Farber (“Farber”, “we”, or “us”) includes entities operating as Farber Group, A. Farber & Partners Inc., Circle & Square, and Tax Solutions Canada.
Why do we collect personal information?
We may ask for your personal information to establish and serve you as our client or on behalf of our client(s) or others whose interests we may represent. The types of personal information we collect depend on the nature of our engagement and relationship with you. Generally, we collect personal information to provide our services to clients, to administer client accounts, to establish and manage client relationships and other commercial relationships, to determine a client’s right to participate in an engagement that we have undertaken, to fulfill certain statutory obligations, and to assist clients in fulfilling their own statutory obligations.
Additionally, we collect personal information to provide our clients with newsletters and email alerts, hold events for our clients, share business and employment opportunities with our clients, and evaluate client satisfaction.
We will only collect the information we need for the purposes of which we have advised you.
What personal information do we collect?
We may obtain information about you from many sources, including the following:
- Information we receive from you, or which is provided to us on your behalf, on Statements of Affairs, Statements of Income and Expenses, Proofs of Claim, job applications, related documents, and other forms, such as your name, address, email address, date of birth, telephone number, employer name, job title, marital status, number and type of dependents, assets, liabilities, expenses, and income.
- Information from third parties about your transactions with them or others, such as your name, address, telephone number, age, credit card usage, insurance coverage, transaction history, account number(s), claims history, level of indebtedness, and asset ownership and usage.
- Information from consumer reporting agencies, public records, and data collection agencies, such as your obligations with others and your creditworthiness.
- Information from credit counselors or other advisors including name, address, telephone number, age, marital status, credit usage, employment history, addictions, social history, and other information relating to your solvency, or the solvency of others.
- Information gathered from visitors to Farber’s website, such as your user preferences and website analytics information (see our Cookie Notice).
We do not collect personal information about children
We understand the importance of protecting the privacy of children. This Website is not designed or intended for use by children under 16 years old, nor do we knowingly collect or store personal information about children under 16 years old. If you believe that we have collected personal information about a child under 16 years old, please contact our Privacy Officer at the coordinates below so that we may delete the information.
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, consumer reporting agencies, credit counselors, other parties involved in your transaction or file, government agencies or registries, employers (if we are acting for you at your employer’s request), and accountants or other professional advisors.
How do we use your personal information?
We do not sell personal information
Unless expressly authorized by you or in conjunction with a transfer of ownership of all or part of our business, we will never sell your personal information to any third party.
Use of personal information
- to provide you our services, including pursuant to an engagement with you or on your behalf
- to assess client eligibility for credit
- to manage our business, including fulfilling contractual obligations and auditing our operations
- to administer client accounts
- to detect and prevent negligence, fraud, and theft
- to evaluate client satisfaction
- to provide you with information about our services
- to provide you with newsletters and email alerts
- to hold events for our clients
- to share business and employment opportunities with our clients
- to fulfill our statutory obligations
The following are some of the purposes for which we may also use your personal information:
Our websites are for general information use and we do not collect any personal information from website visitors other than cookies, the use of which is outlined in our Cookie Notice. There are circumstances where you may choose to register to our events or subscribe to our services. In these cases, Farber may contact you in the context of your registration or subscription.
Executive search portal
Farber allows you to subscribe to our news and event notifications. If you so subscribe, we may collect your name, email address, company name, and job title so that we may send you information that is relevant to you and your current role.
Farber events are managed via our Website. For event registrations where we need to process a payment from you, we may use your personal information and/or disclose your personal information to a third party payment processor for such purposes.
Careers at Farber
If you apply for a career at Farber, we may use your personal information to evaluate your candidacy for a career at Farber and may retain any cover letter, resume, and documents you supply to us for the purposes of evaluating them with respect to future relevant opportunities.
How do we protect your personal information?
Farber employs industry-accepted physical, technological, and organizational safeguards to protect your personal information. We have policies and procedures in place to protect your personal information from loss, unauthorized access, modification, or disclosure. We operate out of secure premises and have implemented technological safeguards, including security software, passwords, and firewalls to prevent unauthorized computer access. Access to your personal information is restricted to employees of our member companies and our agents whom we determine have a legitimate business interest in accessing such information for the purposes of carrying out our engagements or providing authorized services to you. Further, we provide training and communications programs designed to educate employees about the importance and need to observe the safeguarding and confidentiality of your personal information.
All our suppliers and agents, as part of their agreements with us, are bound to maintain your confidentiality and may not use your personal information for any unauthorized purpose.
When your personal information is no longer needed for the purposes explained to you, we will destroy or erase it, or convert it to an anonymous form.
Please note that no method of transmitting or storing information is completely secure. While we take appropriate measures to protect your personal information, there is always a risk that it may be lost, intercepted or misused. We may exchange electronic versions of documents and e-mails with you using commercially available software that is vulnerable to attack by viruses and other destructive electronic programs. We cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be virus-free. We make no warranty with respect to the integrity of any electronic communications between us and you or with respect to the security of any such communication and you consent to our exchange of electronic communications, including confidential documents, unencrypted.
Disclosures of your personal information
We may release your information to third parties in the following instances:
- With your consent. You may consent to Farber sharing your information with a third party, including other member companies of Farber. For instance, where you apply for an advertised vacancy through our executive search portal, we may disclose your personal information to the company advertising the vacancy.
- For servicing purposes to our suppliers and agents. We disclose limited information, on an as-needed basis, to our suppliers and agents who provide goods and services to you or to us so that we may carry out our engagement with you. For instance, where we need to process a payment from you for services to which you have subscribed, we may disclose your personal information to a third party payment processor.
- When required or permitted by law. We may disclose personal information when necessary to comply with court orders and regulatory rules. We may disclose personal information to help us collect a debt owed to us by you. We are also obligated to complete certain statutorily mandated forms in the course of carrying out engagements where we are the “Trustee in Bankruptcy” or the “Trustee” or “Administrator” under a proposal, which may require the disclosure of personal information.
- For administrative purposes. We may disclose your personal information to satisfy our administrative and insurance requirements.
- Business transactions. We may transfer your personal information in connection with the merger, reorganization, sale, or transfer of all or part of our business. We may disclose your personal information before and after the transaction. However, if the transaction is completed, we will require the third party acquirer 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.
Information transferred to service providers
When we transfer your personal information to a third party to provide administrative and other services, we use appropriate measures to ensure that the third party will only use your personal information to perform the services we have specified. The global nature of our business sometimes requires us to use administrative service providers who may be located in the United States or elsewhere outside of Canada. Accordingly, your personal information may be transferred outside of Canada and if so, will be subject to the legal requirements of the applicable foreign jurisdictions, including local requirements to disclose information to courts, law enforcement, and national security authorities. If you wish to obtain more information about our policies and procedures relating to our transferring and processing information outside of Canada, please contact our Privacy Officer at the coordinates below.
Your right to access your personal information
You may ask for access to any personal information that we hold about you. You also may ask how we collected the information, how we are using it, and to whom we have disclosed it. Your request for access must be in writing, and should be addressed to our Privacy Officer at the coordinates below. We will acknowledge your request in writing. We may request that you provide us with information to allow us to confirm your identity before providing you with the information that you have requested. Access will generally be provided free of charge; however, if you request that information be copied or transmitted, we may charge a reasonable fee. We will notify you of the amount of the charge in advance, and provide you with an opportunity to withdraw your request. We will provide you with access to your personal information within 30 days of our receipt of your request, or provide written notice that additional time will be required to comply with your request.
In certain circumstances, we may be unable to provide access to some or all of the information that we hold about you, including instances where those records contain the personal information of other persons, contain confidential information proprietary to Farber or its partners, or cannot be disclosed for other legal reasons. If we are unable or not permitted by law to provide you with access, we will provide you with an explanation and indicate further options available to you.
Keeping your information accurate
We will make every reasonable effort to keep your personal information accurate and up to date. You can help by keeping us informed of any changes to your personal information, such as a change in email, mailing addresses, or telephone number(s). If you find any errors in our information about you, please tell us and we will correct the information. We will also convey the corrected information to other relevant parties, as needed. For information that remains in dispute, we will note the dispute in your file.
Commercial electronic mailing lists
Farber makes every effort to remain compliant with anti-spam legislation, including Canada’s Anti-Spam Legislation (CASL). We will only send commercial electronic messages (“CEMs”) to you with your consent. Should you wish to join our mailing list, please visit https://farbergroup.com/sign-up-for-our-news-and-insights/ . Should you no longer wish to receive CEMs from Farber, please follow the unsubscribe instructions included toward the bottom of a CEM or email us at firstname.lastname@example.org with “Unsubscribe” in the subject line and your email address in the body. Please note that we may still send you certain essential CEMs relating to a current Farber engagement or that we are legally required to send to you.
Withdrawing your consent
You may refuse or withdraw consent for us to collect, use, process, or disclose your information at any time and we will record and respect your choice. Certain consequences may flow from such refusal or withdrawal and we will advise you of those, if applicable, at that time. Such a decision must be communicated by you, in writing, to our Chief Privacy Officer at the coordinates below.
Additional terms applicable to European Union data subjects
Farber is the “data controller” of personal data collected by all of Farber Group, A. Farber & Partners Inc., Circle & Square, and Tax Solutions Canada. As data controller, Farber collects, processes, discloses, and safeguards your personal data in compliance with the requirements of GDPR, as amended from time to time. We understand our legal obligation to protect your personal data, and we take that obligation very seriously.
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 you request, to take the steps necessary to provide you with such services;
- in the furtherance of our legitimate interests in maintaining business relationships and communication with you as a business contact about our activities and services. We consider that our legitimate interests are in compliance with GDPR and your fundamental rights and freedoms. You have the right to object to any of this processing. To do so, please contact our Privacy Officer at the contact coordinates below; or
- under a legal obligation to collect or process personal data from you.
Retention of your personal data
Additional data subject rights
In addition to the rights described above under “Your right to access 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 that we will be unable to provide you with certain services. 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.
Addressing your concerns
If you have 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 in writing at the address set out below. For “access to information” requests, any such access provided will be free of charge, unless otherwise stated beforehand, and we will respond to your request as promptly as possible. We treat all privacy concerns seriously and will investigate any reasonable concern and seek to resolve it within a reasonable amount of time.
150 York Street, Suite 1600
Toronto, ON, Canada M5H 3S5
Attention: Chief Privacy Officer
Last updated: October 7, 2019.