Privacy Policy
|
Introduction We have adopted this Canadian Customer Privacy Policy to guide how we utilize Personal Information about Customers. “Personal Information” means information about an identifiable individual, and includes names, telephone numbers, addresses, e-mail address, credit card numbers, and related credit and transactional information and certain other personal information. Customers may provide to us by any means, including through our websites, by e-mail, telephone, fax or mail. This Policy will evolve and change as we continue to study privacy issues. How We Use Your Personal Information Our purpose in establishing this Policy is to advise you of the policies and information practices we follow in collecting, storing, using and disclosing Personal Information. This Policy is designed in a manner that recognizes both the right of privacy of individuals with respect to their Personal Information and our need to collect, use or disclose such Personal Information for purposes that a reasonable person would consider appropriate under the circumstances. When Personal Information is sent by an individual to us as described in this policy, it will be treated in accordance with this policy as described below. Except as otherwise permitted or required by law, we will not collect, use, or disclose your Personal Information without your consent. Generally, by providing us with your Personal Information, you are communicating your consent to our collection, use and disclosure of such information for the purposes for which you provided the information to us, and as described in this Policy. However, you will, at the point of collection of the Personal Information, and from time to time thereafter, be given the option of “opting out” of or “opting in” to our collection, use and disclosure of your Personal Information for certain other purposes by signing a form, checking a box on a form, clicking on an icon (or via a similar electronic method) on our websites, or by contacting us as described below. If you do not want us to collect your Personal Information or use it for purposes other than as necessary to fulfill your request, please use the “opt out” option so that your information is not collected or used. If you have submitted Personal Information to us and wish to later opt out or withdraw your consent to its retention, use or disclosure, please contact us using the methods described below. You may opt out or withdraw your consent, subject to legal or contractual restrictions, at any time and on reasonable notice. Customers can elect to opt out from any or all of the following communications: 1) Mail – e-mail and direct mail;(2) Phone -telephone and fax solicitation; or (3) Contact – all communications including e-mail, direct mail, fax and telephone. In addition, Customers can opt out of further e-mail communications by following the directions included in our e-mail communications or by visiting the website and following the opt-out instructions. A Customer may also contact us through the methods stated below for a number of other purposes, including: (1) to opt-out of communications as described in “Consent/Opt-Out” above; (2) to receive information or special offers; (3) to provide feedback and comments on this Policy; (4) to request access to or correction of the Customer’s Personal Information; and (5) to make inquiries or complaints regarding our Privacy Policy and/or privacy practices: Individual send to us certain Personal Information collected in connection with your website membership, including the name, address, telephone number, e-mail address (if provided) and transaction detail (what goods and services were charged and the method of payment) collected. In addition, we may collect, use or disclose Personal Information that you voluntarily provide to us for the purposes described under “How We Use Your Personal Information”, including Personal Information submitted by visitors to the website. How We Use Your Personal Information With your consent, we may use your Personal Information for various purposes as described below. Except as otherwise permitted or required by law, or as may otherwise be noted in this Policy, Customers will be given the opportunity to opt out of or opt in to use of their Personal Information for secondary purposes when Personal Information is collected, and at any time thereafter by contacting us as described in the Consent/Opt-Out section. We may use third party service providers to perform services on our behalf, and we provide Personal Information to such providers solely for the specific services that they are performing. These service providers are prohibited from using or disclosing Personal Information for any other purpose. E-mails. We will ask each Customer to submit their e-mail address for the primary purposes of sending membership confirmations when your request is made online or when you otherwise request e-mail confirmation. In addition, Customers can register on the website to receive such e-mail offers. With your consent, we may also collect Customer e-mail addresses for purposes of conducting consumer research and surveys, as more fully described below. At any time a Customer may opt-out of receiving e-mail communications by following the directions posted in the e-mail communications, by visiting the website and following the opt-out instructions, or by following the contact instructions described above in the Consent/Opt Out section. Direct Mail/Outbound Telemarketing. Customers who supply Personal Information may receive periodic mailings or phone calls from us with information on new products and services or upcoming special offers/events. Customers may also receive mailings/calls from third parties we select whom we believe offer potentially valuable goods or services. We will only disclose your Personal Information to these third parties with your consent. Customers will be offered the option to decline or opt out from these communications at the time the information is collected. Customers may also contact us to opt-out of such communications as described above in the Consent/Opt-Out section. Research/Survey Solicitations. From time to time we may perform research (online and offline) by conducting surveys of our Customers. Participation in these surveys is voluntary, and the information collected will be used for research and reporting purposes and to help us to better serve Customers by learning more about their needs. The survey responses may also be used by us to determine the effectiveness of our websites, various types of communications, advertising campaigns, and/or promotional activities. TCP Global Solutions may also share and disclose aggregate data to other parties for anonymous research, statistical, and analysis purposes. Participants who do not wish to receive e-mail or other communications, including communications relating to surveys, will be provided the opportunity to opt-out of the receipt of such communication at the time of collection of their Personal Information or by notifying us as described above in the Consent/Opt-Out section. Other Uses of Personal Information. In addition to the uses described above, we will use or disclose your Personal Information for certain general business purposes including the following: (1) Using Personal Information to enforce a contract with us or any Terms of Use of our websites; (2) Providing information on corporate credit card usage to the corporate card holder Customer directly or through third party service providers; (3) Transferring and/or disclosing Customers’ Personal Information to parties connected with the contemplated or actual financing, insuring, sale, or assignment or other transfer of the beneficial interest in all or substantially all of the assets or shares in the capital of TCP Global Solutions, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. Limiting Collection, Use, Disclosure and Retention We collect, use and disclose Personal Information only to the extent necessary to fulfill the purposes for which it was collected and as required or permitted by law. Your Personal Information is retained only as long as is necessary to fulfill those purposes, subject to reasonable legal limitations periods, statutory or regulatory retention requirements and legitimate business requirements. We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification. Credit card numbers used for payment are automatically encrypted so that they cannot be easily accessed. We safeguard our Customers’ Personal Information on the Internet by using industry-standard practices. Although “guaranteed security” does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information. Access to your Personal Information is restricted to those employees and agents who need such access to do their jobs and to fulfill the purposes for which the Personal Information was collected. Currently, our websites utilize a variety of different security measures designed to protect Personal Information from unauthorized access by users both inside and outside TCP Global Solutions, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs) and authentication mechanisms (e.g., digital certificates) This helps maintain the confidentiality, privacy, and integrity of transactions, and also helps to protect confidential information – such as credit card numbers, online forms, and financial data – from loss, misuse, interception and hacking. We take all commercially reasonable efforts to create and maintain “firewalls” and other appropriate safeguards to ensure that, to the extent TCP Global Solutions controls the Personal Information, the Personal Information is used, accessed and disclosed only as authorized by TCP Global Solutions consistent with this Policy, and to prevent unauthorized modification or destruction. Our information protection practices and processes help us to maintain accurate, timely, complete and relevant information for our business purposes. Although we use commercially reasonable efforts to maintain data security when data is transmitted through third party communication service providers, we do not warrant the security of data during such transmission. On our websites we do not collect Personal Information from Customers unless they provide it to us voluntarily and knowingly. When you register as a member with us on the Internet, we will capture information such as name, address, telephone number, e-mail address, and credit card number and related transactional information to process your membership. The primary purpose of capturing the e-mail address is to send a membership confirmation. However, the Personal Information may also be used to send Customers e-mail offers from us and select third party partners, when the Customer has consented to such communications as described in the “Email” section above. Information provided on the Internet is treated the same as that collected offline, and we will only use it for other purposes, such as contests, promotions or surveys, where the Customer has consented as described above. Third Party Websites. Third party websites (i.e. websites not affiliated with or controlled by TCP Global Solutions) that you may access through links, banners and/or other means of electronic connection on our websites may have their own separate terms of use, privacy and data collection practices, and security measures. We have no control over these third party websites and no responsibility or liability for the practices, policies, terms and security measures implemented by third parties on their websites. Your interaction with these sites will not be governed by this Policy or the terms of use of our websites. In addition, these third party websites may have content, advertising, banners, links, sponsors, partners and connections over which we have no control and no responsibility. We do not endorse or approve the content, terms of use, privacy policy, advertising or sponsors of any linked website. Aggregated Non-Personal Information. Like many other Internet sites, we may automatically collect certain non-Personal Information regarding our Customers, such as software client information (for example, IP addresses to the extent not identified with an individual, browser versions and operating systems) and aggregate information (for example, number of pages accessed) in order to analyze Web traffic and usage trends, and to enable us to tailor content and services to provide a better fit to our Customers’ needs. Information of this nature does not pertain to your specific identity and is not associated with your Personal Information. We may use IP addresses to identify you when we feel it is necessary to enforce compliance with our website Terms of Use, to comply with applicable law, or to protect our service, website, users and others. Our websites may use third party service providers to serve and host our advertisements. These third parties may place cookies on your computer if you click on the advertising. The third party cookies may be used to (among other things) track whether the site was accessed from the advertisement. We do not control these third party cookies, so they may not follow this Policy or the rules we have set for our own cookies. If you do not want to activate these third party cookies, do not click on the advertising. We may be permitted or required by law to collect, use or disclose Personal Information about you without your consent for certain purposes or under certain circumstances, including, but not limited to, disclosure to a law enforcement agency, response to a court order, under the discovery process in litigation and prosecution, or collecting a debt which you owe to us. We make efforts to ensure the accuracy of Personal Information we use to fulfill your requests and for purposes for which you have consented, and to correct and update our database as necessary for the stated purpose. In the event a Customer notifies us that such Personal Information held by TCP Global Solutions or a Franchisor is inaccurate or outdated, TCP Global Solutions, where appropriate and upon notification and sufficient time for verification, will take all reasonable steps to correct any inaccuracy or update outdated information of which we are made aware. In addition, we will update Personal Information we store and provide it to the third parties described in this Policy when you indicate the information has changed, such as changes of address or e-mail address, (a) in response to your request and/or (b) in order to fulfill the purpose for which such Personal Information was collected, and/or as otherwise required by law. You may request access to your Personal Information in our possession by writing to us at the address provided above. We establish and maintain a file of Personal Information for each Customer. Your file will be kept at TCP Global Solutions, RR #1 Box 2, Elgin Ontario Canada K0G 1E0 and only authorized employees and agents of TCP Global Solutions who require access to your Personal Information to fulfill their job requirements will have access to your file. If you wish to access your file or make corrections to it, please contact us as described above. In some limited circumstances, we may not be able to grant you access to your Personal Information, for example if doing so would threaten the security of another individual. Please feel free to download or make a copy of this Policy. You may obtain a copy free of charge by writing to us at Privacy Officer, TCP Global Solutions, RR # 1 Box 2, Elgin Ontario Canada, K0G 1E0, and with a request for the Canadian Customer Privacy Policy. We may change or terminate this Policy at any time without prior notice. We will post any Policy changes to our websites to notify you of these changes and provide you with the ability to opt out of any new, unanticipated uses of Personal Information not previously disclosed in the Policy. Any such changes shall be effective immediately upon posting. Your continued use of our websites and/or provision of your Personal Information after such posting constitutes your acceptance of these changes. Please check our Policy periodically, or contact us as described above, if you are concerned about how your Personal Information will be used. |
