What does this Policy encompass?
This Policy describes how LLL complies with PIPEDA including the purposes for which information is collected, used and disclosed, CWST’s treatment of personal information and your rights concerning your personal information. This Policy also applies to all individuals whose personal information is collected by LLL including, without limitation, by signing up for memberships or toolkits.
The responsibility for the personal information under LLL’s control rests with its Privacy Officer. The individual designated as Privacy Officer may change from time to time, however, his or her identity will be made known upon request.
LLL will never disclose personal information under its control to third parties, except for an identified purpose, and with your express or implied consent or in accordance with PIPEDA.
Why we collect information from you
LLL collects personally identifiable information from you only with your knowledge and consent. LLL collects, uses and discloses personal information based on the products and services you request from us. For example, we collect, use and disclose personal information to complete purchases of membership packages or our toolkit on our website. We also use your personal information to deliver information to you that you have requested from us, including by virtue of signing up for our toolkit or by becoming a member. We also use your personal information to accept payment, record your membership or subscription start and end dates and generate a membership card for you. Finally, we will use your personal information to collect aggregated data (such as average age of users and other demographics) so that we may better serve our clientele.
We collect non-personally identifiable information from you in order for us to better understand how our Website is used. Information about a user's visit is logged, however your IP address is never referenced to personally identifiable information. Usage statistics are gathered in a non-intrusive manner. The log files are private documents and are primarily used by the server administrator for error notification, server administration and to monitor Website performance. At times portions of the log files may be viewed by others for the purpose of server administration, security or when required by law.
LLL collects both personally identifiable information and non-personally identifiable information with the goal to serve you better and to offer or bring your attention to products and services that may interest you.
In addition to the above, other purposes for which LLL collects, uses and discloses are as follows:
- Communications between you and LLL and notes concerning those communications.
- LLL collects and uses credit card information for the purposes of processing purchase transactions and stores and uses such information only for the purposes of processing membership / toolkit renewals where you have agreed to such renewals.
- When you are entering a contest sponsored or administered by LLL, LLL collects certain information so that it can contact you for the purpose of administration of the Contest.
- Personal information may be collected for the purposes of identification.
- Personal information may be collected for the purpose of communicating changes to our Website or your membership or other promotions.
- Upon any sale of LLL, your personal information may be disclosed to and used by the purchaser for any of the purposes listed in this Policy.
- LLL may implement certain Google analytics advertising features that use first party and third party cookies to collect and disclose information about the internet usage on your computer so that LLL and others may tailor their respective product and service offerings to that computer’s user based on your internet usage. You are not personally identified by the information. If you wish to opt out of the Google analytics advertising feature on any particular computing device, you do so by clicking: https://tools.google.com/dlpage/gaoptout/
- LLL’s Social Media accounts collect any personal information you disclose in your social media accounts when you ‘follow’, ‘like’ or similarly subscribe to our accounts. We will market to you through these channels with ad information and the like. You can control what and how information is received by adjusting the settings within your social channels account settings.
Consent is required for the collection of personal information for the above purposes, or any new purposes that LLL identifies from time to time.
The form of consent required by LLL will vary depending on the sensitivity of the information requested and the reasonable expectations of the customer. Consent will be implied for all purposes unless the purpose indicates that express consent will be collected.
LLL may collect, use or disclose your personal information without your consent in circumstances indicated in PIPEDA. For example, LLL may disclose personal information to a collection agency for the purpose of collecting any amounts owed.
LLL does not collect personal information indiscriminately. LLL limits the collection of personal information to that which is necessary for purposes it identifies.
LLL primarily collects personal information directly from you; however, personal information may also be collected from other sources including other people who represent that they have the right to disclose information.
The personal information that LLL collects directly from you may be collected in a variety of ways, including, by being disclosed directly by you to LLL, generated by your transactions with LLL of website usage, or observed by LLL.
The types of personal information collected include: (i) including name, address, amount paid, payment history, complaints, requests, items purchased, birthdate, and the like; and (ii) information necessary to identify you.
Limiting Use, Disclosure and Retention
LLL only uses and discloses information for the purposes for which it was collected, or otherwise in accordance with PIPEDA. Any new purpose for which the information is to be used or disclosed shall be documented, and consent will be obtained for it.
Unless this Policy indicates otherwise, LLL retains your personal information for a minimum period of seven years after the expiry of any services provided to you. Personal information will be disposed of by shredding or otherwise destroying it. Third party services may be retained to destroy personal information; however, that third party will be required to provide assurances to LLL that it will protect the personal information. Your personal information in connection with sending you promotions and newsletters will be kept until you unsubscribe from receiving such promotions and newsletters.
Personal information will be kept as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You are responsible for informing LLL about changes to your personal information. If you have concerns about the accuracy of your personal information collected by LLL, then please contact LLL at the phone number or address indicated at the end of this document.
LLL protects personal information against loss or theft; as well as unauthorized access, disclosure, copying use or modification; with security safeguards appropriate to the sensitivity of the personal information. Files are protected by keeping them in areas restricted to employees, and/or in locked filing cabinets or rooms. LLL’s employees have been made aware of the need to safeguard personal information and they only access the information on an as-needed basis. LLL also uses firewalls and passwords to protect electronic personal information.
LLL actively invests in maintaining security levels appropriate for the protection of digital assets to protect against the loss, misuse and alteration of data used by our system. LLL fulfills its security responsibilities through regular remote back-ups, updating security patches promptly and periodic reviews of our security systems and procedures.
LLL’s policies and practices related to the management of personal information are contained in this Policy. The Policy as well as additional information and documents are available from the Privacy Officer on request. They include:
- A Personal Information Request Form to be used to inquire about or gain access to personal information held by LLL; and
- A Privacy Complaint Form used to complain about LLL’s treatment of personal information.
Upon written request, LLL will divulge the existence, use and any disclosure made of personal information and will give you access to your information. Written requests must be delivered to the Privacy Officer at the address at the end of this Policy. Personal Information Request Forms are available from the Privacy Officer on request. If assistance is needed with the request, please contact the Privacy Officer.
LLL will respond to an access request within 30 days, unless an extension of time is required, pursuant to PIPEDA, in which case the response may take up to an additional 30 days. A fee for reasonable costs incurred pursuant to the request may be charged to you by LLL, provided that you are informed of the fee in advance and do not withdraw your request.
LLL may require additional information from you in order to locate certain personal information. If this is the case, the additional information will not be used for any purpose other than that of locating the personal information.
If your information on file with LLL is proven to be incomplete or incorrect, it will be amended as required. Where necessary, the amended information will be transmitted to third parties using the information in question.
LLL will not comply with access requests in certain situations:
• If it would reveal information about a third party;
• If the information is subject to solicitor-client privilege;
• If to do so would reveal confidential commercial information; and
• If the information was generated in the course of a formal dispute resolution process.
If LLL does not comply with an access request, it will inform you of the reasons for such refusal.
Any concerns respecting LLL’s compliance with PIPEDA should be addressed to the Privacy Officer. A Privacy Complaint Form is available from the Privacy Officer. LLL will investigate and respond to written complaints within 90 business days of receiving a complaint. If a complaint is found to be justified then LLL will take appropriate measures, including, if necessary, amending its policies and procedures.