This Privacy Code sets out the principles that govern the collection, use and disclosure of our clients' personal information and applies to all of VAB's representatives.
It is VAB's policy that all its communications with third parties comply with the requirements of Canada’s privacy legislation, the Personal Information Protection and Electronic Documents Act ("PIPEDA"), the Canada’s Anti-Spam Legislation, passed in 2010 and effective July 1st 2014 ("CASL"), and our own commitment to protecting our clients' privacy.
Personal Information means information about an identifiable individual, but does not include the name, title or business address or telephone number of an representative of an organization.
1. Why does VAB collect Personal Information?
VAB collects Personal Information for the following purposes:
- To enroll a client in programs or services.
- To collect and process payments for programs or services.
- To notify clients of programs, services, special events, exhibitions and fundraising initiatives.
- To assist in the display and sale of artworks.
- To better understand our clients' needs and preferences, VAB maintains a record of services that our clients receive from us and we may ask for additional information (for example, through surveys and feedback requests) so that we can better meet those needs, and continue to develop improved services to our clients.
- To meet legal and statutory requirements.
2. Why and when do we disclose Personal Information?
VAB may disclose Personal Information for the following purposes:
- VAB will only use or disclose the clients' Personal Information where necessary to fulfill the purposes identified at the time of collection.
- VAB may disclose its clients' Personal Information to a person who is a legitimate representative of the client.
- VAB may disclose a clients' Personal Information to meet legal or regulatory requirements.
3. How does VAB protect its clients' Personal Information?
- VAB will not collect, use or disclose our clients' Personal Information for any purpose other than those identified above, except with the clients consent.
- VAB will protect our clients' Personal Information with appropriate security measures.
- VAB will comply with any reasonable and lawful client request to access their Personal Information.
- VAB will protect the confidentiality of our clients' Personal Information when dealing with third party companies.
- VAB will endeavor to keep our clients' Personal Information as accurate and up-to-date as necessary for the purposes listed above.
4. External Communication
VAB representatives must receive explicit consent from our clients, prior to sending any marketing email correspondence.
A client may choose to be excluded from our external communications and withdraw consent at any time, subject to legal or contractual obligations.
5. VAB Anti-Spam Policy
VAB has a strict zero-tolerance policy against spamming. All representatives must refrain from using our operating and messaging systems, including but not limited to email, instant messaging, or texting (collectively, "Electronic Address") to distribute any unsolicited commercial electronic messages for which consent has not been received. This includes all one-to-one email communications with clients and mass emailing. Our representatives are prohibited from sending unsolicited electronic messages of any kind, including mass emails, in connection with encouraging the participation in any activities.
VAB considers spamming to be any activity whereby a representative, directly or indirectly, transmits an electronic message to any Electronic Address for which prior consent of such electronic message has not been granted.