privacy

Personal Information Protection Policy

At Genieall, we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.

While we have always respected our clients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of the recent changes to privacy laws in Canada.

We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

scope of this policy

This Personal Information Protection Policy applies to Genieall.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Genieall.

definitions

Personal Information means information about an identifiable individual (E.g., including name, age, address and phone number, etc).  Personal information does not include contact information (described below).

Contact information means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy.

Privacy Officer means the individual designated responsibility for ensuring that Genieall complies with this policy.

Policy 1 – collecting personal information

1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect client information that is necessary to fulfill the following purposes:

  • To verify identity;
  • To verify creditworthiness;
  • To open and manage an account;
  • To deliver requested products and services;
  • To process a blog/newsletter subscription;
  • To provide our managed services;
  • To ensure a high standard of service;
  • To meet regulatory requirements.

Policy 2 – consent

2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Genieall to use their personal information in certain ways.  A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the client in making the decision.

2.5 We may collect, use or disclose personal information without the client’s, knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law;

  • In an emergency that threatens an individual’s life, health, or personal security;

  • When the personal information is available from a public source (e.g., a telephone directory);

  • When we require legal advice from a lawyer;

  • For the purposes of collecting a debt;

  • To protect ourselves from fraud;

  • To investigate an anticipated breach of an agreement or a contravention of law.

Policy 3 – using and disclosing personal information

3.1  We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

  • To conduct client surveys in order to enhance the provision of our services;
  • To contact our clients directly about products and services that may be of interest;

3.2  We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell client lists or personal information to other parties (unless we have consent to do so).

Policy 4 – retaining personal information

4.1  If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – ensuring accuracy of personal information

5.1  We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.

5.2  Clients may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3  If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year.  If the correction is not made, we will note the clients’ correction request in the file.

Policy 6 – securing personal information

6.1  We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks in line with the scope of our Information Security Management System.

6.2  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – providing clients access to personal information

7.1  Clients have a right to access their personal information, subject to limited exceptions. Some examples include:  solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3  Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.

7.4  We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 If the request is made electronically, we will provide the data in an accessible electronic format.

Policy 8 – cookies and analytics

8.1 Genieall uses cookies, IP address and web log data to collect aggregate data about website visitors to help us understand how to best serve our customers best.

8.2 Genieall may use third party tracking software to gather information about where users are coming from and how they are using our site. This data is collected and used in an aggregated form to evaluate our website performance and marketing programs.

8.3 Genieall website may contain links to other websites. While Genieall proactively seeks to promote sound privacy polices with all its partners, it is not responsible for the privacy practices or the content of such websites and suggests that each visitor reviews their privacy policies before providing any personal information.

8.4 Genieall uses a third-party analytics company, Google Analytics, to collect non-personal information in the form of various usage and user metrics when visitors use our website. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information.

8.5 The third-party analytics company who collects information on our website may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to visitors’ activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.

8.6 Each visitor may opt out of the cookie by visiting the Google advertising opt-out page or you may opt out of Google Analytics by visiting the Google Analytics opt-out page.

Policy 9 – children

9.1 Genieall’s website is not intended nor designed for use by children under the age of 13. To comply with the Children’s Online Privacy Protection Act, children under 13 should not provide us with any personal information online. We strongly urge parents to supervise their children while online.

Policy 10 – changes to Privacy Policy

10.1 Genieall reserves the right to amend and update this Privacy Policy at any time. Any updates or amendments will be posted on this page for visitor review.

Policy 11 – questions and complaints: the role of the privacy officer or designated individual

11.1  The Privacy Officer or designated individual is responsible for ensuring Genieall’s compliance with this policy and the Personal Information Protection Act.

11.2  Clients should direct any complaints, concerns or questions regarding Genieall’s compliance in writing to the Privacy Officer.

Contact information for Genieall’s Privacy Officer or designated individual:

compliance@genieall.com

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