Privacy Policy.

Who does this Privacy Policy apply to?

This Privacy Policy applies to Sexton Group Ltd. (“Sexton Group”) and the website located at www.sextongroup.com (the “Website”). By using the Website, individuals consent to the terms and application of this Privacy Policy.

The privacy and security of personal information is very important to Sexton Group. It is Sexton Group’s policy to protect and respect the privacy of personal information in accordance with applicable privacy laws. This Privacy Policy explains Sexton Group’s privacy and security practices with respect to all personal information in the possession and control of Sexton Group, and may be supplemented by additional, specific policies, procedures, and practices.

What information does Sexton Group collect?

Sexton Group collects personal information from individuals when they register or establish a user account on the Website, subscribe to Sexton Group’s newsletter, respond to a survey, or fill out a Sexton-provided form. Individuals may, however, visit the Website anonymously. The type of information that Sexton may collect includes, for example, name, email address, mailing address, phone number, and other information individuals may choose to provide.

Visitors to the Website should also be aware that anonymous technical information may be collected by Sexton Group as a result of a visit to the Website. For example, this information may include the visitor’s IP address, browser type, operating system, domain name, access times and referring website addresses. Sexton Group uses this anonymous technical information for purposes such as diagnosing problems with Sexton Group’s information systems and servers, improving the

operation and content of the Website, and compiling aggregate and statistical information. For more information, please refer to the discussion of the use of cookies and data analytics contained in this Privacy Policy.

Sexton will not attempt to link or match such anonymous technical information with any personally identifiable information unless Sexton has the subject individual’s consent, Sexton or its service providers have detected or reasonably suspect any unlawful use of Sexton services or a privacy or security breach, or Sexton has a legal duty or right to do so.

What does Sexton Group use the collected information for?

Sexton may collect personal information about individuals for the following purposes:

  • To administer, plan, and manage its relationship with and to communicate with individuals;
  • To provide individuals with requested information and/or products or services;
  • To better understand how Sexton may improve its services;
  • To develop and conduct the business and operations of Sexton Group;
  • To provide individuals with information on current and future programs and services or other developments with respect to Sexton Group and its affiliates and partners (in accordance with applicable laws such as Canada’s Anti-Spam Legislation – see below);
  • To comply with applicable legal and regulatory requirements; and
  • To protect Sexton’s legal rights and property;

(collectively, the “Authorized Purposes”).

Sexton Group may collect personal information for other purposes where it has a legal duty or right to do so or where Sexton has a good faith belief that it is necessary to protect the property or rights of Sexton.

Sexton does not collect personal information for any other purposes, unless it has the consent of the individual to whom it relates.

How does Sexton Group collect personal information?

Sexton only collects personal information about an individual with the individual’s knowledge and consent. Generally, this means that Sexton collects personal information directly from the individual to whom it relates, whether via the Website, or by e-mail, telephone, fax, or in person. Occasionally, Sexton may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.

Does Sexton Group use cookies?

Sexton or its service providers may use “cookies” on the Website. “Cookies” are small text files placed on computers that can collect and store a variety of information. Permanent cookies are stored indefinitely on a user’s hard drive unless manually deleted, while temporary cookies are automatically deleted from the user’s browser upon logging out of a website. Web browsers typically allow users to disable permanent and/or temporary cookies.

Cookies enable a website’s or service provider’s systems to recognize the visitor’s browser and capture and remember certain information. Sexton use cookies to understand and save individuals’ preferences for future visits.

Does Sexton Group use data analytics?

Please note that the Website uses Google Analytics to improve the performance and functionality of the Website. This web analytics tool allows the collection, analysis, measurement and reporting of data about web traffic and visits to the Website for the purpose of understanding and optimizing web usage. For example, information in cookies may be used for the purpose of web analytics to remember individual online interactions with the Website. When an individual computer requests the Website, the Website collects the following types of information for web analytics purposes: the originating IP address, the date and time of the request, the type of browser used and the page(s) visited. The information collected is disclosed to Google, an external third party service provider. The information is de-personalized and anonymized prior to being stored on the service provider's servers in order to help safeguard individual privacy. For more information about how Google collects, uses, and processes data, please visit: http://www.google.com/policies/privacy/partners.

Does Sexton Group disclose any personal information to outside parties?

Sexton does not sell, trade, or otherwise transfer to outside parties personally identifiable information. Sexton only uses or discloses personal information as reasonably required to facilitate the Authorized Purposes listed above.

In some cases, Sexton may share personal information with third party service providers performing functions on Sexton’s behalf, including, for example, vendors that provide information technology services, hosting services, or provide analytics or assessment services.

Sexton does not otherwise use or disclose personal information unless Sexton has an individual’s consent, Sexton has a good faith belief that disclosure of the information is necessary to protect the rights or property of Sexton, or Sexton has a legal duty or right to do so.

Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

How does Sexton Group obtain and manage consent from visitors?

Individuals provide their consent to the collection, use, and disclosure of personal information by Sexton when they provide their information to Sexton or use its programs or services.

Individuals can deny or withdraw their consent to Sexton’s collection, use and disclosure of their personal information at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, Sexton may not be able to provide certain programs or services.

Sexton may use personal information it collects to inform individuals of current and/or new programs or services or other developments that Sexton or its affiliates or partners believe will be of interest to individuals in accordance with applicable customer agreements and applicable laws, including Canada’s Anti-Spam Legislation. Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax or regular mail. Individuals provide their

consent to Sexton and its members and partners contacting them in this manner when they use Sexton’s products or services, or enter into a customer agreement with Sexton Individuals may opt-out of receiving such communications by contacting Sexton at the address below.

How does Sexton Group protect personal information?

Sexton has in place reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of personal information under its control. These include, for example, a requirement that all collected sensitive or personal information is to be accessed only by those authorized by Sexton, with special access rights to Sexton systems, and all individuals with such access are required to keep the information they may access strictly confidential.

The protection of personal information is of paramount concern to Sexton, and Sexton is prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws.

Sexton makes every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from individuals. Sexton relies on individuals to notify Sexton if there is a change to their personal information that may affect their relationship with Sexton.

Sexton retains personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.

Does Sexton Group provide access to personal information?

Sexton will provide individuals with access to the personal information Sexton holds about them in accordance with applicable laws. Sexton reserves the right to require that any request for access to personal information be made in writing. Generally, there is no cost for such access. However, Sexton reserves the right to charge such costs on a case-by-case basis in accordance with applicable laws. The individual will be notified in advance if charges apply.

Sexton will correct or amend the personal information in its files where it can be shown that the information is incorrect or incomplete.

Does Sexton Group store personal information?

Sexton will store the personal information on its internal servers and/or the servers of its service providers.

Sexton’s service providers may store and/or process personal information outside of Canada (including, for example, in the United States of America). When information is stored or processed outside of Canada, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. Sexton has taken appropriate technical, organizational, and legal steps to secure this information.

Online Privacy Policy Only

This Privacy Policy applies only to information collected through the Website and not to information collected offline.

Terms and Conditions

Please visit Sexton Terms of Use for all terms and conditions, disclaimers, and limitations of liability applicable to and governing the use of the Website.

Changes to the Privacy Policy

The foregoing policy is effective as of April 14, 2022.u. Sexton reserves the right to change this Privacy Policy at any time in accordance with applicable laws – please check the Website for updates to this Privacy Policy.

Contact Sexton

For further information about Sexton privacy practices, to make a request for access to personal information, or to exercise any other rights outlined in this Privacy Policy, please contact Sexton’s Privacy Officer at the following address or phone number:

Sexton Group Ltd
1345 Kenaston Blvd
Winnipeg MB, R3P 2P2

Phone: 204-694-0269