We at The Feldman Agency Inc. and its affiliated companies and divisions are committed to protecting your privacy and share your concerns about the protection of your personal information. As a result, we have created this policy, which has been developed pursuant to the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) affiliated companies and divisions include; The Feldman Agency Inc., TFA, TFA Partnerships, Ace Events & Turbo.

What Is Considered Personal Information

Personal information includes not only a person's full name, address, telephone number, date of birth, e-mail address, but also any other information about them, such as dietary preferences, travel habits and medical history. Business contact information (the content of normal business cards) is not considered personal information.

Why We Collect and Use Personal Information

If you are a client, we will have some basic information about you for the purpose of representing you. We understand that much of this information is private, which is why we collect personal information primarily for the following purposes:

1. To establish and maintain a responsible commercial relationship with you and to provide ongoing service. For example, in order to contract a performance, we require commercial and personal information for both the Artist and the Purchaser. In the case of the Artist we only include commercial information that is necessary in the contract process (ie: tax identification numbers, management contact information, AFM(American Federation of Musicians Union) local information and SIN/SS numbers for AFM purposes). In the case of the Purchaser, we include business addresses, phone/fax numbers and e-mail address.

2. To manage and develop our business and operations. We maintain a record of the contracts we have negotiated in the past (including offers, settlements, ticket counts). This occurs so that we can serve you better. For example, we will refer to previous contracts when negotiating future deals to ensure that the most appropriate deal is made (based on history). This information is for internal use only and would only be released to you or your duly appointed representatives upon request.

3. To meet legal and regulatory requirements. For example, we may collect information in response to a court order, or to satisfy a request for information from a body like the Canadian Recording Industry Association (CRIA) or the American Federation of Musicians.

4. To promote and advance the careers of our clients. Information about our clients is collected for use in promotional activities coordinated by us, in fan club or artist website settings, for distribution to media, and for sharing with record companies and others who form the strategic team for our clients.

5. To inform you about our organization and artists. Occasionally, we circulate to various distribution lists our newsletters or other material published by us concerning news of our artists and news about our organization. These circulations are done on an "opt-out" subscriber basis, and each circulation contains information on how to "unsubscribe” or cease receiving this type of material. When Do We Disclose Personal Information

There is a variety of circumstances where we may need to disclose some personal information about our clients. Here are some examples:

1. We may disclose a client's personal information to a person who, in the reasonable judgment of TFA, is seeking the information as an agent of the client. For example, we may provide information about a client's account to the Client's legal representative if we are satisfied that the individual is requesting the information on behalf of the client.

2. Client information may be shared among TFA business units to help us serve our clients better and to provide them with services, such as placing their music in film and TV, which combine services from different parts of our organization.

3. We may disclose a client's personal information to a credit reporting agency;

4. We may disclose a client's personal information to a public authority or agent of a public authority, if in the reasonable judgment of TFA, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information.

5. We may disclose a client's personal information to:

1. a company engaged in a contract to employ the Artist; or
2. a company or individual employed by TFA to perform functions on its behalf, such as research or data processing; or
3. an agent used by TFA to evaluate the client's credit worthiness or to collect the client's account.

We routinely disclose information to insurers, promoters, talent agents, record labels, music publishers and others in connection with our mandate to manage or book our artists. Where disclosures are made in the ordinary course of our business the client is usually aware of and has consented to such disclosure, or the disclosure occurs in circumstances where consent can be implied due to the nature of the activity and the circumstances of our engagement by the artist.

Where disclosure is made outside the ordinary course of business or in unusual circumstances, we would seek the express consent of the artist, and require the other party to use the information only for the purpose for which it is disclosed and to maintain the information subject to privacy practices and procedures which are consistent with this policy.

6. We may also disclose your information as required or permitted by applicable law. How We Collect Personal Information

Usually, information is collected directly from our clients. We also collect information from managers, promoters, business managers, accountants, record labels, music publishers and others associated with our clients. Certain information is collected from publicly available sources. As well, information on members of a musical group may be coordinated through designated points of contact between our organization and the group.

How Do We Protect Your Personal Information

In order to protect your personal information and your right to privacy, TFA:

1. will not collect, use or disclose your personal information for any purpose other than those identified above, except with your consent;
2. will protect your personal information with appropriate security safeguards;
3. will protect the confidentiality of your personal information when dealing with other organizations;
4. will strive to keep your personal information as accurate and up-to-date as is necessary for purposes identified above; and
5. will honour any request you may make for access to your personal information, pursuant to applicable law. Access to My Personal Information

You can request access to your personal information to verify, update, or correct it, and to have any obsolete personal information removed. You can also request to review any of your personal information that we have retained and how we have used it.

Subject to certain exceptions prescribed by law, and provided we can authenticate your identity, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate.

You can also ask us to change your preferences regarding how we use or disclose your information, or let us know that you do not wish to receive any further communication from us.

Withdrawing Consent

We consider that as part of our mandate in our relationship with our clients we have their consent to continue to collect, use and disclose your personal information for the purposes identified above. However, you do have choices and can refuse or withdraw your consent by contacting us at privacy@feldman-agency.com or (416) 598-0067 or by mail, Attention: Privacy Officer, 33 Hazelton Avenue, 2nd Floor, Toronto, ON, M5R 2E3. You may refuse to provide personal information to us. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, in either case, this may limit our ability to serve you or work with you on a project

Contacting Us

We have appointed a privacy officer who can be contacted by mail at 33 Hazelton Avenue, 2nd Floor, Toronto, ON, M5R 2E3 or by telephoning (416) 598-0067 and asking for the chief privacy officer or by e-mail at privacy@feldman-agency.com. If you have any questions or concerns about our privacy practices, contact us. We are also developing appropriate information dispute resolution procedures and information access procedures. Further information is available on request.

Our Websites

Information We Collect Automatically

Like many other web sites, our websites automatically collect certain non-personal information regarding web site users that does not identify you. Examples include the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the web site, the internet address of the website from which you linked directly to the web site, the operating system you are using, the sections of the web site you visit, the web site pages read and images viewed, and the content you download from the web site. This non-personal information is used for web site and system administration purposes and to improve the web site.

Links To Other Websites

Our web site may contain links to other web sites or internet resources. When you click on one of those links you are contacting another web site or internet resource. We have no responsibility or liability for or control over those other web sites or internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other sites to learn how they collect and use information about you.