Display Date: October 30, 2020
- Canada’s federal privacy legislation, the Personal Information Protection and Electronic Documents Act (hereinafter ” PIPEDA “);
- Quebec’s provincial privacy legislation, the Act respecting the Protection of Personal Information in the Private Sector (hereinafter ” RPPIPS “);
All personal information collected by Cōv communications is in a fair, reasonable, equitable and non intrusive manner and with your consent. Personal information is only accessible for the specific use for which it was obtained. Collected Personal information is only accessible to those required to meet the purposes for which they are collected. Cōv communications values the privacy of its website’s visitors who may choose to transmit us Personal information. Cōv communications acknowledges the importance of suitable protections and management of the Personal information you provide us. This Policy will assist you in understanding the Personal information Cōv communications may collect, how such information may be used and to whom such information may be disclosed.
This Policy discloses Cōv communications ’s practices with regards to the information collected online from users of the Cōv communications website https://covcommunications.com/ (hereinafter “Website“).
For any questions about this Policy, we refer you to Cōv communications ’s privacy officer of Personal information by either of the following methods:
- by email to this following address: email@example.com
- by mail to this following address:
4400, rue Garand
1. TYPE OF INFORMATION WE MAY COLLECT
1.1 “personal information” refers to any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is someone who can be identified, directly or indirectly, by reference to one or more specific factors to his physical, physiological, mental, economic, cultural or social identity. Personal information shall include, but is not limited to name, home address, home number, cell phone number, email address and employment related information such as may be found on resumes, background verification information or employment references.
1.2 “non-personal information” refers to any information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and therefore not subject to special protection and can be regularly shared with anyone inside or outside Cōv communications . Business contact information shall include, but is not limited to: business name, business address, business telephone number, and is not considered personal information in some jurisdictions.
2. COMMITMENT: ADHERING TO THE TEN PRIVACY PRINCIPLES
In Canada, “Fair Information Practices” regarding your personal information are contained in a series of ten (10) privacy principles developed by the Canadian Standards Association and incorporated into Canadian federal privacy legislation PIPEDA. Cōv communications adheres to the 10 privacy principles as follows:
Principle 1 – Accountability. Cōv communications is accountable for all personal information under its control and has appointed a privacy officer who must ensure and meet compliance of Cōv communications ’s Policy and the ten (10) privacy principles. The privacy officer is the one identified herein. Cōv communications is also accountable for the personal information disclosed to a third party for any purposes described herein. In this regard, Cōv communications shall take reasonable means to ensure the confidentiality of personal information by third parties, in accordance with the Policy.
Principle 2 – Identifying Purposes for collection of personal information. Cōv communications must identify the purpose for which personal information is collected at or before the time of collection. Some of the identified purposes for which Cōv communications collects, uses and discloses your personal information (hereinafter the “Identified purposes“) are described below in this Policy. In this regard, in the course of business, Cōv communications collects personal information only for the following Identified purposes:
- establish, develop and maintain business relationships with customers, employees and other individuals with whom it deals;
- sell, improve, develop or otherwise commercialize its products and services;
- detect and assess customers’ interests, needs and expectations in order to improve the present services and products or to offer new products and services;
- administer and manage its business;
- ensure the systems efficiency, reliability and security;
- meet legal and regulatory obligations.
If Cōv communications intends to collect, use and/or disclose your personal information for additional purposes, it shall obtain your consent, unless the law provides otherwise.
Principle 3 – Consent. Cōv communications shall obtain your informed consent, verbally or in writing, for the collection, use or disclosure of your personal information, except as permitted by law or under this Policy. By using any services provided by Cōv communications , you agree to the collection, use and disclosure of your personal information, including the terms of the contract between you and Cōv communications . In this regard, Cōv communications could collect, use or disclose your personal information without your consent in any of the following cases:
- when such collection, use or disclosure is clearly in your interest and that obtaining consent is not possible within a reasonable time under the circumstances, particularly in the case of an emergency, where the life, health or safety of a person is threatened;
- when such collection, use or disclosure of confidential information is contrary to the purpose of that collection, use or disclosure, particularly in the context of a breach of your contractual obligations or to prevent or stop an illicit activity;
- when such collection, use or disclosure of confidential information is made to any Cōv communications agent assigned to debt collection, or is intended to allow Cōv communications to meet any applicable law, subpoena, warrant or other order of a competent court.
Cōv communications shall not require you to consent to the collection, use or disclosure of information before providing a product or a service, unless the collection, use or disclosure in question is necessary for the purposes set in the Policy. You may withdraw consent at any time, subject to legal or contractual restrictions between you and Cōv communications and a reasonable notice. However, given your refusal, Cōv communications may not be able to provide all your products and services. You may contact Cōv communications to be informed of the implications of such withdrawal.
Principle 4 – Limiting collection. Cōv communications shall limit the collection of personal information, both the amount and the type, to what is necessary to meet the Identified purposes, or any other purposes for which Cōv communications shall obtain consent. Cōv communications shall collect your personal information by fair, honest and lawful means, and not by misleading or deceiving you about the purpose for which information is being collected. Finally, in addition to collecting personal information mainly from you, Cōv communications may also collect such information from other sources including credit bureaus or other third parties claiming to be authorized to communicate such personal information.
Principle 5 – Limiting use, disclosure and retention. Cōv communications shall not use or disclose personal information for purposes other than Identified purposes for which it was collected, except with your previous consent or as required by law. Cōv communications shall retain your personal information only as long as necessary to fulfill the Identified purposes. For your information, you understand that Cōv communications may disclose your personal information to:
- any third party operating a business of telecommunications services provider;
- any third party engaged by Cōv communications to provide services, including credit perception, credit analysis, credit survey, improvement of Cōv communications operating business, etc.
- any third party to whom Cōv communications might want to sell part of its business, assets of any entity participating in Cōv communications ’s operational funding;
- any other third party, with your consent or when such disclosure is required by law, including any communication at the request of law enforcement.
Only Cōv communications employees who require access for business reasons, or whose duties reasonably require it, are granted access to your personal information. In some cases, personal information may be stored or processed abroad, and is subject to applicable laws in those countries. Cōv communications shall retain your personal information only for the necessary or useful period for the Identified purposes, or for the period prescribed by law. In the event that personal information was used to make a decision about you, Cōv communications has the obligation to retain it, for a reasonable period of time, to allow you to exercise your right to access the confidential information or the reasons of such decision. Finally, personal information that is no longer necessary to Cōv communications and which is no longer required by law to be kept shall be destroyed, deleted or anonymized.
Principle 6 – Accuracy. Cōv communications shall use reasonable efforts to ensure that your personal information is accurate, complete, current and necessary for the Identified purposes, all in order to minimize the risk that false personal information may be used to make a decision about you.
Principle 7 – Security Safeguards. Cōv communications protects your personal information by appropriate security safeguards to its sensitivity, including by verifying the identity of any third party wishing to access to such personal information. Also, in the event that personal information is transmitted to third parties, Cōv communications shall sign agreements so that such third parties undertake to maintain the protection of your personal information.
Principle 8 – Openness. Cōv communications shall make available specific information about its policies and practices relating to the management of personal information.
Principle 9 – Individual access to personal information. Subject to certain exceptions, Cōv communications undertakes, upon written request, to reveal you the existence, use and disclosure of your personal information and give you access to your personal information, all provided in an understandable way, within a reasonable time and at minimal or no cost, unless required by law. However, notwithstanding what is provided above and in exceptional cases, in particular when personal information may be disclosed for legal reasons, security reasons or business reasons, Cōv communications could refuse to provide access to all your personal information. You have the right to challenge the accuracy and integrality of the personal information we hold and have the opportunity to correct the personal information, if required. In this regard, in case of errors in such personal information, Cōv communications shall act promptly and expeditiously to correct these errors. Finally, in order to access your personal information, please contact the Cōv communications ’s privacy officer of this Policy.
Principle 10 – Challenging compliance. You have the right to address a challenge concerning compliance with this Policy to Cōv communications ’s privacy officer. In this regard, Cōv communications will establish mechanisms to receive and to follow any complaint and all inquiries about its policies and practices regarding the management of personal information. If Cōv communications finds a complaint to be justified, appropriate measures will be taken, including amending its policies and practices, if necessary.
3. TERMS AND CONDITIONS OF WEBSITE USE
4. OTHER DISPOSITIONS
Cōv communications may, at any time and in its sole discretion, modify this Policy. In such a case, Cōv communications shall display a notice on its website at the bottom of the page, and this modification will be effective on the display date of the modified Policy. Cōv communications assumes no liability towards you or other Internet users for the non-compliance of the Policy. The Policy is governed by the applicable laws in Quebec. The parties acknowledge the exclusive jurisdiction of Quebec courts towards any matters discussed herein and agree to comply. If a competent court declares that any provision hereof is invalid, illegal or unenforceable in any way whatsoever, the other provisions will not be affected and will remain in force. Cōv communications ’s default to insist on an absolute respect of any terms of this Policy can not constitute a waiver of any breach of it and will not prevent it, subsequently, to insist on the absolute respect of this modality, or constitute a waiver of any subsequent breach sanction, whether or not of the same nature.