On January 1, 2004, the third phase of the Canadian Federal Law about Personal Information Protection and Electronic Documents Act (PIPEDA) came into effect. This Act governs information collected as part of commercial activity by any private sector organisation. It states that information must be gathered with consent, collected for a reasonable purpose, used for the limited purpose for which it was gathered, be accurate, be open for the owner's inspection and correction, and stored securely. TrueSmarts already maintains a high level of security with respect to the confidentiality of your personal information but we are now obligated by law to advise and obtain consent to the terms of collection, disclosure and storage of your data.
The following outlines our 10 principles to which we adhere in protecting your personal information.
TrueSmarts is responsible to protect all personal information under its control or transferred to a third party for processing. Personal information can include name, home address and phone number, age, identification numbers, credit information, customer preferences and other items that personally relate to you as an individual. TrueSmarts has appointed a Privacy Officer, who is responsible for our accountability and compliance.
2. Identifying Purposes
Whenever personal information is collected by TrueSmarts, we will identify why the information is being collected and how it will be used. If we have collected information in the past, we will not use it for any other purpose than that expressly stated at the time of collection. The reasons personal information is collected by TrueSmarts include:
- Identifying preferences and improving service;
- Establishing eligibility for promotional services;
- Informing you of new products or services that may interest you.
Type of Information Collected
The type of information we collect from you relates to your account or profile with us. This may include: name, address, contact information, preferences, credit information for payment purposes, and publicly available information.
How it's Collected
Information is collected directly from you through surveys, online registration, and requests for information.
Your consent will be obtained either in person, through writing, email, telephone, or the Internet.
Under certain circumstances TrueSmarts will need to disclose your personal information without your consent. This may include:
- Where required by law; or
- Where required by law enforcement, legal investigation or a regulatory body.
4. Limiting Collection
Information collected will only be expressly used for the purpose outlined at the time of collection. TrueSmarts will not indiscriminately collect or maintain personal information on its members.
5. Limiting Use, Disclosure and Retention
TrueSmarts does not disclose your personal information for any purposes other than, for which it was originally collected, unless we have first obtained consent from you. We do not sell or rent your personal information and we will not retain the information for longer than is necessary to fulfill the purpose for which it was originally collected.
Personal information will be maintained in an accurate, complete and up-to-date format as is necessary and reasonably practical to fulfill the purpose for which it was collected.
TrueSmarts protects your personal information by security safeguards, which are appropriate to the sensitivity of the information. These include premises security; locked filing cabinets; information technology security such as restricted access to specific programs, firewalls and software security; and restricting access to personal information only to those employees and partners to which it is necessary. We keep our employees up-to-date on policies and procedures regarding protecting personal information.
We may use the services of a third party to process personal information. However, we ensure there are confidentiality agreements in place so that your information is protected while in their possession.
TrueSmarts will make its policies and practices that apply to the protection of personal information available to anyone on which it holds information.
9. Individual Access
Upon written request, TrueSmarts will inform you if we are maintaining any personal information about you. If so, we will provide it for your review of accuracy and completeness and will amend it as appropriate. However, TrueSmarts reserves the right to confirm your identity before providing this personal information. TrueSmarts can refuse access in certain circumstances including when granting access would have an unreasonable impact on the personal privacy of others, when the request is frivolous or when it may impact TrueSmarts rights and property.
Requests for access to your personal information should be made in writing to the Privacy Officer by email at firstname.lastname@example.org
10. Challenging Compliance
TrueSmarts compliance with this policy may be challenged by directing concerns or complaints to the Privacy Officer by the above-mentioned method.
Use of our Web Sites
You can visit our web sites without telling us who you are or revealing any personal information, including your e-mail address. Our web servers automatically recognize your domain name when you visit our site, and this information is aggregated and used to measure statistics regarding the use of our site, such as the number of visitors, average time spent on the site, pages viewed and similar information. However, this information is not disclosed or shared with third parties.
TrueSmarts goal in collecting personal information online is to continually improve the content of our web sites and to offer services that best meet your preferences and desires.