At Secure Home Services Inc. (“Secure Home Services”) your privacy is important to us and we want you to understand our practices with respect to gathering and handling personal information. We are committed to maintaining the confidentiality, security and accuracy of your personal information. This Privacy Code (the “Privacy Code”) describes the information that Secure Home Services collects, how we use it and to whom that information may be disclosed.
Under Canada’s federal Personal Information Protection and Electronic Documents Act (PIPEDA), Secure Home Services is responsible for the protection of your personal information and the fair handling of it at all times- throughout the organization and in dealings with third parties. Secure Home Services carries out its obligations by following the 10 principles of fair information practices outlined in PIPEDA. The 10 principles are as follows and discussed in detail below.
- Identifying purposes
- Limiting collection
- Limiting use, disclosure, and retention
- Individual access
- Challenging compliance
What is Personal Information?
Privacy concerns focus on Personal Information, that is, information that could identify a specific individual such as names, addresses,
e-mail addresses, and telephone number. For the purposes of this Privacy Code, “personal information” means information about an identifiable individual. This does not include the name, title, business address or telephone number of an employee of an organization.
Active Energy collects personal information to provide you with the product and services contracted for, and to develop its business and operations, including:
- Establishing, managing and terminating business relations with you;
- Reviewing the products and services that we provide to you;
- Informing you of our products and services other than those that you have specifically requested,
- Protecting us against error, fraud, theft and damage to our goods and property;
- Enabling us to comply with applicable law or regulatory requirements; and
- Any other reasonable purpose to which you consent.
When we collect your personal information, the purpose(s) for collecting the information will be communicated before or at the time of collection.
It is important to us that we collect, use or disclose your personal information where we have your consent to do so or as provided in this Privacy Code. Secure Home Services will seek your consent at the time that we collect the personal information (the majority of the cases, consent is obtained at the time you enter into a contract with Secure Home Service). In some circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Code or separately), we will endeavor to advise you of that purpose before such use or disclosure.
Depending on the sensitivity of the personal information, your consent may be express, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you accept our products or services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the contact information set out below. In some circumstances, a change in or withdrawal of consent may limit our ability to provide products or services to, or acquire products or services from, you.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
The personal information that Secure Home Services collects from you is primarily for the purpose of providing the product and services contracted with Secure Home Services by you. When we collect your personal information (either by phone on your agreement), the purpose(s) for collecting the information will be communicated before or at the time of collection.
- Contact and identification information, such as name, address, telephone number and e-mail address;
- Natural Gas Utility Account Information;
- Product and service related information;
- Credit and financial information such as billing and credit history or payment history;
- Customer relationship information, such as customer service requests; and
- Business relationship information.
As a general rule, Secure Home Services collects personal information directly from you. If third parties hold information Secure Home Services requires, we will endeavor to ensure the information has been collected with your consent. Personal information does not include the name, title or business address or telephone number of an employee of an organization.
Limiting Use, Disclosure and Retention
We use and disclose your personal information when, for example:
- It is for purposes described in this Privacy Code;
- To provide you with our products and services;
- We are required by law to do so;
- The information is publicly available; or
- It is required for any additional purposes that may be described at the time we advise you of the use of your personal information (which consent may be express, deemed or implied).
Your personal information may be disclosed when, for example, it is:
- To provide you with the products and services;
- To employees, contractors, consultants and other parties (including other members of Secure Home Services) who require the information to assist us to establish, maintain and manage our business relationship with you, including, for example, third parties that provide services to us or on our behalf or third parties that collaborate with Secure Home Services in the provision of services to you;
- To another party, in the event of a change in ownership of all or a part of Secure Home Services through some form of merger, purchase, sale, lease or amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Code, unless you consent otherwise; and
- Permitted or required by applicable law or regulatory requirements;
- Part of Secure Home Services’ regular reporting activities to other Secure Home Services subsidiaries in and outside of Canada;
- To protect the rights and property of Secure Home Services;
- During emergency situations or where necessary to protect the safety of a person or group of persons;
- Personal information that is already available to the public;
- With your consent.
Except as otherwise permitted or required by applicable law or regulatory requirements, Secure Home Services will endeavor to retain your personal information only for as long as is necessary to fulfill the purposes for which the personal information was collected.
Accuracy of Personal Information
It is important that the personal information Secure Home Services holds about you is accurate and current. Secure Home Services requires you to keep us informed of changes to any personal information.
Safeguarding Personal Information
Secure Home Services has policies, procedures, and technology in place to protect your personal information against loss, theft, or unauthorized access and disclosure.
Accessing Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact us using the contact information set out below. Please note that any such communications must be in writing.
When making an access request, we require specific information from you to confirm your identity and right to access, as well as to search for, and provide you with, the personal information that we hold about you. We may charge you a fee to access your personal information; but we will advise you of any fee in advance. If you need help in preparing your request, please contact us.
Secure Home Services may not be able to provide you with access to your personal information, where such refusal is permitted or required by applicable law or regulatory requirements. Secure Home Services will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
You can direct any questions or concerns about this Privacy Code to Secure Home Services. Secure Home Services will maintain procedures to receive and investigate complaints and complainants will be advised of the results of any such investigation.
Revision to this Privacy Code
Secure Home Services may from time to time make changes to this Privacy Code to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with personal information. We will post any revised version of this Privacy Code on our website. Any changes to this Privacy Code will be effective from the time they are posted, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, unless you consent to that change.
This Privacy Code does not create or confer on any individual or on Secure Home Services any rights, or impose on Secure Home Services any obligations beyond any rights conferred or obligations imposed by Canadian privacy legislation.
If you have any questions regarding your personal information, please contact the Director of Operations at Secure Home Services. To get more information about Secure Home Services’ Privacy Code, change or withdraw your consent or make a complaint under this Privacy Code, you can:
Email us at firstname.lastname@example.org
Write to us at:
Secure Home Services
390 Brant Suite, Suite 202