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Privacy Policy

Introduction

Protecting the privacy and confidentiality of personal information is an important aspect of the way DATA Communications Management Corp. (DCM) conducts its business. Inherent throughout DCM’s corporate culture is our commitment to managing, enforcing, and practicing our Privacy Policy. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is fundamental to DCM’s daily operations.

DCM strives to protect and respect personal information of its customers, employees, suppliers, business partners, and so on in accordance with all applicable privacy laws including, Canadian federal Personal Information Protection and Electronic Documents Act (PIPEDA), as amended by the Digital Privacy Act (Canada) (collectively, “Privacy Laws”). Each staff member of DCM must abide by this organization’s procedures and practices when handling personal information. Our Privacy Policy provides you with all of the safeguards set forth in PIPEDA and applies to the management of personal information in any form whether oral, electronic, or written.

DCM is not engaged in selling personal information to third parties for such third parties’ use in marketing or solicitation.

Purpose

This Privacy Policy informs everyone of DCM’s commitment to privacy and establishes the methods by which privacy is ensured.

Scope

This Privacy Policy applies to all personal information within DCM’s possession or under its control other than personal information received from DCM clients as part of services provided by DCM to said DCM clients, unless specifically provided in the underlying contractual arrangements. For clarity, our Privacy Policy does not apply to information other than personal information.


Definitions

Personal information – any identifying information about an individual or group of individuals, including name, date of birth, address, phone number, e-mail address, social insurance/security number, nationality, sex, gender, health history, financial data, credit card numbers, bank account numbers, assets, debts, liabilities, payment records, credit records, loan records, opinions, religion, and personal views.

Consent – means either express consent or implied consent.

  • Express consent is given either verbally or in writing in terms of authorizing collection, use and/or disclosure of the individual’s personal information for the purposes stated at the time consent is sought or otherwise in this Privacy
  • Implied consent is consent that one concludes has been given based on what an individual does or does not do in the circumstances.

 

The Privacy Principles for DATA Communications Management Corp.

Our privacy management plan is based on ten guiding principles in Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and includes guidelines on the collection, storage, and retention of personal information as follows:

1. Accountability

DCM is responsible for personal information under its control. As a result, DCM has designated an individual, James Lorimer, as Chief Privacy Officer (CPO). As CPO, he is the individual who is accountable for DCM’s compliance with the ten principles set out herein.

2. Identifying purposes

The purpose of the information and the way it is to be used must be clearly identified before DCM receives it. There are specific protocols for its transmission and handling, including project ID and individual access codes, which must be communicated to all relevant internal and external parties. In general, DCM collects, uses, and discloses personal information about you in order to provide services to and otherwise engage with our customers. More specifically, DCM collects, uses and discloses your personal information for the following purposes:

  • To establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual and legal obligations;
  • To develop and manage our business and operations. This may include the sharing of personal information by and between DCM personnel and affiliated companies, and with third party service providers and agents, for such purposes;
  • To audit compliance with DCM policies and contractual and legal obligations;
  • To distribute our newsletters and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers; and
  • To provide products and services of third parties with whom DCM has a commercial relationship; as permitted by, and to comply with, any legal or regulatory requirements or provisions; and for any purpose to which you consent. DCM will collect, use and disclose only that personal information necessary for the valid business purposes that have been identified.

3. Consent

The knowledge and consent of the individual is required for the collection, use, or disclosure of personal information, except as permitted by Privacy Laws. Pursuant to this Privacy Policy, you acknowledge your consent to DCM for collection, use and disclosure of your personal information which you provided to DCM, as stated above. When a customer requires DCM to collect third-party personal information on its behalf, it is the customer’s responsibility to ensure that any consent that is required pursuant to Privacy Laws has been obtained by the individual(s) in question, that such consent was informed and documented (including, the disclosed purpose of such collection) and that the information collected is limited to that reasonably required for the realization of the purpose disclosed to the individual when consent was sought.

4. Limiting collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by DCM. Information shall be collected by fair and lawful means and may be collected from other sources including, but not limited to, credit bureaus or other third parties who confirm that they have the right to disclose the information. In most cases, collection shall be pursuant to the underlying contractual arrangements.

5. Limiting use, disclosure and retention

Personal information shall not be used or disclosed for purposes other than those for which it is collected (“Purposes”), except with the consent of the individual or as required or permitted by Privacy Laws. Personal information shall be retained only as long as necessary for the fulfillment of those Purposes or as required by Personal information may be disclosed to DCM’s service providers that DCM has retained that require access to such personal information in order to perform the services for DCM. These may include services in terms of the hosting, operation and/or maintenance of its information systems, websites, online platforms and portals, the processing of any payment made in conjunction with any purchase of products, any fulfillment of any purchase of products, customer service, the undertaking of customer satisfaction surveys or with respect to other operational, marketing, financial or technical matters. Personal information may also be disclosed in conjunction with any outsourcing of DCM’s operations or business processes (or the repatriation of the foregoing). Personal information may be disclosed in conjunction with any sale of DCM and/or any of its affiliates, or any of their respective businesses or parts of their respective businesses.

6. Accuracy

DCM will take reasonable measures to ensure that personal information that is being used or otherwise relied upon is accurate, complete, and up-to-date. DCM will update and/or supplement personal information as and when necessary to fulfill the identified Purposes. DCM will correct any inaccuracy in terms of personal information upon notification from you. DCM reserves the right to validate requested changes to the personal information in its possession or under its control both in terms of the identity of the individual requesting such changes or in terms of the changes themselves. DCM may not routinely update personal information if the foregoing is not necessary to fulfill the identified purposes and if the foregoing will not adversely affect the subject individual(s).

7. Safeguards

Security safeguards, appropriate to the sensitivity of the information, shall be maintained in regard to personal information in our possession or under our The security safeguards are designed to protect personal information against loss or theft, as well as unauthorized access, disclosure, interception, copying, use, modification or deletion. Technological measures include use of passwords, firewalls, and encryption. Please note, however, that the implementation and maintenance of such security safeguards does not eliminate the risk of any unauthorized access, reproduction, interception, alteration, destruction, distribution or publication of personal information. Please do not communicate sensitive personal information through such means, including any personal health information. You acknowledge and understand that information communicated over public networks or by unsecured e-mail or other unencrypted communications is subject to interception and you assume sole responsibility for use of any such communications.

8. Openness

DCM shall make information readily available to you about its Privacy Policy and practices relating to the management of personal information, which is accessible on our website datacm.com.

9. Individual access

Upon request, subject to certain exceptions under Privacy Laws, you shall be informed of the existence, use, and disclosure of your personal information and shall be given access to that information. You may wish to challenge the accuracy and completeness of the personal information and have it amended as appropriate.

  • Note: In certain situations, under Privacy Laws, DCM may not be able to provide access to some or all of your personal information it holds or may otherwise be entitled to deny access or otherwise provide details in terms of the foregoing. The reasons for denying access will be provided to you upon Exceptions may include, without limitation, information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

10. Challenging compliance

You may wish to address a concern in writing, regarding DCM’s compliance with the above principles to DCM’s Chief Privacy Officer. DCM shall investigate all complaints and respond within (30) thirty days. If a complaint is found to be justified, DCM shall take appropriate measures to resolve the complaint, including, if necessary, amending this Privacy Policy and

Individuals can obtain more information as well as a copy of the federal legislation through the Privacy Commissioner of Canada’s web site at www.privcom.gc.ca.

Policy Statement

  • DCM assumes full accountability for the personal information within its possession and control. This organization has appointed a Chief Privacy Officer as custodian of all privacy matters and legal compliance with privacy laws.
  • DCM obtains personal information directly from the individual to which the information belongs. Individuals are entitled to know how DCM uses personal information and this organization will limit the use of any personal information collected only to what is needed for those stated purposes. DCM will obtain individual consent if personal information is to be used for any other DCM will not use that information without the consent of the individual.
  • Under no circumstances will DCM sell, distribute, or otherwise disclose personal information or contact lists to third parties. However, limited disclosure may be required as part of DCM fulfilling its stated contractual and other legal obligations and day-to-day operations. This may include consultants, suppliers, or business partners of DCM, but only with the understanding that these parties obey and abide by this Privacy Policy and comply with its requirements, to the extent necessary of fulfilling their own business duties and day-to-day operations.
  • DCM will retain personal information only for the duration it is needed for realizing the underlying Purpose(s). Notwithstanding the foregoing, personal information may be retained beyond the realization of the main purpose(s) for which it was originally collected where the foregoing is necessary, useful or relevant to the completion of any ancillary transaction, for bona fide record retention purposes, where required by law, where residual obligations or liabilities may exist or come to exist), where such retention is necessary, useful or relevant for internal administrative, accounting, technical and operational purposes (including claim management and actual and prospective litigation), where the personal information is relevant to litigation or potential litigation and/or where such retention is reasonable and otherwise permitted by applicable laws. Once personal information is no longer required, it will be destroyed in a safe and secure manner. However, certain laws may require that certain personal information be kept for a specified amount of Where this is the case, the law and its data retention requirements will supersede this policy.
  • DCM endeavours to protect personal information with the appropriate security measures, physical safeguards, and electronic precautions. DCM maintains personal information through a combination of paper and electronic files. Where required by law or disaster recovery/business continuity policies, older records may be stored in a secure, offsite location.
    • Access to personal information will be authorized only for the employees and other agents of DCM who require the information to perform their job duties, and to those otherwise authorized by law.
    • DCM’s computer and network systems are secured by complex Only authorized individuals may access secure systems and databases.
    • Active files are kept in locked filing.
    • Routers and servers connected to the Internet are protected by a firewall and are further protected by virus attacks or “snooping” by sufficient software.
    • Personal information is not transferred to volunteers, summer students, interns, or other non- salaried staff by e-mail or any other electronic electronic format.While reasonable safeguards and security measures are in place to prevent against unauthorized use, access, or disclosure of your personal information, DCM cannot guarantee that such safeguards are impenetrable from breaches. Individuals assume the risk of unauthorized use, access, interception or disclosure of their personal information that may occur as a result of transmission over networks outside the control of DCM or access of encrypted information by unauthorized persons.
  • DCM’s website will include our Privacy Policy Statement and disclose our personal information Individuals inputting data into the website will be notified of:
    • personally identifiable information about the individual that is collected from the Website or through affiliate sites;
    • information about the organization collecting the data;
    • how the data will be used;
    • with whom the data may or may not be disclosed;
    • what options are available to the individual regarding the collection, use, and disclosure of personal information;
    • the information technology security procedures in place that protect against the destruction, loss, theft, alteration, or misuse of personal information under DCM possession and control;
    • how the individual may access and correct any inaccuracies in their personal information;
    • that DCM may share compiled demographic information with its business partners and/or advertisers, but no personal information that can identify any individual person shall be disclosed;
    • that this website may contain links to other sites, but DCM is not responsible for the privacy practices of other organizations’ sites;
    • that IP addresses will be logged in order to administer the site, track visitor movement, and gather demographic information; and these IP addresses will not be linked to any personally identifiable information;
    • any registration or order form asking site visitors to enter personal or financial information will be protected by SSL encryption; and
    • site visitors are given the choice to opt out of having their personal information used at the point where the information is gathered.
  •  In most instances, DCM will grant individuals access to their personal information upon presentation of a written request and satisfactory identification. If an individual finds errors of fact with his/her personal information, he or she may notify DCM as soon as possible to make the appropriate corrections. Should DCM deny an individual’s request for access to his/her personal information, DCM will advise in writing of the reason for such a refusal. The individual may then challenge the decision.
  • DCM may use personal information without the individual’s consent under particular circumstances. These situations include, but are not limited to:
    • DCM is under obligation by law to disclose personal information in order to adhere to the requirements of an investigation of the contravention of a regional or federal, under the purview of the appropriate
    • An emergency exists that threatens an individual’s life, health, or personal
    • The personal information is for in-house statistical study or
    • The personal information is already publicly
    • Disclosure is required to investigate a breach of
  • DCM does not knowingly retain any personal information about any individual under the age of 16 years of age and, to the extent permitted to do so by applicable laws, DCM will securely delete such information from its systems upon being requested to do so by a parent or legal guardian. DCM may, however, retain personal information about an individual that is less than 16 years of age where: (i) such individual has purchased a DCM product in regard to information relating to such purchase; (ii) such personal information is relevant to litigation or potential litigation; (iii) such individual has undertaken any wrongful conduct or conduct that is otherwise actionable in regard to the exercise by DCM, its parent, or its affiliates of any remedy or recourse available to them; and/or (iv) such retention is reasonable and otherwise permitted under Privacy Laws.
  • Personal information is kept at secure facilities and on secure servers owned and operated by DCM and/or third party service providers retained by DCM that are located in

Privacy and Our Website

DCM may collect personal information through its website located at www.datacm.com (the “Website”). This section of the Privacy Policy applies to the operation of the Website and all associated services provided by DCM (the “Online Services”).By accessing the Website, individuals consent to the collection, use, disclosure and retention of their personal information as described in our Privacy Policy.

Purposes

The following is a summary of the reasons why personal information is collected in regards to an individual’s access of the Website and use of the Online Services:

  • personal information is required to make use of certain features of the Website;
  • personal information is required to help DCM improve the Website by better understanding how the Website is being accessed and used by end users; and
  • personal information is required to help DCM assess products sold through the Website and determine which products should be offered through the Website and how such products, and the promotion, offer and sale of such products, may be
  • personal information is required to communicate with individuals in terms of inquiries that they may make or to send them promotional offers and materials with respect to the Website, DCM products and/or those of its parent and affiliates.

DCM may combine or aggregate any of the personal information collected in conjunction with individuals accessing the Website and/or using the Online Services, offline, or elsewhere for any of these purposes, including delivering targeted advertisements that are based on an individual’s previous online activity on the Website.

Collection

The following personal information may be collected in terms of an individual’s access and use of the Website or certain sections or features of the Website:

  • An individual may be required to provide his or her name, e-mail address, mailing address and/or phone number when he or she requests product information or contacts DCM in regard to his or her use of the Website or contractual relationship with
  • An individual may through the Website sign up to one or more mailing lists. In conjunction with the foregoing, he or she will be requested to provide his or her name and e-mail
  • You may be required to provide your name, e-mail address, mailing address and/or telephone number when you create a user account for the Website, including our online Client portal accessible through the Website; you may also have the option of providing additional personal information about yourself such as your age, marital status and other demographic information. We may suggest and recommend DCM products to you based on your user profile generated by your registration
  • The Website may allow or invite individuals to request demonstrations of certain DCM products. Individuals who choose to do so, will be asked to provide their name and e-mail address and may receive an e-mail to confirm their registration and subsequent e-mail communications to provide updates and reminders and, in some instances, confirmation of their attendance at live
  • An individual’s use of social media networks and social media account names may be made known to DCM when such individual opts to “like” or “follow” DCM or its products via social media sites such as Facebook, LinkedIn, Instagram and Certain features of the Website may attempt to determine your geographical location through your IP address.
  • DCM may monitor access to certain Website resources and features by end users and other browsing patterns and Any such data will be anonymized and aggregated and will not be associated with any particular individual. DCM will ensure that an individual’s personal information cannot be reconstructed from such anonymized and aggregated information.
  • In some instances, we may ask individuals to provide us with their feedback in terms of their user experience on the Website, with respect to any dealings with any of our personnel or with respect to any of their purchases of our products. Individuals who choose to provide DCM with such feedback, agree that DCM may use it internally to assess any changes or improvements to the Website, its products, its services, its operations, its pricing, its marketing materials and practices as well as its other business practices. If an individual provides DCM with contact information, DCM may contact such individual to obtain clarifications or obtain your further

Cookies

Through the use of computer “cookies” we collect data such as your IP address, browser type, operating system software, city, country, and specific DCM web pages through which you have clicked. This data is collected automatically and utilized to help us improve our Website. If you wish, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, if a user refuses a cookie, he or she may not be able to access some portions of the Website and/or use some of the features available on the Website.

Please note that third party service providers retained by DCM use cookies and/or device identifiers to provide services and/or to serve ads based on someone’s past visits to websites, including our Website. Such third parties have access to both cookies created through access to our Website and through access to third party websites. More specifically, DCM uses both Google Ads and Google Analytics which make use of first party and third party cookies stored on your device. You are encouraged to access and review their privacy policy.

You may opt out of Google’s use of cookies or device identifiers by visiting Google Ads settings at https://myadcenter.google.com/?hl=en&sasb=true#display_optout. Information about how you can opt out of other third party service providers’ use of cookies may be obtained at https://thenai.org/opt-out/.


Employment Opportunities

Please note that the Website’s “Career” section redirects users to DCM’s job posting LinkedIn page. Applications submitted through LinkedIn and any other information provided to DCM through such LinkedIn are subject to both our Privacy Policy and LinkedIn’s own privacy policy and terms and conditions of use. By submitting an application or providing personal information through LinkedIn, you agree to be bound by both and consent to the information collection, disclosure, use and retention described in each of the foregoing.


User communications

When an individual sends e-mail or other communications to DCM, DCM will use such individual’s contact information and whatever other information is provided in the underlying communication for the purposes of DCM’s review, processing, redirection, escalation, and response to such communication and any comments or inquiries contained therein. These can include e-mails sent by an individual or messages sent via the “Contact Us” feature of the Website to make inquiries or report incidents relating to the Website.


Clickstream Data & Embedded Links

“Clickstream Data” refers to information generated by the activity of Internet users based upon the websites they visit, links they click or apps they use. DCM may provide links to other websites, and we are able track the path of these links as followed by the user. We use this information to improve our Website and services offered on our Website, and to measure the overall effectiveness of our communications with customers.


Log Data

When individuals visit the Website, their web browser will send data about their computer’s IP address, type of browser or version, and statistics regarding the time spent on the Website (and/or on particular webpages or sections of the Website) and actions performed on the Website (“Log Data”).

Log Data is usually only logged for a temporary period of time. Log Data may, however, be retained for security purposes such as to block users who are suspected of breaching the Website’s terms of use from further accessing the Website.

Log Data may also be anonymized and aggregated to compile statistical information which may be used for operational, marketing or other commercial purposes.


Do not track signals

Some browsers include “Do Not Track” features that, when activated, send a signal or preference to the websites you visit indicating that you do not wish to be tracked (“DNT Signals”). Because there is not yet a common understanding of how to interpret DNT Signals, we do not currently respond to these when you access and interact the Website or use any Online Service.


Hyperlinks

The Website may contain hyperlinks to websites and other online platforms or portals owned and operated by third parties and over which DCM has no control. Individuals accessing such hyperlinks acknowledge and agree that DCM is not responsible for the collection and use of their personal information by such third parties through such third party websites and other online platforms or portals. Individuals are strongly encouraged to review the privacy policies of each website or other online platform or portal that they visit.

Changes to the Privacy Policy

DCM reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our websites. We will provide to you such revised Privacy Policy upon written request to the Chief Privacy Officer. However, DCM will obtain the necessary consents required under applicable Privacy Laws if it seeks to collect, use or disclose an individual’s personal information for purposes other than those to which your consent has previously been obtained unless otherwise required or permitted by Privacy Laws.

Further Information

DCM has an appointed a Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable Privacy Laws. For information on DCM’s privacy practices, please contact our Chief Privacy Officer at:

DATA Communications Management Corp.

9195 Torbram Road

Brampton Ontario L6S 6H2

Email: privacy@datacm.com

Phone: 905-791-3151