1. GENERAL

1.1 Our Commitment to Protecting Your Privacy

We, at K-Town Lock and Key, value your privacy and we strive to ensure that our clients are aware that their privacy is of the utmost importance to us. We collect, use and disclose personal information about our clients only as is required to enable us to establish and manage the relationship necessary to provide services to you. While K-Town Lock and Key places a high priority on the protection of personal information shared with us by our clients, legislation is in place that governs how personal information must be managed and protected. We are committed to complying with the legislation. We want you to understand why and how we collect, use, disclose, retain and secure your information.

 

1.2 Definitions

  1. collection” – the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including sources other than the Individual to whom the Personal Information belongs, by any means.
  2. Consent” – voluntary agreement to the collection, use or disclosure of Personal Information for defined purposes.
  3. disclosure” – making Personal Information available outside K-Town Lock and Key.
  4. Employee” – means an employee or ex-employee of K-Town Lock and Key.
  5. K-Town Lock and Key” means the group of K-Town Lock and Key companies and their affiliates.
  6. identified purposes” – means the purposes identified in this Policy.
  7. Individual” – any person, who directly or indirectly provides his or her Personal Information to K-Town Lock and Key as described in the Policy.
  8. Personal Information” – means information about an identifiable Individual, and therefore does not include information that cannot be associated with a specific individual.
  9. Privacy Legislation” – means, the British Columbia Personal Information Protection Act and associated regulations as amended from time to time; and the Canada Personal Information Protection and Electronic Documents Act and associated regulations as amended from time to time, as applicable.
  10. Privacy Officer” – means the privacy officer of K-Town Lock and Key.
  11. use” – the treatment, handling, management and retention of Personal Information.

 

1.3 Scope and Accountability

K-Town Lock and Key provides marketing services to its clients. This Policy applies to each of the entities which are collectively defined as “K-Town Lock and Key” in section 1.2 above.

K-Town Lock and Key is responsible for Personal Information in its custody and under its control, and has designated a Privacy Officer who is generally accountable within the organization and is responsible for our compliance with this Policy, and for ensuring that the Policy complies with the Privacy Legislation.

 

  1. PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

 

2.1 Purposes Identified at Time of Collection

We identify the purposes, through either direct explanation (ie. this Privacy Policy, verbally in onboarding meetings, etc.) or through the use of other notification means, for which we collect Personal Information at or before the time of collection from an Individual, and collect only that information necessary for such identified purposes.

 

2.2 New Purposes

When we wish to use or disclose the Personal Information for a new purpose, we will identify the new purpose prior to such use or disclosure and obtain consent at that time, unless such use or disclosure without consent is permitted or required by law. In certain circumstances, Consent for the use or disclosure for a particular purpose may be sought after the information has been collected, but before it is used or disclosed (for example, when we want to use the Personal Information for a new purpose).

 

2.3 Purposes Limited

We ensure that the purposes for collection, use and disclosure are limited to purposes that a reasonable person would consider appropriate in the circumstances.  Some of the purposes for which we collect, use and disclose or communicate Personal Information are:

  • to create and maintain an effective business relationship;
  • for quality assurance purposes such as the recording of telephone calls;
  • to facilitate account, billing, credit, collections and customer services, including but not limited to the collection of contact information;
  • to provide ongoing marketing and various other services to our clients;
  • to further develop, enhance and market products and services offered by K-Town Lock and Key, which may include contacting our clients to advise them of new services or other programs;
  • to understand customer needs and preferences, which may include contacting our clients to ask them to participate in a survey regarding our programs and services;
  • to meet legal and regulatory requirements; and
  • to manage K-Town Lock and Key’s business and operations.

 

 

2.4 Collection of Computer Information from Website

When you use marketer.ca (our “Website”), we automatically collect certain computer information generated from your interaction with our Website. Such information is not typically considered Personal Information. We collect the following information:

 

1. Cookies

Our Website uses “cookies” and other technologies to enhance your online experience, including personalizing the content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access features on our Website correctly or at all. We never place Personal Information in Cookies.

 

2. Automatic Information

In the interest of providing our visitors and clients with a secure online experience, our servers automatically record information when you visit our website, including the URL, IP address, browser type and language, and the date and time of your request. We use all of this information to analyze trends among our users to help improve our Website.

 

3. Google Analytics

Our Website uses “Google Analytics” to collect information about the use of our Website. Google Analytics collects information such as how often users visit our Website, what pages they visit when they do so, and what other sites they used prior to coming to our site. We use the information we get from Google Analytics to improve our site. Google Analytics collects only the IP address assigned to you on the date you visit our site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal Information. Although Google Analytics uses cookies to identify you as a unique user the next time you visit our Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our site is restricted by the Google Analytics Terms of Use. http://www.google.com/analytics/terms/us.html. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. https://tools.google.com/dlpage/gaoptout.

 

  1. CONSENT FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

 

3.1 Types of Consent

We may seek Consent in various ways, depending on the circumstances and the type of information collected, including, for example, using an application form and/or a check-off box, or collecting oral consent – in particular, when information is collected over the telephone.

 

3.2 Withdrawal of Consent

An Individual may withdraw Consent at any time, on reasonable notice, subject to legal or contractual restrictions.  We will inform the Individual of the implications of such withdrawal, which in some cases may be an inability for K-Town Lock and Key to continue to provide services to the Individual.

 

3.3 Exceptions to Requirement for Consent

The Privacy Legislation sets out specific circumstances under which K-Town Lock and Key may collect, use or disclose personal information without the knowledge or Consent of the individual.

 

  1. LIMITING COLLECTION, USE, DISCLOSURE AND RETENTION OF PERSONAL INFORMATION

 

4.1 Collection

K-Town Lock and Key limits both the amount and type of Personal Information collected to that which is necessary to fulfil the identified purposes.

With your consent, we may collect Personal Information from you in person, at one of our offices, over the telephone or by corresponding with you via mail, email or the Internet. By providing your Personal Information to or otherwise corresponding with K-Town Lock and Key via email you acknowledge that you are aware that email is not a secure form of communication. Furthermore, with your consent, we may collect Personal Information from other sources.

The type of Personal Information we collect and maintain in your customer file, may include, but is not limited to your: name, business address, email address, telephone number, transaction history, and other payment and billing information

 

4.2 Use and Disclosure

K-Town Lock and Key limits the use and disclosure of Personal Information for purposes other than those identified purposes, unless the Consent of the Individual has been obtained or if the use and disclosure is permitted or required by law.

Unless we have your explicit consent to do so, we will not sell, rent or lease your personal information to third parties.

There are some instances where K-Town Lock and Key may disclose your Personal Information to fulfill regulatory and legislative obligations and to conduct our business in the ordinary course. In those instances where we do provide information to third parties, we provide only that Personal Information that is required in the circumstances and we include various provisions in our contracts that have been designed to protect privacy and security of your Personal Information. Third parties may include, but are not limited to:

  1. a collection agency for the purpose of collection of accounts payable; and
  2. a service provider that has been engaged by K-Town Lock and Key to perform certain services for us, which may include partners, consultants and suppliers to K-Town Lock and Key.

We may further disclose your Personal Information without your consent, in the following circumstances:

  1. as permitted or required by applicable law or regulatory requirements;
  2. to comply with valid legal processes such as search warrants, subpoenas or court orders;
  3. during emergency situations or where necessary to protect the safety of a person or group of persons; or
  4. any other circumstances permitted or required under PIPA.

 

4.3 Retention Limited

K-Town Lock and Key has developed guidelines for the retention of Personal Information, which include minimum and maximum retention periods in compliance with the Privacy Legislation. The underlying principle of these retention guidelines is to keep Personal Information only as long as remains necessary or relevant for the identified purposes; and as required by law.

 

  1. ACCURACY, CORRECTION, AND ACCESS

 

5.1 Accuracy

We endeavor to keep Personal Information in our custody and control accurate, complete, and up-to-date as this will allow us to provide the best service to our clients.  Our clients can assist us by ensuring that the information they provide to K-Town Lock and Key is current and accurate.

 

5.2 Correction Requests

Individuals may make a request to correct or rectify Personal Information held by K-Town Lock and Key.  The request must be made in writing and provide sufficient detail to allow K-Town Lock and Key to identify the Personal Information, and the correction being sought.  If the Individual successfully demonstrates that the Personal Information is inaccurate or incomplete, we will correct the Personal Information, as required, and send the corrected Personal Information to any third party to which we disclosed the Personal Information in the prior year.  If no correction is required to be made, we will note the request for correction and annotate the file accordingly.

For clarity, the requirement for a correction request to be made in writing does not pertain to requests to change contact information such as address, telephone number or email address. These changes may still be made over the telephone by contacting one of our customer service representatives.

 

5.3 Access Requests

An Individual may make a request for access to his or her Personal Information in the custody or control of K-Town Lock and Key.  The request must be made in writing and provide sufficient detail to allow K-Town Lock and Key to identify the Personal Information.  K-Town Lock and Key will:

  1. inform the Individual of the existence, use and disclosure of his or her Personal Information, as requested;
  2. provide the Individual with access to the requested Personal Information, subject to statutory exemptions; and
  3. respond to the Individual within the time limits prescribed by the Privacy Legislation.

 

5.4 Fees for Access

Where we are entitled to charge a fee in order to implement the access request, we will advise the Individual of the amount of the fee and the statutory entitlement to challenge the amount of the fee or request a fee waiver.

 

  1. SECURITY

 

6.1 Security Safeguards

To protect Personal Information, regardless of the format in which it is held, against loss or theft, unauthorized access, collection, disclosure, copying, use, or modification, we have implemented security safeguards which are appropriate to the sensitivity of the information that has been collected, the amount, distribution, format of the information, and the method of storage.  The methods of protection used include, but are not limited to:

  • physical measures, for example, locked filing cabinets and restricted access to offices and data centres;
  • organizational measures, for example, limiting access on a “need-to-know” basis; and
  • technological measures, for example, the use of passwords and encryption.

 

  1. UPDATES

 

7.1  Updates to Privacy Policy

Any updates to this Privacy Policy shall be acknowledged and updated in a timely manner. We may add, modify, or remove portions of this Privacy Policy when we feel it is appropriate to do so.

 

  1. COMPLIANCE AND CONTACTS

 

8.1 Complaint to Privacy Officer

An Individual can submit a complaint in writing to the Privacy Officer concerning our compliance with the above principles. We will receive and respond to inquiries or concerns/complaints about our policies and practices relating to the handling of Personal Information.

 

8.2 Privacy Officer Contact Information

All inquiries should be in writing and addressed to the Privacy Officer as follows:

Privacy Officer
Suite 100, 1975 Springfield Road

Kelowna, British Columbia
V1Y 7V7

 

Retention of personal information

35  (1) Despite subsection (2), if an organization uses an individual’s personal information to make a decision that directly affects the individual, the organization must retain that information for at least one year after using it so that the individual has a reasonable opportunity to obtain access to it.

(2) An organization must destroy its documents containing personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that

(a) the purpose for which that personal information was collected is no longer being served by retention of the personal information, and

(b) retention is no longer necessary for legal or business purposes.

When you update policy, add a sentence similar to “This Privacy Policy was last updated in April of 2017.”

CONTACT

P.O. Box 27013, Kelowna, British Columbia, V1X 7L7