1. Commitment to Privacy
(1) Information technology has brought many ways to do business. It allows businesses and customers to interact through electronic means that enables companies to conduct their business efficiently and provide the highest standard of customer service. At the same time, this has brought legitimate concerns about security and privacy of personal information passed from the customer to the business.
2. Privacy Protection in Canada
(1) The Personal Information Protection and Electronic Documents Act (PIPEDA), of the Federal Government of Canada, significantly impacts the way private businesses, corporations, Federal agencies, not-for-profit organizations and associations handle the personal information they have collected in the course of their business. At the same time, it will clearly establish a code of privacy practices that will provide Canadians and those customers of Canadian companies which adhere to this legislation, a mechanism to ensure their personal information is handled respectfully.
(2) PIPEDA acknowledges the need to protect an individual's right to privacy and also addresses the necessity of collecting private information for businesses in the conduct of their business affair. The act provides guidelines and principles for businesses for the accountability, purpose, obtaining of consent, disclosure, accuracy, safeguarding, openness of policy and access to personal information that was entrusted to its care.
(3) The PIPEDA principles:
- (a) accountability;
- (b) identifying the purposes for personal information collection;
- (c) obtaining consent;
- (d) limiting the collection of personal information;
- (e) limiting use, disclosure, and retention of personal information;
- (f) accuracy of personal information;
- (g) safeguarding personal information;
- (h) openness about policies and procedures;
- (i) providing access to personal information; and
- (j) challenging compliance.
Under the Act, we at Sublive are obliged to demonstrate to our customers and to any individual our commitment in protecting one's personal and private information. We have developed our policy to meet the compliance of the Protection of Personal Privacy and PIPEDA.
4. The Personal Information We Collect
- Contact information, i.e., phone number and/or e-mail address
- How did you hear about Sublive?
(2) To process your requested services, our Customer Representative and Sublive website interface will likely collect the following personal information:
- Contact number
- E-mail address, if any
- Home address
- Contact information of person signing for the Services
- Financial disclosure of necessary information compliant in detail as the services requested of Sublive
5. Why We Collect Your Personal information?
(1) Sublive collects personal information only for the following purposes:
- (a) to establish and maintain responsible commercial relations with you and provide you with ongoing service(s) as requested of us by you;
- (b) to obtain information for billing and collection;
- (c) to manage the flow between borders in and out of Canada;
- (d) to manage and develop Sublive's business and operations to provide its customer the highest level of satisfaction; and
- (e) to meet legal and regulatory requirements.
6. What is personal information
Personal Information is any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity. Personal information is information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal information shall include but is not limited to: identifying information such as name, home address, home telephone number, e-mail address, Social Security number, financial information and employment-related information such as may be found on resumes, applications, background verification information, or in employment references. In agreeing to acquire services from Sublive you agree with us in all circumstances financial transaction information and anaylsis thereof associated with point of sales software, provided it is or is made devoid of any of the foregoing, is not personal information.
7. We Will Not Use Your Personal Information Without Your Consent
(1) In general, the use of our products and services by a customer constitutes implied consent for us to collect, use and disclose personal information for all identified purposes.
(2) Customers of Sublive may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice; however the nature of the Services Sublive offers would typically require any cusomter to also terminate those services should such wish to terminate disclosure of personal information. Customers can contact Sublive at 1-888-407-0501 or via email at email@example.com to express their intention to withdraw their consent.
8. We Will Only Use Your Personal Information for the Purpose We Mentioned
(1) We can only use your personal information for the purpose we have stated and within the limits of the PIPEDA. In most instances this will be for use in providing the Services you have requested of Sublive.
(2) Sublive will not collect personal information unless you contact us directly. In the future, Sublive may use this information to contact you regarding products or promotions, as well as other products and services, which may be of interest to you. If you do provide us with personal information we may use the information to contact you, via e-mail, regular mail, telephone or other means, to provide you with information that you requested about specific products or services, provide additional future information about products or services that may be of interest to you, and to learn about and develop products and services. If you do not want this information disclosed you may "opt out" of future contacts at any time by un-subscribing from our database pursuant to the terms of any services agreement you may have with us or should we not have an agreement with you then via contacting the Privacy Officer, in writing, as described below in the section titled "Contact Us".
(3) Is Your Information Accurate? We do our best to keep your personal information as accurate as possible during the collection process. We may from time to time, update your personal information within the limits of the purpose we have mentioned.
(4) If the purpose of the collection of personal information has been fulfilled, we can no longer gather updates of your personal information.
9. How Long Do We Keep Your Personal Information?
(1) We maintain your personal information until the purpose we have mentioned has been fulfilled. We also take into consideration the amount of time required by law to maintain such records.
(2) After such time, your personal information will be properly disposed according to our guideline in the destruction of personal information, however in your agreement to acquire Services from Sublive you agree that your personal information may be used for not less than one (1) year subsequent to the termination of Services for the production of Sublive Services to others who purchase such Services in the generation of group data records. Group data records are industry comparison benchmarks of performance for certain key performance index markers within a business such as gross profit, annual sales, sales per day, etc. In agreeing to acquire services from Sublive you agree with us in all circumstances group data records and anaylsis thereof associated with point of sales software is not personal information.
10. Our Commitment to Data Security
(1) We are committed to protect your personal information with security safeguards appropriately in place including measures for continuiously working to prevent loss, invalid access, use, modification, disclosure or other misuse of your personal information. All reasonable steps are taken to prevent unauthorized use or disclosure of your personal information.
(2) The methods of protection include:
- (a) physical measures, for example, locked filing cabinets and restricted access to offices;
- (b) organizational measures, for example, security clearances and limiting access on a "need to know" basis; and
- (c) technological measures, for example, the use of passwords and encryption.
(3) We make the effort to train our employees and make them aware of the importance of maintaining the confidentiality of personal information. Only Sublive's employees with a business need to know, or whose duties reasonably so require, are granted access to your personal information.
(4) We store personal information data only to the extent of its purpose including Services acquired from customers of Sublive and as maybe required by law. Sublive shall store your personal information via secured databases located within the United States of America and or other countries outside of Canada.
11. Public Non-subscriber Website Access
12. Subscriber Services - Subway
13. Children and Data Collection
Sublive adheres to the United States of America federal privacy protection standards as stated in that country's Children's Online Privacy Protection Act ("COPPA"). We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any personal information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately as is set out at "Contacting US" and/or via email at firstname.lastname@example.org. We will use reasonable efforts to promptly delete the child's information from our databases.
14. Contacting Us
(2) We will make the effort to respond to all inquiries within the required period provided by the PIPEDA. We have put in place a Privacy Officer to look after the implementation and compliance of the Act.