PLEASE READ THE FOLLOWING CAREFULLY.
1. Commitment to Privacy
- Information technology has brought many ways to do business. It allows businesses and consumer users to interact through electronic means that enables companies to conduct their business efficiently and provide the highest standard of customer service. At the same time, this has brought legitimate concerns about security and privacy of personal information passed from the customer to the business.
2. Privacy Protection in Canada
- The Personal Information Protection and Electronic Documents Act (PIPEDA), of the federal government, significantly impacts the way private businesses, corporations, federal agencies, not-for-profit organizations and associations handle the personal information they have collected in the course of their business. At the same time, it will clearly establish a code of privacy practices that will provide Canadians from coast to coast with a mechanism to ensure their personal information is handled respectfully.
- PIPEDA acknowledges the need to protect an individual’s right to privacy and also addresses the necessity of collecting private information for businesses in the conduct of their business affair. PIPEDA provides guidelines and principles for businesses for the accountability, purpose, obtaining of consent, disclosure, accuracy, safeguarding, openness of policy and access to personal information that was entrusted to its care.
The PIPEDA principles:
- identifying the purposes for personal information collection;
- obtaining consent;
- limiting the collection of personal information;
- limiting use, disclosure, and retention of personal information;
- accuracy of personal information;
- safeguarding personal information;
- openness about policies and procedures;
- providing access to personal information; and
- challenging compliance.
Under the Act, we at Klusster are obliged to demonstrate to our users and to any individual our commitment in protecting one’s personal and private information. We have developed our policy to meet the compliance of CSA Model for the Protection of Personal Privacy and PIPEDA.
4. The Personal Information We Collect & How it is Shared
- Business Owners – Klusster collects the name and contact details of each Business Owner who creates a profile in Klusster, along with the contact information of the business they are setting up a profile for. The personal contact details are shared with Klusster Owners but not Consumer Users.
- Klusster Owners – Klusster collects the name and contact details of each Klusster Owner who creates a profile in Klusster and creates a klusster. The personal contact details are shared with Business Owners and Consumer Users. Klusster also collects credit or debit card information from Klusster Owners who pay for the service. This information is stored and only processed once per month, for the sole purpose of payment towards an outstanding unpaid invoice.
- Consumer Users – Klusster collects first name, last name and the email addres of any Consumer User who wwishes to subscribe to the mailing list for a klusster. This information is stored in www.klusster.com but is not shared with Business Owners or Klusster Owners. Consumer Users can unsubscribe from any email distribution list by using the Unsubscribe link on an email they receive.
5. Why We Collect Your Personal information?
Klusster collects personal information only for the following purposes:
- to establish and maintain responsible commercial relations with you and provide you with ongoing service;
- to obtain information for billing and collection;
- to manage and develop Klusster’s business and operations to provide its customer the highest level of satisfaction, including the integrity of business and Klusster profiles; and
- to meet legal and regulatory requirements.
- Customer Representatives collecting personal information, as a result of a user support request, can be asked to explain the purposes for which the information is being collected. The purposes shall be stated in such a manner that the customer shall understand.
6. We Need Your Consent
Consent is required for the collection of personal information and the subsequent use or disclosure of this information.
7. We Will Not Use Your Personal Information Without Your Consent
- By using the service of Klusster, it constitutes your implied and express consent for us to collect, use and disclose personal information for all identified purposes.
- Users may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Users can contact Klusster at firstname.lastname@example.org to express their intention to withdraw their consent. Users may also contact email@example.com for more information regarding the implications of withdrawing consent.
8. We Will Only Use Your Personal Information for the Purpose We Mentioned
- We can only use your personal information for the purpose we have stated and within the limits of the PIPEDA.
- In the event that we want to use your personal information for a purpose not previously identified, consent with respect to use or disclosure may be sought after the information has been collected, but before it is used.
- Is Your Information Accurate? We do our best to keep your personal information as accurate as possible during the collection process. We may from time to time, update your personal information within the limits of the purpose we have mentioned.
- If the purpose of the collection of personal information has been fulfilled, we can no longer gather updates of your personal information.
9. How Long Do We Keep Your Personal Information?
- We maintain your personal information until the purpose we have mentioned has been fulfilled. We also take into consideration the amount of time required by law to maintain such records.
- After such time, your personal information will be properly disposed according to our guideline in the destruction of personal information.
10. Our Commitment to Data Security
- We are committed to protect your personal information with security safeguards appropriately in place.
The methods of protection include:
- physical measures, for example, locked filing cabinets and restricted access to offices;
- organizational measures, for example, security clearances and limiting access on a “need to know” basis;
- technological measures, for example, the use of passwords and data encryption; and
- investigative measures where required to safeguard the interests of Klusster or its users.
- We make the effort to train our employees and make them aware of the importance of maintaining the confidentiality of personal information. Only Klusster’s employees with a business need to know, or whose duties reasonably so require, are granted access to your personal information.
- We store personal information data only to the extent of its purpose and to meet the period as required by law. After this period, your personal information will be properly disposed according to our guidelines in the destruction of personal information.
11. How Do We Dispose of Your Private Information?
We shall destroy, erase, or make anonymous personal information that is no longer required to fulfill the identified purposes and meeting the required period by law.
12. We Will Adhere to the Following Guidelines In Disposing Your Personal Information
- We will shred paper documents containing personal information and properly dispose them through a federally approved disposal company.
- We will delete personal information from our files.
- In the event that the personal information can not be deleted, we would then make the information anonymous to make sure that the identity of the person having that personal information is not compromised.
13. Your Right to Your Personal Information We Collect
- We recognize your right to your personal information we have collected. Our Customer Representatives will make the effort to inform you of what information we have on you. You in return have the right to ask for such information.
14. Canada’s Anti-Spam/Spyware Law (CASL)
CASL came into effect on July 1, 2014. We are making every effort to comply with the subject legislation. If you determine we are not doing so, kindly contact Our Customer Representatives mentioned in paragrpah 16 below.
15. User’s Acceptable Use Policy & Terms & Conditions
16. Contacting Us
- We will make the effort to respond to all inquiries within the required period provided by the PIPEDA. We have put in place a Privacy Officer to look after the implementation and compliance of the Act.