The privacy of your personal information is of the utmost importance to Parrish and Heimbecker, Limited (“P&H”, “we”, “us” or “our”, as appropriate).

This Privacy Policy governs P&H’s collection, use, storage, disclosure and disposal of personal information (i) obtained in the course of the purchase, sale, promotion, and distribution of our products and services, (ii) collected to engage in marketing and advertising in relation to the products and services that we offer, and (iii) provided online through our corporate website located at http://www.parrishandheimbecker.com (the “website”). It also explains how we use cookies and similar technologies.

By doing business with P&H, providing us with your personal information, or by visiting our website, you agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy does not apply to personal information about our employees, partners or contracted staff, which is dealt with in a separate policy.

Accountability
P&H is accountable and responsible for the proper management of all personal information in its custody and control. P&H’s Privacy Officer is responsible for overall privacy compliance.

P&H is committed to meeting its obligations under Canadian federal and provincial privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA). Personal information refers to information that identifies you as an individual. Personal information collected by P&H may include both (i) information obtained directly from the individuals from which we purchase grains, sell products to, or provide services to, such as the individuals’ name, home address, personal email address, home telephone number, financial information; and (ii) personal information obtained through our website.

Our business operations involve providing products and services to commercial customers as well. In this capacity, we may process the business contact information or other business information of our commercial customers. Although business contact information does not qualify as personal information under PIPEDA, we strive to use the same confidentiality and standard of care with our commercial customers and their business data as we do with the personal information of our individual customers.

Policies, procedures, guidelines, and safeguards have been put in place to ensure your information is protected. Confidentiality and privacy are important to our business, and our Employee Handbook requires all employees, partners or contracted staff of P&H to maintain customer confidentiality.

Our Collection and Use of Your Personal Information
P&H believes in collecting and using personal information responsibly and only for the purpose for which it was collected. We require your personal information in order to establish a relationship with you. We may collect and use your personal information to:

• establish your identity;
• ensure our records are accurate;
• verify previously given information when necessary;
• create, establish and administer your account;
• execute transactions/provide services to you;
• properly report account status to you;
• provide you and your representatives with account statements/information;
• provide you with customer statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account;
• respond to customer or supplier inquiries;
• provide customers with access to information about P&H services and products;
• understand the needs of customers and prospective customers so as to offer products and services that meet those needs;
• develop and offer additional products and services that we feel may be of interest to our customers or that we believe meet our customers’ changing needs; and
• allow us to meet contractual requirements relating to the products and services provided to you or obtained from you, (collectively, the “Authorized Purposes“).

P&H only collects personal information about an individual with the individual’s knowledge and consent. Generally, this means that we collect most of our information about you directly from you. For details on the type of information that we may collect when you visit our website, please refer to the section of this Privacy Policy entitled “Website Privacy“.

Your Consent and Right to Withdraw Consent
Your consent may be express or implied. In general, by doing business with P&H or submitting information to us in connection with our products and services, you are indicating your consent to our collection, use and disclosure of your personal information in the manner described in this Privacy Policy.

An express consent form is also contained in our Customer Credit Application Form and other agreements. Express consent may also be obtained when clients purchase a product or service subsequent to account opening. An authorized representative of the client (such as a legal guardian or a person having power of attorney) can give consent.

P&H may from time to time contact you to provide you with offers for other products and services. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us by mail at 1400-201 Portage Avenue, Winnipeg, Manitoba, Canada R3B 3K6 or by telephone at 204-956-2030. Your decision to withdraw personal information may limit the services or products we are able to provide to you.

Sharing of Personal Information
P&H only uses and discloses personal information as reasonably required for the Authorized Purposes listed above. In furtherance of the Authorized Purposes, your information may be made available to related companies or third-party service providers to fulfill the purposes for which it has been collected. Moreover, P&H may share your personal information as follows:

• Service providers. We hire service providers to perform services on your behalf. We provide them with a limited amount of information in order that they may provide services including, but not limited to, data processing, document storage, imaging, and undertake mailings on our behalf. They are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others.
• As permitted or required by law. P&H is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may release certain personal information when we believe in good faith that such release is reasonably necessary to protect the rights, property, and safety of others and ourselves and to outside sources to help us collect a debt owed to us by you.
• Business re-organization and transaction. As we continue to grow, we may in the future re-organize or streamline parts of our operations. Since our business is based on our client relationships, we may disclose personal information to a third party in connection with an amalgamation, re-organization, transfer or financing of parts of our business. However, in the event the sale goes through, we will require that the receiving party agree that they will be similarly bound by the provisions of this Privacy Policy and that they will only use and disclose your personal information as we are similarly entitled under this Privacy Policy. In the event the sale does not go through, we will require the potential purchaser to not use or disclose your personal information in any manner whatsoever and to completely erase the same.
• Affiliates. P&H may disclose personal information with its affiliates for the purpose of obtaining a better understanding of and making decisions about our industry and business, including for strategic planning purposes.

Where personal information is shared with such third parties, P&H takes reasonable steps to ensure that such third parties are bound by appropriate agreements or other measures to protect the confidentiality of the personal information.

Website Privacy
When you visit our website, we may collect the following type of information:

• Information that you provide. We may collect your name, contact information, e-mail address and any other information provided when you interact with us, make an inquiry through our website or otherwise contact us. We will only use this information to contact you in order to answer your questions and requests, to manage our everyday business needs, and in compliance with applicable law. If you have applied for employment with P&H, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within P&H as well as other career development resources.
• Information collected using electronic means. Using electronic means we may also collect technical information, such as cookies. A cookie is a small data file that a website may create and write to a computer’s hard drive when a user visits the site. The information collected may include the IP address of your computer, which browser you used to view our website, operating system, resolution of screen, location, language settings in browsers and the website you came from and searched for keywords (if arriving from a search engine). This information is used to recognize you as a previous user of the website, offer customized web pages for your use, track your activity at our website to respond to your needs, and otherwise facilitate your web experience. The cookies that we may use will not be used to retrieve any information from your computer that you have not already provided. You can block the use of cookies by activating the settings in your browser but if you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of our website.

This Privacy Policy only addresses the use and disclosure of information by P&H. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy policies provided by all third parties prior to providing them with information.

Commercial Electronic Communications
You can always limit the communications that P&H sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Please note that even if you opt-out of promotional emails, we may still need to contact you with important information about your account or our business relationship, in compliance with Canada’s Anti-Spam Legislation. If you have any questions about your choices or if you need any assistance with opting-out, please contact the P&H Privacy Officer at the address in the Inquiries and Complaints section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.

Access
Upon written request, we will provide you with access to your personal information in accordance with applicable privacy laws. Most of your information is in the form of account documentation and transaction records. Although every effort will be made to accommodate your request, please note that we may refuse access in certain circumstances prescribed by law such as: where the information contains the personal information of other persons, where disclosure of your information to you would reveal our confidential commercial information or violate our legal privilege, or where we are otherwise required or permitted by law to refuse access.

Keeping Information Accurate
P&H uses reasonable efforts to keep personal information up-to-date, accurate, and relevant for its intended use. You are responsible for informing us of any changes to your personal information             such as if you move, if there is a change in your contact numbers or if there is any other material change in your personal information. If you find any errors in our information about you, let us know and we will make the corrections needed as soon as reasonably possible and make a reasonable effort to convey such changes to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Retention
We retain your personal information only as long as it is reasonably required for the Authorized Purpose it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed or required, we have procedures to destroy, delete, erase or convert it to an anonymous form in a secure manner.

Storing and Safeguarding Personal Information
Security safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which it is held. P&H’s safeguards vary depending on the sensitivity of the personal information. The highest level of protection is given to the most sensitive personal information.

For example, all client information is protected from unauthorized access through the use of secure passwords, user logons, or other security procedures. Within P&H, we restrict access to personal information about you to those P&H Personnel who need to know the information in order to perform their jobs, such as servicing your accounts or notifying you about new or existing services. To protect information about you, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we regularly review and adjust these safeguards (including security and encryption methods) in response to advances in technology. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time.

Your personal information may be kept in electronic, microfilm or paper format at the offices of P&H, its affiliates or its third-party service providers. Your information may also be kept in secure off-site storage facilities.

Security Incidents
P&H will take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws including, without limitation, complying with mandatory breach reporting and record keeping requirements.

P&H Personnel who become aware of any security related incident, or suspect the occurrence of any security related incident, are required to immediately report the matter to P&H’s Privacy Officer or appropriate P&H management. P&H’s Privacy Officer will ensure that the necessary record-keeping and notification requirements relating to security incidents are met.

Location of Your Personal Information
We usually store and process your personal information in Canada. However, the disclosure of your personal information in accordance with this Privacy Policy may result in your personal information being transferred, processed and/or stored outside of Canada. In such event, P&H will take appropriate technical, organizational, and legal steps to secure such information, and will ensure that individuals are notified that their personal information may be transferred, processed or stored outside of Canada and may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. The laws of other countries regarding the collection, use, and disclosure of personal information may be different from the laws of Canada.

Inquiries and Complaints
If you have any questions about privacy and confidentiality, or any concerns about the way a request for personal information was handled, you can contact us at the coordinates below:

Parrish and Heimbecker, Limited – Head Office

ATTN:  Privacy Officer

Address:
201 Portage Avenue, Suite 1400
Winnipeg, Manitoba
CANADA R3B 3K6

Tel. 1-204-956-2030

Toll Free 1-800-665-8937

Fax. 1-204-943-8233

In most instances, we will investigate and reply to inquiries or complaints within 30 days. Where a complaint is found to be justified, P&H will take appropriate measures, if necessary, including amending our privacy policies and/or information handling practices. If we are unable to respond to your inquiry within 30 days, you will be notified in advance of the end of such 30 day period of when you should expect to receive a response. Please be sure to include your name, address, phone number and information relating to the nature of your inquiry or complaint.

Change of Privacy Policy. Our Privacy Policy may change from time to time. We reserve the right to modify and update this Privacy Policy at any time and in our sole discretion. We will not materially reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on our website and, if the changes are significant, we will provide a more prominent notice.

This Privacy Policy was last updated on July 5, 2019.

Please note that both the English and French versions of our Privacy Policy have equal legal value.