Privacy policy

PRIVACY POLICY

STATEMENT OF PURPOSE

This Privacy Policy is meant to inform customers of ThinkTel Communications Ltd. (“ThinkTel”) of our policy with regards to how we collect, use or disclose our customer's personal information. This Privacy Policy does not apply to information regarding ThinkTel’s corporate customers. That information is protected by contractual arrangements between ThinkTel and its corporate customers.


OUR COMMITMENT TO YOUR PRIVACY

ThinkTel is committed to protecting your privacy. We do not sell or exchange your personal information, and we are active in ensuring that your sensitive information is protected against any form of misuse.


COMPLIANCE

ThinkTel is fully compliant with federal legislation that has been designed to protect you and your personal information. We have based our privacy policy on the 10 standard Privacy Principles included in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada), also referred to as P.I.P.E.D.A.


SUMMARY OF PRINCIPLES

ACCOUNTABILITY

ThinkTel has designated privacy officers to respond to any complaints or inquiries with regards to how we use your personal information. These officers are responsible for overseeing our compliance with P.I.P.E.D.A. All ThinkTel employees are trained to follow our policy and procedures.

If you have any questions concerning the use of your personal information, you may call us at 1.866.92THINK (928.4465) and speak to one of our customer service representatives.

If you have any unresolved issues, you may write to us.

By email :
privacy.officer@distributel.ca

By mail :
ThinkTel Communications, a division of Distributel Communications Ltd. c/o Privacy Officer
177 Nepean St. Suite 300
Ottawa, ON  K2P 0B4


CONSENT

When subscribing to any of our services, you are providing implied consent for us to collect personal information like your name, phone number, and billing information.

We will obtain your express consent prior to using or disclosing your personal information for a purpose that is not described within this policy, or that we did not identify to you at the time of collection.

When dealing with certain legal, medical, or security issues, ThinkTel may be required by law to disclose your personal information without seeking or obtaining your consent.


IDENTIFYING PURPOSES

For what purposes does ThinkTel collect, retain, use, and disclose my personal information?

  • To meet legal and regulatory requirements.
  • To establish and provide you with ongoing service.
  • To help us understand and determine which of our services might better suit your needs.
  • To manage and improve our business operations.

In instances where we require your personal information for a purpose that is not listed above, ThinkTel will identify the purpose at the time of collection.


LIMITING COLLECTION

ThinkTel shall limit the type and quantity of personal information collected to the amount necessary to carry out the identified purpose(s). At the time of collection, our representative will explain why the information is needed.


LIMITING USE, DISCLOSURE, AND RETENTION

We will retain your personal information only long enough to satisfy the purpose(s) to which you have already consented. Within a reasonable time after the purpose has been satisfied, your sensitive information will be destroyed or made anonymous. Unless you provide express consent for the purposes for which the company has informed you that it is collecting your personal information, all information kept by the company regarding the customer, other than the customer's name, address and listed telephone number, is confidential and may not be disclosed by the company to anyone other than:

  • the customer;
  • a person who, in the reasonable judgment of the company, is seeking the information as an agent of the customer;
  • another telecommunications company, provided the information is required for the efficient and cost-effective provision of telecommunications services and disclosure is made on a confidential basis with the information to be used only for that purpose;
  • a company involved in supplying the customer with telephone or telephone directory related services, provided the information is required for that purpose and disclosure is made on a confidential basis with the information to be used only for that purpose; or
  • an agent retained by the company to evaluate the customer’s credit worthiness or in the collection of the customer's account, provided the information is required for and is to be used only for that purpose.

The fact that you are a ThinkTel customer may be revealed to other ThinkTel customers when using certain plans.


ACCURACY

Keeping in mind the purpose of its use, we will make every reasonable effort to keep your personal information as accurate and complete as possible.


SAFEGUARDS

ThinkTel will ensure that your personal information is protected against unauthorized access and any other type of misuse, by maintaining industry standard security safeguards. Excluding when they are in use by authorized personnel, paper-based files containing personal information are secured within a restricted area. Electronic data containing personal information is restricted to authorized users only.


OPENNESS

We encourage you to read this privacy policy. If you are not able to print a hard copy from our website, we will gladly provide you with one. If you wish to discuss the policy, we are ready to answer any questions you may have.


INDIVIDUAL ACCESS

You are entitled to have access to your personal information. Upon your written request, ThinkTel will promptly inform you of the existence, use, or disclosure of your personal information. In some limited circumstances, if the information you requested is too costly to make available to you or if it conflicts with any legal or commercial proprietary obligations, ThinkTel may withhold access or charge a reasonable fee. In the event that ThinkTel does withhold access, you will be notified of the reason(s) no later than 14 days after your request was submitted. You may challenge the accuracy of the information under our care, and have it amended when appropriate.


CHALLENGING COMPLIANCE

We are committed to being as receptive and accommodating as possible in responding to any issues you may have about the handling of your personal information. Any customer complaints received by ThinkTel about our compliance with P.I.P.E.D.A., will be acknowledged, investigated, and recorded.

If you have any general questions concerning the use of your personal information, you may call us at 1.866.92THINK (928.4465) and speak to one of our customer service representatives.

If you have any unresolved issues, you may write to us.

By email :
privacy.officer@distributel.ca

By mail :
ThinkTel Communications, a division of Distributel Communications Ltd. c/o Privacy Officer
177 Nepean St. Suite 300
Ottawa, ON  K2P 0B4

If you feel that the ThinkTel privacy officer has not resolved your issue adequately, you may challenge our compliance with The Privacy Commissioner of Canada.

The Privacy Commissioner of Canada can no longer process complaints via email, only by letter.

By mail:

The Privacy Commissioner of Canada

112 Kent St., Place de Ville, Tower B, 3rd Floor

Ottawa, ON K1A 1H3

 

By phone:

1 800 282-1376



GLOSSARY OF TERMS

To aid in the use of our policy, we have included a glossary of terms.

Personal Information: P.I.P.E.D.A. defines personal information as "information about an identifiable individual". Simply stated, any information about you that is not readily available to the public is protected under the Act, for example: credit records, ethnicity, passwords, income, etc.

(P.I.P.E.D.A.) Personal Information Protection and Electronic Documents Act: This legislation was enacted as of January 1st, 2004. You can download and print the act in its entirety at www.privcom.gc.ca.

Express consent: may be taken to be given by a customer where the customer provides:

  • written consent;
  • oral confirmation provided by an independent third party;
  • electronic confirmation through the use of a toll-free number;
  • electronic confirmation via the Internet;
  • oral consent, where an audio recording of the consent is retained by ThinkTel; or
  • consent through other methods, as long as an objective documented record of customer consent is created by the customer or by an independent third party.

Implied consent is consent that can be reasonably inferred from an individual’s action or inaction. For example, to subscribe to any of our services we need some basic information from you to set up your account.


OUR RIGHT TO UPDATE THIS POLICY

ThinkTel reserves the right to add, modify, or remove any section of this document in order for it to remain representative of ThinkTel's business operations and continue to be compliant with P.I.P.E.D.A.