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Privacy Code
P.I.P.E.D.A – L P R D E


 

Ebox Inc.

This code has been written in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), SC 2000, c. 5 and the Telecommunications Act, SC 1993, c. 38.

Responsibility

In the event of any unresolved issue or claim, contact us in writing, by mail at:

Ebox Inc.
100-1225 Saint-Charles West
(Roundabout at the Longueuil Terminus)
Longueuil QC J4K 0B9

1.0 Consent to the collection, use, and disclosure of personal information –Principle 1

1.1 When you sign up for Ebox, the Personal Information that you disclose to us enables us to provide you with products and services that best suit your needs. We collect only the Personal Information that is strictly necessary to provide our services. You have the option of not giving us Personal Information. However, if you choose this option, we may be unable to provide you with the service or the information you have requested.

1.2 Should Ebox have to deal with certain legal questions, public safety issues, or situations involving an emergency services intervention, Ebox may be legally bound to disclose your Personal Information without obtaining your prior consent.

1.3 Unless you have given your express consent or unless disclosure is required by judicial authorities or by the Act, none of the Personal Information that Ebox has pertaining to you can be disclosed to anyone (including its Authorized Representatives), with the exception of:

1.3.1 you yourself;

1.3.2 a person, who in the reasonable opinion of Ebox, is seeking information as your Mandatary;

1.3.3 a telephone company other than Ebox, on the condition that the information is required for the purpose of providing efficient and cost-effective telephone service delivery; that the disclosure is made in a confidential manner; and that the information is used for this purpose only;

1.3.4 a company providing you with services related to telephone service or telephone directories, on the condition that the information is required for this purpose; that the disclosure is made in a confidential manner; and that the information is used for this purpose only.

1.4 Furthermore, at Ebox, we shall use your Personal Information for certain purposes, such as:

1.4.1 approving your request to sign up for Ebox’s services;

1.4.2 staying in contact with you;

1.4.3 keeping you up to date on current product and service offers and promotions;

1.4.4 detecting and preventing potential fraud or the illegal, improper, or inappropriate use of our products and services;

1.4.5 assessing your level of satisfaction with our products and services;

1.4.6 respecting the law;

1.4.7 the work of an officer or an Authorized Representative whose services are retained by Ebox to obtain payment of the client’s account.

1.5 It is important that you know that under no circumstances shall we sell information about our subscribers to whomever, nor shall we share information about our subscribers with organizations, including our affiliated companies, except in the following cases: (i) upon your consent and solely for the purpose of enabling the latter to offer you their own products or services; or (ii) if the affiliated company is acting as an Authorized Representative.

2.0 Goal statement – Principle 2

2.1 The goal of the privacy policy is to protect our clients and our employees in the context of the delivery of our services.

3.0 Collection limitation – Principle 3

3.1 An Authorized Representative undertakes the Personal Information Collection process primarily through the person involved, but sometimes the Collection is done in another manner when the Act so authorizes. For example, the Mandatary may undertake the Collection of Personal Information from credit-rating agencies or Third Parties who are authorized to Share this Information.

4.0 Conservation of Personal Information – Principle 4

4.1 Ebox keeps Personal Information only for the period it is necessary or useful for the purposes identified, or as per the requirements of the Act. Depending on the circumstances, when Personal Information has been used to make a decision regarding someone about whom Ebox has Personal Information, Ebox shall keep on file an explanation of the decision’s rationale for a reasonable period of time to enable Ebox to provide this person with access to these reasons.

4.2 Ebox applies control measures, timelines, and reasonable, systematic practices in terms of the conservation and the destruction of Personal Information and files that are no longer needed, that are no longer relevant to the purposes identified, or that are no longer required under the Act. Such Information is destroyed, erased, or depersonalized.

4.3 Ebox automatically keeps log files for a period of 90 days unless the law specifies otherwise, i.e. conserving the data longer, e.g., in the case of a copyright infringement notice or a court mandate. In such cases, Ebox must extend the archiving period for the logs, without obtaining your consent.

5.0 Accuracy – Principle 5

5.1 Ebox shall update Personal Information as needed. Anyone who has disclosed Personal Information to Ebox may challenge the accuracy and the comprehensiveness of the Personal Information about them, and have the appropriate corrections made.

5.2 Ebox promptly corrects or completes any Personal Information deemed inaccurate or incomplete. Any unsettled dispute regarding the accuracy or the comprehensiveness of Personal Information must be recorded in the file of the person involved. As applicable, Ebox shares any Personal Information that has been changed with Third Parties who have access to this Personal Information, or informs them of the existence of an unsettled dispute.

6.0 Security measures – Principle 6

6.1 Ebox shall ensure that your Personal Information is protected from any unauthorized access, and from any other type of misuse, by applying the industry’s standard security mechanisms.

6.2 Access to electronic data containing Personal Information shall be restricted to duly authorized users.

7.0 Transparency – Principle 7

7.1 Upon request, Ebox shall provide a person with a list of the Personal Information that it has on that person, as well as with details on its practices in terms of managing this Personal Information.

8.0 Client and employee access to personal information – Principle 8

8.1 Subject to the exceptions stipulated in the Act, Ebox informs anyone concerned who requests it of the existence of Personal Information pertaining to themselves, of how this Information is used, and of the fact that this Information has been shared with Third Parties. Subject to the exceptions stipulated in the Act, upon request, Ebox shall enable the person concerned to consult the Personal Information included in their file. This Personal Information shall be provided in an understandable manner, within a reasonable timeframe, and at minimal cost, if any, to the person concerned. After receiving the access request and before disclosing Personal Information to the person concerned, Ebox may review the file contents solely for the purpose of ensuring that any Personal Information pertaining to other individuals shall not be made available. Any change made during this process shall be for the sole purpose of complying with the Act. In certain situations, it may be impossible for Ebox to allow the person concerned to consult all of the Personal Information that Ebox has pertaining to them. For example, Ebox cannot provide access to the Information if the Communication would reveal confidential commercial information; if the Information is protected by lawyer-client privilege; if the Information was obtained through an official process to settle a dispute; or if the Information was collected during an investigation into a breach of contract or a violation of federal or provincial law. Upon request, Ebox shall provide the reason for the refusal to provide access to the Personal Information.

8.2 In terms of providing a record of the Communication of Personal Information, Ebox shall provide a list of the Third Parties to whom it may have provided Personal Information regarding the person concerned, when it is not possible to provide a definitive list.

To ensure the protection of Personal Information, the person concerned may be required to provide adequate ID to enable Ebox to determine the existence, use, and Communication of Personal Information and to authorize access to that person’s file.

9.0 Complaints concerning non-compliance with the Code’s principles

9.1 Any person concerned may lodge a complaint concerning non-compliance with the principles stipulated in this Code by contacting the person responsible for ensuring compliance with Ebox’s Code.

9.2 Ebox shall conduct an investigation into every complaint pertaining to respecting the Code. Should a complaint be substantiated, Ebox shall take the appropriate steps, including amending the Code and altering its practices, as needed. Should a complainant not be satisfied with the decision of the person in charge of the protection of Personal Information at Ebox, they may contact the Privacy Commissioner of Canada, 112 Kent St., Ottawa, Ontario, K1A 1H3.

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