PRIVACY POLICY
THIS POLICY DESCRIBES HOW PERSONAL
INFORMATION ABOUT YOU MAY BE COLLECTED, USED AND DISCLOSED, AND HOW YOU CAN GET
ACCESS TO, AND/OR CORRECT, THIS INFORMATION. PLEASE REVIEW IT
CAREFULLY.
I.
YOUR PRIVACY RIGHTS
Creative Art Glass Inc. recognizes
the importance of privacy and the sensitivity of personal information. We are
committed to protecting any personal information we hold. For these reasons we
have created the following Privacy Policy ("Privacy Policy"). This Privacy
Policy outlines how we manage your personal information and safeguard your
privacy. This policy also applies to Creative Art Glass Inc.'s affiliate
Canadian organizations, including Abax Communications Group. From January 1,
2004, all businesses engaged in commercial activities must comply with the
Personal Information Protection and Electronic Documents Act, and the Canadian
Standards Association Model Code for the Protection of Personal Information,
which it incorporates. The Act gives you rights concerning the privacy of your
personal information. Creative Art Glass Inc. is responsible for the personal
information we collect and hold. To ensure this accountability, we have
developed this policy, and trained our employees about our policies and
practices.
II.
WHAT IS PERSONAL INFORMATION
Personal Information or "PI" for
short is defined as any information about an identifiable individual, but does
not include the name, title or business address or telephone number of an
employee of an organization. For example, your PI includes information that
relates to your physical or mental health, race, origin, color, religion, age,
marital status, education, medical, criminal or employment history, information
relating to financial transactions, identifying number, an unlisted address or
unlisted telephone number, fingerprints, and blood type, among others. In
addition, some information that is otherwise publicly available is not protected
by the Act.
III.
HOW WE COLLECT, USE AND DISCLOSE YOUR PERSONAL
INFORMATION.
We collect, use and disclose
personal information for many different reasons. Below, we describe the
different categories of our uses and disclosure as well as give you some
examples of each category.
A. Collection, Use, Disclosure, and Retention of Personal Information.
Principles of Personal Information:
1. Creative Art Glass Inc. will not
collect any personal information about you unless it relates directly to
activities our organization performs. Creative Art Glass Inc. will obtain your
consent before or at the time the information about you is collected, with very
few exceptions. Normally, we ask for your consent in writing, but in some
circumstances, we may accept your oral consent. Sometimes, your consent may be
implied through your conduct with us or we may not ask for your specific consent
in a case of urgency or where we believe you would consent if asked and it is
impractical to obtain your consent. Any information previously collected about
you will not be re-collected. In order for us to continue to use the previously
collected information, we need your consent. You may also withdraw your consent
in writing, to stop any future uses or disclosure (to the extent we have not
taken any action relying on that consent). Your withdrawal will not have an
effect on the use or disclosure occurring prior to our receipt of your
withdrawal.
2. Creative Art Glass Inc. will notify
you about the purpose for which information about you is requested at or before
the information about you is collected. This notification may be provided orally
or in writing. In the event Creative Art Glass Inc. wishes to use your
information for a new purpose, you will be notified, and have an opportunity to
provide or refuse your consent.
3. After obtaining your consent,
Creative Art Glass Inc. may only use or disclose your PI for the purpose for
which the information was collected, or for a use consistent with that purpose.
We will use or disclose such information only for the purpose for which it was
collected, unless we have your consent, or unless the use or disclosure fits
into one of the exceptions listed below. When information is to be used or
disclosed for a purpose not previously identified to you, such new purpose will
be identified for you prior to use or disclosure, and your consent will be
requested.
4. Whenever possible, Creative Art
Glass Inc. will collect PI directly from you, unless you have authorized
otherwise. We collect information only by lawful and fair means and not in an
unreasonably intrusive way.
5. Creative Art Glass Inc. will take
reasonable steps to ensure that your PI is accurate, up-to-date, and as complete
as possible. If Creative Art Glass Inc. holds information about you and you can
establish that it is not accurate, up-to-date and complete, we will take
reasonable steps to correct it. If any of your information changes, please
inform us so that we can make any necessary changes.
6. We retain personal information for
only as long as we need it to effectively provide our services and for a
reasonable length of time thereafter in case we need to meet any potential
obligations or legal or government requirements. We destroy paper files
containing personal information by shredding. We destroy electronic information
by deleting it, and when the hardware is discarded, we ensure that the hard
drive is physically destroyed.
B. Exceptions to Consent.
Under certain circumstances we may use and/or disclose your PI without your consent or knowledge. For example:
1. When disclosure is authorized, or
required by law. For example, we will disclose PI when a law, court order or a
subpoena requires that we disclose information. We will also make disclosures
when the Attorney General of Canada requires it for proceedings involving the
Crown in right of Canada or the Canadian Government.
2. For governmental investigation
activities. For example, we will provide information to assist the government
when it conducts an investigation, audit or inspection of an organization or
other person based upon breach of an agreement or a contravention of federal or
provincial law, or if the information relates to national security, the defense
of Canada or the conduct of international affairs.
3. In emergency situations. We may disclose
PI because of an emergency that threatens the life, health or security of an
individual. In this case, we will inform you in writing of the disclosure.
4. For
legal activities. We may provide your PI to a lawyer who is representing
Creative Art Glass Inc..
5. For
debt collection. We may disclose your PI for the purpose of collecting a debt
owed by you to Creative Art Glass Inc., if any.
C.
Security
Safeguards.
Creative Art Glass Inc. takes all
reasonable precautions to ensure that your personal information is kept safe
from loss, unauthorized access, modification or disclosure.
Among the steps taken to protect
your information are:
… premises security such as
supervised or locked cabinet storage;
… restricted file access to
personal information;
… deploying technological
safeguards like passwords, security software and firewalls to prevent hacking or
unauthorized computer access;
… paper information is
transmitted through sealed, addressed envelopes or boxes by reputable companies;
… electronic information is
transmitted either through a direct line or is anonymized or encrypted;
… internal password and
security policies. We use a number of consultants and agencies that may, in the
course of their duties, have limited access to personal information we hold.
These include computer consultants, office security and maintenance, bookkeepers
and accountants, credit card companies, website managers and landlord. We
restrict their access to any personal information we hold as much as is
reasonably possible. We also have their assurance that they follow appropriate
privacy principles.
IV.
YOUR RIGHTS ASSOCIATED WITH YOUR
PI
You have the following rights with
respect to your PI:
A. The Right to Access Your PI. In most
cases, you have the right to look at or get copies of your PI that we have, but
you must make the request in writing. However, we reserve the right to confirm
the identity of the person seeking access to personal information at or before
complying with any access requests. Summary information is available upon
request. More detailed requests, which require archive or other retrieval costs,
may be subject to a small fee. In certain situations, we may deny your request
for access. If we do, we shall explain why. Your rights to access your personal
information are not absolute. We may deny access when:
… denial of access is required
or authorized by law;
… we have disclosed information
to a government institution for law enforcement or national security
reasons;
… information relates to
existing or anticipated legal proceedings against you;
… when granting you access would have
an unreasonable impact on other people's privacy;
… when granting access could
harm an individual's life or security;
… to protect our organization's
rights and property; or where the request is frivolous or
vexatious.
Creative Art Glass Inc. does not use
your Social Insurance Number as a way of identifying or organizing the
information we hold upon you.
B. The Right to Receive an Accounting
of Uses and Disclosures. You have a right to request and receive a list of
instances in which we have disclosed your PI to third parties. We will attempt
to be as specific as possible in identifying the organizations to which we have
disclosed your PI. At a minimum, we will provide you a list of organizations to
which we may have disclosed your PI.
C. The Right to Correct or Update Your
PI. If you believe that there is an error or omission in your PI, you have the
right to request that we correct the error or omission. You must provide the
request and your reason for the request in writing. If you can establish that
the information we hold is inaccurate, we will take reasonable steps to correct
it. We will also take reasonable steps to advise any third parties to whom we
have disclosed your personal information of the correction. If we refuse your
request to correct information, we shall explain why.
V.
COMMUNICATING WITH US
E-mail is not a 100% secure medium,
and you should be aware of this when contacting us to send personal or
confidential information.
VI.
CHANGES TO PRIVACY POLICY
We reserve the right to change the
terms of this our Privacy Policy at any time. Any changes to our Privacy Policy
will apply to the PI we already have in our possession, or information we may
collect in the future. When we make an important change to our Privacy Policy,
we will publish the new policy.
VII.
REQUEST FOR
ACCESS/CORRECTION
If you have any questions about this
Privacy Policy, or if you wish to correct or access your personal information,
please contact our Chief Privacy Officer at: Creative Art Glass Inc., 525
Denison Street, Markham, Ontario, Canada L5R 1B8 Attn: Chief Privacy Officer Or you may
contact our Chief Privacy Officer directly at 905-940-6568 or info@CreativeArtGlass.com. If you
are not satisfied with our response, the Privacy Commissioner of Canada can be
reached at: 112 Kent Street, Ottawa, Ontario K1A 1H3Tel: 1-800-282-1376 Web site:
http://www.privcom.gc.ca/
VIII.
EMPLOYMENT
INQUIRIES
If you apply to Creative Art Glass
Inc. for a job, we need to consider your personal information, as part of our
review process. We normally retain information from candidates after a decision
has been made, unless you ask us not to retain the information. If we offer you
a job, which you accept, the information will be retained in accordance with our
privacy procedures for employee records.
IX.
WEB SITE
Our web site contains links to other
web sites that are provided and maintained exclusively by third parties. Web
sites provided and maintained by third parties are not subject to this Privacy
Policy. Please review the privacy policies on those web sites to determine their
information handling practices. On our web site, like most other commercial
websites, we may monitor traffic patterns, site usage and related site
information in order to optimize our web service. We may provide aggregated
information to third parties, but these statistics do not include any
identifiable personal information.
X.
EFFECTIVE DATE OF THIS POLICY
This policy went into effect on
January 1, 2004.