Introduction We have adopted this Canadian
Customer Privacy Policy to guide how we utilize Personal Information about
Customers. "Personal Information" means information about an identifiable
individual, and includes names, telephone numbers, addresses, e-mail
address, credit card numbers, and related credit and transactional
information and certain other personal information. Customers may provide
to us by any means, including through our websites, by e-mail, telephone,
fax or mail. This Policy will evolve and change as we continue to study
privacy issues.
How We Use
Your Personal Information Our purpose in establishing
this Policy is to advise you of the policies and information practices we
follow in collecting, storing, using and disclosing Personal Information.
This Policy is designed in a manner that recognizes both the right of
privacy of individuals with respect to their Personal Information and our
need to collect, use or disclose such Personal Information for purposes
that a reasonable person would consider appropriate under the
circumstances.
Contacting Us
The Information We Collect How We
Use Your Personal Information We collect, use and disclose
Personal Information only to the extent necessary to fulfill the purposes
for which it was collected and as required or permitted by law. Your
Personal Information is retained only as long as is necessary to fulfill
those purposes, subject to reasonable legal limitations periods, statutory
or regulatory retention requirements and legitimate business requirements.
TCP GLOBAL
SOLUTIONS
CANADIAN CUSTOMER PRIVACY POLICY
AND INFORMATION PRACTICES STATEMENT
Revised August 2007
We at TCP Global Solutions, (sometimes hereinafter, "we" or "us"),
recognize the importance of protecting the privacy of Personal Information
collected online or offline by us about our members, visitors and
prospective clients. This policy explains when and how we treat Personal
Information provided to us.
Contents:
When Personal Information is sent by an individual to us as described in
this policy, it will be treated in accordance with this policy as
described below.
This is our Privacy Policy for Canada online and offline.
Consent/Opt-Out
Except as otherwise permitted or required by law, we will not collect,
use, or disclose your Personal Information without your consent.
Generally, by providing us with your Personal Information, you are
communicating your consent to our collection, use and disclosure of such
information for the purposes for which you provided the information to us,
and as described in this Policy. However, you will, at the point of
collection of the Personal Information, and from time to time thereafter,
be given the option of "opting out" of or "opting in" to our collection,
use and disclosure of your Personal Information for certain other purposes
by signing a form, checking a box on a form, clicking on an icon (or via a
similar electronic method) on our websites, or by contacting us as
described below. If you do not want us to collect your Personal
Information or use it for purposes other than as necessary to fulfill your
request, please use the "opt out" option so that your information is not
collected or used. If you have submitted Personal Information to us and
wish to later opt out or withdraw your consent to its retention, use or
disclosure, please contact us using the methods described below. You may
opt out or withdraw your consent, subject to legal or contractual
restrictions, at any time and on reasonable notice.
Customers can elect to opt out from any or all of the following
communications: 1) Mail - e-mail and direct mail;(2) Phone -telephone and
fax solicitation; or (3) Contact - all communications including e-mail,
direct mail, fax and telephone. In addition, Customers can opt out of
further e-mail communications by following the directions included in our
e-mail communications or by visiting the website and following the opt-out
instructions.
You should keep in mind that, if you refuse to consent to, opt out of, or
withdraw your consent to our collection, use and/or disclosure of your
Personal Information that is necessary to fulfilling your request, we may
not be able to offer you certain goods, services and benefits.
A Customer may also contact us through the methods stated below for a
number of other purposes, including: (1) to opt-out of communications as
described in "Consent/Opt-Out" above; (2) to receive information or
special offers; (3) to provide feedback and comments on this Policy; (4)
to request access to or correction of the Customer's Personal Information;
and (5) to make inquiries or complaints regarding our Privacy Policy
and/or privacy practices:
By e-mail: info@tcpglobalsolutions.com
By phone to the Customer Service department: 866-843-8244
By mail: Privacy Officer, TCP Global Solutions, RR 1 Box 2,
Ontario Canada K0G 1E0.
Individual send to us certain Personal Information collected in connection
with your website membership, including the name, address, telephone
number, e-mail address (if provided) and transaction detail (what goods
and services were charged and the method of payment) collected. In
addition, we may collect, use or disclose Personal Information that you
voluntarily provide to us for the purposes described under "How We Use
Your Personal Information", including Personal Information submitted by
visitors to the website.
With your consent, we may use your Personal Information for various
purposes as described below. Except as otherwise permitted or required by
law, or as may otherwise be noted in this Policy, Customers will be given
the opportunity to opt out of or opt in to use of their Personal
Information for secondary purposes when Personal Information is collected,
and at any time thereafter by contacting us as described in the
Consent/Opt-Out section. We may use third party service providers to
perform services on our behalf, and we provide Personal Information to
such providers solely for the specific services that they are performing.
These service providers are prohibited from using or disclosing Personal
Information for any other purpose.
Contests. Occasionally, we run contests. We use Personal
Information provided only if the Customer consents to use of such
information for these contests. Customers will be given the opportunity to
opt out of use of their Personal Information for these contests when
providing this information for membership registration, and may opt out at
any time by contacting us as described above in the Consent/Opt-Out
section. Customers may also sign up for these contests at trade shows, in
which case the Customers who participate or enter will be asked to provide
Personal Information, such as the Customer's name, address, telephone
number or e-mail address. If a Customer participates in a contest,
his/her Personal Information may be used to reach him/her about the
contest, and for other promotional, marketing and business purposes. All
contests entry forms will provide a way for participants to opt-out of any
communications from the contest's manager or administrator that are not
related to awarding prizes for the contest.
E-mails. We will ask each Customer to submit their e-mail address
for the primary purposes of sending membership confirmations when your
request is made online or when you otherwise request e-mail confirmation.
In addition, Customers can register on the website to receive such e-mail
offers. With your consent, we may also collect Customer e-mail addresses
for purposes of conducting consumer research and surveys, as more fully
described below. At any time a Customer may opt-out of receiving e-mail
communications by following the directions posted in the e-mail
communications, by visiting the website and following the opt-out
instructions, or by following the contact instructions described above in
the Consent/Opt Out section.
Direct Mail/Outbound Telemarketing. Customers who supply Personal
Information may receive periodic mailings or phone calls from us with
information on new products and services or upcoming special
offers/events. Customers may also receive mailings/calls from third
parties we select whom we believe offer potentially valuable goods or
services. We will only disclose your Personal Information to these third
parties with your consent. Customers will be offered the option to decline
or opt out from these communications at the time the information is
collected. Customers may also contact us to opt-out of such communications
as described above in the Consent/Opt-Out section.
Research/Survey Solicitations. From time to time we may perform
research (online and offline) by conducting surveys of our Customers.
Participation in these surveys is voluntary, and the information collected
will be used for research and reporting purposes and to help us to better
serve Customers by learning more about their needs. The survey responses
may also be used by us to determine the effectiveness of our websites,
various types of communications, advertising campaigns, and/or promotional
activities. TCP Global Solutions may also share and disclose aggregate
data to other parties for anonymous research, statistical, and analysis
purposes. Participants who do not wish to receive e-mail or other
communications, including communications relating to surveys, will be
provided the opportunity to opt-out of the receipt of such communication
at the time of collection of their Personal Information or by notifying us
as described above in the Consent/Opt-Out section.
Other Uses of Personal Information. In addition to the uses
described above, we will use or disclose your Personal Information for
certain general business purposes including the following: (1) Using
Personal Information to enforce a contract with us or any Terms of Use of
our websites; (2) Providing information on corporate credit card usage to
the corporate card holder Customer directly or through third party service
providers; (3) Transferring and/or disclosing Customers' Personal
Information to parties connected with the contemplated or actual
financing, insuring, sale, or assignment or other transfer of the
beneficial interest in all or substantially all of the assets or shares in
the capital of TCP Global Solutions, including for the purposes of
determining whether to proceed or continue with such transaction or
business relationship or fulfilling any records or other reporting
requirements to such parties.
Limiting Collection, Use, Disclosure and Retention
Security
We endeavor to protect your Personal Information using physical,
electronic or procedural security measures appropriate to the sensitivity
of the information in our control. These measures include safeguards to
protect Personal Information against loss or theft, as well as
unauthorized access, disclosure, copying, use and modification. Credit
card numbers used for payment are automatically encrypted so that they
cannot be easily accessed.
We safeguard our Customers' Personal Information on the Internet by using
industry-standard practices. Although "guaranteed security" does not exist
either on or off the Internet, we make commercially reasonable efforts to
make the collection and security of such information consistent with our
Privacy Policy and all applicable laws and regulations. We maintain
physical, electronic and procedural safeguards as appropriate to safeguard
your Personal Information. Access to your Personal Information is
restricted to those employees and agents who need such access to do their
jobs and to fulfill the purposes for which the Personal Information was
collected.
Currently, our websites utilize a variety of different security measures
designed to protect Personal Information from unauthorized access by users
both inside and outside TCP Global Solutions, including the use of
encryption mechanisms (e.g., Secure Socket Layers or SSLs) and
authentication mechanisms (e.g., digital certificates) This helps maintain
the confidentiality, privacy, and integrity of transactions, and also
helps to protect confidential information - such as credit card numbers,
online forms, and financial data - from loss, misuse, interception and
hacking.
We take all commercially reasonable efforts to create and maintain
"firewalls" and other appropriate safeguards to ensure that, to the extent
TCP Global Solutions controls the Personal Information, the Personal
Information is used, accessed and disclosed only as authorized by TCP
Global Solutions consistent with this Policy, and to prevent unauthorized
modification or destruction. Our information protection practices and
processes help us to maintain accurate, timely, complete and relevant
information for our business purposes. Although we use commercially
reasonable efforts to maintain data security when data is transmitted
through third party communication service providers, we do not warrant the
security of data during such transmission.
The Internet
On our websites we do not collect Personal Information from Customers
unless they provide it to us voluntarily and knowingly. When you register
as a member with us on the Internet, we will capture information such as
name, address, telephone number, e-mail address, and credit card number
and related transactional information to process your membership. The
primary purpose of capturing the e-mail address is to send a membership
confirmation. However, the Personal Information may also be used to send
Customers e-mail offers from us and select third party partners, when the
Customer has consented to such communications as described in the "Email"
section above. Information provided on the Internet is treated the same as
that collected offline, and we will only use it for other purposes, such
as contests, promotions or surveys, where the Customer has consented as
described above.
Third Party Websites. Third party websites (i.e. websites not
affiliated with or controlled by TCP Global Solutions) that you may access
through links, banners and/or other means of electronic connection on our
websites may have their own separate terms of use, privacy and data
collection practices, and security measures. We have no control over these
third party websites and no responsibility or liability for the practices,
policies, terms and security measures implemented by third parties on
their websites. Your interaction with these sites will not be governed by
this Policy or the terms of use of our websites. In addition, these third
party websites may have content, advertising, banners, links, sponsors,
partners and connections over which we have no control and no
responsibility. We do not endorse or approve the content, terms of use,
privacy policy, advertising or sponsors of any linked website.
Aggregated Non-Personal Information. Like many other Internet
sites, we may automatically collect certain non-Personal Information
regarding our Customers, such as software client information (for example,
IP addresses to the extent not identified with an individual, browser
versions and operating systems) and aggregate information (for example,
number of pages accessed) in order to analyze Web traffic and usage
trends, and to enable us to tailor content and services to provide a
better fit to our Customers' needs. Information of this nature does not
pertain to your specific identity and is not associated with your Personal
Information. We may use IP addresses to identify you when we feel it is
necessary to enforce compliance with our website Terms of Use, to comply
with applicable law, or to protect our service, website, users and others.
Cookies. We may place a "cookie" on your web browser. A cookie is a
very small text file that is sent to a Customer's browser from a web
server and stored on the Customer's computer hard drive. It assigns the
computer a unique identifier. The cookie stores information on your hard
drive so we can communicate with you more efficiently, respond to you
based on prior sessions at which you provided information about you or
your preferences to us and understand what you prefer to view on our
websites. Cookies do not tell us your individual identity or passwords
unless you have chosen to provide these to us, for example where you are
using the website to request a membership. Your browser may be set to
allow you to be notified when a cookie is to be placed on your browser,
decline the cookie or delete cookies that have been placed on your
browser. Some functions of our websites, such as membership access, may
not work or may work slowly if a cookie is refused or deleted.
Our websites may use third party service providers to serve and host our
advertisements. These third parties may place cookies on your computer if
you click on the advertising. The third party cookies may be used to
(among other things) track whether the site was accessed from the
advertisement. We do not control these third party cookies, so they may
not follow this Policy or the rules we have set for our own cookies. If
you do not want to activate these third party cookies, do not click on the
advertising.
Compliance with Laws
We may be permitted or required by law to collect, use or disclose
Personal Information about you without your consent for certain purposes
or under certain circumstances, including, but not limited to, disclosure
to a law enforcement agency, response to a court order, under the
discovery process in litigation and prosecution, or collecting a debt
which you owe to us.
Correction/Access
We make efforts to ensure the accuracy of Personal Information we use to
fulfill your requests and for purposes for which you have consented, and
to correct and update our database as necessary for the stated purpose. In
the event a Customer notifies us that such Personal Information held by
TCP Global Solutions or a Franchisor is inaccurate or outdated, TCP Global
Solutions, where appropriate and upon notification and sufficient time for
verification, will take all reasonable steps to correct any inaccuracy or
update outdated information of which we are made aware. In addition, we
will update Personal Information we store and provide it to the third
parties described in this Policy when you indicate the information has
changed, such as changes of address or e-mail address, (a) in response to
your request and/or (b) in order to fulfill the purpose for which such
Personal Information was collected, and/or as otherwise required by law.
You may request access to your Personal Information in our possession by
writing to us at the address provided above. We establish and maintain a
file of Personal Information for each Customer. Your file will be kept
at TCP Global Solutions, RR #1 Box 2, Elgin Ontario Canada K0G 1E0 and
only authorized employees and agents of TCP Global Solutions who require
access to your Personal Information to fulfill their job requirements will
have access to your file. If you wish to access your file or make
corrections to it, please contact us as described above. In some limited
circumstances, we may not be able to grant you access to your Personal
Information, for example if doing so would threaten the security of
another individual.
Downloading
Please feel free to download or make a copy of this Policy. You may obtain
a copy free of charge by writing to us at Privacy Officer, TCP Global
Solutions, RR # 1 Box 2, Elgin Ontario Canada, K0G 1E0, and with a request
for the Canadian Customer Privacy Policy.
Policy Changes
We may change or terminate this Policy at any time without prior notice.
We will post any Policy changes to our websites to notify you of these
changes and provide you with the ability to opt out of any new,
unanticipated uses of Personal Information not previously disclosed in the
Policy. Any such changes shall be effective immediately upon posting. Your
continued use of our websites and/or provision of your Personal
Information after such posting constitutes your acceptance of these
changes. Please check our Policy periodically, or contact us as described
above, if you are concerned about how your Personal Information will be
used.