, work with the assistance of the client to respond to your access and/or correction request(s).
Subject to applicable law, please note that we may not be able to provide you with access to your personal information if it:
- is prohibitively costly to provide;
- contains references to other individuals;
- cannot be disclosed for legal, security or commercial proprietary reasons;
- is subject to solicitor-client or litigation privilege; or
- cannot be disclosed for any other reason permitted by law.
To the extent that you are not satisfied with our response to your written request, please contact our Privacy Officer (as provided in Section 9).
B. Complaints
We are committed to answering and resolving any privacy related questions, concerns, complaints, and inquiries. Please feel free to contact our Privacy Officer, using the contact information provided in Section 9 below.
Hugessen’s Privacy Officer will acknowledge receipt of your inquiry. Within 30 days of receiving your inquiry, our Privacy Officer will notify you regarding whether your inquiry has been resolved, or, in more complex cases, advise you what further steps are being taken and when you may expect a resolution.
If you are unsatisfied with our response or if your privacy related question(s), concern(s), complaint(s), or inquiry(ies) remains unresolved, you may contact your privacy regulator to file a complaint. For residents of Ontario, please contact:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Telephone: 1-819-994-5444
Toll Free: 1-800-282-1376
TTY: 1-819-994-6591
Website: www.priv.gc.ca
If you reside outside of Ontario, then you may use the following link to locate information on your provincial or territorial privacy regulator to file a complaint: www.priv.gc.ca/en/about-the-opc/what-we-do/provincial-and-territorial-collaboration/provincial-and-territorial-privacy-laws-and-oversight/.
8. Additional Rights
There are some additional rights that you may have according to where you are located. These rights are described below, and you can contact us to action them accordingly. If you are an employee of a client, Hugessen may, in accordance with applicable law, work with the assistance of the client to respond to requests relating to your actioning of any rights.
A. Dissemination, De-Indexation or Re-Indexation
Subject to applicable law, you may have the right to require us to cease disseminating your personal information or to de-index any hyperlink to your personal information if the dissemination of the information contravenes the law or a court order.
In addition, subject to applicable law, and provided certain conditions are met, you may require us to cease disseminating your personal information, de-index any hyperlink to such information, or re-index any hyperlink to such information.
B. Deletion
Subject to applicable law, you may ask that we delete certain personal information that we hold about you. However, please note that we may be required (by law or otherwise) to retain your personal information and not delete it. If this were to occur, then we will try to comply with your request after fulfilling any applicable retention requirement.
Additionally, once personal information is disclosed to third parties, we may no longer be able to access that personal information (as maintained by the third party) and cannot force the deletion of such information by those third parties.
C. Data Processing Use and Objection
Subject to applicable law, you may have the right to request that we restrict how we use or disclose your personal information. You may also have the right to object to the processing of your personal information. We will agree to any such restriction, provided that the law allows it and the restriction does not impact our ability to operate our business, provide diagnostic services, and comply with the law. Even when we agree to a restriction request, we may still use or disclose your personal information for the purpose of public health, safety and other similarly permitted public benefits, or as otherwise required by law.
D. Automated Decision Making
Subject to applicable law, if at any time our services use automated decision making to process personal information, you may have the right to object to the use of your personal information.
E. Data Portability
Subject to applicable law, you may have the right to receive your personal information in a structured, commonly used technological format.
F. Cross Border Transfers
This paragraph F is only applicable to residents of Québec. Where permitted by applicable law, we may disclose the personal information we have collected about you outside of Québec.
9. Contact
To exercise your rights, or if you have any questions, inquiries, or complaints about this Privacy Policy or Hugessen’s privacy practices, please contact our Privacy Officer as follows:
Hugessen Consulting Inc.
Privacy Officer
130 Adelaide Street West, Suite 3000, Richmond Adelaide Centre, Toronto, ON M5H 3P5
Email: privacy@hugessen.com
Last Updated: February, 2025