Privacy Policy

1. Introduction

Truespeed Internet Services Inc. (“Truespeed”) provides a broad range of telecommunications services to Customers, including Internet access and phone service in Canada. Truespeed is committed to maintaining the privacy, confidentiality, security and accuracy of customer and employee information. The Truespeed Privacy Policy (“Privacy Policy”) is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided by Truespeed to their customers. The objective of the Privacy Policy is responsible and transparent practices in the management of personal information, in accordance with provincial and federal legislation. Truespeed will continue to review the Privacy Policy from time to time to make sure it is relevant and remains current with changing technologies and laws and the evolving needs of Truespeed and our customers.

2. Summary of Principles

Principle 1 – Accountability

Truespeed is responsible for personal information under our control and has designated personnel who are accountable for compliance with the following principles.

Principle 2 – Identifying Purposes for Collection of Personal Information

Truespeed shall identify the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a customer is required for the collections, use or disclosure of personal information, except where inappropriate.

Principle 4 – Limiting Collection of Personal Information

Truespeed shall limit the collection of personal information to that which is necessary for the purposes identified. Truespeed shall collect personal information by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention of Personal Information

Truespeed shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Truespeed shall retain personal information, only as long as necessary for the fulfillment of those purposes.

Principle 6 – Accuracy of Personal Information

Truespeed will perform best efforts to ensure that personal information is accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 – Security Safeguards

Truespeed shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness Concerning Policies and Practices

Truespeed shall make readily available to customers specific information about their policies and practices relating to the management of personal information.

Principle 9 – Customer Access to Personal Information

Truespeed shall inform a customer of the existence, use and disclosure of his or her personal information upon request and may at its sole discretion give the individual access to the information. A customer shall be able to challenge the accuracy and completeness of the information and request it be amended as appropriate.

Principle 10 – Challenging Compliance

A customer shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Truespeed’s compliance with the Privacy Policy.

3. Scope and Application

The ten principles that form the basis of the Privacy Policy are interrelated and Truespeed shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. In compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the commentary has been tailored to reflect personal information issues specific to Truespeed.

The scope and application of the Privacy Policy are as follows:

The Privacy Policy applies to personal information about customers of Truespeed that is collected, used or disclosed by Truespeed.

The Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.

The Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Truespeed:

Information that is publicly available; or

The name, title or business address or telephone number of an employee of an organization. The application of the Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations, tariffs or agreements, or the order or determination of any court or other lawful authority including any applicable regulations, orders or determinations of the Canadian Radio-television and Telecommunications Commission.

4. Definitions

Collection – the act of gathering, acquiring, recording or obtaining personal information from any source including third parties, by any means.

Consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of Truespeed. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

Customer – an individual who uses, or applies to use, Truespeed products or services or otherwise provides personal information to Truespeed in the course of Truespeed’s commercial activities.

Disclosure – making personal information available to a third party.

Employee – an employee of Truespeed.

Personal Information – information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual. For a customer, such information includes a customer’s credit card information, billing records, service and equipment, and any recorded complaints.

Third Party – an individual other than the customer or his agent or an organization other than Truespeed.

Use – the treatment, handling, and management of personal information by Truespeed.

5. The Truespeed Privacy Policy in Detail

Principle 1 – Accountability

Truespeed is responsible for personal information under their control and shall designate one or more persons who are accountable for compliance with the following principles.

1.1 Responsibility for ensuring compliance with the provisions of the Privacy Policy rests with the senior management of Truespeed, which shall designate one or more persons to be accountable for compliance with the Privacy Policy. Other individuals within Truespeed may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.

1.2 Truespeed shall make known, upon request, the title of the person or persons designated to oversee Truespeed’s compliance with the Privacy Policy.

1.3 Truespeed is responsible for personal information in their possession or control, including information that has been transferred to a third party for processing. Truespeed shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7).

1.4 Truespeed has implemented policies and procedures to give effect to the Privacy Policy, including:

Implementing procedures to protect personal information and to oversee Truespeed compliance with the Privacy Policy;

Establishing procedures to receive and respond to inquiries or complaints;

Training and communicating to staff about the Truespeed policies and practices; and

Developing public information to explain Truespeed’s policies and practices.

Principle 2 – Identifying Purposes for Collection of Persona Information

Truespeed shall identify the purpose for which personal information is collected at or before the time the information is collected.

2.1 Truespeed collects personal information only for the following purposes:

To establish and maintain responsible commercial relations with customers and to provide ongoing service;

To understand customer needs;

To develop, enhance, market or provide products and services;

To manage and develop their business and operations, including personnel and employment matters; and

To meet legal and regulatory requirements.

Further references to “identified purposes” mean the purposes identified in this Principle 2.1

2.2 Truespeed shall specify orally, electronically or in writing the identified purposes to the customer at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Truespeed who shall explain the purposes.

2.3 Unless required by law, Truespeed shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a customer is required for the collection, use or disclosure of personal information, except where inappropriate.

3.1 In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, Truespeed may use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.

Truespeed may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.

Truespeed may disclose personal information without knowledge or consent to a third party representing Truespeed, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.

3.2 In obtaining consent, Truespeed shall use reasonable efforts to ensure that a customer is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer.

3.3 Generally, Truespeed shall seek consent to use and disclose personal information at the same time they collect the information. However, Truespeed may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.

3.4 Truespeed will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only it such collection, use or disclosure is required to fulfill the identified purpose.

3.5 In determining the appropriate form of consent, Truespeed shall take into account the sensitivity of the personal information and the reasonable expectations of their customers.

3.6 In general, the use of products and services by a customer constitutes implied consent for Truespeed to collect, use and disclose personal information for all identified purposes.

3.7 A customer may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers may contact Truespeed for more information regarding the implications of withdrawing consent.

Principle 4 – Limiting Collection of Personal Information

Truespeed shall limit the collection of personal information to that which is necessary for the purposes identified. Truespeed shall collect personal information by fair and lawful means.

4.1 Truespeed collects personal information primarily from our customers.

4.2 Truespeed may also collect personal information from other sources including credit bureaus or other third parties that represent that they have the right to disclose the information.

Principle 5 – Limiting Use, Disclosure and Retention of Personal Information

Truespeed shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Truespeed shall retain personal information only as long as necessary for the fulfillment of those purposes.

5.1 In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. (See Principle 3.1)

5.2 In addition, Truespeed may disclose a customer’s personal information to:

Another telecommunications services provider for the efficient and effective provision of telecommunications services;

An entity involved in supplying the customer with communications or communications directory services;

Another entity for the Development, enhancement, marketing or provision of any of the products or services of Truespeed;

An agent retained by Truespeed in connection with the collection of the customer’s account;

Credit grantors and reporting agents;

A person who, in the reasonable judgement of Truespeed, is seeking information as an agent of the customer; and

A third party or parties, where the customer consents to such disclosure is required by law.

5.3 Truespeed may disclose personal information about their employees:

For normal personnel and benefits administration;

In the context of providing references regarding current or former employees in response to requests from prospective employers, to the extent that such references are granted at all; or

Where disclosure is required by law.

5.4 Only those employees of Truespeed who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about customers.

5.5 Truespeed shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as require by law. Depending on the circumstances, where personal information has been used to make a decision about a customer, Truespeed shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.

5.6 Truespeed shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 – Accuracy of Personal Information

Personal information shall be accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

6.1 Personal information used by Truespeed shall be sufficiently accurate, complete and up-to-date to minimize the possibility that the inappropriate information may be used to make a decision about a customer.

6.2 Truespeed shall update personal information about customers when necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 – Security Safeguards

Truespeed shall protect personal information by security safeguards appropriate to the sensitivity of the information.

7.1 Truespeed shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Truespeed shall protect the information regardless of the format in which it is held.

7.2 Truespeed shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

7.3 All employees of Truespeed with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.

Principle 8 – Openness Concerning Policies and Practices

Truespeed shall make readily available to customers specific information about their policies and practices relating to the management of personal information.

8.1 Truespeed shall make information about their policies and practices easy to understand, including:

The title and address of the person(s) accountable for Truespeed compliance with the Privacy Policy and to whom inquiries or complaints can be forwarded;

The means of gaining access to personal information held by Truespeed; and

A description of the type of personal information held by Truespeed, including a general account of its use.

8.2 Truespeed shall make available information to help customers exercise choices regarding the use of their personal information and the privacy-enhancing services available from Truespeed.

Principle 9 – Customer Access to Personal Information

Truespeed shall inform a customer of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to the information. A customer shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.

9.1 Upon request, Truespeed shall afford to a customer a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in the understandable form within a reasonable time and at minimal or no cost to the individual.

9.2 In certain situations, Truespeed may not be able to provide access to all the personal information that they hold about a customer. For example, Truespeed may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Truespeed may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, Truespeed shall provide the reasons for denying access upon request.

9.3 Upon request, Truespeed shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Truespeed shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.

9.4 In order to safeguard personal information, a customer may be required to provide sufficient identification information to permit Truespeed to account for the existence, use, and disclose personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

9.5 Truespeed shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Truespeed shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

9.6 A customer can obtain information or seek access to his or her individual file by contacting a designated representative at 613-865-7733.

Principle 10 – Challenging Compliance

A customer shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Truespeed’s compliance with the Privacy Policy.

10.1 Truespeed shall maintain procedures for addressing and responding to all inquiries or complaints from their customers about Truespeed’s handling of personal information.

10.2 Truespeed shall inform their customers about the existence of these procedures as well as the availability of complaint procedures.

10.3 The person(s) accountable for compliance with the Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4 Truespeed shall investigate all complaints concerning compliance with the Privacy Policy. If a complaint is found to be justified,

Truespeed shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer shall be informed of the outcome of the investigation regarding his or her complaint.

6. The Privacy Policy in Practice – Questions and Answers

Q. Why does Truespeed have a Privacy Policy?

A. Our Privacy Policy ensures that our commitment to your privacy is upheld. The Privacy Policy reflects our most recent policies setting out your rights and our obligations respecting the treatment of your personal information by Truespeed. The Privacy Policy complies with the requirements of the Personal Information Protection and Electronic Documents Act as well as the Canadian Standards Association Model Core for the Protection of Personal Information.

Q. How does Truespeed ensure that their employees and agents adhere to the Privacy Policy when handling personal information?

A. Employees and agents acting on our behalf are required to adhere to the Privacy Policy. All of our employees who have access to personal information are trained in the handling of such information, and new employees receive training on privacy as a fundamental part of their initial company training. All of our employees must review and commit to the Privacy Policy annually.

Q. What is personal information?

A. Personal information is information about an identified individual. This includes information about your product and service subscriptions and usage.

Q. Why does Truespeed collect information?

A. Collecting information helps us to serve you better. Truespeed collects personal information only for the following purposes:

To establish and maintain responsible commercial relations with you and provide ongoing service;

To understand your needs and eligibility for products & services;

To recommend particular products & services to meet your needs;

To develop, enhance, market or provide products and services;

To manage and develop the business and operations of Truespeed, including personnel and employment matters; and

To meet legal and regulatory requirements.

Your personal information will not be used for any other purposes without your consent.

Q. Do you share personal information with any other parties, and if so, who?

A. Our general policy is not to provide personal information to any party outside of Truespeed. However, there are certain limited circumstances, outlined below, in which it is necessary to do so. When we do provide personal information to third parties, we provide only that information that is required in the circumstances. Information provided to third parties is used only for the purpose stipulated and is subject to strict terms of confidentiality. Employees of the companies to whom we may provide information must adhere to our privacy standards.

Third parties to whom we may have to provide personal information include:

An agent acting on behalf of Truespeed, such as an entity hired to perform installation or maintenance on our behalf;

Another communications service provided, in order to offer efficient and effective communications services (e.g., to provide Internet services while outside our coverage area for Internet services);

A collection agency, for the express purpose of the collection of past due bills;

Law enforcement agencies, in emergencies, for internal security matters, or where required by court order or search warrant; and

Emergency services, in emergency situations.

Q. How does Truespeed safeguard personal information?

A. We take all of the necessary precautions to ensure the safeguarding of your information, whether it is stored electronically or in paper format. In all cases, information is retained in secure facilities, protected from unauthorized access and kept only as long as is reasonably required. For example, our electronic files are backed up for redundancy, password protected, and accessible only by authorized employees, on a need-to-know basis.

Q. What are “Cookies” and does Truespeed use them?

A. During user interaction with Internet sites, a browser feature called “Cookies” may be used to collect information anonymously and track user patterns on the web. A cookie is a small text file containing a unique identification number that identifies your browser – but not you – to computer systems each time you visit a site that uses cookies. Cookies tell them which pages of their sites are visited and by how many people. This helps companies enhance the on-line experience of visitors to their sites.

Unless you specifically advise them, companies do not know who you are, even though they may assign your browser a cookie. They cannot use cookies, by themselves, to disclose the individual identity of any site user, and they do not combine information gathered by a cookie with personally identifiable information like your name, telephone number, or email address without your consent.

Most major websites use cookies and most major browsers are set up to accept them. If you wish, you can set your browser to either notify you when you have received a cookie, or to refuse to accept cookies.

Q. What do I do if I have further questions?

A. If you have further questions or concerns about your privacy, you can contact us at 613-865-7733, option 3. Our customer service representative will assist you in this regard.

Q. Who is responsible for overall compliance with the Privacy Policy?

A. Everyone who works at Truespeed Internet Services Inc. is responsible for the compliance with the Privacy Policy and the applicable privacy restrictions.

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