SCOPE OF POLICY
WHAT DO WE COLLECT?
We collect the following types of personal information: the first name, last name, phone number, fax number, email address, company name, address, city, province, postal code and credit information of all persons who use Connect services or equipment.
HOW DO WE COLLECT INFORMATION?
We collect information from you in a variety of ways, including the following:
- sign-up forms;
- our "contact us" form;
- comments, feedback and other information you provide to us via email, phone, fax or otherwise;
- private messages you send and receive;
- faxes received; and
- information collected in or under our agreements with you or your company, such as our Customer Service Agreements.
We collect, use and disclose your personal information for the following purposes:
- to open your account with us and provide services to you;
- to authenticate your identity;
- to investigate and enforce compliance with our agreements and policies;
- to process your payments through our third-party payment processors;
- to protect us, you and others from fraud and error and to safeguard our business interests;
- to comply with legal and regulatory requirements;
- as part of a sale of any or all our business; and
- to respond to emergency situations.
The above collections, use, and disclosures are a reasonably necessary part of your relationship with us. We might also collect, use and disclose your personal information for the following purposes:
- to personalize your experience with us through our website and through our customer service representatives;
- to communicate news about us and our services;
- to allow us and third parties to offer additional or alternate products and services to you;
- to evaluate and improve our products and services; and
- to invite you to participate in surveys, contests or special events.
You may instruct us to refrain from using or sharing your personal information at any time by providing written notification to our Privacy Officer. We acknowledge that the sharing of your personal information in any or all of the ways described above is at your option and we will not refuse you access to any product or service merely because you have advised us to stop using or sharing your personal information in any or all of the ways described above.
If we want to use your personal information for a new purpose, we will disclose this to you and ask for your consent unless the new use is already authorized or required by law.
We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where:
- the information is publicly available;
- we are obtaining legal advice; or
- we reasonably expect that obtaining consent would compromise an investigation or proceeding.
Other exceptions may also apply.
Your consent can be expressed, implied or given through an authorized representative such as a lawyer or agent. Your consent may also be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw your consent at any time, subject to legal, contractual and other restrictions if you give reasonable notice of withdrawal of your consent to us. On receipt of such notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.
LIMITS ON COLLECTION OF PERSONAL INFORMATION
We will not collect personal information indiscriminately but will limit the collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.
LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL INFORMATION
We will keep a record of your personal information for at least one year, except to the extent that you delete or remove that information yourself.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose of such personal information is no longer being served by retention of the personal information and retention of the personal information is no longer necessary for a legal or business purpose; however, it may not be possible or practical to delete personal information from all backup media, especially if that media is stored offsite or contains co-mingled data.
We will take due care when destroying personal information to prevent unauthorized access to personal information.
We will make a reasonable effort to ensure that the personal information we are using or disclosing is accurate and complete. If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended personal information to third parties to whom the personal information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
SAFEGUARDING PERSONAL INFORMATION
We will protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who provide services to us. Some specific safeguards may include:
- physical measures such as locked filing cabinets;
- organizational measures such as restricting employee access to files and databases as appropriate;
- electronic measures such as passwords and firewalls; and
- investigative measures where we have reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
You may receive messages from third parties; we cannot ensure that these third parties will respect your privacy, so you should be very cautious about sharing any personal information with them.
You have a right to access your personal information held by us.
Upon written request and authentication of identity, we will provide you with your personal information which is under our control. We will also provide you with information about the ways in which personal information is being used and a description of the individuals and organizations to whom personal information has been disclosed. We may charge you a reasonable fee for providing you with the information you have requested.
Within 30 days following our receipt of a written request from you, we will either make the information available to you or provide you with written notice that additional time is required to fulfill your request for the information.
In some situations, we may not be able to provide you access to certain personal information you have requested (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm our competitive position). We may also be prevented by law from providing you access to certain personal information.
Where we have refused to provide you access to your personal information, we will notify you in writing of our refusal, documenting the reason or reasons therefor and outlining further steps which are available to you to access the information.
We will, on request, provide you with information regarding our complaint procedure.
(403) 540-0000 or e-mail [email protected]
Questions? Contact Connect today.