1.0 PURPOSE
1.1
SETPRO CO. INC. (“SETpro”) recognizes the importance of privacy and the risk of the unauthorized use or disclosure of personal information that comes into the possession or control of SETpro from the use by clients of the Log-In function of the website for clients to access and download their Pro tools (“Log-In function”).
1.2
SETpro further recognizes the necessity to design and implement measures for the security of personal information that comes into the possession or control of SETpro from the use by clients of the SETpro website.
1.3
The purpose of this Website Privacy Policy is to describe the types of personal information collected from clients using the Log-In function of the SETpro’s website, how such information is used and the measures taken by SETpro’s to ensure its privacy and security.
2.0 DEFINITIONS
2.1
In this Website Privacy Policy, unless otherwise stated, the following terms shall have the meaning prescribed for each:
“Personal Information” means all information about an identifiable individual provided or otherwise collected by the Log-In function of the SETpro Website. Personal information includes all information about an identifiable person as defined under the Personal Information Protection and Electronic Documents Act SC 2000, c 5 and includes for purposes of this Website Privacy Policy the person’s email address, employer name, employer address, employer phone number.
“Website” means the set of interconnected web pages designed and developed by SETpro which includes an interactive function for client’s to access their Pro tools.
3.0 APPLICABILITY
3.1
This Website Privacy Policy applies to SETpro and customers accessing the Log-In function of the SETpro Website. It describes the technology and procedures of SETpro in offering its services to clients accessing the interactive function of the Website to ensure the privacy and security of their Personal Information.
4.0 POLICY
4.1
SETpro is committed to ensuring the privacy and security of Personal Information and to meeting its obligations under all applicable Canadian privacy legislation.
4.2
SETpro is committed to collecting, using and disclosing Personal Information provided by customers through the Log-In function of the SETpro Website only for reasonable and bona fide business-related purposes.
4.3
SETpro is committed to taking all reasonable steps to ensure the continuing privacy and security of all Personal Information provided by customers through the Log-In function of the SETpro Website.
4.4
SETpro has established the position of Chief Information Security Officer, responsible for the development and implementation of all necessary rules and procedures for the collection, use, disclosure and retention of Personal Information, including Personal Information provided by customers through the Log-In function of the SETpro Website. The Chief Information Security Officer shall ensure compliance with this Website Privacy Policy and all applicable privacy legislation.
5.0 PRIVACY STANDARDS
5.1Personal Information of customers disclosed through their use of the Log-In function of the SETpro Website shall be collected, used and disclosed by SETpro only for reasonable, business-related purposes, and in accordance with the following privacy principles:
5.1.1Consent.
(a)Express consent is required for the collection, use and disclosure of Personal Information. Customer consent to use Personal Information disclosed through their use of the service agreement is implied for the purposes of undertaking the Log-In and download of Pro tools from SETpro and other reasonably expected business-related purposes.
(b)SETpro may use the Personal Information provided by customers through the Log-In function of the SETpro website, without consent, to send user emails/release bulletins and compliance with any applicable law, regulation, or the order of any court or other lawfully constituted authority.
5.1.2
Limiting Collection. The collection of Personal Information from customers through the Log-In function of the Website will be restricted to that required by the SETpro to undertake the business-related purposes for which it was provided and for SETpro to meet its legal obligations.
5.1.3
Limiting the Use, Disclosure, and Retention of Personal Information. Personal Information collected from customers through website access requests and the Log-In function of the Website will be used and retained only for undertaking the access to the clients Pro tools and to send client notification related to SETpro Pro tools from SETpro and other reasonably expected business-related purposes, or for compliance with any applicable law, regulation, or order of any court or other lawfully constituted authority.
5.1.4
Security of Personal Information. SETpro will take all commercially reasonable steps to protect Personal Information from unauthorized access, use or disclosure. Reasonable steps include physical, electronic and procedural measures appropriate to the level of sensitivity of the Personal Information.
5.1.5 Access to Personal Information.
(a)Customers may access their Personal Information by contacting the Client Experience and Operations manager.
(b)SETpro will correct or update any Personal Information upon request.
(c)SETpro reserves the right to charge a customer requesting access to their Personal Information a reasonable fee for doing so where the costs of providing access are significant.
5.1.6
Response to Inquiries and Complaints. The Chief Information Security Officer will investigate and respond to all customer complaints in regard to the treatment of their Personal Information at the earliest opportunity. If the complaint is found to be justified, the Chief Information Security Officer will so inform the customer and ensure that appropriate corrective measures are taken.
6.0 CONTACT
6.1
Questions concerning this policy should be brought to the attention of the Company Chief Information Security Officer.
