NEGLIA DESIGN INC.
Currency: January 31, 2018
I. Identifying the purposes and Use of Personal Information
Before collecting any Personal Information, Neglia Design will identify why the Personal Information is required and how it will be used. This Personal Information is documented and kept on file at Neglia Design’s offices in Canada. Neglia Design will obtain the Customer’s consent before using or disclosing Personal Information for purposes other than the original reasons given.
Neglia Design collects and uses a Customer’s Personal Information for the following purposes:
- Collecting, recording and using Personal Information relevant to the performance of the services rendered to and for a Customer;
- Recording and determining the services received by a Customer during his or her relationship with us;
- Marketing our services;
- Administration, billing, accounting and collection in relation to a Customer’s relationship with us;
- Protecting against fraud and error;
- Offering a Customer additional services which may be of interest to such Customer, and personalizing the Customer’s on-line experience;
- Communicating with a Customer generally or to ensure Customer satisfaction;
- Analysing trends, administering our website, tracking Customer’s movements within our website, gathering demographic information and conducting market research;
- Improving the services offered to Customers in the future;
- Enabling Customers to post comments and/or images and upload and download information;
- Complying with all applicable laws; and
- Such other specific purposes which are communicated to a Customer by Neglia Design and its representatives before collection of the Personal Information.
We may use, share and disclose a Customer’s Personal Information to our affiliates, associates, agents, suppliers and such other third parties as Neglia Design, acting reasonably, may deem necessary for the fulfillment of the purposes noted above or where otherwise permitted by law. In the unlikely event that Neglia Design or substantially all of its assets are acquired by a third party, a Customer’s Personal Information may be one of the assets transferred to such third party.
Except in certain extraordinary circumstances, Neglia Design does not collect, use or disclose a Customer’s Personal Information without their knowledge and consent. Such extraordinary circumstances may include, without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent.
III. Limiting collection
IV. Limiting use, disclosure and retention
Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Customer, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous.
Neglia Design has security safeguards in place designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Personal Information under the care of Neglia Design. The nature of the safeguards depends on the sensitivity, format, location and storage of the Personal Information. These security measures may from time to time include locked cabinets, computer passwords, software firewalls to stop hackers, encryption software, restricting access to Personal Information to only those employees or representatives who have a need to know and, if deemed necessary by Neglia Design in its sole discretion, confidentiality covenants from third parties to whom Personal Information has been disclosed.
E-mail, telephone and the internet are not a 100% secure medium, and Customers should be aware of this when contacting us to send Personal Information.
VII. Accountability and Openness
VIII. Individual access
Upon written request of a Customer, Neglia Design will provide such Customer with access to his or her Personal Information. Neglia Design will correct or amend any inaccuracies in the Customer’s Personal Information, and such amended information will be forwarded to any third parties who require access to the information. Neglia Design has the right to refuse a request for access to Personal Information:
- If the information is protected by legal privilege;
- If granting access would reveal confidential commercial or financial information;
- If doing so would reasonably be expected to threaten the life or security of another individual;
- If the information was collected for purposes related to the detection and prevention of fraud;
- If the information was generated in the course of a formal dispute resolution process;
- If the information would likely reveal Personal Information about another Customer;
- If the request is vexatious or frivolous; and/or
- To protect Neglia Design’s rights and property.
If the request of a Customer for such individual’s Personal Information is denied, the individual will be informed in writing of the reasons for the denial, as well as any recourse available to such individual.
Access to a Customer’s Personal Information will be at no cost to such Customer. Minimal charges may apply, however, for the transcription, reproduction or transmission of documents containing Personal Information.
IX. Challenging compliance
If a complaint (“Complaint”) regarding Neglia Design’s handling of Personal Information is received, an individual (the “Investigator”) with the skills necessary to conduct an investigation fairly and impartially will be assigned. The Investigator will have access to all relevant records and will be permitted to speak with employees of Neglia Design who handled the Personal Information access request. The complainant will receive notification of the outcome of the investigation clearly and promptly. Any inaccurate Personal Information or policy/procedure changes will be modified, if necessary, based on the outcome of the Complaint.