Appleby Systems Georgetown Ltd. Personal Information Protection Policy At Appleby Systems Georgetown Ltd, we are committed to providing our clients, customers, members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers, members, protecting their personal information is one of our highest priorities. We have always respected our customers’ privacy and safeguarded their personal information. We will inform our customers 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. This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ personal information and allowing our clients, customers, members to request access to, and correction of, their personal information.
Anonymous Web Site TrackingAppleby Systems Georgetown does not collect any information about the identity of individuals searching our website. Appleby Systems Georgetown does, however, collect anonymous information through Google Analytics and Google Analytics Demographics and Interest Reporting. This anonymous information is analyzed to help us develop content that responds to the interests of our website visitors. This anonymous information collection includes things like:
- What pages of our site users visit and how long they spent there.
- How they found the site.
- Age range.
- Broad online interests (e.g. sports, travel, green living). Topics considered sensitive, like thos ebased on race, religion, sexual orientation, health, financial information, etc. are not associated with interests. Individuals can always change their interest settings here.
- Users can opt out of the Google Analytics tracking by downloading this browser add on.
Scope of this PolicyThis Personal Information Protection Policy applies to Appleby Systems Georgetown Ltd. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Dr. H.V.A.C Ltd.
DefinitionsPersonal Information –means information about an identifiable individual [. E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information]. 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 Appleby Systems Georgetown Ltd. complies with this policy.
Policy 1 – Collecting Personal Information1.1 Unless the purposes for collecting personal information are obvious and the customer 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 customer information that is necessary to fulfill the following purposes: Purposes statement, which may or may not be applicable to your organization, include:
- To verify identity;
- To verify creditworthiness;
- To identify client, customer, member preferences;
- To understand the financial needs of our clients, customers, members;
- To open and manage an account;
- To deliver requested products and services
- To enrol the client in a program;
- To send out association membership information;
- To contact our customers, for follow up information;
- To ensure a high standard of service to our customers;
- To meet regulatory requirements;
Policy 2 – Consent2.1 We will obtain customer 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 provided 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, customer, member voluntarily provides personal information for that purpose. 2.3 Consent may also be implied where a client, customer, member 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, fundraising and the client, customer, member 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, customers, members can withhold or withdraw their consent for Dr. H.V.A.C Ltd. to use their personal information in certain ways. A client’s, customer’s, member’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, customer, member in making the decision. 2.5 We may collect, use or disclose personal information without the customer’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- 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 Information3.1 We will only use or disclose client, customer, member 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 customer surveys in order to enhance the provision of our services;
- To contact our customers directly about products and services that may be of interest
Policy 4 – Retaining Personal Information4.1 If we use customer personal information to make a decision that directly affects the customer we will retain that personal information for at least one year so that the customer, has a reasonable opportunity to request access to it. 4.2 Subject to policy 4.1, we will retain customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the client, customer, member or disclosed to another organization. 5.2 Customers 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 customers’ correction request in the file.
Policy 6 – Securing Personal Information6.1 We are committed to ensuring the security of customer, personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. 6.2 The following security measures will be followed to ensure that customer personal information is appropriately protected:
- Physically securing offices where personal information is held
- The use of user IDs, passwords, encryption and firewalls
- Restricting employee access to personal information as appropriate