Hale is committed to protecting the privacy and confidentiality of the Personal Information (defined below) of our clients, employees, and third parties with which it deals. This privacy policy outlines Hale’s information-handling
practices and the various procedures in place to ensure that Personal Information is managed in accordance with the
Personal Information Protection and Electronic Documents Act (Canada) and other applicable privacy laws.
Hale needs to collect, use, and disclose certain types of Personal Information in the course of its operations. For the
purposes of this Policy, the term “Personal Information” generally refers to any information, regardless of the format in which it resides, that may reasonably lead to the identification of a specific individual. Hale may also collect nonidentifiable, aggregated data to compile broad demographic information that cannot and will not be used to
specifically identify any individuals (“Aggregate Data”). Where information is deemed to be Aggregate Data, it shall
not be subject to the terms and conditions contained in this Policy.
Hale may also collect non-identifiable, aggregated data to compile broad demographic information that cannot and will not be used to specifically identify any individuals (“Aggregate Data”). Where information is deemed to be
Aggregate Data, it shall not be subject to the terms and conditions contained in this Policy.

Collection and Consent
Hale collects information using fair and lawful means and only requests those items of Personal Information
necessary for its operations. From time to time, it may be reasonably necessary for Hale to obtain information about
an individual from other sources.
From time to time, Hale may use Personal Information to distribute information to clients and others generally with
respect to its operations and products. If at any time an individual expresses to Hale that he or she no longer wishes
to receive this type of information, Hale will cease using that individual’s Personal Information for these purposes.
To withdraw consent, an individual may contact the Chief Privacy Officer.
Unless permitted by law, Hale will not collect Personal Information without first obtaining the consent of the
individual to whom the information pertains. In most cases, Hale will ask that the individual specifically consent to
the collection, use, and disclosure of Personal Information for specific, identified purposes; however, sometimes
Hale may reasonably imply an individual’s consent through their conduct in dealing with or working for Hale.

Additionally, there are instances where proceeding without the express consent of an individual is justified or
permissible, such as:
Where required by law, administrative agency, or other governmental institution
Where it is reasonably necessary to protect the safety, property, interests, or other rights of an individual or
identifiable group of individuals
Where circumstances have given rise to a right of action for Hale to pursue its available remedies, e.g., to collect
amounts owing to Hale, or to establish or limit liability

Use and Disclosure
Except when otherwise permitted by law, Hale will use Personal Information for the purposes identified to the
affected party. Hale’s uses may include advising clients of the promotional events available through Hale,
administration, billing, accounting, and collection issues related to a client’s account with Hale. When Personal
Information is to be used for a purpose not identified, Hale will take all reasonable steps to ensure that the new
purpose is identified prior to use.
Hale may need to disclose certain items of Personal Information to third parties in relation to its operations. Thirdparty disclosure may occur in any of the following circumstances:
with the prior consent of the individual
when Hale is required or authorized by law to do so, for example, pursuant to a court order

In the event that Hale or any of its assets are acquired by a third party, or Hale merges with another entity, Personal
Information held by Hale may be a transferred asset. Any acquiring entity will be required to adhere to and observe
the terms and conditions under which such Personal Information was collected.
Changes

This Policy may be revised from time to time to reflect changes to Hale’s internal policies and procedures or to
applicable privacy laws. In the event there is an amendment to this Policy, Hale will post a notice on its website
advising of the change. The statements set forth in this Policy, and any future amendments hereto, apply to all
Personal Information in the custody and control of Hale, whether collected prior to or following the implementation
of this Policy.

All assurances made under this Policy and the administration of our internal privacy procedures are the
responsibility of Hale’s Privacy Officer. Questions about this Policy should be directed to the Privacy Officer using
the contact information set out above.
Website
Hale’s website may contain links to third-party sites, which are not governed by this Policy. Further, Hale may
monitor traffic patterns, site usage, and related site information to optimize web service. Aggregate Data relating to
the website may be provided to third parties.

If you have any questions about this policy, please contact info@haleoutdoors.com