Promotion Solutions Inc.

Privacy Policy for Customers

Protecting Customer Information
Promotion Solutions Inc. has always been committed to protecting the privacy of customers and has long-standing security measures in place to preserve the confidentiality of sensitive information, including personal information received on behalf of its customers. 

Background
The federal government has passed legislation dealing with the collection, use and disclosure of information about any identifiable individual.  This legislation is called the Personal Information Protection and Electronic Documents Act or PIPEDA, and applies to commercial activities across Canada that collect, use and/or disclose personal information, except in those provinces that have passed substantially similar legislation.  In those jurisdictions, the substantially similar provincial legislation will apply.

Scope of this Policy
This policy sets out ten principles that will be observed by Promotion Solutions Inc. (“Promotion Solutions”) in the collection, use and disclosure of information of customers.  A separate policy applies to employees.  If personal information is made anonymous by removing details so that an individual is not identifiable to the user or recipient of that information, it is not governed by this Policy but still will be treated with appropriate safeguards.

Promotion Solutions’ customer base is such that Promotion Solutions collects personal information for itself only in very rare circumstances.  Generally, Promotion Solutions receives personal information on behalf of its customers to enable Promotion Solutions to run contests, fulfill rebates, fulfill premium offers and perform other similar fulfillment activities. 

The Ten Principles of Customer Personal Information Protection

    Principle 1 - Accountability

    Promotion Solutions is responsible for all personal information under its control and its Personal Information Protection Officer (“PIP Officer”) is accountable for Promotion Solutions’ compliance with the principles described in this Policy. 

    The Promotion Solutions PIP Officer may be contacted at 905-822-6969 ext. 221 or at fax number 905-822-4206 or at email privofficer@Promotionsolutions.net.

    Principle 2 - Identifying Purposes

    The purposes for which personal information is collected will be identified by Promotion Solutions at or before the time the information is collected.  Promotion Solutions will also document the purposes for which personal information is collected. 

    Principle 3 - Consent

    The knowledge and consent of the individual, express or implied, are required for the collection, use or disclosure of personal information.  Consent may be given orally or in writing.  The type of consent obtained relates to the sensitivity of the information disclosed.

    Principle 4 – Limiting Collection

    Promotion Solutions will limit the amount and type of personal information collected to that which is necessary for the purposes identified by Promotion Solutions. The personal information will be collected by fair and lawful means.

    Principle 5 - Limiting Use, Disclosure and Retention

    Promotion Solutions will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law.  Personal information will be retained only as long as necessary for the fulfillment of those purposes.  New uses and disclosure require new consent. 

    Principle 6 - Accuracy

    Promotion Solutions will keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.  Promotion Solutions will minimize the possibility that inappropriate information is used to make a decision about the individual.

    Principle 7 - Safeguards

    Promotion Solutions will protect personal information with security safeguards appropriate to the sensitivity of the information to protect it against loss, theft, unauthorized disclosure, copying use or alteration.

    Principle 8 - Openness

    Promotion Solutions will be open about its policies and procedures with respect to management of personal information.  Promotion Solutions will ensure that individuals are able to acquire information about Promotion Solutions’ policies and procedures without unreasonable effort.  Promotion Solutions will make this information available in a form that is generally understandable.

    Principle 9 – Individual Access

    Upon a customer’s request in writing, Promotion Solutions shall inform a customer of the existence, use, and disclosure of his or her personal information and the customer shall be given access to that information, except where the law requires or permits Promotion Solutions to deny access.

    Principle 10 – Challenging Compliance

    An individual will be able to direct a challenge concerning compliance with the above principles to the designated individual or individuals accountable for Promotion Solutions’s compliance, including the PIP Officer.  Individuals may also make a complaint to the Privacy Commissioner.