Privacy Policy
AIC Global Communications Inc. recognizes that your right to privacy is an important
issue. We understand your interest in protecting your private information while
using our telecommunications products and services. As a result, AIC manages your
personal information with extreme care as reflected through this privacy policy.
Scope and Application
AIC's privacy policy applies to personal information about the Company's customers
and employees that is collected, used, or disclosed by the Company. It also applies
to the management of personal information in any form whether oral, electronic or
written. The policy will apply to and protect all personal information collected,
used or disclosed by AIC, except information that is publicly available, such as
a customer's name, address, telephone number and electronic address, when listed
in a directory or made available through directory assistance. The name, title or
business address or telephone number of an employee of an organization or other
information about the customer or employee that is publicly available and is specified
by regulation pursuant to the Personal Information Protection and Electronic Documents
Act are also not fall under the policy.
Personal information which may fall under the policy may include but is not limited
to social insurance number, drivers license number, credit card information, payment
and banking information, details of calls, internet user names and activity reports,
passwords and PIN numbers. This Personal information may be collected when a person
subscribes to or uses our voice (local, long distance), data, Internet services
or products. It will also be collected when a person makes any inquiries by telephone,
signs an agreement, registers or provides information by email or through the internet,
inquiries about his/her services, registers online, makes additional orders for
services or when he/she makes a complaint.
Guidelines For Internet/Website Users
There are additional guidelines that apply to persons who use our Websites and portals.
In addition to the principles outlines above, AIC may permit third parties to offer
users with subscription and/or registration-based services through the Websites.
In such circumstances, AIC cannot be responsible for any actions or policies of
such third parties. Users should check the applicable privacy policy of each third
party when providing any personal information or even when simply visiting a third
party website.
AIC also reminds users that voluntarily disclosed information online in discussion
areas or other public areas of our Websites can be collected and used by third parties
and may result in unsolicited messages from third parties. Unfortunately, such activities
are beyond the control of AIC.
Any submissions made to discussion areas or other public areas on our Websites are
done so with the user's understanding that they are accessible to third parties.
If comments are not intended for third parties, you are advised not to make any
submissions.
In any event, users can request AIC to cease from sending electronic mail or advertising
from AIC or its authorized agents at any time by simply contacting us below.
AIC's policy generally and in connection with Internet use is subject to the requirements
or provisions of any applicable legislation, regulations or agreements, or order
of any court, or other lawful authority. Your use of our Websites is also subject
to these requirements as well as AIC's Terms and Conditions of Services which is
available for viewing at www.aicom.com.
The Privacy Principles AIC Follows
To better understand our policy; AIC has set out some definitions to use when reading
and interpreting the principles below:
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collection - the
act of gathering, acquiring, recording, or obtaining personal information from any
source, including third parties, by any means.
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consent - voluntary
agreement with the collection, use and disclosure of personal information for defined
purposes. Consent can be either express or implied and can be provided directly
by the individual or by an authorized representative. Express consent can be given
orally, electronically or in writing, but is always unequivocal and does not require
any inference on the part of the Company. Implied consent is consent that can reasonably
be inferred from an individual's action or inaction.
customer - an individual who uses, or applies to use, the Company's products
and services or otherwise provides personal information to the Company in the course
of the Company's commercial activities.
disclosure - making personal information available to a third party.
employee - an employee of the Company, and for the purpose of this privacy
policy only, includes independent and other contractors performing services within
the Company.
Company - AIC Global Communications Inc. and its affiliates.
personal information - information about an identifiable individual but not
aggregated information that cannot be associated with a specific individual.
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For a customer,
such information includes social insurance and driver license number, credit card
and banking information, usage and billing records, user names, passwords and PIN
numbers.
For an employee, such information includes information found in personal
employment files, performance appraisals, and medical information. |
third party -
an individual other than the customer, or the customer's agent, or organization
outside the Company.
use - the treatment, handling, and management of personal information by
and within the Company.
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Principle 1 - Accountability
AIC is responsible for personal information under its control. Responsibility for
ensuring compliance with the provisions of AIC policy rests with the Privacy Officer
within the Company.
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1.1
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Other individual within
the Company may be delegated to act on behalf of the Privacy Officer or to take
responsibility for the day-to-day collection and processing of personal information.
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1.2 |
The Company is responsible
for personal information in its possession or custody, including information that
has been transferred to a third party for processing or other purposes related to
the Company's business and operations. The Company shall use contractual or other
means to provide a comparable level of protection while the information is in the
possession of the third party. (See principle 7)
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1.3 |
The Company shall implement
policies and procedures to give effect to the Company's Privacy Code, including:
a) implementing procedures
to protect personal information;
b) establishing procedures to receive and respond to inquiries or complaints;
c) training and communicating to employees about the Company's policies and practices;
and
d) developing public information to explain the Company's policies and practices.
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Principle 2 - Identifying
Purposes for Collection of Personal Information
The Company shall identify the purposes for which personal information is collected
at or before the time the information is collected.
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2.1 |
The Company collects
personal information only for the following purposes:
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a) |
to establish and maintain
responsible commercial relations with customers and to provide ongoing service and
offers; |
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b) |
to understand customer
needs and preferences; |
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c) |
to develop, enhance,
market or provide products and services; |
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d) |
to manage and develop
the Company's business and operations, including personnel and employment matters;
and |
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e) |
to meet legal and regulatory
requirements. |
Further references to
identified purposes mean the purposes identified in this Principle 2.1.
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2.2 |
The Company shall specify
orally, electronically or in writing the identified purposes to the customer or
employee at or before the time personal information is collected. Upon request,
persons collecting personal information shall explain these identified purposes
or refer the individual to a designated person with the Company who shall explain
the identified purposes.
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2.3 |
Unless required by law,
the Company shall not use or disclose for any new purpose, personal information
that has been collected without first identifying and documenting the new purpose
and obtaining the consent of the customer or employee.
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Principle 3 - Obtaining
Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer or employee are required for the collection,
use or disclosure of personal information, except where inappropriate.
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3.1 |
In certain circumstances
personal information can be collected, used or disclosed without the knowledge and
consent of the individual. For example, the Company may collect, use or disclose
personal information without knowledge or consent if it is clearly in the interests
of the individual and consent cannot be obtained in a timely way.
The Company may also collect, use and disclose personal information without knowledge
or consent if:
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a) |
seeking the consent of
the individual might defeat the purpose of collecting the information, such as in
the investigation of a breach of an agreement or a contravention of a federal or
provincial law; |
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b) |
there is an emergency
where the life, health or security of an individual is threatened; or |
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c) |
disclosure is to a lawyer
representing the Company, to collect a debt, to comply with a subpoena, warrant
or other court order, or otherwise required by law.
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3.2 |
In obtaining consent,
the Company shall use reasonable efforts to ensure that a customer or employee is
advised of the identified purposes for which personal information will be used or
disclosed. The customer or employee shall state purposes in a manner that can be
reasonably understood
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3.3 |
Generally, the Company
shall seek consent to use and disclose personal information at the same time it
collects the information. However, the Company may seek consent to use and disclose
personal information after it has been collected, but before it is used or disclosed
for a new purpose.
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3.4 |
The Company will require
customers to consent to the collection, use or disclosure of personal information
as a condition of the supply of a product or service only if such collection, use
or disclosure is required to fulfill the identified purposes.
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3.5 |
In determining the appropriate
form of consent, the Company shall take into account the sensitivity of the personal
information and the reasonable expectations of its customers and employees.
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3.6 |
In general, the use of
the Company products and services by a customer or visitor to a Website, or the
acceptance of employment or benefits by an employee, constitutes implied consent
for the Company to collect, use and disclose personal information for all identified
purposes.
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3.7 |
A customer or employee
may withdraw consent at any time, subject to legal or contractual restrictions and
reasonable notice. Customers and employees may contact the Company for more information
regarding the implications of doing so. |
Principle 4 - Limiting
Collection of Personal Information
The Company shall limit the collection of personal information to that which is
necessary for the identified purposes. The Company shall collect personal information
by fair and lawful means.
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4.1 |
The Company collects
personal information primarily from its customers and visitors to its Websites or
employees.
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4.2 |
The Company may also
collect personal information from other sources including but not limited to credit
bureaus or other third parties who represent that they have the right to disclose
the information.
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Principle 5 - Limiting
Use, Disclosure, and Retention of Personal Information
The Company shall not use or disclose personal information for purposes other than
those for which it was collected, except with the consent of the individual or as
required by law. The Company shall retain personal information only as long as necessary
for the fulfillment of those purposes, or as required by law.
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5.1 |
The Company may disclose
a customer's personal information to:
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a) |
another communications
company for the efficient and cost-effective provision of telecommunications services; |
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b) |
a company involved in
supplying the customer with communications or communications directory related services; |
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c) |
a company or individual
retained by the Company to perform functions on the Company's behalf, such as research
and data processing; |
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d) |
another company or person
for the development, enhancement, marketing or provision of any of the Company's
products or services; |
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e) |
credit grantors and report
agencies; |
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f) |
an agent used by the
Company to evaluate a customer's credit worthiness or to collect the customer's
account |
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g) |
a public authority or
agent of a public authority, if in the reasonable judgment of the Company, it appears
that there is imminent danger to life or property which could be avoided or minimized
by disclosure of the information; |
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h) |
a person who, in the
reasonable judgment of the Company, is seeking the information as an agent of the
customer; and |
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i) |
law and emergency
require a third part or parties, where the customer consents to such disclosure
or disclosure
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5.2 |
The Company may disclose
personal information about its employees:
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a) |
for normal personnel
and benefits administration; |
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b) |
in the context of providing
references regarding current or former employees in response to requests from prospective
employers; or |
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c) |
where law requires disclosure.
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5.3 |
Only those Company employees
who require access for business need to know, or whose duties reasonably so require,
are granted access to personal information about customers and employees.
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5.4 |
The Company shall keep
personal information only as long as it remains necessary or relevant for the identified
purposes or as required by law. Depending on the circumstances, where personal information
has been used to make a decision about a customer or employee, the Company shall
retain, for a period of time that is reasonably sufficient to allow for access by
the customer or employee, either the actual information or the rationale for making
the decision.
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5.5 |
Personal information
that is no longer necessary or relevant for the identified purposes or required
to be retained by law shall be destroyed, erased or made anonymous. In any event,
the Company shall maintain reasonable and systematic controls, schedules and practices
for such information, its retention and destruction. |
Principle 6 - Accuracy
of Personal Information
Personal information the Company maintains shall be as accurate, complete, and up-to-date
as is necessary for the purposes for which it is to be used.
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6.1 |
Personal information
used by the Company shall be sufficiently accurate, complete, and up-to-date to
minimize the possibility that inappropriate information may be used to make a decision
about a customer or employee.
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6.2 |
The Company shall update
personal information about customers and employees as and when necessary to fulfill
the identified purposes or upon notification by the individual. |
Principle 7 - Security
Safeguards
The Company shall protect personal information through security safeguards appropriate
to the sensitivity of the information.
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7.1 |
The Company shall use
appropriate security measures to protect personal information against such risks
as loss or theft, unauthorized access, disclosure, copying, use, modification or
destruction regardless of the format in which it is held. The Company shall use
care in disposing of or destroying personal information to prevent unauthorized
parties from gaining access to the information.
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7.2 |
The Company shall protect
personal information disclosed to third parties by contractual agreements stipulating
the confidentiality of the information and the purposes for which it is to be used.
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7.3 |
All of the Company's
employees with access to personal information shall be required as a condition of
employment to contractually respect the confidentiality of personal information. |
Principle 8 - Openness
Concerning Policies and Practices
The Company shall make readily available to customers and employees specific information
about its policies and practices relating to the management of personal information.
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8.1 |
The Company shall make
information about its policies and practices easy to understand, including:
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a) |
the title and address
of the person or persons accountable for the Company's compliance with the Privacy
Code and to whom inquiries or complaints can be forwarded; |
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b) |
the means of gaining
access to personal information held by the Company; and |
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c) |
a description of the
type of personal information held by the Company, including a general account of
its use.
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8.2 |
The Company shall make
available information to help customers and employees exercise choices regarding
the use of their personal information and the privacy-enhancing services available
from the Company.
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Principle 9 - Customer
and Employee Access To Personal information
The Company shall inform a customer or employee of the existence, use and disclosure
of his or her personal information upon request and shall give the individual access
to that information, except in certain circumstances. A customer or employee shall
be able to challenge the accuracy and completeness of the information and have it
amended as appropriate.
NOTE: In certain situations, the Company may not be able to provide access to all
of the personal information it holds about a customer or employee. Exceptions may
include information that is prohibitively costly to provide, information that contains
references to other individuals, information that cannot be disclosed for legal,
security or commercial proprietary reasons, information that is subject to solicitor-client
or litigation privilege, or, in certain circumstances, information of a medical
nature. The Company shall provide the reasons for denying access upon request.
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9.1 |
Upon request, the Company
shall afford customers and employees a reasonable opportunity to review the personal
information in the individual's file. Personal information shall be provided in
understandable form within a reasonable time and at a minimal or no cost to the
individual.
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9.2 |
Upon request, the Company
shall provide an account of the use and disclosure of personal information and,
where reasonably possible, shall state the source of the information. In providing
an account of disclosure, the Company shall provide a list of organizations to which
it may have disclosed personal information about the individual when it is not possible
to provide an actual list.
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9.3 |
In order to safeguard
personal information, a customer or employee may be required to provide sufficient
identification information to permit the Company to account for the existence, use
and disclosure of personal information and to authorize access to the individual's
file. Any such information shall be used only for this purpose.
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9.4 |
The Company shall promptly
correct or complete any personal information found to be inaccurate or incomplete.
Any unresolved differences as to accuracy or completeness shall be noted in the
individual's file. Where appropriate, the Company shall transmit to third parties
having access to the personal information in question any amended information or
the existence of any unresolved differences.
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9.5 |
A customer can obtain
information or seek access to his or her individual files by contacting a customer
service representative.
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9.6 |
An employee can obtain
information or seek access to his or her individual files by contacting his or her
manager or Human Resources. |
Principle 10 - Challenging
Compliance
A customer or employee shall be able to address a challenge concerning compliance
with the above principles to the designated person or persons accountable for the
Company's compliance with the policy.
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10.1 |
The Company shall maintain
procedures for addressing and responding to all inquiries or complaints from its
customers and employees about the Company's handling of personal information.
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10.2 |
The Company shall inform
its customers and employees about the existence of these procedures as well as the
availability of complaint procedures.
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10.3 |
The person or persons
accountable for compliance with the Company's policy may seek external advice where
appropriate before providing a final response to individual complaints.
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10.4 |
The Company shall investigate
all complaints concerning compliance with the policy. If a complaint is found to
be justified, the Company shall take appropriate measures to resolve the complaint
including, if necessary, amending its policies and procedures. A customer or employee
shall be informed of the outcome of the investigation regarding his or her complaint.
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For inquiries or more
information, please contact us directly through our Privacy Office as follows by:
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E-mail: |
privacy@aicom.com |
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Telephone: |
1-604-708-3899 |
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Mail: |
AIC Global Communications
Inc.
#130-4200 No. 3 Rd.,
Richmond, BC
V6X 2C2 |
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Attention: |
Privacy Office
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