At El Chango Media Inc. ("Vancouver Trails"), we are committed to providing our customers, with exceptional service. Using our any of our software applications (each an "App") involves the collection, use and disclosure of some personal information about our customers protecting their personal information is one of our highest priorities.
"Personal Information" means information about an identifiable individual but does not include Contact Information.
"Contact Information" means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this Policy or PIPA.
"Privacy Officer" means the individual designated responsibility for ensuring that Vancouver Trails complies with this policy and PIPA, namely: Vancouver Trails Attention: Privacy Officer 5678 Dorset Street Burnaby, BC V5J 1L7
Collecting Personal Information
Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection. We will only collect customers' information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify preferences of customers;
- To open and manage an account, if applicable;
- To deliver requested products and services or information of our products or services;
- To send out App information;
- To contact our customers for promotional activities;
- To ensure a high standard of service to our customers;
- To meet regulatory requirements;
- To collect and process payments, if applicable;
We will obtain our customer's consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent). Consent can be provided in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose. Consent may also be implied where a customer is given notice and a opportunity to opt-out of his or her personal information being used for marketing of services or products, and the customer does not explicitly opt-out.
Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers can withhold or withdraw their consent for Vancouver Trails to use their personal information in certain ways. Such decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. We may collect, use or disclose personal information without the customer's knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual's life, health, or personal security;
- When the collection, use, or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
- When the personal information is available from a public source;
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law;
Using and Disclosing Personal Information
We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To conduct customer surveys in order to enhance the provision of our services;
- To contact our customers directly about products and services that may be of interest.
We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so. We will may sell customer lists or personal information to other parties if we have consent to do so.
Retaining Personal Information
If we use customer personal information to make a decision that directly affects the customer we will will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it. Subject to this Policy, we will retain customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization. Customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customers' correction request in the file.
Securing Personal Information
We are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. The following security measures will be followed to ensure that customer personal information is appropriately protected: Physically securing offices where personal information is held, the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access), and contractually requiring any service providers to provide comparable security measures.
We will use appropriate security measures when destroying customer's personal information such as shredding any physical documents or permanently deleting electronic information.
We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Providing Access to Personal Information
Customers, have a right to access their personal information, subject to limited exceptions. A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer. Upon request, we will also tell customers how we use their personal information and to whom it has been disclosed if applicable. We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer of the cost and request further direction from the customer on whether or not we should proceed with the request. If a request is refused in full or in part, we will notify the customer in writing, providing the reasons for refusal and the recourse available to the customer.
We reserve the right to modify, change or replace this Policy at any time for any reason without notice to the customer, so please take the time to review it frequently. Changes and clarifications will take effect immediately upon their posting on our website or any App. If Vancouver Trails makes material changes to this Policy, we will notify the customer here that it has been updated, so that thecustomer are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose such information.
By using our website or App, each customer represents to Vancouver Trails that they are at least the age of majority in the customer's jurisdiction of residence (and, in any case, the Customer must be at least 18 years old), and the customer have given us the customer's consent to allow any of the customer's dependents to use the App.
If a customer clicks or selects any links (such as advertisements) through the App, they may be directed away from the App. Vancouver Trails is not responsible for the privacy practices of other sites and encourage such customer to read their respective privacy policies.
Questions and Complaints: The Role of the Privacy Officer or designated individual
Customers, should direct any complaints, concerns or questions related to this policy in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of British Columbia.