Hilltop Partner Network Inc. (HPN) is committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information (“Personal Information”). As part of this commitment, our Privacy Policy governs our actions as they relate to the collection, use and disclosure of Personal Information. Our Privacy Policy is based upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act.

1. Introduction

We are responsible for maintaining and protecting the Personal Information under our control. This Privacy Policy governs HPN’s data collection and usage on hilltoppn.com, the HPN Communities portal, and the Hilltop Hub, hereafter called the “Sites”. By using the Sites, you consent to the data practices described in this statement.

2. Identifying Purposes

We collect, use and disclose Personal Information to provide you with the product or service you have requested and to offer you additional products and services we believe you might be interested in. The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address, payment and other contact information is provided as part of the order process.

3. Consent

Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law. Providing us with your Personal Information is always your choice. However, your decision not to provide certain information may limit our ability to provide you with our products or services. We will not require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except as required to be able to supply the product or service.

4. Limiting Collection

The Personal Information collected will be limited to those details necessary for the purposes identified by us, or as otherwise required or permitted by this Privacy Policy or applicable laws. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, or the Internet:

• Information collected indirectly, through our Sites’ technology. When you access our Sites, our Internet access logs automatically record your browser type, the time and date of your visit, the IP address of the connecting computer, and the URLs you accessed. None of this information is personally identifying. It is used solely for system administration purposes and to analyze traffic on our Sites.
• Directly, when you knowingly provide information (for example, to join the network as a member, in the online user profile you create, or when you complete a contact form through the Sites). Information that we obtain directly from you is used only for those purposes in which we have specifically obtained your permission and only so that we can serve your needs and our legitimate business objectives. Information that members share in their user profile in HPN Communities and/or Hilltop Hub will be visible to all other members using those Sites.
• Directly, when members engage with other members through the Sites (for example, by posting in the member forum or sending a direct message in HPN Communities). Information that members share in posts on the HPN Communities forum will be visible to all other members using the Site. Direct Messages sent through HPN Communities can be accessed by the Sites’ Administrators and the intended recipient(s) but are not visible to other members or HPN employees.

5. Limiting Use, Disclosure and Retention

Personal Information may only be used or disclosed by us for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by this Privacy Policy or applicable laws.

HPN does not sell, rent, or lease member or customer lists to third parties. We may, from time to time, share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to HPN, and they are required to maintain the confidentiality of your information.

HPN does not collect or disclose sensitive personal information, such as race, religion, or political affiliations.

6. Accuracy

Personal Information will be maintained in an as accurate, complete, and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

7. Safeguarding Information

Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information. We take all reasonable precautions to protect your Personal Information from any loss or unauthorized use, access or disclosure.

When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

8. Access

Upon request, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to it. You may verify the accuracy and completeness of your Personal Information, and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.

9. Challenging Compliance with Privacy Laws

All questions or concerns regarding our privacy practices should be directed to the contact information below.

We will investigate all complaints concerning compliance with this Privacy Policy and if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our privacy policies and procedures.  We will inform you of the outcome of the investigation regarding your complaint.

10. Policy Changes and Suggestions

HPN reserves the right to add, remove or modify portions of this Privacy Policy at any time at our discretion. You are encouraged you to periodically review this Privacy Policy to be informed of how we are protecting your information.

Questions or inquiries with respect to our Privacy Policy or our practices by contacting member.info@hilltoppn.com.

Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca/en/.

Additional Information

Cookies

A cookie is a small computer file or piece of information that may be stored in your computer’s hard drive when you visit our Sites. We may use cookies to improve our Sites’ functionality and, in some cases, to provide visitors with a customized online experience.

Cookies are widely used, and most web browsers are configured initially to accept cookies automatically. You may change your Internet browser settings to prevent your computer from accepting cookies or to notify you when you receive a cookie so that you may decline its acceptance. Please note, however, if you disable cookies, you may not experience optimal performance of our Sites.

Other Websites

Our Sites may contain links to other third-party sites that are not governed by this Privacy Policy. Although we endeavour to only link to sites with high privacy standards, our Privacy Policy will no longer apply once you leave our Site. HPN is not responsible for the privacy of information or other content on websites outside of our own Sites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

 

Updated: January 2024