Last Updated April 2017
If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact Ms. Jane’s Privacy Officer for guidance or clarification.
Collection of Personal Information
Ms. Jane collects and uses only the personal information that we need for providing services and operating our business. Generally, Ms. Jane collects the personal information including a name and an email address from individuals for managing Ms. Jane’s business and operations, including customer relationships and matters, verifying access rights to the Site, and enforcing our legal relationship with you.
Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by Applicable Law. We may assume your consent in cases where you volunteer information for an obvious purpose.
You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain Services if we do not have the necessary personal information and your consent to access the personal information.
Use of Personal Information
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask Users to provide their consent orally electronically through the Site or an email communication.
In cases that do not involve sensitive personal information, we may rely on “opt-out” consent.
The amount and type of personal information collected by Ms. Jane shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by Applicable Law.
Personal information collected by Ms. Jane or on behalf of Ms. Jane will be sent to Ms. Jane’s head office in Calgary, Alberta, or to servers located in Ontario, Canada, and will be subject to the laws of Canada.
Use of Technical Information
We receive and send data from our servers and from your web browser software when you visit the Site, including your IP address, the time and information about the page you requested and the website through which you were linked to the Site, if any (“Technical Information”). We may use tracking technologies to acquire Technical Information in a variety of ways, including the following: keeping count of return visits to the Site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best. We use aggregated Technical Information to measure and improve the effectiveness of the Site and improve its content and responsiveness to visitor interests. We will not combine the Technical Information with any Personal Information we have collected. For clarity, the aggregate Technical Information we produce in relation to use of the Site does not identify individual visitors. We may disclose the aggregate Technical Information about the use of the Site to our service providers, regulatory bodies, and others
Your internet browser has a feature called “cookies”. A cookie is a small amount of data stored on your computer or device about your visit to our site. Cookies tell us nothing about who you are, however, unless you specifically give us personal information. You do not need to have cookies turned on to visit the Site. You may also elect not to allow cookies to be collected by selecting certain options on your internet browser.
Access to Personal Information
Upon request received by Ms. Jane in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information held by Ms. Jane should be directed to Ms. Jane’s Privacy Officer.
Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any documentation provided in support of such verification shall be used for verification purposes only.
Ms.Jane responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation.
A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee.
Requested information will be provided in a form that is generally understandable.
Ms. Jane will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual when required or authorized to do so by Applicable Law. When it is not possible to provide a list of the organizations to which it has actually disclosed information, Ms. Jane will provide a list of organizations to which it is likely to have disclosed information.
Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from Ms. Jane, individuals wishing to view an original record will do so at Ms. Jane’s head office and under the supervision of designated Ms. Jane personnel.
Limitation to Access
Ms. Jane will only refuse you access to personal information relating to you in circumstances permitted or required by the Applicable Law. In the event that Ms. Jane refuses to provide access to information, it will provide you with the reasons for its refusal upon request, unless Ms. Jane is prevented by Applicable Law from disclosing the reasons to you. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Ms. Jane will respond to your requests for access in accordance with applicable privacy legislation.
Maintenance of Personal Information
Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.
Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by Ms. Jane and have it amended as appropriate.
Individuals seeking a correction or amendment to their personal information should direct their requests in writing to Ms. Jane’s Privacy Officer.
All formal requests to amend personal information must be accompanied by appropriate supporting documentation. Ms. Jane’s Privacy Officer will manage any exceptions. The amended information will be transmitted to third parties, as appropriate.
If the individual is not satisfied with the results of the request, Ms. Jane shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.
Security of Personal Information
Personal information will be retained only as long as necessary, including for compliance with the Applicable Law, and will be disposed of in a manner that is appropriate to the sensitivity of the personal information. We render User personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying User personal information, including shredding paper records and permanently deleting electronic records.
Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.
We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.
If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.
Questions and Complaints
If you have a question or concern about any collection, use or disclosure of personal information by Ms. Jane, or would like to request access to your own personal information, please contact our privacy group at, firstname.lastname@example.org.