Privacy Policy
Introduction
2degreesC believes the protection of personal information is an important priority. We are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as doing our part to inform our clients of the privacy issues surrounding online projects. This privacy policy outlines how we will comply with PIPEDA and the ten founding principles contained in Schedule 1 of PIPEDA. This privacy policy governs www.2degreesC.com and 2degreesC Inc.
Accountability
2degreesC understands it has a responsibility to protect the personal information under its control. To oversee compliance with PIPEDA, 2degreesC Inc. has designated David Noble, Principal, as its Privacy Officer. He can be contacted as follows:
David Noble
2degreesC Inc.
200 Woolwich St. #202
Guelph,
ON
N1H
3V7
(519) 362-9123
noble@2degreesC.com
Any questions, comments, requests, or complaints regarding our privacy policy, personal information handling procedures, or our compliance with PIPEDA and Schedule 1 of PIPEDA should be directed to the designated officer.
Cookies
2degreesC does not use cookies on www.2degreesC.com.
Log File
Our web servers use log files to analyze trends, administer our site, track
users' movements on an aggregate basis, and gather broad demographic
information for aggregate use. The log files include things such as Internet
Protocol addresses (IP addresses), browser types and versions, Internet service
providers (ISPs), referring/exit pages, platform types, date/time stamp, and
number of clicks. We currently use Webalyzer
and AW Stats as our primary
statistics systems.
Notice of Collection
We will inform individuals of the purpose for collecting information before or
at the time we collect it. If a new purpose(s) for the information arises after
it has been collected, explicit permission to use the information for the new
purpose(s) will be obtained from the individuals to whom the information
belongs, prior to its use. Any modification to the original purpose(s) will be
documented in the Information Log.
Third Parties
2degreesC does not share its information with third parties, except where
specifically authorized by any persons whose personal information is being
collected and shared.
Consent
2degreesC will obtain consent from an individual to
collect, use, and/or disclose their personal information. Consent will be
obtained either before or at the time of collection and in cases where a new
purpose(s) has been identified after collection, consent will be obtained for
the new purpose prior to use. We also recognize that the principle of obtaining
consent is dependant on the level of sensitivity of the information and the
reasonable expectations of the individual. Given this, 2degreesC will take
reasonable efforts to consider these things, in accordance with PIPEDA,
whenever necessary.
Withdrawing Consent
Any time an individual wishes to withdraw consent they can contact the
2degreesC Privacy Officer and the procedures and consequences of withdrawal
will be explained. After such discussion and the identity of the individual
and/or group has been verified, the 2degreesC Privacy Officer will be more than
happy to take the necessary and requested actions required to handle withdrawal
of consent.
Limiting Collection
2degreesC will only collect information for the
purposes stated before or at the time of collection of that information from an
individual. We will specify the amount and type of information that is being
collected and limit collection to those specifications.
Limiting Use, Disclosure, and
Retention
2degreesC will only use and disclose personal
information for the purposes stated before or at the time of collection of that
information. We will specify the amount and type of information that is being
collected and limit use and disclosure to those specifications.
Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose
personal information when required by law when we have a good-faith belief that
such action is necessary to comply with a current judicial proceeding, a court
order, or legal process served on www.2degreesC.com
or 2degreesC Inc.
Business Transitions
In the event 2degreesC goes through a business transition, such as a merger,
being acquired by another entity or selling a portion of its assets, users'
information will, in most instances, be part of the assets transferred.
Accuracy
2degreesC will make sure information is as
accurate, complete, and up-to-date as is necessary for the purpose(s) that it
was collected, used, and/or disclosed. We do not routinely update personal
information that is submitted through our online contact form. In the event an
individual would like to add, edit, or delete their information, the 2degreesC
Privacy Officer will assist with this after verifying the individual's
identity.
Openness
One of 2degreesC's primary method of communication
in its line of business is by digital means. Therefore its policies and
procedures are primarily made available digitally, namely online via the
Internet. In the event that digital access requires unreasonable effort on
behalf of the individual, 2degreesC would be happy to send a package on our
policies and procedures to requesting individuals, provided the cost of doing
so is not prohibitively expensive. Questions, comments, and requests regarding
our privacy policies and procedures can be forwarded to our Privacy Officer.
Individual Access
2degreesC will give an individual access to their
personal information upon request, provided none of the exceptions noted in
Paragraph 4.9 of Schedule 1 of PIPEDA apply. We must receive a request for
access to personal information in writing, as per Paragraph 8(1) of PIPEDA and
we will assist anyone in doing so, if required, as per Paragraph 8(2) of
PIPEDA. If an individual would like their information added to, edited, or
deleted after gaining access, the 2degreesC Privacy Officer will be happy to
comply, if possible. Certain circumstances may require us to refuse to provide
a visitor with a copy of their information, but we will provide reasons for our
refusal. For example, if you request access to your information and it contains
information belonging to another individual who will not grant you permission
to view their information, nor can that information be removed, we would be
unable to grant you access.
Complaints Regarding Access
Requests for access to information are recorded in our Information Log. If an
individual feels a request for information has not been handled satisfactorily,
the individual should notify the 2degreesC Privacy Officer in writing by email
or regular mail. Dissatisfaction will also be noted in the Information Log and
the Privacy Officer will take reasonable efforts to remedy the complaint, if
found justified.
Challenging Compliance
If an individual has a challenge regarding
2degreesC's compliance with PIPEDA and Schedule 1 of PIPEDA, they must contact
the 2degreesC Privacy Officer. The complaint must contain the date, individuals
involved, an explicit statement of the events that occurred, and contact
information for the individual submitting the complaint. The Privacy Officer
will investigate the complaint to the best of their abilities and with
reasonable effort. The individual filing the complaint will be notified of the
actions taken to remedy the complaint. The complaint will also be noted in the
Information Log. In the event an individual is dissatisfied with the remedy for
the complaint they may contact the Privacy
Commissioner of Canada.
Links
The 2degreesC web site contains links to other
sites. Please be aware that 2degreesC is not responsible for the privacy
practices of these other sites. We recommend site visitors make themselves
aware of the policies of these other sites. Our privacy statement only applies
to www.2degreesC.com.
Notification of Changes To
Our Policies
2degreesC will notify individuals of changes by
updating the privacy policy, placing an announcement in the ‘News' page on www.2degreesC.com, and any other method
deemed appropriate. As noted in section 2. Identifying Purposes, if the
intended purpose for information collection changes, the individual to which
the information belongs will be notified via email or other method of
communication indicated at the time the information was originally collected
prior to its use for the new purpose.
Children's Privacy
The 2degreesC site does not knowingly collect
children's information nor does it target children. In the event we discover we
have collected, used, or disclosed children's information through the site we
will take immediate action to discontinue such activity. Reasonable effort will
be taken to notify the parent/guardian of the child/children involved of the
circumstances and any action taken to investigate the matter.
Resources
Several resources were used in the creation of this
privacy policy.
Organization for Economic Co-operation and
Development: Privacy
Policy Generator
Privacy Commissioner of Canada: Personal
Information Protection and Electronic Documents Act (PIPEDA) and Your Responsibilities:
A Guide for Businesses and Organizations
This statement was last updated May 26, 2014.