If you have any questions about this policy or do not agree with it, please contact our Privacy Officer by email at firstname.lastname@example.org before using this Website.
This version in effect since March 23, 2011
We are dedicated to adhering to the following principles that relate to the collection, use, retention and disclosure of personal information in Canada. These principles are based on Canada’s Personal Information Protection and Electronic Documents Act, in effect since January 1, 2004.
ITC is accountable for all personal information in its control. This includes information under the direct control of ITC, as well as personal information that ITC may transfer to its affiliates or to third party service providers for servicing, processing, storage or other purposes that facilitate ITC’s business operations. ITC will use contractual or other measures to require third parties that process information or provide services on our behalf, such as credit account verification and similar confirmations, to maintain a level of privacy protection comparable to our own practices.
Few individuals within ITC are responsible for the day-to-day collection and processing of personal information, including our Reception Associates, Owners and account administration personnel. However, ITC has a designated Privacy Officer who is ultimately accountable for the handling of all personal information under the control of ITC and for ensuring that the principles set out in this Policy Statement are being complied with. Any questions with regard to the manner in which ITC handles or manages personal information should be directed to our Privacy Officer who can be reached via email at email@example.com or at the following address: 7 – 25 Scurfield Blvd, Winnipeg, Manitoba, R3Y 1G4
COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
We may use and disclose the personal information we collect from our members and other individuals to manage our relationship with such individuals, to administer accounts, to provide business services and carry on our business operations and as may otherwise be required or permitted by law. For example, we may use personal information to provide members with specials and other information announcing ITC services, deals or products, and to provide members, at our discretion, with preferred member benefits. We also analyze information about our members to determine their preferences and to help us ensure that we are providing our members with the types of programs and services that they are looking for.
In providing some of these services, we may hire outside service providers located in Canada, the United States or elsewhere to act on our behalf. In these instances, we will only transfer personal information to these organizations as is necessary for them to perform their services. We also ensure that these organizations have agreed to keep your information protected in a manner consistent with this policy and that they agree to not use this information for any other purpose.
Whenever collecting personal information for any other purpose, ITC will disclose the purpose(s) for which the information is being collected, the manner in which ITC plans to use the information and the entities to whom the information will be disclosed. We do not collect personal information that is not necessary for the purposes we identify. We will not refuse to provide a service to an individual if they choose not to provide us with their personal information, unless their failure to provide such information makes us unable to provide such service.
In most cases, consent to the collection and use of personal information will be implied through the provision to ITC, by a member or other individual, of any and all information required for ITC to provide its business services effectively, including insurance valuation requests and repair services. Such consent will also be implied when personal information is provided by members through our website for purchases, services, requests and/or any other purpose. ITC will notify and obtain the consent of the individual to whom the information relates only before collecting, using or disclosing personal information out of the ordinary course of business. If we choose to use personal information already in our custody for a purpose that was not identified at the time we initially collected the information, we will seek the consent of the affected individuals before using this information for the new purpose, unless obtaining such consent is not required by law in the specific circumstances. Individuals may withdraw consent to the collection, use and disclosure of their personal information at any certain time. Note, however, that such withdrawal may make it impossible for ITC to provide certain services to such individuals.
LIMITS TO COLLECTING PERSONAL INFORMATION
We limit the type of mandatory information collected by us to only the personal information that is required to accomplish the identified purpose of managing our relationship with our members and other individuals, to administer accounts, to provide services and to otherwise carry on ITC’s business operations.
MANAGEMENT OF PERSONAL INFORMATION
ITC has instituted policies and procedures as to how long it retains information that it collects. Personal information that is no longer required to fulfill the purposes identified when the information was collected is either destroyed, erased or rendered anonymous to prevent unauthorized parties from gaining access to the information.
ITC has implemented security safeguards to protect personal information in our control against loss, theft, misuse and interception by third parties. These safeguards include organizational, technical and physical measures designed to protect information from unauthorized access, disclosure, copying, use or modification. Among the steps taken are:
• premises security;
• restricted file access to personal information;
• technology safeguards, including security software, firewalls to prevent hacking and
other unauthorized computer access; and
• internal password and security policies.
If requested, ITC will make available certain information about our policies and practices relating to the management of personal information. Any such requests should be sent to our Privacy Officer who can be contacted as set out above.
ACCURACY AND CURRENCY OF PERSONAL INFORMATION
ITC is committed to open and fair privacy practices which comply with the Personal Information Protection and Electronic Documents Act as well as any other applicable legislation.
Any individual may request access to the individual’s personal information that ITC has in its custody by contacting ITC’s Privacy Officer in writing. After receiving such a request, our Privacy Officer shall inform the individual of the existence, use and disclosure of their personal information and shall allow the individual to access such information. If the Privacy Officer cannot provide the individual with a list of the actual disclosures, he or she will provide the individual with a list of organizations to which ITC may have disclosed their personal information.
In certain circumstances, access to personal information may be denied. If we deny an individual’s request for access to their personal information, we will advise such individual in writing of the reason for the refusal and they may then challenge our decision.
Where personal information is used on an on-going basis, ITC undertakes to correct any information that is shown to be inaccurate, incomplete or not up to date. Otherwise, ITC does not routinely update personal information unless it is necessary to fulfill the purposes for which the information is collected. ITC must be advised, by the individual to whom the information relates, of any correction to be made to their personal information. The Privacy Officer will take steps to ensure that this information is corrected.
Upon notification from an individual of their desire to have any or all of their personal information in our records deleted or destroyed, ITC may undertake to delete or destroy all such information to the extent that retention of such information is not required by law, or for any other lawful business purpose, such as the investigation of claims or the defence of an action. In the event that an individual wishes to challenge ITC’s compliance with any of these principles, they can contact ITC’s Policy Officer using the contact information set out above. All complaints will be investigated. If ITC finds a complaint to be justified, appropriate measures will be taken, including, if necessary, amending our policies and practices.
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at 112 Kent Street, Ottawa , ON K1A 1H3 , 1-800-282-1376.
All policies and procedures of ITC are reviewed periodically and, as such, we may change this Policy from time to time. This Policy is effective as of the date written at the top of this Policy.
WHAT INFORMATION DO WE COLLECT?
In general, you can use this Website without giving us any information. However, additional services may be available if we have certain information about you. We may collect the following information:
- account registration information including your name, telephone number, postal address and email address;
- if you contact us, we may keep a record of that correspondence; and
- information regarding your personal or professional interests, demographics, experiences with our programs and contact preferences in order to provide you with further correspondence about our programs and services.
WHAT DO WE DO WITH THE INFORMATION WE COLLECT?
We use this information to provide you with a better service, and in particular for the following reasons: internal record keeping; to improve our products and services; to communicate with you by email, telephone or post if you have ordered or purchased memberships, services or products from us, either regarding the order or purchase or other matters regarding transactions between us or your relationship with us; to communicate with you with regard to your membership; to contact you by email, telephone, SMS, MMS or post according to your preferences, in order to share information with you about our programs, products, services and events that may be of interest to you; to contact you for market research purposes, if you have not objected to such use. Please note that you can object to the use of your data for market research purposes at any time. To do so please contact our Privacy Officer at firstname.lastname@example.org.
As above, we would like to provide you with information about new programs, products, promotions, special offers and other information, which we think you may find interesting. Where you have consented to us doing so, we may send you such information by postal mail and telephone. If you do not want your information used for direct marketing purposes at any time, please contact our Privacy Officer at email@example.com to let us know and we will not send you any direct marketing.
We would also like to provide you with the information above by email. However, we appreciate that email “spam” has become a problem in recent years. If you are a member or you have previously asked us for information on our programs or services; We may contact you regarding this or other matters regarding transactions between us or your relationship with us, or send you information on our range of programs by email, unless you have asked us not to do so; and We may also use your email address to share information about our services and events that may be of interest to you by way of ITC informational emails, unless you have asked us not to do so.
Otherwise, when you provide us with personal information, we will ask you whether you would like us to send you ITC. informational emails. If you decide at any time that you no longer wish to receive marketing emails from us, please click on the unsubscribe link in the email. Alternatively, you may at any time contact our Privacy Officer at firstname.lastname@example.org.
HOW TO GET COPIES OF OR AMEND THE INFORMATION WE HAVE COLLECTED
You may request details of personal information we hold about you under the applicable data protection legislation. If you would like a copy of the information held on you please write to our Privacy Officer at email@example.com.
If you think any information we have about you is incorrect or incomplete, or you wish to have your details removed from our contact database please write to our Privacy Officer at firstname.lastname@example.org as soon as possible. We will correct or update any information as soon as possible.
We may link to other websites that are not within our control. When we do this, we will try and make it as clear as possible that you are leaving our Website. We are not responsible for these websites in any way. Once you have left our Website, we cannot be responsible for the protection and privacy of any information that you provide. You should exercise caution and look at the privacy statement applicable to the website in question.
You can, should you choose, disable the cookies from your browser and delete all cookies currently stored on your computer. On Microsoft Internet Explorer, this can be done by selecting “Tools/Internet Options” and reviewing your privacy settings or by selecting “delete cookies”. However please note that this may prevent you from taking full advantage of the Website. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org No information obtained from cookies from which individual members can be identified will be used by us for marketing purposes.