FlexITy Solutions Inc. (“FlexITy”) is committed to maintaining the privacy of your personal information. Our commitment to you has been developed in accordance with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and ensures that your personal information will only be collected, used, and disclosed in compliance with the law.
Scope of Policy
Where a FlexITy customer collects personal information through solutions provided by FlexITy, FlexITy will work with the customer to ensure those solutions reasonably assist the customer in complying with its privacy obligations.
From time to time changes to this policy may be made and these changes will be incorporated into a revised statement which will be posted here in order to ensure that you will always have the most current information with respect to FlexITy’s privacy practices.
What is Personal Information?
“Personal Information” is information about an identifiable individual but does not include the name, title, business address or telephone number of an employee of an organization. It also does not include information that is available in the public domain.
Collection and Disclosure of Information
FlexITy collects the following information that does not identify you:
- Technical information from your computer’s web browser, including your Internet IP address, if you followed a link to our website, the address of the website you came from; the time you spend on our website; the pages you visit; the operating system and web browser software you use; and, if you locate our website through a search engine, the keywords you used to find us. This information is stored only in aggregate form and used for statistical analysis in an effort to improve our website. FlexITy reserves the right, however, to attempt to link this information to an individual in the event it becomes necessary in order to investigate a security breach related to its website. FlexITy may use your account information and transaction history in an aggregate form for internal use in order to provide a higher level of service to its customers.
- When you visit www.FlexTEL.FlexITy.ca, your web browser is assigned a temporary text file called a cookie. It is placed on your computer for programming purposes only and facilitates your ability to use our website by providing a unique identifier as you move from page to page. If you make use of our search engine, the “cookie” will also remember the keywords you enter. All of this information allows your web browser to “remember” where you have been and allows you to retrace your steps through our website. Most web browsers have a command which allows you to delete cookies after each internet session. The cookie is never redirected to servers outside of FlexITy’s control.
Except as set out above, FlexITy does not collect personal information about guests to its website, other than personal information which is voluntarily provided. In certain situations, you may be requested to provide personal information for specific purposes. For example:
- In the event that you make a help request or an e-mail inquiry regarding some aspect of FlexITy’s business or website you will need to provide your e-mail address and may also provide other personal information. FlexITy will use this information only to respond to your request. FlexITy will retain a copy of your inquiry for up to three (3) months and may thereafter retain information with respect to the nature of your inquiry, cleared of all personal information, which will no longer be associated with you as an individual.
- You may fill out an online survey or questionnaire in which case personal information will be obtained in accordance with the survey or questionnaire. The purposes of the collection and information regarding retention of this information will be provided as part of the survey or questionnaire.
- You may have to provide personal information as part of a contest or promotional offer in which case the purpose of collection and information with respect to retention will be provided to you as part of the entry form.
- We may collect personal information from you if you request products or services. In this case, your personal information will be retained for as long as necessary in order to provide the products or services and for a reasonable period thereafter. If you do not wish your personal information to be used for marketing or promotional purposes, you may specify this when providing the information originally or thereafter by contacting us.
We value your privacy and will keep your personal information secure. To this end, we provide a secure online environment using encryption during transmission. FlexITy also protects your personal information from unauthorised access by locating all databases which retain this information on access-controlled systems behind secure firewalls.
FlexITy does not sell or trade your personal information with other companies. Subject to the following exceptions, we will not disclose your personal information to third parties without your consent. FlexITy may disclose your information in accordance with PIPEDA, including but not limited to situations where such disclosure is required by law, , to comply with valid legal processes such as a subpoena or court order, to collect a debt owed by you to FlexITy, or . where failure to disclose your personal information may put the safety of another individual at risk.
If you have provided personal information and wish to have it removed from our system at a any time, please contact our Privacy Compliance Officer at PCO@FlexITy.ca.
The accuracy of the personal information in our possession depends on you. Please contact FlexITy to inform us of any changes to your information or to confirm the accuracy of the information we retain.
FlexITy ascribes to ten privacy principles to ensure that your personal information is protected:
FlexITy is accountable and responsible for personal information in its possession and under its control. FlexITy has designated a Privacy Compliance Officer (“PCO”) who is accountable for FlexITy’s compliance with this Policy.
FlexITy has adopted procedures to protect your personal information, to receive and respond to complaints and inquiries, to train staff regarding policies and procedures and to communicate policies and procedures to its customers.
For more information on these policies please contact our PCO at PCO@FlexITy.ca.
2. Identifying Purposes
When collecting your personal information, FlexITy will tell you why it is collecting the information and will provide, on request, contact information for the PCO who can answer further questions about the collection.
Generally, FlexITy collects personal information for the following purposes:
- to respond to inquiries about products or services that you are using or are considering purchasing;
- to provide and administer the products and services that you purchase;
- to authenticate your identity;
- to collect information to enable us to improve our products and services;
- to administer contests or promotional offers; and
- to protect us, yourself, and others from fraud or error.If your personal information is to be used by FlexITy for a purpose not previously identified, FlexITy will contact you prior to using your personal information for this purpose to obtain your consent, unless the use is authorised or required by law.
FlexITy will obtain your consent to collect, use or disclose your personal information except where FlexITy is authorized or required by law to do so without consent. For example, we may collect, use or disclsoe personal information without your knowledge or consent where:
- the information is publicly available, as defined by statute or regulation;
- we need to collect debts owed to us by you;
- we are obtaining legal advice;
- we reasonably expect that obtaining consent would compromise an investigation or proceeding; or
- we are contemplating selling all or part of FelxITy’s business;Other exceptions may apply.Your consent can be expres, implied or given through an authorized representative such as a lawyer, agent or broker. Consent may be provided orally, in writing, electronically, by negative option, or otherwise.
You may withdraw your consent at any time, subject to legal or contractual restrictions, and provided that reasonable notice is given to FlexITy. Once notice is given, FlexITy will inform you of the likely consequences of withdrawing your consent, which may include FlexITy’s inability to provide the services requested.
4. Limiting Collection
FlexITy will limit its collection of personal information to that which is reasonable and necessary to provide the services requested, or as authorized by law. FlexITy will collect information only by lawful means.
5. Limiting Use, Disclosure and Retention
Your personal information will only be used or disclosed for the purposes consented to by you or as authorized by law.
FlexITy shall keep personal information only as long as it remains necessary or relevant for the identfied purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, FlexITy shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.
FlexITy will destroy, erase or make anonymous documents or other records containing your personal information once it is reasonable to believe that retention is unwarranted for legal or business purposes. FlexITy will take due care when destroying personal information so as to prevent unauthorized access to the information.
In the event that FlexITy requires the services of a third party in order to deal with your personal information, FlexITy will ensure that the third party adheres to privacy procedures and will keep your personal information confidential. FlexITy will not provide more information than is necessary to the third party and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.
FlexITy does not trade or sell personal information.
FlexITy may disclose personal information about it employees in the following circumstances:
- where the employee consents to the disclosure;
- for normal human resources and benefits administration;
- to respond to requests for references from prospective employers of current or former employees;
- where disclosure is required by law.
FlexITy will make reasonable efforts to ensure that your personal information is accurate and complete. In most cases, however, FlexITy relies on you to ensure that the personal information provided is current, complete and accurate..
If you demonstrate the inaccuracy or incompleteness of your personal information, FlexITy will amend it as required. If appropriate, we will send the amended information to third parties to whom your personal information had previously been disclosed.
When a challenge regarding the accuracy of your personal information is not resolved to your satisfaction, FlexITy will make note that a request to amend the personal information under its control was made but that the information was not amended.
FlexITy has made appropriate security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal of your personal information. Some specific safeguards that have been implemented include:
- physical measures such as locking filing cabinets;
- organizational measures such as restricting employee access to files and databases, as appropriate;
- electronic measures such as passwords, firewalls and
- investigative measures where FlexITy has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
We will take reasonable steps, through contractual or other reasonable means to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to us.
Note that confidentiality and security are not assured when information is transmitted by email. Please notify the PCO in writing at PCO@FlexITy.ca if you do not want FlexITy to communicate with you by email.
FlexITy is open about its privacy policies and procedures relating to the management of personal information. Information about these policies and procedures can be obtained from our office by written request. FlexITy reserves the right to refuse to disclose sensitive information about its policies and procedures to ensure the integrity of its security procedures and business methods.
9. Individual Access
FlexITy will honour your right to be informed of the existence, use and disclosure of your personal information, and your right to access your personal information. Upon written request, FlexITy will provide you with your personal information in its possession; a description of how your personal information is being used; and a list of those to whom your information has been disclosed. We will respond to such requests within  days or provide written notice where additional time is required to respond. We may charge you a reasonable fee for responding to your request.
In some situations, FlexITy may not be able to provide access to certain personal information. Examples of such situations include situations where disclosure would reveal the personal information of another individual, the personal information is subject to legal privilege, the personal information was collected for the purposes of an investigation, or where disclosure would reveal confidential commercial information that could harm the competitive position of FlexITy. In some circumstances FlexITy may be prevented by law from providing access to your personal information. Where FlexITy refuses your request for access to your personal information, it will do so in writing and will explain the reasons why your request is being denied and will identity further steps that are available to you.
10. Challenging Compliance
FlexITy will, on request, provide information regarding its complaint procedures on request. Any inquiries, complaints or questions regarding this Policy should be directed in writing to the PCO at PCO@FlexITy.ca.