Purpose and Scope:
Circuit Stream respects and upholds a customer’s right to privacy and to protection of the customer’s information. Circuit Stream is committed to ensuring compliance with applicable privacy legislation.
This document sets out the policy of Circuit Stream with respect to the protection of the privacy of the customer’s information.
“Customer information” for the purposes of this policy means information about a customer and customer’s business. It does not include information which cannot be associated with a specific customer.
“Third party” for the purposes of this policy is an individual or an organization other than Circuit Stream or the customer.
Circuit Stream is accountable for the customer information in its possession or control, including information that has been transferred to a third party for processing. Circuit Stream has appointed a Privacy Officer who is responsible for the organization’s compliance with this Policy.
All staff are obligated to protect the privacy of customers with regard to all customer information collected by Circuit Stream. Staff are required to follow the procedures of this Policy regarding the management of customer information.
Staff will be adequately trained and provided with information about the privacy laws applying to the organization.
2. Purposes for Collection, Use & Disclosure
Circuit Stream collects and uses customer information for the following purposes:
- in the software development life cycle to design and develop software for the customer
- to design, develop and improve Circuit Stream’s underlying infrastructure, codebase and business model to create a better experience for the customer;
- to provide ongoing software based training services;
- to design, develop and improve Circuit Stream course training services;
- to help the customer improve and optimize business performance;
- to process payments for services provided;
- to enable us to provide statistical information to potential funding organizations.
Circuit Stream will not collect, use or disclose information beyond that required to fulfill the specified purposes.
When customer information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use.
Unless we hear otherwise from you, your use of Circuit Stream’s services and facilities constitutes consent for us to collect, use, and disclose customer information for the purposes stated in this Policy.
You may refuse or withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. Refusal or withdrawal of consent may prevent us from providing to you a service or access to our facilities.
You may refuse or withdraw your consent by contacting us at email@example.com with subject line [Privacy]. Our staff will explain your options and any consequences of refusing or withdrawing consent, and will record your choices.
4. Disclosure of Information to Third Parties
The only circumstances under which customer information may be disclosed to third parties is with express consent from the customer in writing, or as required by law. If customer information is required to be disclosed to third parties, Circuit Stream will ensure that appropriate security undertakings, such as confidentiality clauses in contractual agreements, are employed to protect the transfer and use of customer information. Circuit Stream does not sell, trade, or rent information to third parties.
5. Limiting Collection
We collect customer information only for the purposes identified above.
6. Limiting Use, Disclosure, and Retention
We do not use or disclose customer information for any purpose other than those for which it was collected, except as required by law, or with consent from the customer.
Customer information is retained only as long as is necessary for the fulfillment of the purposes for which it was collected, or as required by law.
Circuit Stream will make all reasonable efforts to ensure that customer information is as accurate, complete, and current as required for the purposes for which it was collected. Circuit Stream relies on customers to ensure that certain information about them, such as their contact information, is current, complete, and accurate. It is the customer’s responsibility to inform Circuit Stream if their information changes.
Circuit Stream will update customer information, when necessary to fulfill the purposes for which the information was collected.
Customers may challenge the accuracy of customer information and request an amendment by written request to the Privacy Officer at firstname.lastname@example.org with the subject line [Privacy].
Circuit Stream uses security safeguards to protect customer information. These safeguards are appropriate to the sensitivity of the information.
Circuit Stream will make all reasonable efforts to protect customer information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
9. Customer Access
Customers have the right to access their information under the control of Circuit Stream. The Privacy Officer will assist them with their access requests. We will deal with access requests within 5 days of the request being made.
Access requests should be made, by email, to the Privacy Officer at email@example.com with the subject line [Privacy]. In certain exceptional situations, further to privacy legislation, we may not be able to provide access to certain customer information that we hold about customers. Examples of where we may not provide access include, but are not limited to, the following:
- where provision may reveal information about another customer;
- where the information is subject to solicitor-customer privilege;
- where the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law; or
- where provision could reasonably be expected to threaten the health or safety of an individual.
If access cannot be provided, Circuit Stream will notify the customer making the request, by email, of the reasons for the refusal.
10. Openness Concerning Policies and Practices
Circuit Stream will make available specific information about its policies and practices regarding the management of customer information. To contact us to obtain further information regarding our policies and practices, please refer to section 13 below.
11. Response Procedure to Data Requests from Governments or Third Parties
See section 6 for policy on information disclosure.
In the event that it is required by law to disclose information, Circuit Stream will notify the customer, by phone call and email, within 24 hours of the request being received.
13. Concerns or Questions Regarding Compliance
A customer may address a concern or question about compliance with this policy to Circuit Stream’s Privacy Officer, at firstname.lastname@example.org with the subject line [Privacy]. A customer may also file a complaint with the appropriate regulatory body.
Circuit Stream will investigate any complaints received by email. If a complaint is found to be justified, Circuit Stream will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer will be informed, by email, of the outcomes of the investigation regarding their complaint.