Privacy Policy

Number 01.08b
Issue Date March 2011
Amendment Date July 6, 2015

TOLKO INDUSTRIES LTD. and all of its subsidiaries including but not limited to: Tolko Marketing and Sales, Tolko Finance Ltd. and Premium 1 Papers

Your privacy is important to Tolko Industries Ltd. and its affiliates, including Tolko Marketing and Sales, Tolko Finance Ltd. and Premium 1 Papers (collectively “Tolko”).

This Website Privacy Policy explains how Tolko collects, uses, discloses, retains and deletes the personal information you may provide to Tolko while using the Tolko website – http://www.tolko.com – (the “Website”) and the services provided through the Website.

Tolko also has a general Privacy Policy that sets out the principles that are observed by Tolko with respect to the collection, use, disclosure, retention and deletion of personal information, including when you deal directly with a Tolko representative or when you are an employee of Tolko. For information about the general Privacy Policy, please contact privacy.officer@tolko.com.

Your Consent

By using the Website, and submitting information to Tolko through the Website, you are consenting to the collection, use, and disclosure of your personal information in accordance with this Website Privacy Policy.  You also agree that your company is consenting to the collection, use, and disclosure of your company’s information (including its relationship with Tolko).  If you do not consent to this Website Privacy Policy, or cannot bind your company to the terms of this Website Privacy Policy, you may not provide personal information on the Website.

Information Automatically Collected

Non-Identifiable InformationThe Website automatically collects non-identifiable information, such as the Internet Protocol (“IP”) address of your computer, the IP address of your Internet Service Provider, the date and time you access the Website, the Internet address of the website from which you linked to the Website, the operating system you are using, and the Website pages read, images viewed and information downloaded. This non-identifiable information is used for system administration purposes and to improve the Website. Non-identifiable information may be disclosed to others and permanently archived for future use.

Tracking InformationTolko may use non-identifiable information to create tracking information reports regarding Website use and Website user demographics. These reports will be provided to others. The tracking information in the reports is not connected to the identities or other personal information of individual Website users. Tolko may link tracking information with Website users’ personal information but, once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Website Privacy Policy. 

CookiesTolko’s website, email messages, services and advertisements may also use “cookies” or other similar technologies, such as web beacons, pixel or gif tags, and action tags. Those technologies collect information that assists Tolko to improve Tolko services, use of the Website, advertising and customer communications. 

For example, the information provided through cookies and similar technologies may be used to recognize you as a previous user of the Website (so you do not have to enter your personal information every time), offer personalized web page content and information for your use, and otherwise facilitate your Website experience. Tolko may use web beacons, pixel or gif tags, and action tags to confirm that email messages have been delivered and opened. 

Tolko treats information collected by cookies and similar technologies as non-personal information, except that if IP addresses or other similar identifiers are considered personal information under your local laws then Tolko will treat that information as personal information for the purposes of this Website Privacy Policy.

You may choose to decline or disable cookies if your browser permits, but doing so may affect your ability to access or use certain features of the Website.

Personal Information

In this Website Privacy Policy, “personal information” means information about an identifiable individual and documents and records containing that information.

If you browse the Website, you do so anonymously. Tolko does not collect your personal information from the Website unless you voluntarily provide it to us.

Your Personal Information – During your use of the Website, Tolko may ask you to voluntarily provide us with personal information for purposes such as facilitating communications with you, facilitating your use of the Website, providing products and services to you, or other specified purposes. If you choose not to provide certain requested personal information, you may be unable to use certain features of the Website.

Updating and Accessing Your Personal Information – Tolko relies on you to provide accurate and current personal information. Where appropriate and upon your written request to the Privacy Officer at privacy.officer@tolko.com, Tolko will revise personal information if it is inaccurate, incomplete, or irrelevant. At any time, you may seek access to your personal information by sending your request to the Privacy Officer at privacy.officer@tolko.com. Tolko will respond to written requests within 30 days. Except where otherwise permitted or required by law to deny access, Tolko will provide you with access to your personal information. Tolko will assist any individual who requires assistance preparing an access request.

Use of Your Personal Information – Tolko may use your personal information to contact and correspond with you, facilitate and enhance your use of the Website, provide products and services to you, to keep accounts and records related to purchases, sales and other transactions, and as otherwise specified at the time of collection, or permitted by law. Tolko may develop a confidential profile for you, which will be used to provide services to you and facilitate your use of the Website. Additionally, Tolko may keep a record of all communications with you.

Disclosure of Your Personal Information –Tolko may disclose your personal information to its affiliates, agents, dealers, suppliers and service providers for use in connection with matters relating to your use of the Website or the provision of products and services to you. Tolko requires its affiliates, agents, dealers, suppliers and service providers to agree to use personal information only for the purposes for which it is provided to them, and to protect the privacy of your personal information in a manner that is consistent with this Website Privacy Policy.

If you post material to the Website, your user name and email address (which may disclose your company information) will be disclosed on the Website as the source of the materials. Materials posted to the Website are generally available to all Website users, except those materials subject to a password will be available only to Website users with the password and Tolko. 

Tolko may also disclose your personal information in connection with a proposed or actual business transaction in which Tolko is involved (such as a corporate reorganization, merger or acquisition, or the sale of some or all of Tolko’s business or assets), but Tolko will require that the information recipient agree to protect the privacy of your personal information in manner that is consistent with this Website Privacy Policy and applicable law. 

Your personal information may be subject to access by and disclosure to law enforcement agencies in accordance with applicable law. Tolko may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order, or litigation disclosure obligations. Tolko may disclose your personal information if Tolko reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance.

Tolko may disclose your personal information to law enforcement authorities or other organizations if Tolko reasonably believes the disclosure is necessary or appropriate to protect and enforce Tolko’s legal rights, interests and remedies or to protect the business, operations or customers of Tolko or other persons, including to detect or prevent unlawful or fraudulent activities or other misconduct. For more information about the disclosure of your personal information, please contact the Privacy Officer at privacy.officer@tolko.com.

Collection, Use and Disclosure of Employee Personal Information – The restrictions set forth in this Website Privacy Policy regarding the collection, use and disclosure of personal information do not apply to “employee personal information” as that term is defined by applicable personal information protection statutes. Tolko maintains a separate policy for the use and disclosure of employee personal information.

Emails/Messages from Tolko – You may unsubscribe from Tolko’s commercial electronic messages by using the applicable unsubscribe procedure included in those messages or by contacting us at privacy.officer@tolko.com, subject to exceptions prescribed by applicable law.

Retention, Location, Protection and Disposal of Personal Information – Tolko will store and process your personal information in Canada. Tolko retains your personal information for the period necessary to fulfill the purposes outlines in this Website Privacy Policy or such longer retention period as may be required or permitted by applicable law. 

To help protect your personal information Tolko employs reasonable safeguards – including physical, administrative, and technological security safeguards – appropriate to the sensitivity of the personal information in Tolko’s possession or under Tolko’s control to protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. Nevertheless, security risks on the Internet cannot be eliminated and Tolko cannot and does not guarantee that your personal information will not be disclosed in ways not otherwise described in this Website Privacy Policy.

Tolko will delete or dispose of your personal information when Tolko is no longer reasonably required to retain the personal information for the purposes set forth or referenced in this Website Privacy Policy.

Other Matters

Business Contact Information – To the extent permitted by law, the provisions of this Website Privacy Policy concerning personal information do not apply to information (such as your name, position or title, business address, business telephone number, business fax number and business email address) that enable you to be contacted at a place of business.

Contests and Promotions – If contests, or promotions, are made available through the Website, and the contest or promotion rules regarding the collection, use, disclosure, retention and deletion of personal information conflict with this Website Privacy Policy, the contest or promotions rules will govern the personal information collected for that contest or promotion.

Former users – If you stop using the Website, or your permission to use the Website is terminated, Tolko may continue to use and disclose your personal information in accordance with this Website Privacy Policy .

Website Use Agreement – The Website Use Agreement governing your use of the Website (which may be viewed by clicking here) contains important provisions, including provisions disclaiming, limiting, or excluding the liability of Tolko for your use of the Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding your use of the Website. Each of those provisions applies to any disputes that may arise in relation to this Website Privacy Policy including any collection, use, disclosure, retention and deletion of your personal information and are of the same force and effect as if they had been reproduced directly in this Website Privacy Policy.

Other Websites - The Website may contain links to other websites or Internet resources that are not subject to the Website Privacy Policy. When you click on one of those links you are contacting another website. Tolko has no responsibility or liability for, or control over, those other websites or their collection, use and disclosure of your personal information.

Website Privacy Policy Changes - To accommodate changes in the Website, changing technology, and legal developments, this Website Privacy Policy may be revised in Tolko’s absolute discretion and without any prior notice or liability to you or any other person. Tolko’s collection, use, disclosure, retention and deletion of your personal information through the Website will be governed by the version of this Website Privacy Policy in effect at that time when the information is collected, used, disclosed, retained or deleted. New versions of the Website Privacy Policy will be posted on the Website and will be available upon request from Tolko. Your continued dealings with Tolko, or your use of the Website subsequent to any changes to this Website Privacy Policy, will signify your consent to the collection, use disclosure, retention and deletion of your personal information in accordance with the revised Website Privacy Policy. Accordingly, when you use the Website you should check the date of this Website Privacy Policy and review any changes since the last version. You should also bookmark this page and periodically review this Website Privacy Policy to ensure that you are familiar with the most current version.

Your Comments – Tolko welcomes your comments and questions about this Website Privacy Policy or your personal information. At any time, you may contact Tolko’s Privacy Officer by sending an email to privacy.officer@tolko.com.

English Language – You and Tolko have each expressly requested and required that this Website Privacy Policy and all related documents be drawn up in the English language. Les parties conviennent et exigent expressement que ce Politique et tous les documents qui s’y rapportent soient rédigés en anglais.