SVS Marketing Policy on Privacy of Customer Personal Information

Products purchased on this site are fulfilled, billed and shipped by SVS Marketing.

SVS Marketing will comply with: (i) Personal Information Protection and Electronic Documents Act ("PIPEDA"), a federally enacted act which protects personal information that is collected, used or disclosed and (ii) any future provincial protection of privacy legislation as it relates to the rights of customers. For the purposes of this policy, personal information means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Any reference to a customer within this policy is in reference to personal information and not business information ("Customer").

The Canadian Standards Association Model Code ("Code") for the protection of personal information is a national standard that was developed by the Canadian Standards Association. The Code is a central part of PIPEDA. The Code's ten privacy principles are identified in PIPEDA as follows:

1. Accountability
2. Identifying Purpose
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure & Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance

SVS Marketing has implemented policies and procedures to give effect to the principles, including:

1. Implementing procedures to protect personal information.
2. Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information by SVS Marketing.
3. Training staff and communicating information to staff about SVS Marketing policies and procedures.
4. Developing information to explain SVS Marketing policies and procedures to Customers.

These principles are explained in more detail below:

1. Accountability

   SVS Marketing is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for SVS Marketing compliance with PIPEDA.

   Identifying Purpose

   SVS Marketing will identify and document the purposes for which it collects personal information. Only personal information that is necessary for those identified purposes will be collected. If SVS Marketing intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and consent for such new purpose will be obtained from the Customer to which the personal information relates prior to using such personal information. Customer inquiries regarding the purposes for the collection, use and disclosure of personal information will be addressed by SVS Marketing or referred to the Privacy Officer.

   Consent

   The knowledge and consent of Customers is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law. SVS Marketing will seek consent for the collection of personal information at the time of collection, wherever possible. SVS Marketing will make a reasonable effort to ensure that Customers are advised of the purposes for which the personal information being collected will be used, and will state the purposes in a manner that will allow Customers to reasonably understand how their personal information will be used or disclosed by SVS Marketing.

   Consent may be obtained in a variety of ways, for example, through an application form, orally by telephone or by electronic media, depending on the circumstances and the type of personal information being collected, and in particular, on the sensitivity of the personal information. The reasonable expectations of Customers will be considered when obtaining consent. For example, where Customers provide their names and addresses for mailing and billing purposes, they should reasonably expect that this information would also be used for sending out Customer Satisfaction Surveys, where the choice to respond is the Customers'.

   Although information may be publicly available, SVS Marketing will treat this in accordance with PIPEDA principles. Moreover SVS Marketing may provide personal information to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.

   The use of SVS Marketing will be considered consent to collect, use and disclose personal information for stated purposes..

   Consent may be withdrawn by a Customer by providing reasonable notice to SVS Marketing to the Privacy Officer. SVS Marketing will inform the Customer of any implications of such a withdrawal. Any withdrawal of consent will still allow SVS Marketing to use and disclose a Customer's personal information in order to collect or enforce payment of amounts owing as a result of a Customer's previous or continuing use of SVS Marketing services.

   Subsequent use of www.goforgoldsaftey.ca will automatically provide consent for the collection, use, disclosure and retention of personal information.

2. Limiting Collection

   The collection of personal information will be limited to that which is appropriate in the circumstances.

   The only information collected through the Website, goforgoldsafety.ca other than that provided by the Customer voluntarily to initiate a transaction, is browser information.

3. Limiting Use, Disclosure & Retention

   SVS Marketing will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the Customer or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.

   Certain SVS Marketing employees may be given access to a Customer's personal information collected by SVS Marketing in so far as their duties require access for the purposes outlined. SVS Marketing employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purposes.

   Personal information that has been used to make a decision about a Customer will be retained in accordance with the SVS Marketing document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. SVS Marketing retains personal information of a Customer only for as long as it is required for SVS Marketing’s business purposes or as required by federal and provincial laws.

4. Accuracy

   SVS Marketing will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

   SVS Marketing will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. SVS Marketing will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is accurate and up-to-date.

   Access to a Customer's personal information on record with SVS Marketing may be requested by that Customer in order to review and amend their personal information, as appropriate. In circumstances where personal information has been provided by a third party, SVS Marketing will refer the Customer to that party. It is the responsibility of the third party to maintain accuracy of the personal information that is provided by them.

   Safeguards

   SVS Marketing will take reasonable steps to protect personal information through security safeguards appropriate to the sensitivity of the personal information. Employees of SVS Marketing who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

5. Openness

   SVS Marketing will make readily available to Customers specific information about its policy and guidelines relating to the management of personal information.

   SVS Marketing will be open about its policy and procedure with respect to the management of personal information, and Customers will be able to acquire information about these policies easily and in a form that is generally understandable.

6. Individual Access

   SVS Marketing will inform a Customer of the existence, use and disclosure of their personal information (including to third parties) and will provide access to that personal information, upon written request. SVS Marketing will assist a Customer in the preparation of a request for access when such a Customer requests assistance. SVS Marketing will inform the Customer whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible.

   There may, however be situations in which SVS Marketing will not be able to provide access to all the personal information that it holds about a Customer, although these situations will be limited and specific, and permitted or required by law. For example, SVS Marketing will not be able to provide access to a the Customer's personal information where giving such access would likely reveal personal information about a third party, unless that third party's personal information can be severed from the Customer's personal information. If SVS Marketing refuses a request for access, the Customer will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Customer of their recourse.

   SVS Marketing will require that Customers requesting access to their personal information will provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit SVS Marketing to provide an account of the existence, use and disclosure of the Customers' personal information.

   SVS Marketing will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information may have been disclosed when it is not possible to provide a list of the organizations to which specific personal information have actually been disclosed.

   SVS Marketing will respond to a Customer's request to access their personal information within a reasonable time, and not later than 30 days after receipt of the request. SVS Marketing may be entitled to a 30 day extension to respond, in limited circumstances, in which case the Customer will be notified of such an extension, the new time limit, the reasons for extending the time limit, and their right to make a complaint to the Privacy Commissioner with respect to the extension.

   SVS Marketing may charge a reasonable fee for responding to a request. This fee will be determined based on the request and any request specific administrative or system costs that may be incurred, and will advise the Customer, in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.

   A Customer will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or addition of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate. In some circumstances, the Customer will be referred to a third party to amend their information.

   When a Customer's challenge to the accuracy and completeness of their personal information is not resolved to their satisfaction, SVS Marketing will record the unresolved challenge and will transmit the existence of the unresolved challenge to third parties who have access to the personal information, where appropriate.

7. Challenging Compliance

   A Customer will be able to address a challenge concerning compliance with the above principles to the Privacy Officer. SVS Marketing will handle all complaints or inquiries about the policies and procedures relating to the handling of personal information in line with the processes that are in place.

   SVS Marketing will inform Customers who make inquiries or lodge complaints of the existence of the relevant complaint procedures. SVS Marketing will investigate all complaints, and if a complaint is justified, SVS Marketing will take appropriate measures, including amending policies and procedures.