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Lambton Communications Limited o/a Security Response Center Privacy Policy

Lambton Communications Limited o/a Security Response Center (“SRC” or “we”) are committed to protecting the privacy of our customers. The protection of your Personal Information is another way in which we continue to provide exceptional service.

SRC is committed to ensuring the accuracy, security and privacy of Personal Information in compliance with all applicable legislation. The SRC Privacy Policy contains the principles and guidelines for how we process the Personal Information of customers, service providers and other individuals (“you” or “your”).

Definitions

Personal Information means information about an identifiable individual, or information that allows an individual to be identified. For the purposes of this Privacy Policy, personal information is information about an identifiable individual as it is defined in the Personal Information Protection and Electronics Document Act. Generally, business contact information is not considered to be Personal Information.

Process or Processing or Processed – the collection, use, disclosure, retention and/or deletion of Personal Information.

Consent for Collection, Use and Disclosure of Your Personal Information

Consent is required for the collection, use and disclosure of your Personal Information. SRC makes best efforts to obtain your consent at the time your Personal Information is collected. By submitting Personal Information to SRC, you agree that we may Process this information in compliance with this Privacy Policy, and as permitted or required by law.

You may withdraw your consent to collect, use or disclose your Personal Information at any time by advising SRC privacy officer at privacy@SRC.net. The withdrawal of your consent is to be provided in writing or by email. It is important that you understand that by withdrawing your consent to Process your information, SRC may no longer be able to provide you with, or to continue to provide you with, certain services which may be of value to you.

Privacy legislation, in specific and limited circumstances, allows for the collection, use or disclosure of information without consent. If such an exception is relied upon, SRC will document all exceptions along with the rationale to support our reliance on it.

What Personal Information does SRC Collect?

During your interaction with SRC, and while providing services to you, we may collect or obtain Personal Information about you. The types of information that SRC may collect about you includes, but is not limited to your name, address, telephone number, email address(es), billing and accounting information, employment information, and financial and payment information.

Why does SRC Collect Your Personal Information?

In general, SRC collects, uses or discloses the Personal Information of our customers or service providers to install security monitoring equipment and to provide monitoring services.

Use of Personal Information to Provide Services to Our Customers

In order to provide alarm installation and monitoring services, SRC may use your Personal Information for the following purposes:

• to determine whether SRC can provide service to a customer;
• to manage customer relationships;
• to provide alarm installation and/or monitoring services;
• to share Personal Information to and from third parties for the purpose of providing alarm installation and/or monitoring services;
• as permitted by, and to comply with, any legal or regulatory requirements or provisions; and,
• for any other purpose to which you consent.

Use of Personal Information for the Operation of Our Business

SRC may also use your Personal Information for the purposes of, or in connection with, the following:

• customer account opening and other administrative purposes;
• financial accounting and invoicing;
• client relationship purposes, which may involve contacting you to receive feedback on services provided;
• determining whether to establish and maintain commercial relationships with suppliers, vendors, and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual obligations;
• business development purposes, including to contact and communicate with customers, suppliers and other third parties, and to conduct surveys, research and evaluations;
• developing, enhancing, marketing, selling or otherwise providing SRC products and services;
• distributing our newsletters and other informational and promotional communications to individuals on our mail and email lists, including via third party mailing houses and email service providers;
• detecting and protecting SRC, our customers and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity;
• receiving service from our professional advisors, such as lawyers, accountants and consultants; and,
• protecting our rights and those of our customers.

Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with your consent, or as required by law. SRC will obtain your consent, if your Personal Information is to be used for a purpose other than for which it was originally collected, used or disclosed.

To Whom Does SRC Disclose Your Personal Information?

In order to fulfill one of the purposes in the “Why Does SRC Collect Your Personal Information” section above, we may disclose your Personal Information to: third parties that provide services to SRC; a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangement; to our insurers or regulatory agencies, or others in connection with regulatory or other activities relating to SRC’ obligations; to government or law enforcement authorities; or any third party, when you have provided your consent.

We may need to disclose your Personal Information if required to do so by law, by a regulator or during legal proceedings.

In cases where disclosure of information to a third party is authorized, the least amount of information appropriate for the intended purpose is disclosed.

Where is Your Personal Information Stored?

Your Personal Information is stored in secured locations and on servers controlled by SRC, within Canada.

Some of the recipients of your Personal Information listed in the “To Whom Does SRC Disclose Your Personal Information” section above may be based outside of Canada. Laws in jurisdictions outside of Canada may not afford the same level of privacy protection. In such cases, we will make best efforts to ensure that there are adequate safeguards in place, including contractual safeguards, to protect your Personal Information.

How Does SRC Protect Your Personal Information?

SRC uses a range of physical, electronic and organizational measures appropriate to the sensitivity of your Personal Information to ensure that it is kept secure. These measures include:

• education and training to relevant staff to ensure they are aware of our privacy obligations when handling Personal Information;
• administrative and technical controls to restrict access to Personal Information;
• technological and security measures, including firewalls, multi-factor authentication, encryption and malware software; and,
• physical security measures, such as security passes to enter areas where Personal Information is stored or can be accessed.

SRC strives to protect the Personal Information of our clients. While we use appropriate security measures once your Personal Information has been disclosed to us, the transmission of data over the internet (including by electronic communications) cannot be guaranteed to be secured.

Retention of Your Personal Information

SRC will retain your Personal Information for the longer of the following periods: (i) as long as is necessary to provide the services for which we were retained; (ii) any retention period that is required by law; (iii) the end of the period in which litigation or investigations might arise in response of the services provided to our customers; or (iv) as directed by SRC internal retention schedule.

Your Privacy and the SRC Website

We may collect information about you whenever you interact with our website, including your device information, browsing information, and browsing activity (collectively, “automatically collected information”). Automatically collected information may include IP addresses, unique device identifiers, cookie identifiers, device and browser settings and information, and internet service provider information. Automatically collected information also may include information about when and how you access and use our website, such as the date and time of your visit or use, the websites you visit before coming and after leaving our website, how you navigate our website and the website pages and items you view.

Cookies – When an individual visitor accesses the SRC website, we may use a browser feature called a ‘cookie’ to collect information such as the type of internet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from the website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.

Online Communications – In order to provide our website visitors with a service or information, visitors may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, subscribing to a newsletter or a mail or email list, participating in a seminar or other event, and participating in contests and surveys. If you are known to SRC as a registered user of an online service, we may combine and store Personal Information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.

Promotional Email Communications – Occasionally, we may send marketing or promotional email communications to you, including information about the services of SRC. In this process, we may collect certain information related to your viewing and use of the email communication, and compile generally the related statistics. We may combine and store any such information to manage and improve our email communications to you. We will include instructions on how to unsubscribe if you decide you do not want to receive any future marketing or promotional emails from SRC.

Links – Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third-party websites may have different privacy policies and practices than SRC, and we have no responsibility for such third-party websites.

How to Make an Inquiry About Your Personal Information?

You have various rights in relation to your Personal Information. Specifically, you have a right to:

• obtain confirmation that we are processing your Personal Information and request a copy of your Personal Information held by SRC.
• request that we update your Personal Information or correct such Personal Information that you think is incomplete or inaccurate. If there is a disagreement about the accuracy of your Personal Information, a notation will be made to your Personal Information setting out your correction.

Further Information

SRC has appointed a privacy officer to oversee compliance with our Privacy Policy and applicable privacy legislation. For additional information on SRC’ privacy practices, or to express concern about compliance with this Privacy Police, please contact our privacy officer at:

Privacy Officer
Security Response Center
506 Christina St N,
Sarnia, ON N7T 5W4

privacy@SRC.net

1.877.263.2627

Changes to the Privacy Policy

On occasion, we may modify or amend the Privacy Policy.

To communicate when the Privacy Policy is revised, the revision date at the bottom of the page will be changed. The amended Privacy Policy will apply from that revision date. It is recommended that you periodically review this Privacy Policy to remain informed about how we are processing and protecting your Personal Information.

Revised: February 25, 2025

Accessibility Policy

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