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CASL Acceptable Use

ANTI-SPAM COMMITMENT

msg global solutions Canada Inc., and each of its affiliates or programs (“Cookhouse Labs”), is committed to providing transparency to outside parties with respect to the compliance of the organization’s electronic communication with Canada’s Anti-Spam Legislation, in effect as of July 1st, 2014, and its relevant rules and regulations (hereinafter “CASL”). To that end, the Msg global solutions Anti-Spam Commitment is a formal statement of rights and obligations which is made available to outside parties. It is intended to inform outside parties of the type of responsible and transparent practices adopted by Msg global solutions when electronically communicating with outside parties, to inform outside parties about who they may contact at Msg global solutions for any concern pertaining to electronic communications, and to inform such outside parties of where and how they may unsubscribe to any electronic communications from msg global solutions. This document also includes a series of answers to questions about spam and msg global solutions’ practices that are frequently asked by outside parties that msg global solutions may communicate with.

1. APPLICATION AND SCOPE.

This Anti-Spam Commitment generally applies to any electronic communications sent by msg global solutions to outside parties and is protected by a range of business procedures, processes and policies to ensure that such communications are done in compliance with CASL. msg global solutions, in its electronic communications with outside parties, has to comply with the rules established by CASL and enforced by the Canadian Radio-television and Telecommunications Commission, the Competition Bureau and the Privacy Commissioner of Canada. CASL regulates all commercial electronic messages (“CEM”), which are messages that include among their purposes, the encouragement of participation in a commercial activity.

2. WHAT IS msg global solutions DOING TO COMPLY WITH CASL?

msg global solutions has undertaken various initiatives in order to make sure that it is compliant with CASL. It has adopted this Anti-Spam Commitment to provide transparency to outside parties with respect to the compliance of the organization’s electronic communication practices with CASL, as well as undertaken the following initiatives:

msg global solutions has implemented CASL compliant consent forms

The consent of outside parties is necessary in order for msg global solutions to send a CEM. This consent typically must be “express”, but in certain circumstances consent can be “implied” and in others, messages are specifically exempt from consent requirements. msg global solutions has modified certain consent forms in order to ensure that the express consent obtained from recipients is in compliance with CASL.

Your communication preferences can be updated at any time by visiting the Preference Centre, which can be accessed at any time via our website, and you will be notified via email when changes have been made. You can have your email address removed from our mailing lists at any time, although even if you unsubscribe to receiving CEM from Msg global solutions, you may still receive electronic messages from msg global solutions which relate to an ongoing business relationship or which are exempt under CASL.

msg global solutions has modified its email footers

msg global solutions has modified its email footers to manage CASL’s consent requirements. Under CASL, all CEM sent must include certain prescribed content. For example, msg global solutions must clearly identify itself as the party sending the CEM, provide a method whereby the recipient can readily contact msg global solutions, such as a mailing address and one of (i) a telephone number with active response voicemail; (ii) an email address; or (iii) a web address; and provide a working unsubscribe mechanism. CASL compliant email footers have been updated on all CEM sent from msg global solutions, in order to ensure compliance with CASL.

msg global solutions has incorporated Unsubscribe Mechanisms

msg global solutions has incorporated unsubscribe mechanisms into all CEM, in order to manage CASL’s consent requirements. Under CASL, each CEM must provide a working unsubscribe mechanism (functional for 60 days), which must be processed without delay, within a maximum of 10 business days. msg global solutions has set up a uniform process in order to ensure that all unsubscribe requests will be complied with. You may at any time unsubscribe from receiving CEM from Msg global solutions by following the process laid out in the electronic message you receive, or contact: hello@cookhouselabs.com. However, even if you unsubscribe to receiving CEM from msg global solutions, you may still receive electronic messages from msg global solutions which relate to an ongoing business relationship or which are exempt under CASL.

3. WHY ARE YOU RECEIVING AN ELECTRONIC MESSAGE FROM msg global solutions?

The types of CEM msg global solutions may send from time to time could include the following:

  • CEM sent to msg global solutions’s current or potential clients (whether individuals or businesses), by msg global solutions’s marketing department or msg global solutions’s sales and business development team. For example, this may be for prospecting purposes or in order to answer a request for information or an inquiry;
  • CEM sent to msg global solutions’s current or potential service providers by various msg global solutions business units. For example, msg global solutions may outsource part of its activities to a third party (such as a maintenance company, a translation service provider, etc.) or, msg global solutions HR department may contact potential employees electronically for recruitment purposes.
  • CEM sent to msg global solutions’s current or potential business partners. For example, this may be for building or finding new ventures and partnerships with industry companies, groups and associations.

If you have received a CEM from msg global solutions and you believe that you should not have, please assess as to whether you have provided implied or express consent to receive CEMs from msg global solutions, or if an exemption applies.

  • Express Consent: You can verify that you have provided express consent to msg global solutions (or verify the status of your consent) by reviewing your preferences in the Preference Centre.
  • Implied Consent: msg global solutions may infer your implied consent if:
  • msg global solutions has an existing business relationship with you or has a former business relationship with you which terminated less than two years ago (for instance, you are a former client);
  • msg global solutions received an inquiry from you within the last 6 months;
  • You disclosed your electronic address to a msg global solutions employee (for example you provided your business card to a msg global solutions employee) or you conspicuously published your electronic address (for example, via a corporate website or in a brochure) and the CEM sent is in connection with your business role and function.

When is an electronic message exempt under CASL?

If you are receiving an electronic communications from msg global solutions, it may be a message that is exempt under CASL. This would be the case if the message is one the following:

  • you have a personal relationship with the msg global solutions employee who contacted you, meaning that you have previously had a direct, voluntary, two-way communication;
  • you have a family relationship with the msg global solutions employee who contacted you;
  • the CEM is sent within msg global solutions (between employees of msg global solutions);
  • the CEM is sent between msg global solutions and another business, where there is an ongoing relationship between msg global solutions and this other business;
  • the CEM was sent by msg global solutions to you, in order to respond to your request or inquiry; or
  • the CEM was sent by msg global solutions to you, in order to enforce a legal right or obligation (for instance, if you have an outstanding debt, or breached a contract that you have with msg global solutions, etc.).

In certain situations, your consent is not required for certain types of messages sent by msg global solutions, although you may still unsubscribe from future transmission of similar messages. The type of messages where msg global solutions does not need your consent is an electronic message that:

  • is sent once, following a referral by a current msg global solutions client, service provider, business partner or employee who also has a personal or business relationship with you;
  • only provides you with a request for a quote or an estimate;
  • only facilitates or confirms a transaction;
  • only provides msg global solutions warranty, product recall, safety or security information; or
  • only provides information about your ongoing use of msg global solutions services or products or ongoing purchases (including updates and upgrades).

If you have received a CEM, and you believe that you should not have, please contact us immediately at hello@cookhouselabs.com and we will promptly remove your address from our list (within maximum 10 business days).

4. SOCIAL MEDIA.

You may be contacted by a msg global solutions employee via social media, such as LinkedIn, if you are connected on the social network with the msg global solutions employee, or if you have indicated through your preference settings the fact that you are open to receiving messages about new business opportunities or ventures. You may also be contacted if you have conspicuously published your electronic address (for instance, on a social media website), have not indicated that you did not wish to receive CEM, and the CEM sent is in connection with your business role and function.

5. WHAT TO DO IF YOU NO LONGER WISH TO RECEIVE CEM FROM msg global solutions.

At msg global solutions, we take the law very seriously. You may unsubscribe at any time from receiving CEM, by visiting the Preference Centre or clicking on the link in any CEM that you may receive from Msg global solutions, and we will remove you from our list within ten (10) business days.

6. AMENDMENT OF THIS ANTI-SPAM POLICY AND GUIDELINES.

  • From time to time, Msg global solutions will review and update this Anti-Spam Commitment as required to keep current with rules and regulations, new technologies, standards, our business practices and outside parties’ concerns. We will post any Anti-Spam Commitment changes on this page and, if the changes are significant, we will provide a more prominent notice (including, as the case may be, email notification of Anti-Spam Commitment changes).

7. QUESTIONS OR CONCERNS ABOUT THIS ANTI-SPAM COMMITMENT?

If you need further assistance, please contact us at: hello@cookhouselabs.com

Revised November 11, 2019.

Accessibility for Ontarians with Disabilities

Documents Available Notification (AODA)

Dear Valued Clients and Visitors,

msg global solutions Canada Inc. has created policies and procedures to meet their obligations regarding customer service outlined in the Integrated Accessibility Standards under the Accessibility for Ontarians with Disabilities Act. 2005.

Our accessibility policies are available for your review in a number of formats. Should you wish access to these documents in another way, please notify: hello@cookhouselabs.com

Statement of Organizational Commitment

msg global solutions is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence. We believe in integration and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and meeting our accessibility requirements under the Accessibility for Ontarians with Disabilities Act and Ontario’s accessibility laws.

Statement of Commitment to Accessibility

msg global solutions is committed to providing a barrier-free environment for all stakeholders including our clients/customers, employees, job applicants, suppliers, and any visitors who may enter our premises, access our information, or use our services. As an organization, we respect and uphold the requirements set forth under the Accessibility for Ontarians with Disabilities Act(2005), and its associated standards and regulations.

msg global solutions understands that we have a responsibility for ensuring a safe, dignified, and welcoming environment for everyone. We are committed to ensuring our organization’s compliance by incorporating accessibility legislation into our
policies, procedures, equipment requirements, training, and best practices. We will review these policies and practices annually, as organizational changes occur, or in anticipation of compliance deadlines. In addition, we will strive to meet the needs of individuals with disabilities in a timely and effective manner.

Providing an accessible and barrier-free environment is a shared effort, and as an organization, msg global solutions is committed to working with the necessary parties to make accessibility for all a reality. For more detailed information on our accessibility policies, plans, and training programs, please contact hello@cookhouselabs.com

Alternate Format Request Form

msg global solutions is committed to providing accessible, quality services. Communications in alternate formats will be made available upon request within a reasonable time period in a mutually agreed upon format. Please complete and submit the below form to hello@cookhouselabs.com

Accessibility Standards for Customer Service Record of Customer

Thank you for visiting msg global solutions and Cookhouse Labs. We value all our clients and strive to meet everyone’s needs. We look forward to your feedback. Please send us an email at hello@cookhouselabs.com

Privacy Policy

msg global and its innovation lab program Cookhouse Labs Privacy Policy

We at msg global solutions and our affiliates or programs (e.g. Cookhouse Labs) are committed to protecting your privacy. This Privacy Policy applies to our website and all of its associates websites (the “Websites”). This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your Personal Information. By using the Websites, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites.

The terms of our privacy policy, which can be found below, is based on the ten principles set out the Canadian Standards Association’s Model Code for the Protection of Personal Information.

Ten Privacy Principles

Accountability: We are responsible for personal information under our control and we have designated individuals who are accountable for our compliance with these privacy principles.

Identifying Purposes: We shall disclose the purposes for which we collect your personal information either before or at the time the information is collected.

Consent: Your knowledge and consent is required for our collection, use or disclosure of your personal information, subject to certain exceptions set out in the law. Your consent may be expressed in writing, verbally, electronically, and in certain circumstances, may also be implied.

Limiting Collection: Your personal information shall only be collected by fair and lawful means, and will be limited to that which is necessary for the identified purposes.

Limiting Use, Disclosure and Retention: Your personal information may only be used or disclosed for the purposes for which it was collected, other purposes to which you have consented or if required by law. Your personal information shall be retained only as long as necessary for the fulfillment of identified purposes, or as required or permitted by law.

Accuracy: We shall use reasonable efforts to ensure that your personal information is accurate, complete and as up-to-date as is necessary for the purposes for which it is to be used.

Safeguards: We shall protect your personal information using security safeguards appropriate to the sensitivity of your information to prevent unwanted release, misuse or intrusion.

Openness: Information about our privacy policies and procedures for handling your personal information shall be made available to you.

Individual Access: Upon written request, you will be informed of the existence, use and disclosure of your personal information. In addition, you will be given access to your personal information, as permitted by law. You may also verify the accuracy and completeness of your personal information and, where appropriate, request that it be amended.

Inquiries and Concerns: You may contact us if you have any questions or concerns about our privacy policies and procedures.

We periodically update this Privacy Policy. We encourage you to review this Privacy Policy periodically.

Important Information

1.1. Changes to this Privacy Policy

We may update or replace this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. If we make any material changes we will notify you by posting the revised Privacy Policy on our Websites. This helps you to always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Your continued use of the Websites and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

1.2. Contact Us

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at: hello@cookhouselabs.com, or by postal mail to: Cookhouse Labs, 30-34 Duncan St, Toronto, Ontario, Canada M5H 1A1, Attn: Privacy.

Information We Collect

2.1. When You Visit our Websites

You are free to explore the Websites without providing any information about yourself. However, when you visit the Websites, we may request that you provide Personal Information about yourself and we will collect Navigational Information.

2.2. “Personal Information”

This refers to any information that you voluntarily submit to us through the use of our Websites, and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter, Instagram and Google, or publicly available information that we acquire from service providers.

2.3. “Navigational Information”

This refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see section 4 the “Navigation Information” section, below.

2.4. Information About Individuals Under 18

The Websites are not intended for or targeted at individuals under 18, and we do not knowingly or intentionally collect information about individuals under 18. If you believe that we have collected information about an individual under 18, please contact us at:  hello@cookhouselabs.com, or by postal mail at: Cookhouse Labs, 30-34 Duncan Street , Toronto, Ontario, Canada M5H 1A1, Attention: Privacy, so that we may delete the information.

How We Use Information We Collect

3.1. We Never Sell Personal Information

We will never sell your Personal Information to any third party.

3.2. Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to: (a) improve your browsing experience by personalizing the Websites and to improve underlying marketing software; (b) send information to you which we think may be of interest to you by post, email, or other means; and (c) provide other companies with anonymized statistical information about our users — but this information will not be used to identify any individual user. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your unique Personal Information to the third party. In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.

3.3. Use of Navigational Information

We use Navigational Information to operate and improve the Websites and underlying marketing software. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about the Software Provider.

3.4. Customer Testimonials and Comments

We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

3.4. Use of Credit Card Information

We do not directly collect credit card information from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

3.5. Service Providers

We employ other companies and people to provide services to visitors to our Websites, such as the use of underlying marketing software, and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.

3.6. Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When sensitive Personal Information (such as geo-location data) is collected on our Websites and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

If you have any questions about the security of your Personal Information, you can contact us at: hello@cookhouselabs.com, or by postal mail at: Cookhouse Labs, 30-34 Duncan Street, Toronto, Ontario, Canada M5H 1A1, Attention: Privacy.

3.7. Social Media Features

Our Websites include social media features (“Social Media Features”), such as the Facebook Like button, the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features.  Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

3.8. External Websites

Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

3.9. Retention of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about our services and products, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information. We will delete this information from the servers at an earlier date if you so request, as described in the “Opting Out and Unsubscribing” section below.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

3.10. International Transfer of Information

To facilitate our global operations, we may transfer and access Personal Information from around the world, including Canada. This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected.

3.11. Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered on the Websites. In this event, you will be notified via email and/or a prominent notice on our Website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

3.12. Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights; protect your safety or the safety of others; investigate fraud; or comply with a law, court order or legal process.

Navigational Information

4.1. Cookies

Cookhouse Labs use cookies or similar technologies to analyze trends, administer the Website, track users’ movements around the Website and to gather demographic information about our user base, as a whole.

We use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize pages on our Websites, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Websites you visit. Cookhouse Labs keeps track of the Websites and pages you visit within Cookhouse Labs, in order to determine what portion of the Website is the most popular or most used. This data is used to deliver customized content and promotions within the Website to customers whose behavior indicates that they are interested in a particular subject area.

4.2. Log Files

We may collect demographic information, such as your postal or zip code, age, gender, preferences, interests and favorites using log files that are not associated with your name or other Personal Information. There is also information about your computer hardware and software that is automatically collected by us. This information can include: your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Cookhouse Labs for marketing purposes, to maintain the quality of the Websites and to provide general statistics regarding use of the Website. For these purposes, we do link this automatically-collected data to Personal Information, such as name, email address, address and phone number.

4.3. Clear Gifs (Web Beacons/Web Bugs)

We employ a software technology called clear gifs (a.k.a. “web beacons” or “web bugs”), that help us better manage the Website by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of visitors to our Websites.  In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients.  This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers’ Personal Information. If you would like to opt-out of these emails, please see “Opting Out and Unsubscribing”.

4.5. Third Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy. We do not have access or control over these third party tracking technologies.

How to Access & Control Your Personal Data

5.1. Reviewing, Correcting and Removing Your Personal Information

Upon request Cookhouse Labs will provide you with information about whether we hold any of your Personal Information. You have the following rights with respect to that information:

To request access, correction, updates or deletion of your personal information;

To object to processing of your personal information;

To restrict processing of your personal information;

To request portability of your personal information; and

To opt out of being solicited by Cookhouse Labs,

To exercise any of these rights, please contact us at: hello@cookhouselabs.com, or by postal mail at: Cookhouse Labs, 30-34 Duncan Street, Toronto, Ontario, Canada M5H 1A1, Attention: Privacy. We will respond to your request to change, correct or delete your information within a reasonable timeframe, and notify you of the action we have taken.

If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information.

5.2. Anti-Spam Policy

Our Acceptable Use Policy, at: www.cookhouselab.com/casl-acceptable-use, applies to us and, among other things, prohibits us from sending unsolicited commercial email in violation of applicable laws, and requires the inclusion of an “opt-out” mechanism in any commercial electronic messages that we send.

5.3. To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our commercial electronic messages, contacting us at: hello@cookhouselabs.com, or by postal mail at: Cookhouse Labs, 30-34 Duncan Street, Toronto, Ontario, Canada M5H 1A1, Attention: Privacy.

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