Privacy Policy
ISQsolutions is committed to principles of internet security and respect for your privacy. This privacy policy explains why and when personal information is collected and why this information is needed by ISQsolutions or a third party.Under The Personal Information Protection and Electronic Documents Act which governs the collection, use and disclosure of personal information in the commercial sector, ISQsolutions is required to adhere to 'Ten Privacy Principles' set out in the National Standard of Canada, Model Code for the Protection of Personal Information effective January 1, 2001. It governs the behavior of employees and agents acting on ISQsolutions behalf when dealing with personal information. The purpose in which information is collected and used. It provides procedures for an individuals access to and correction of personal information.
Ten Privacy Principles:
1. Accountability
2. Identifying Purposes
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure and Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance
1. - ACCOUNTABILITY
ISQsolutions is responsible for personal information under its control and will designate an individual or individuals who are accountable for the organizations compliance with the following principles.
1.1 Accountability for ISQsolutions compliance with the principles rests with the senior management of ISQsolutions and the person or persons designated by senior management as Privacy Officer, even though other individuals within the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within the organization may be delegated to act on behalf of senior management or the Privacy Officer.
1.2 ISQsolutions senior management has designated the following person to act as Privacy Officer to oversee the organizations compliance with the principles:
Attention:
ISQsolutions Legal Department c/o Privacy Officer
ISQ Webhosting Inc.
130 Spadina Avenue, Suite 602
Toronto, Ontario, Canada M5V 2L4
Facsimile: (416) 703-4802
2. IDENTIFYING PURPOSES
ISQsolutions will identify the purposes for which personal information
is collected at or before the time the information is collected.
2.1 ISQsolutions collects personal information only for the following
purposes (identified purposes):
(a) to provide service(s) and/or products to its customers;
(b) to maintain commercial relations and to communicate with its customers
(which will include, but not be limited to: billing, collection, advertising,
promotion, account verification);
(c) to identify customer needs and/or preferences;
(d) to meet legal and regulatory requirements;
(e) to administer and manage its business operations
2.2 ISQsolutions will provide notice of the identified purposes either
orally, electronically or writing prior to or at the time of collection
of the personal information.
2.3 In order to open a hosting account or to register a domain name at
ISQsolutions an individual is required to provide corporate or personal
information by way of an electronic online form. To register a domain
name corporate or personal information is required by the relevant registry
of the TLD (top level domain) for which the individual apply to register
a domain name through ISQsolutions. This information may include but
not be limited to company name, full name, mailing address, email address,
contact information, registrant, billing, administrative, technical contacts
and credit card details.
2.4 Use of personal information by third parties or as required by the
relevant TLD registries, the Internet Corporation for Assigned Names
and Numbers (ICANN) the international governing body for TLDs (Top Level
Domains) requires that registrars must make available the corporate or
personal information collected from the individual when the individual
apply to register a domain name to the public through the publicly accessible
database known as the Whois Database. This is a public policy adopted
by the domain name industry as a whole.
2.5 On occasion, ISQsolutions may engage third party companies or individuals
to perform services on our behalf. Our relationships with such third
party companies are governed by our contracts with them. Those companies
are required to hold your personal information strictly confidential.
2.6 ISQsolutions will use personal information to advise its customers
of any information relating to the services provided to them through
ISQsolutions. This includes but is not limited to notices for renewal
of services, of system upgrades or any information relevant to the product
and service. Occasionally, ISQsolutions will communicate to the customer
special bonus and new product offers that we think may be of value to
the customer. If the customer wishes to opt-out of receiving targeted
communications from ISQsolutions in electronic, printed or verbal format
(other than information included with their renewal notice or monthly
billing), simply inform ISQsolutions in writing at Privacy Office, ISQ
Solutions Inc., 130 Spadina Avenue, Suite 602, Toronto, Ontario, Canada
M5V 2L4 or by fax to 416-703-4802.
2.7 When personal information that has been collected is to be used for
a purpose not previously identified, the new purpose will be identified
prior to use. Unless the new purpose is required by law, ISQsolutions
will obtain the consent of the individual before information is used
for that new purpose.
3. CONSENT
The knowledge and consent of the individual are required for the collection,
use or disclosure of personal information, except where inappropriate.
3.1 In certain circumstances, personal information can be collected,
used, or disclosed without the knowledge and consent of the individual.
For example, legal, medical or security reasons may make it impossible
or impractical to seek consent. When information is being collected for
the detection and prevention of fraud or for law enforcement, seeking
the consent of the individual might defeat the purpose of collecting
the information. Seeking consent may be impossible or inappropriate when
there is an emergency threatening the individuals life, health or security,
or where the individual is a minor, seriously ill, or mentally incapacitated.
In other instances, information may be publicly available. Moreover,
ISQsolutions may provide personal information to its lawyer or agent
to collect a debt, comply with a subpoena, warrant or other court order,
government institution requesting the information upon lawful authority,
or as may be otherwise
required by law.
3.2 ISQsolutions will generally seek consent for the use or disclosure
of the information at the time of collection. In certain circumstances,
consent with respect to use or disclosure may be sought after the information
has been collected but before use (for example, when ISQsolutions wants
to use information for a purpose not previously identified).
3.3 ISQsolutions will make a reasonable effort to ensure that the individual
is advised of the purposes for which the information will be used. To
make the consent meaningful, the purposes will be stated in such a manner
that the individual can reasonably understand how the information will
be used or disclosed.
3.4 ISQsolutions will not, as a condition of the supply of a product
or service, require an individual to consent to the collection, use,
or disclosure of information beyond that required to fulfill the explicitly
specified and legitimate purposes.
3.5 The form of consent sought by ISQsolutions may vary, depending upon
the circumstances and the type of information disclosed. In determining
the form of consent to use, ISQsolutions will take into account the
sensitivity of the information and the reasonable expectations of the
individual. An authorized representative (such as a legal guardian or
a person having power of attorney) can also give consent.
ISQsolutions will seek express consent when the information is likely
to be considered sensitive.
Implied consent will generally be appropriate when the information is
less sensitive. The use of services or products by a customer or the
acceptance of employment by an employee will be considered implied consent
to collect, use and disclose personal information for all identified
purposes.
3.6 An individual may withdraw consent at any time, subject to legal
or contractual restrictions and reasonable notice. ISQsolutions will
inform the individual of the implications of such withdrawal. In order
to withdraw consent, an individual must provide notice to ISQsolutions
in writing.
3.7 With respect to personal information already collected by ISQsolutions
prior to the publication of this Privacy Policy, this Policy will constitute
reasonable notice to ISQsolutions current customers and employees of
the purposes and uses for which such personal information has been collected.
Should an individual object to these ongoing uses or disclosures, consent
may be withdrawn upon providing notice to ISQsolutions in writing.
4. LIMITING COLLECTION
The collection of personal information will be limited to that which
is necessary for the purposes identified by ISQsolutions. Information
will be collected by fair and lawful means.
4.1 ISQsolutions collects personal information from its customers and
employees for the purposes described under Principle #2.
4.2 ISQsolutions may also collect personal information from such third
parties as credit bureaus, employers or personal references or other
third parties that represent that they have the right to disclose the
information.
4.3 In connection with its Internet business, ISQsolutions may use a
Cookie to collect certain information which it uses to track user patterns
on its web site(s). A Cookie is a text file containing a unique identification
number that identifies a users browser, but not a particular individual.
A Cookie does not identify an individual. Furthermore, ISQsolutions
does not use Cookies in combination with other information to obtain
personally identifiable information. If an individual does not wish to
use Cookies, he or she can re-set their browser to either provide notification
or refuse to accept Cookies.
5. LIMITING USE, DISCLOSURE, AND RETENTION
Personal information will not be used or disclosed for purposes other
than those for which it was collected, except with the consent of the
individual or as required by law. Personal information will be retained
only as long as necessary for the fulfillment of those purposes.
5.1 ISQsolutions may collect, use or disclose personal information without
the individuals knowledge or consent in certain circumstances as described
in Principle #3.1.
5.2 ISQsolutions may disclose a customers personal information to:
(a) another web hosting provider or internet service provider for the
provision of services to that customer;
(b) a person involved in the development, promotion, marketing or enhancement
of ISQsolutions services;
(c) a credit collections agency;
(d) emergency services in an emergency situation;
(e) a person, who, in the reasonable estimation of ISQsolutions, is
an agent of the customer;
(f) any other third party, upon receiving the consent of the customer
or as required by law.
5.3 ISQsolutions may disclose an employees personal information in
the following circumstances:
(a) in the administration of that employees benefits;
(b) in providing references to prospective employers, upon receiving
the consent of the employee;
(c) as may be required by law.
5.4 Certain ISQsolutions employees may be given access to customer and/or
employee information in so far as their duties require access for business
purposes. ISQsolutions employees are governed by a non-disclosure agreement
prohibiting disclosure or use of any confidential or personal information
for any purposes other than the stated business purposes.
5.5 ISQsolutions will retain personal information for only as long as
required to fulfill the identified purposes or as required by law.
5.6 Personal information that is no longer required to fulfill the identified
purposes will be destroyed, erased or made anonymous according to the
guidelines and procedures established by ISQsolutions.
6. ACCURACY
Personal information will be as accurate, complete, and up-to-date as
is necessary for the purposes for which it is to be used.
6.1 The extent to which personal information will be accurate, complete,
and up-to-date will depend upon the use of the information, taking into
account the interests of the individual. Information will be sufficiently
accurate, complete, and up-to-date to minimize the possibility that inappropriate
information may be used to make a decision about the individual.
6.2 ISQsolutions will not routinely update personal information unless
such a process is necessary to fulfill the purposes for which the information
was collected.
6.3 You have the ability to correct or change your personal information
in our records, such as your address and contact information. The process
for changing your information begins in the account area of your control
panel. You may change this information at any time and as often as necessary.
If you need assistance or have questions about changing, updating or
correcting information, you can contact us via e-mail at support@isqsolutions.com.
6.3 Personal information that is used on an ongoing basis, including
information that is disclosed to third parties, should generally be accurate
and up-to-date, unless limits to the requirement for accuracy are clearly
set out.
7. SAFEGUARDS
Personal information will be protected by security safeguards appropriate
to the sensitivity of the information.
7.1 ISQsolutions will protect personal information against loss or theft,
as well as unauthorized access, disclosure, copying, use, or modification.
The nature of the safeguards will vary depending on the sensitivity of
the information that has been collected, the amount, distribution and
format of the information, and the method of storage.
7.2 ISQsolutions protects all personal information regardless of the
format in which it is held. The methods of protection include:
(a) physical measures, such as locked filing cabinets and restricted
access to offices;
(b) organizational measures, such as security clearances and limiting
access on a need to know basis;
(c) technological measures, such as the use of passwords and encryption.
7.3 ISQsolutions makes their employees aware of the importance of maintaining
the confidentiality of personal information. ISQsolutions employees
are governed by a non-disclosure agreement prohibiting disclosure or
use of any confidential or personal information for any purposes other
than the stated business purposes.
7.4 ISQsolutions will use care in the disposal or destruction of personal
information to prevent unauthorized parties from gaining access to the
information.
8. OPENNESS
ISQsolutions will make readily available to individuals specific information
about its policies and practices relating to the management of personal
information.
8.1 ISQsolutions will make its policies and practices with respect to
the management of personal information easily comprehensible and accessible,
by providing upon request:
(a) the name, title, and address of the Privacy Officer accountable for
ISQsolutions policies and practices and to whom complaints or inquiries
can be forwarded;
(b) the means of gaining access to personal information held by ISQsolutions;
and a description of the type of information held by ISQsolutions and/or
its subsidiaries, including a general account of its use.
8.2 ISQsolutions will make this Privacy Policy available online, by
mail or at its place of business. Furthermore, ISQsolutions Customer
Services Representatives will be trained to answer requests at ISQsolutions
toll-free customer service telephone number.
9. INDIVIDUAL ACCESS
Upon request, an individual will be informed of the existence, use, and
disclosure of his or her personal information and will be given access
to that information. An individual will be able to challenge the accuracy
and completeness of the information and have it amended as appropriate.
9.1 Upon request, ISQsolutions will inform an individual whether or
not the organization holds personal information about the individual,
and will provide that individual with a reasonable opportunity to review
the personal.
9.2 ISQsolutions will allow the individual access to his or her personal
information and to correct or change personal information in our records,
such as their address and contact information. The process for changing
information begins in the password protected account area of the individuals
control panel. The individual may change this information at any time
and as often as necessary. If assistance is needed, or for answers to
questions about changing, updating or correcting information, the individual
can contact ISQsolutions via e-mail or telephone.
9.3 ISQsolutions will be as specific as possible in providing an account
of third parties to which it has disclosed personal information about
an individual. When it is not possible to provide a list of the organizations
to which it has actually disclosed information about an individual, ISQsolutions
will provide a list of organizations to which it may have disclosed information
about the individual.
9.4 In certain instances, ISQsolutions will not be able to provide the
individual access to his or her personal information. For example, ISQsolutions
where the information contains references to other individuals; where
the information cannot be disclosed for legal, security or commercial
proprietary reasons; where the information is subject to solicitor-client
or litigation privilege; or where the information can best be available
from another source. In each case, ISQsolutions will provide reasons
for denying any access to personal information.
9.6 When an individual successfully demonstrates the inaccuracy or incompleteness
of personal information, ISQsolutions will amend the information as
required. Depending upon the nature of the information challenged, amendment
involves the correction, deletion or addition of information. Where appropriate,
the amended information will be transmitted to third parties having access
to the information in question.
9.7 When a challenge is not resolved to the satisfaction of the individual,
ISQsolutions will record the substance of the unresolved challenge.
When appropriate, the existence of the unresolved challenge will be transmitted
to third parties having access to the information in question.
10. CHALLENGING COMPLIANCE
An individual will be able to address a challenge concerning compliance
with the above principles to ISQsolutions Privacy Officer.
10.1 ISQsolutions will maintain procedures to receive and respond to
complaints or inquiries about its policies and practices relating to
the handling of personal information. ISQsolutions will make every effort
to ensure that its procedures are easily accessible and simple to use.
10.2 ISQsolutions will inform individuals who make inquiries or lodge
complaints of the existence of relevant complaint procedures.
10.3 The person or persons accountable for compliance with this Privacy
Policy may seek external advice where appropriate before providing a
final response to individual complaints.
10.4 ISQsolutions will investigate all complaints. If a complaint is
found to be justified, ISQsolutions will take appropriate measures,
including, if necessary, amending its policies and practices.
Corporate Office:
ISQ Solutions Inc
25 Milvan Drive
Toronto, Ontario
Canada
M9L 1Y8
Phone: 1-646-998-8116 (USA & Canada)
General inquiries: info@isqsolutions.com
