Privacy Policy

Troubadour Music Inc.

This policy statement (the “Policy”) sets out the privacy policies and practices for Troubadour Music Inc. [and its subsidiaries and affiliates] (collectively, “Troubadour”) with respect to the collection, use, and disclosure of Personal Information. This Policy may be updated by Troubadour giving reasonable notice of the revised Policy (including by e-mail or by posting at Troubadour’s website at [www.raffinews.com]), and this Policy may be supplemented or modified by agreements or communications between Troubadour and an individual.

In this Policy, “Personal Information” means any information about an identifiable individual, as defined under the Personal Information Protection Act (British Columbia) or other applicable laws.

Privacy Officer

Our Privacy Officer is responsible for ensuring Troubadour’s compliance with this Policy. If you have any questions regarding this Policy or regarding Troubadour’s use of Personal Information, please contact our Privacy Officer:

Director, Troubadour Center,
610 Fernhill Road, S8, C40,
Mayne Island, BC,
V0N 2J0
Telephone 250-539-3588
Fax 250-539-3589

Collection and Use

Except where otherwise required or permitted by law, Troubadour will inform individuals of the purposes for the collection, use, or disclosure of the individual’s Personal Information prior to collecting, using, or disclosing the Personal Information.

Troubadour collects information from individuals through various means, including when an individual subscribes for our newsletter or requests information about our products or services. The type of information collected may include an individual’s name, address, e-mail address, or home phone number.

Troubadour uses Personal Information collected from individuals to provide products or services or to respond to requests for information regarding Troubadour’s products and services, and for additional purposes that may be identified at or before the time that the information is collected.

Consent

Requirements for consent to collection, use, or disclosure of Personal Information vary depending on the circumstances and on the type of Personal Information that is intended to be collected, used, or disclosed. In determining whether consent is required and, if so, which form of consent is appropriate, Troubadour will take into account both the sensitivity of the Personal Information at issue and the purposes for which Troubadour will use the information. Consent may be express, implied (including through use of “opt-out” consent where appropriate), or deemed. For example, if an individual provides his/her mailing address and requests information regarding a particular product, consent to use the address to mail product information to the individual is implied.

On giving reasonable written notice to Troubadour, an individual may withdraw consent to the collection, use, or disclosure of his or her Personal Information. Upon receipt of this withdrawal, Troubadour will notify the individual of the likely consequences of withdrawing his or her consent. Except where otherwise required or permitted by law, Troubadour will then stop collecting, using, or disclosing the individual’s Personal Information.

Use, Disclosure, and Retention

Except with the consent of the individual or as required or permitted by law, Troubadour will disclose Personal Information to other parties only as is reasonably required to provide products, services, or information to individuals. For example, Troubadour may disclose mailing information to a shipping service provider in order to ship products to the individual or may provide order information to a financial institution in order to process payment for products or services. Troubadour will take appropriate steps to ensure that such recipients safeguard the Personal Information and use the information only for authorized purposes. Troubadour may also disclose Personal Information to legal, financial, and other professional advisors or in connection with the sale or reorganization of all or part of its business or operations.

Once Personal Information is no longer required to fulfill its intended purposes, and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed, erased, or made anonymous.

Accuracy

Troubadour will make reasonable efforts to ensure that any Personal Information collected by it, or on its behalf, is accurate and complete, particularly where the Personal Information is likely to be used by Troubadour to make a decision that affects the individual to whom the Personal Information relates or if the information is likely to be disclosed to a third party.

Upon written request, an individual may request Troubadour to correct an error or omission in the Personal Information that is under Troubadour’s control. If Troubadour is satisfied on reasonable grounds that a correction should be made, it will amend the information as requested as soon as reasonably possible.

Security

Troubadour will protect Personal Information with security safeguards appropriate to the sensitivity of the information. Security safeguards are employed to protect Personal Information against loss, theft, and unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. The nature of the safeguards will vary depending on the sensitivity of the Personal Information, and may include physical security measures and technological measures.

Troubadour will inform employees about Troubadour’s policies and procedures for protecting Personal Information and employees will be required to comply with this Policy.

Openness

Upon request, Troubadour will make information available about its Personal Information policies and practices and about its complaint process.

Individual Access

Upon written request, with sufficient detail to enable Troubadour to confirm the identity of the individual and to identify the Personal Information being sought, Troubadour will inform an individual of the existence, use, and disclosure of his or her Personal Information that is under Troubadour’s control and will provide access to such information, unless otherwise prohibited or permitted by law.

Challenging Compliance

An individual may direct a complaint concerning compliance with this Policy to Troubadour’s Privacy Officer, and the complaint must be in writing.

Within a reasonable time of receipt of the complaint, the Privacy Officer will conduct an investigation into the compliant and will inform the complainant that the complaint is either: (a) denied (if, in the Privacy Officer’s reasonable opinion, it has no merit), or (b) allowed (if, in the Privacy Officer’s reasonable opinion, the complaint is valid).

If the Privacy Officer allows the complaint, Troubadour will take appropriate measures to correct its Personal Information practices.

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