At Syncopate Financial Leadership Professional Corporation ("Syncopate"), we are committed to maintaining the security, confidentiality and accuracy of the personal information we collect, in order to provide the highest level of service to our clients. Our clients’ trust is our most important asset and with that in mind, we have a comprehensive Privacy Policy for handling personally identifying information.

Our privacy policy adheres to both the guidelines and principals underlying the Personal Information Protection and Electronic Documents Act, as well as our own commitment to ensuring that clients are comfortable providing us with personal information.

What Does This Policy Cover?

Our privacy policy covers Syncopate’s treatment of your personally identifying information when you visit our website or when you use our services. Our policy also covers Syncopate’s handling of any personally identifying information our business partners share with us, as well as the personally identifying information we share with our business partners.

"Personally identifying information" is any information that can, by its very nature, identify who you are. Examples of this type of information are your name, age, ID numbers, telephone numbers, income and ethnic origin, to name a few.

Consent

If you continue to use our website or services and / or submit your personal information to Syncopate, you consent to the purposes and uses outlined below for which Syncopate collects and/or shares your personal information. Specific consent from Syncopate clients for mobile communications is collected separately and can be withdrawn at any time.

What Sort of Information Do We Collect?

You have complete control over your personal information. In general, you can visit our website or contact us through other means without providing us with any personal information. There are, however, instances where we may require personal information.

Information Sharing and Disclosure

Syncopate may only send personally identifiable information about you to other organizations when we have your consent to share the information. Mobile opt-in information and consent are not shared with anyone for any purpose, and are excluded from any other sharing without specific consent.  We may disclose personal information without consent when required by law, but the information we provide will be limited to only what is legally required.

Aggregating Non-Personally Identifiable Information: IP Addresses and Cookies

Anonymous User Browsing: You can visit our website without telling us who you are or revealing any information about yourself, including your e-mail address. In this case, our web server may collect the IP address and domain you used to access our website, the type and version of web browser and operating system you are using; the number, duration and frequency of visits to our website and the website you came from and visit next.

This anonymous information cannot be traced to a specific individual user. It is used by Syncopate to measure the number of visits, average time spent, pages viewed, most popular preferences and other statistics about website visitors. This allows us to determine the characteristics of users on Syncopate’s website and our most popular services. We may use this data to monitor website performance for systems administration purposes, to make the Syncopate website easier and more convenient to use, as well as improving Syncopate’s services and tracking visitor information in aggregate form (e.g. the number of visitors using the website).

Third Party Integrations

This website uses the following third party services for security, analytics, and to enable certain functionalities. These services generate and set browser cookies with the purposes outlined below. These cookies contain randomly generated values. No personal or sensitive data is stored in the cookies.

• Google Analytics is used to track usage patterns in aggregate, which we use to improve our website.
• Google ReCaptcha is used to protect forms on our website from bots, spam and malware.
• Calendly is the booking service enabling visitors to complete a call schedule request.
• Cerber Security is used solely to protect the website from malicious activity.

Security

Syncopate has organizational, physical and technological measures in place to protect against the loss, misuse or alteration of personal information under our control. Security practices are also reviewed on a regular basis.

Contacting Us

If you have any questions about our privacy policy, or about how user information is stored or the record of your visit to our website, please e-mail us at info@SyncopateLeadership.com.

Our culture of responsibility to each other and all our stakeholders demonstrates our commitment to living our values every day.

Our people behave in a manner that upholds and builds our reputation.

Syncopate and all employees act in accordance with the following principles of behavior:

CONDUCT TOWARD EMPLOYEES

Syncopate...

• works to protect the health and safety of all our employees by providing knowledge, tools and support.
• acts and communicates honestly, fairly and respectfully.
• provides a supportive work environment, where employees have the opportunity to reach their fullest potential, where employee diversity is valued, and where employees are free from discrimination and harassment.
• protects the privacy of our employees.
• compensates fairly relative to the local marketplace.
• strives to develop the capabilities of our employees to continuously improve our knowledge base, tools, and performance.
• supports teamwork, collaboration, global connectivity, and the sharing of knowledge and experiences.

EMPLOYEES’ CONDUCT TOWARD SYNCOPATE

Our employees...

• comply with this Code of Conduct and adhere to established policies and procedures.
• maintain a safe and healthy workplace by following safety, health and environmental rules,
  practices, and reporting processes and procedures.
• act in the interests of their colleagues’ health and safety.
• individually and collectively keep the workplace free of harassment, intimidation, bias, violence, threatening behaviour and unlawful discrimination.
• do not release or share confidential information, intellectual property and knowledge or Syncopate data without appropriate permission.
• respect the privacy of other employees.
• act in the best interest of Syncopate and if aware of a Code of Conduct violation or a conflict of interest, real or perceived, report the situation to their direct supervisor or in accordance with reporting compliance procedures below.

CONDUCT WITH CLIENTS AND SUPPLIERS

Syncopate...

• acts in the interests of our clients’ and suppliers’ health and safety.
• expects suppliers, agents, consortia members, joint venture participants, and subcontractors working with us to behave in a manner consistent with our Code of Conduct and Health and Safety policies.
• only undertakes project assignments when it has the capability to carry out the work either solely or with others.
• endeavors to avoid conflict of interest, both as a company and as individuals, and will inform the client of any known conflict of interest in the execution of our work.
• acts with equity, fairness, courtesy and good faith towards clients, suppliers, and business associates.
• respects client confidentiality provisions in our contracts. Client data is not released or shared without permission, except as required by law.
• encourages our clients to undertake projects in a sustainable manner. CONDUCT REGARDING COMPANY ASSETS

Our employees...

• prudently and effectively use funds and resources.
• use assets, supplies and equipment for company business.
• prepare timely, accurate and complete financial accounts and records.
• will not release or share Syncopate’s intellectual property or confidential data without appropriate permission.

CONDUCT TOWARD INDUSTRY

Syncopate...

• competes fairly and offers services on the basis of qualifications and experience.
• when engaged by a client to critically review the work of another professional or firm, informs that professional or other firm of the commission at an appropriate time in accordance with local professional ethical standards and legal requirements.

CONDUCT AS A MEMBER OF SOCIETY

Syncopate...

• makes a positive difference in our communities and in the environment.
• does not engage in acts of corruption or bribery.
• acts in accordance with applicable existing laws of the countries in which we conduct our work.

REPORTING COMPLIANCE CONCERNS

If any employee is aware of a situation that they believe may not comply with this Code of Conduct, is unethical, inappropriate or illegal, they should promptly bring it to the immediate attention, in confidence, of their supervisor(s), unless the incident involves the supervisor(s), in which case it should be brought to the attention of the operating company President or Managing Director.

Any employee may, in confidence, report their compliance concern to an external or alternate internal resource; resource contact information can be found at: https://Syncopate.alertline.com/gcs/welcome

Syncopate will make every effort to protect the confidentiality of individuals who report real or perceived ethical concerns or violations of the law, and no penalties, sanctions or discrimination will be made against such individuals because of their good faith reporting. Every report will be duly investigated and resolved.

Introduction

1. 1. This Employee Privacy Policy Statement (the “Privacy Policy”) contains the policies, procedures and practices to be followed by Syncopate Financial Leadership and any of its present or future subsidiaries (the “Company”) pertaining to the collection, use and disclosure of personal information (the “Personal Information”) of an identifiable person (the “Individual”) that is a present, future or former employee of the Company.
   2. The Company recognizes the confidential nature of the Personal Information in its care and is accountable for the compliance of itself and its directors, officers, management, employees, representatives and agents including consultants and independent contractors (the “Staff”) in protecting this Personal Information.
   3. For the purpose of this Privacy Policy, the term “Personal Information” has the meaning of any information or collection of information in any form, whether oral, electronic or written that pertains to the Individual excluding information that is publicly available in its entirety. Personal Information will also include any publicly available information that is combined with non-publicly available information.
   4. Personal Information includes but is not limited to name, home address, home phone number, home email address, identity verification information, Social Insurance Number, physical description, age, gender, salary, education, professional designation, personal hobbies and activities, medical history, employment history, credit history, contents of resume, references, interview notes, performance review notes and emergency contact information.
   5. Personal Information will not include the Individual's business title, and business address and contact information when used or disclosed for the purposes of reasonable business communication.
   6. The Company will implement policies and procedures that give effect to this Privacy Policy including procedures to protect and secure Personal Information, procedures to receive, investigate and resolve complaints, procedures to ensure adequate training of the Staff concerning the Company's privacy policies, and procedures to distribute new and current information pertaining to the Company's Privacy Policy.
      

      Corporate Privacy Policy

   7. The Company and the Staff will at all times respect the confidentiality of the Personal Information placed in its care. The Company will endeavour to ensure that the policies affecting the collection, storage and disclosure of Personal Information reflect the confidential nature of the information.
   8. The Company will comply with all applicable privacy legislation and regulations in force now and in the future related to protecting the confidentiality of Personal Information.
      

      Purposes for which Personal Information is Collected

   9. Personal Information will be collected, used and disclosed for purposes pertaining to the Individual's employment relationship with the Company, including but not limited to the administration of employee hiring, performance reviews, the administration of employee payroll, processing of employee benefit claims, and for the purpose of complying with all applicable labor and employment legislation.
   10. The purposes for collecting Personal Information will be documented by the Company. Personal Information will only be used for the stated purpose or purposes for which it was originally collected. The purposes for which Personal Information is being collected will be identified orally or in writing to the Individual before it is collected. The person collecting the information will be able to explain the purpose at the time that the information is collected.
   11. The Company may use Personal Information for a purpose other than the originally stated purpose where the new purpose is required by law or where the Company has obtained consent in writing from the affected Individual for each new purpose.
       

       Knowledge and Consent

   12. Knowledge and consent are required from the affected Individual for the collection, use and disclosure of all Personal Information subject to exceptions noted elsewhere in the Privacy Policy statement.
   13. Consent will not be obtained through deception or misrepresentation.
   14. Any use or disclosure of Personal Information will be within the reasonable expectations of the Individual.
   15. Subject to legal and contractual obligations, an Individual may withdraw their consent on reasonable notice.
       

       Legislation and Regulation

   16. Where the Company has Individuals living and working in different jurisdictions the specific rights and obligations of Individuals may vary between jurisdictions.
   17. The Company is subject to the privacy legislation in all jurisdictions in which the Company operates. If any term, covenant, condition or provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid, void or unenforceable, it is the intent of this Privacy Policy that the scope of the rights and obligations of the Privacy Policy be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Privacy Policy statement will in no way be affected, impaired or invalidated as a result.
   18. Where this Privacy Policy provides greater rights and protections to the Individual than the available governing law, the terms of this Privacy Policy will prevail wherever allowed by law.
       

       Scope and Application

   19. The rights and obligations described in this Privacy Policy will apply to all Individuals. The Company and the Staff must comply with the policies, procedures and practices described in the Privacy Policy.
       

       Collection of Personal Information

   20. The type and amount of Personal Information collected by the Company will be limited to the minimum necessary to accomplish reasonable business purposes. Personal Information will not be collected maliciously, indiscriminately or without a reasonable business purpose.
   21. Personal Information will be collected using fair and lawful means.
       

       Access by Authorized Company Representatives

   22. All Personal Information will be released internally only on a need-to-know basis. In the course of normal and reasonable business practices it is the policy of the Company to grant designated Company representatives access to Personal Information files. This access will not exceed that necessary to accomplish the specific business function of the Company representative nor the purpose for which the information was originally collected.
       

       Accuracy of Personal Information

   23. The Company will endeavour to ensure that all Personal Information collected is accurate and validated using reasonable business practices and procedures. The Company is also committed to ensuring that the Personal Information remains accurate for the purpose for which it was collected.
       

       Rights of Access and Correction

   24. The Company will make reasonable efforts to ensure that Personal Information is at all times complete and accurate for its stated purpose.
   25. An Individual may apply for access to their Personal Information by submitting a request in writing along with adequate proof of identity to an authorized personnel officer. Where the application is made in person the requirement for proof of identity will be at the discretion of the personnel officer. The Individual will be provided with a copy of all available information that is not subject to restriction as described in this Privacy Policy. The Company may elect to provide sensitive medical information (the “Medical Information”) through a licensed medical practitioner. All Personal Information and Medical Information will be provided at no cost or at a minimal cost that is not prohibitive.
   26. The Company will also provide a specific summary of how the Personal Information has been used and to whom it has been disclosed. Where a detailed account of disclosure is not available, the Company will provide a list of organizations to which the Personal Information may have been disclosed.
   27. The Personal Information disclosed to an Individual must be in a form that is reasonable and understandable. Where the meaning of information is not clear then translations and explanations will be provided without additional cost.
   28. Where an Individual suspects that an error exists in their Personal Information, the Individual may submit a request in writing for correction. This request should include any relevant information substantiating the error and should describe the correction to be made. The Company will make all reasonable efforts to address any request for correction.
   29. Where the Individual successfully demonstrates an error in their Personal Information the Company will make appropriate corrections. Any modifications, additions or deletions to the Individual's Personal Information will be made only by an authorized personnel officer.
   30. Where a request for correction is not successful, the details and substantiating evidence of the request will be recorded and retained by the Company.
   31. The Company will endeavour to respond promptly to any reasonable request for disclosure and correction made by an Individual to ensure the continued accuracy of Personal Information.
   32. In some instances the Company may be required to limit access to Personal Information because of statutory or regulatory requirements. In all instances however the Company will make all reasonable efforts to comply with the Individual's request for access and correction to the extent of what is allowed by statute or regulation.
   33. The Company may refuse access to portions of the Personal Information of an Individual where it is found to contain Personal Information pertaining to another Individual.
       

       Use and Disclosure of Personal Information

   34. The Company and the Staff will keep confidential all Personal Information in its control except where one or more of the following conditions apply:
       1. 1. where the Individual who is the subject of disclosure has provided written consent;
          2. where the disclosure is in accord with the purposes for which the Personal Information was originally collected;
          3. where the disclosure is for the purpose of providing employment references to prospective employers and where the Personal Information disclosed is limited to information considered reasonably necessary for the purpose of providing employment references;
          4. where the Company is permitted or required to do so by applicable legislation or regulation;
          5. where the disclosure is directed to health benefit providers and where the purpose of the disclosure is in accord with the purposes for which the Personal Information was originally collected;
          6. where the disclosure is required by authorized government representatives who are acting to enforce any federal, provincial or territorial law or carrying out an investigation relating to the enforcement of any federal, provincial or territorial law or gathering information for the purpose of enforcing any federal, provincial or territorial law;
          7. where the Company is required to comply with valid court orders, warrants or subpoenas or other valid legal processes and
          8. in an emergency to protect the physical safety of any person or group of persons.

       Medical Information

2. Where Medical Information is collected pertaining to an Individual, the Company will store and secure all Medical Information with a greater level of protection and in a separate location from Personal Information. Access to Medical Information will be restricted to Company personnel (the “Medical Information Personnel”) specifically selected for this task. The Company will take all reasonable care in selecting the Medical Information Personnel recognizing the extreme sensitivity and confidentiality of all Medical Information.
3. In all cases, any disclosure of Medical Information by the Company to any third party or agency will require the written consent of the affected Individual for each instance.Confidentiality of Drug and Alcohol Results
4. Any documentation collected by the Company related to drug or alcohol impairment test results will remain strictly confidential and will be stored and secured in a separate location from Personal Information and will be safeguarded with a greater level of protection.
5. Any documentation collected by the Company related to drug or alcohol impairment test results may not be disclosed except:
   1. to the Individual or any other person designated in writing by the Individual;
   2. to the Company employee designated to evaluate these test results and
   3. as ordered by any government agency authorized by law or any court having jurisdiction.

Ownership of Personal Information

39. All Personal Information collected by the Company in compliance with this Privacy Policy are business records of the Company.
    

    Retention and Disposal of Personal Information
    

40. Any Personal Information collected by the Company will be retained by the Company during the period of active employment of the Individual as well as during the post-employment period only as long as the Personal Information is required to serve its original purpose or as directed by applicable legislation or regulation.
41. Personal Information that is no longer needed for its stated purpose will be destroyed, erased or made anonymous.
42. The Company will ensure that all practices and procedures relating to the disposal of Personal Information will respect the fundamental policy of confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, will ensure the complete destruction of Personal Information so that there will be no risk of subsequent unauthorized disclosure of Personal Information.
    

    Deceased Individuals
    

43. The rights and protections of the Company's Privacy Policies will extend to deceased Individuals.

Security

44. The Company will take and enforce all reasonable security measures appropriate for the sensitivity of the information to ensure that all Personal Information for every Individual is protected against any form of unauthorized use including but not limited to accidental or malicious disclosure, unauthorized access, unauthorized modification, unauthorized duplication or theft.
45. Methods of security will include but not be limited to the following:
    1. physical security including locked filing cabinets and secure-access offices;
    2. organizational security including security clearances and access limited on a “need-to-know” basis
       and
    3. technological security including passwords and encryption.
46. The Company will educate and inform all Staff regarding the Privacy Policy and related procedures and on the importance of confidentiality of Personal Information and will monitor compliance with the Privacy Policy and may observe and investigate the information management practices of all Staff having care of Personal Information.
    

    Knowledge of Unauthorized Disclosure

47. Responsibility for the security of Personal Information is a responsibility that the Company holds in very serious regard. Any Staff having knowledge of an impending unauthorized disclosure, whether intentional or unintentional, and who fail to act to prevent the unauthorized breach will be subject to sanction as described in the Enforcement section of this document including the immediate dismissal of the offending Staff.
    

    Enforcement

48. All Staff having care over Personal Information must comply with the policies, procedures and practices described in the Privacy Policy. Any breach of any term or condition of this Privacy Policy, whether intentional or unintentional, including but not limited to the unauthorized disclosure of Personal Information is grounds for disciplinary action up to and including the immediate dismissal of any and all responsible Staff. Any breach of any term or condition of this Privacy Policy, whether intentional or unintentional, is grounds for dismissal with cause.
    

    Compliance with Privacy Policy

49. The Company will have a procedure that will allow Individuals to challenge the Company's compliance with this Privacy Policy. The Company will also have procedures to promptly respond to Privacy Policy compliance challenges.
50. The Company will make all reasonable efforts to investigate and respond to compliance challenges relating to this Privacy Policy. Where a challenge is well founded the Company will take action to correct any outstanding problems up to and including amending the Privacy Policy and related procedures.
    

    Mediation and Arbitration

51. In the event a dispute arises out of or in connection with this Privacy Policy, the parties will first attempt to resolve the dispute through friendly consultation.
52. If the dispute is not resolved within a reasonable period then any or all outstanding issues may be submitted to mediation in accordance with any statutory rules of mediation. If mediation is not successful in resolving the entire dispute or is unavailable, any outstanding issues will be submitted to final and binding arbitration in accordance with the laws of the Province of Ontario. The arbitrator's award will be final, and judgment may be entered upon it by any court having jurisdiction within the Province of Ontario.

Syncopate Leadership (Syncopate) has an interdependent health and safety culture built on caring, teamwork and ownership of Health, Safety, Security and Environment (HSSE) by Syncopate employees.

Syncopate is committed to:

• The continued health, safety and security of our employees, subcontractors, clients and the public
• The prevention of injury and illness
• The promotion of personal health and well-being
• Enhanced environmental performance and
• The protection of the environment and prevention of pollution.

Concerning our activities and services, we shall:

• Embed HSSE in our work and business planning and influence our clients and subcontractors to take a similar strategic approach
• Provide our employees with the skills, resources and time that they need to work in a healthy, safe and environmentally responsible manner
• Work to minimize environmental impacts and
• Comply with applicable legislation and other relevant requirements relating to health, safety and
  environment.

The CEO is responsible for establishing the HSSE Policy and objectives for our organization, as well as the implementation of our HSSE Policy and objectives.

Management Teams are responsible for implementation of HSSE objectives and standards, consulting with employees on HSSE matters and resourcing HSSE.

Employees are responsible for complying with legislative and Syncopate ‘s HSSE standards, working in a manner that will not endanger themselves or others, using and maintaining their personal protective equipment, reporting hazardous, unsafe or unhealthy work conditions and incidents, and participating in activities to improve HSSE performance.

Employees are empowered to exercise the right to refuse unsafe work and to take appropriate steps to stop work where necessary.

Contractors are responsible for conducting their work in a manner that meets or exceeds legislative and Syncopate’s HSSE standards.

Syncopate is committed to continual improvement in HSSE. This Policy shall be reviewed and updated annually.

At Syncopate Leadership we are committed to ensuring the appropriate level of confidentiality, integrity and availability of the information entrusted to us by our stakeholders; including clients, management, our staff, suppliers and other business partners.

To support this goal, we have established an information security program, policy and procedures in line with industry and technology practices, so that:

• We are all fully aware of the need to protect information and what our responsibilities are with regards to information security.
• We comply with all relevant legal, regulatory and policy requirements that apply to our information assets.
• We implement cost effective controls to protect information assets from any misuse that could act to the detriment of Syncopate or its business partners.
• Our use of any information assets is in line with our business objectives and the owners of those assets.
• We use data, computer equipment, software, and communication facilities in a manner that enhances the security of those resources.

Syncopate’s CEO is accountable for setting, enforcing, and supporting the Policy and Standards surrounding security of information and information-related assets.

The responsibility for maintaining and supporting security is implicit in the roles and daily duties of all Syncopate employees, temporary workers, consultants, and contractors.

Our policy is to have a global, coordinated commitment to comply with all anti-bribery and corruption laws in the countries in which we do or intend to do business by prohibiting corrupt payments and other improper conduct. All employees and hired persons and entities are required to comply with this policy and are expected to conduct reasonable due diligence on third parties when promoting or conducting our business.

We prohibit bribery and corruption:

• Under no circumstances shall an officer, director or employee, or any third party acting on our behalf, give or pay (or make an offer, promise, or grant authority to pay) anything of value to a government official or any other person or entity, including those in the private or commercial sector, where the gift or payment is intended to induce the recipient to misuse his or her position or to obtain an improper business advantage.
• Employees are NOT authorized to make “facilitation” (or expediting) payments to expedite or secure the performance of certain routine, non-discretionary functions or routine government actions. Employees may only pay official service fees which are publicly posted on fee schedules and for which payment is properly documented.
• If an employee believes that his or her life, limb or liberty is in peril due to a payment demand, the employee should protect his or her health and safety, make the payment, and immediately report the incident to the CEO.
• An employee’s violation of this policy will result in disciplinary action, which may include termination and/or notice to appropriate enforcement agencies. A third party’s violation of this policy may lead to the suspension or termination of any or all agreements and/or notice to appropriate enforcement agencies.
• All employees shall annually sign an Acknowledgement Form confirming their understanding of this policy and the consequences of non-compliance.
• Employees will not provide gifts or hospitality with the intention of persuading anyone to, or rewarding anyone for, acting improperly or misusing his or her authority. Accordingly, gifts or hospitality may only be provided if all of the following conditions are met: the gift and/or hospitality is i) reasonable; ii) customary; iii) appropriate in the particular region and culture in which it is given; iv) provided openly and transparently; v) permitted by all applicable rules governing a recipient’s acceptance; vi) in accordance with Syncopate’s Code of Conduct; and vi) properly documented.
• We recognize that business practices vary regionally and culturally. What is considered unacceptable in one region may be normal or usual practice in another. Nevertheless, adherence to this policy is expected of all employees and third parties at all times. If you need immediate assistance, or are in doubt as to whether any conduct may constitute a breach of this policy, please contact the CEO.
• If you are aware of or are concerned about any non-compliance please contact alertline@SyncopateLeadership.com.