Personal Information Protection
Private Sector Privacy Legislation
Personal Information Protection Policy
Gumshoe Media Inc.
And Its Subsidiaries
GumAzon.com & GumAzon.ca
Personal Information Protection Policy
At Gumshoe Media Inc. and affiliates GumAzon.com & GumAzon.ca, we are committed to providing our customers, vendors and business brands with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers, vendors and business brands protecting their personal information is one of our highest priorities.
While we have always respected our customers, vendors and business brands privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our customers, vendors and business brands of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’, vendors’ and businesses’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’, vendors’ and businesses’ personal information and allowing our customers, vendors and businesses to request access to, and correction of, their personal information.
This Personal Information Protection Policy applies to Gumshoe Media Inc. and its subsidiaries, GumAzon.com and GumAzon.ca.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Gumshoe Media Inc.
Personal Information –means information about an identifiable individual Examples of personal information our organization collects include name, age, home address and phone number, credit card info. Personal information does not include contact information (described below).
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer, vendor and business voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customer, vendor and business information that is necessary to fulfill the following purposes:
· To verify identity;
· To open and manage an account;
· To deliver requested products and services
· To enrol the client in a program;
· To send out membership information;
· To ensure a high standard of service to our [clients, customers, members];
2.1 We will obtain customer, vendor and business consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer, vendor and business voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer, vendor and business is given notice and a reasonable opportunity to opt-out of his or her personal information being used for marketing of new products or services and the customer, vendor and business does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customer, vendor and business can withhold or withdraw their consent for Gumshoe Media Inc. or its subsidiaries GumAzon.com & GumAzon.ca to use their personal information in certain ways. A customer’s, vendor’s and business’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer, vendor and business in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s, vendor’s and business’s knowledge or consent in the following limited circumstances:
· When the collection, use or disclosure of personal information is permitted or required by law;
· In an emergency that threatens an individual's life, or personal security;
· When the personal information is available from a public source (e.g., a telephone directory);
· When we require legal advice from a lawyer;
· For the purposes of collecting a debt;
· To protect ourselves from fraud;
· To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer, vendor and business personal information where necessary to fulfill the purposes identified at the time of collection:
· To conduct customer, vendor and business surveys in order to enhance the provision of our services;
· To contact our [customer, vendor and business] directly about products and services that may be of interest;]
3.2 We will not use or disclose customer, vendor and business personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer, vendor and business lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use customer, vendor and business personal information to make a decision that directly affects the customer, vendor and business, we will retain that personal information for at least one year so that the customer, vendor and business has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer, vendor and business personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer, vendor and business personal information is accurate and complete where it may be used to make a decision about the customer, vendor and business or disclosed to another organization.
5.2 customers, vendors and businesses may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
A request to correct personal information should be forwarded to the Privacy Officer.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customer’s, vendor’s and business’s correction request in the file.
6.1 We are committed to ensuring the security of customer, vendor and business personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer, vendor and business personal information is appropriately protected:
The use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying customer’s, vendor’s and business’s personal information such as deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customer’s, Vendor’s and Business’s Access to Personal Information
7.1 Customers, vendors and businesses have a right to access their personal information, subject to limited exceptions.
· the information is protected by solicitor-client privilege;
· the disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;
· the information was collected or disclosed without consent, as allowed under section 12 or 18, for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed;
· the information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act
o under a collective agreement,
o under an enactment, or
o by a court;
· the information is in a document that is subject to a solicitor’s lien.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell customers, vendors and businesses how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer, vendor and business of the cost and request further direction from the customer, vendor and business on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer, vendor and business in writing, providing the reasons for refusal and the recourse available to the customer, vendor and business.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Gumshoe Media Inc. and its subsidiaries GumAzon.com & GumAzon.ca compliance with this policy and the Personal Information Protection Act.
8.2 Customers, vendors and businesses should direct any complaints, concerns or questions regarding Gumshoe Media Inc. and its subsidiaries GumAzon.com & GumAzon.ca compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer, vendor and business may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Gumshoe Media Inc. and its subsidiaries GumAzon.com & GumAzon.ca Privacy Officer:
Phone: (587) 500-7570