Scope Of Policy
This Policy applies to Men In Kilts (see definition below). This Policy addresses personal information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. However, such information is protected by other Men In Kilts policies and practices and through contractual arrangements.
This Policy does not impose any limits on the collection, use or disclosure of the following information by Men In Kilts:
·your business contact information;
·publicly available information recognized under PIPA.
In this Policy:
Men In Kilts means Men In Kilts Franchise Services Inc and may include its Franchise Owners.
“collection” means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement to the collection, use and disclosure of personal information for specified purposes. Consent may be express or implied. Express consent can be given orally or in writing, it is unequivocal and does not require any inference on the part of Men In Kilts . Implied consent exists when Men In Kilts can reasonably infer consent based upon your action or inaction.
“disclosure” means making personal information available to a third party.
“personal information” means information about an identifiable individual but does not include business contact information of an individual. Personal information does not include information that is about corporate or commercial entities. It also does not include information that cannot be associated with a specific individual.
“PIPA” means the British Columbia Personal Information Protection Act S.B.C. 2003, c.63.
“third party” means an individual or organization other than Men In Kilts and you.
“Privacy Officer” means an individual designated by Men In Kilts who is accountable for Men In Kilts compliance with this Policy and who can be contacted as set out at the end of this Policy.
“use” means the treatment and handling of personal information by and within Men In Kilts.
Men In Kilts is accountable and responsible for personal information under its control. Men In Kilts has designated a Privacy Officer who is accountable for Men In Kilts compliance with this Policy.
Accountability for Men In Kilts compliance rests with the Men In Kilts President who may delegate the day-to-day accountability to the Privacy Officer or Vice President. Other individuals within Men In Kilts may be accountable for the day-to-day collection and processing of personal information or to act on behalf of the Privacy Officer. Ultimate accountability rests with the Men In Kilts Board of Directors.
Men In Kilts will adopt procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding policies and procedures and communicate policies and procedures to you.
The primary reason that we collect certain personal information is to provide the best possible level of customer service. It enables us to deliver service or product announcements, updates and special offers as well as provide convenient and personalized user access and improve the features and usability of our services or products. When collecting information, Men In Kilts will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection.
Men In Kilts collects your personal information for the following reasons:
- to provide and administer products and services requested and to use/disclose the information for any purpose related to the operation of accounts and the provision of requested products and services;
- to determine your financial situation including obtaining credit reports;
- to provide information to third party suppliers of products and services, such as data service providers, cheque printers, card manufacturers, etc.;
- to provide the information to credit bureaus and other financial institutions to update credit information;
- to protect Men In Kilts , yourself and others from fraud and error and to safeguard the financial interests of Men In Kilts ;
- to authenticate your identity;
- to provide information to anyone working with or for Men In Kilts as needed for the operation of an account or the provision of requested products and services;
- to collect debts owed to Men In Kilts ;
- to manage or transfer assets or liabilities of Men In Kilts , such as in the case of acquisitions and mergers, loans syndications and securitizations or sales of mortgages; and
- to comply with legal and regulatory requirements.
- to deliver and support our products and services; personal information such as name, e-mail address, contact preferences, which Men In Kilts products and services you use, and transactional information such as your credit card number.
- to improve our understanding of our customer needs; demographic information such as your occupation and where you use your computer and or mobile devices;
- to analyze trends, administer the site, track your navigation of the site, deliver relevant content and gather broad demographic information for aggregate use (note that IP addresses are not linked to “personally identifiable information”); Tracking information about your visit from the browser on your computer or mobile device, including IP address, cookies and the pages you request may be collected.
- to improve understanding of customer needs and provide relevant services; Aggregate information from multiple users without personally identifying individuals, such as geographic region, we may share internally and or with our business partners.
Men In Kilts is required by law to obtain your social insurance number or social security number to report interest on deposits and dividends on shares and other investment income to Canada Customs & Revenue Agency or United States Customs and Border Protection.
The above collections, uses and disclosures are a necessary part of your relationship with Men In Kilts.
3. Information Collection and Use:
Certain portions of the Men In Kilts web sites and services are open to any online viewer, such as blogs or social media “public,” services and our user forums. Any information that you post in these locations can be read, collected and used by anyone, and could enable others to send you unsolicited messages. Please consider before posting sensitive information to publically accessible areas of our site, and so you should carefully consider how you use the services. Men In Kilts is not responsible for any publication or use of any personal information you choose to post in these locations.
You can configure your browser to accept cookies, reject cookies or notify you when a cookie is being used. However, if you configure your browser to reject cookies, you may not be able to use Men In Kilts products or services that require you to sign in or take advantage of all the features of Men In Kilts.
Men In Kilts may allow third party business partners on some of our web pages to maintain their own cookies on your computer. These business partners do not have access to Men in Kilt’s cookies and their use is subject to their own privacy policies.
Men In Kilts is committed to protecting the security of your information and takes reasonable precautions to protect it. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure and as a result we cannot ensure the security of information you transmit to us; accordingly, you acknowledge that you do so at your own risk. Once we receive your data transmission, we make all commercially reasonable efforts to ensure its security on our systems:
- Any Men In Kilts user account may require a password and if so is protected by encryption and only you have access to it;
- Your personal information and data stored in our systems is protected by various physical, electronic and procedural safeguards. It is housed in a secure facility and Men In Kilts restricts physical and network access to select trained staff and regularly evaluates its technologies, facilities, procedures and potential risks to maintain the security and privacy of our users’ data. As a rule, Men In Kilts employees do not monitor or view your personal information or content stored in any Men In Kilts service, but it may be viewed if we learn that our Terms of Service may have been violated and confirmation is required, or we otherwise determine that we have an obligation to review it; and
- Certain Men In Kilts services support the use of standard SSL encryption to protect data transmissions. However, this is not a guarantee that such data transmissions cannot be accessed, altered or deleted due to firewall or other security software failures.
If Men In Kilts learns of a security system breach we may attempt to notify you and provide information on protective steps, if available, through the e-mail address that you supplied during registration or posting a notice on our web site. Depending on where you live, you may have a legal right to receive such notices in writing. To request written notice of any security breach in writing, please send an e-mail with your request and mailing address to it[AT]meninkilts.com or via postal mail to the address in the Contact Us section below.
- The entities comprising Men In Kilts may use your personal information to offer their additional or alternative services to you and may add it to client lists which they prepare and use for this purpose;
- Men In Kilts may share personal information within the Men In Kilts and with other Men In Kilts authorized suppliers and agents which may offer their services to you;
- Men In Kilts may use your credit card number to verify the CVV.
- Men In Kilts may contact you for survey purposes.
- Men In Kilts may keep your contact info on file with their chosen online service providers.
- Men In Kilts may engage and converse with you on social networks in which your personal information such as a ‘username’ is displayed.
- You may instruct Men In Kilts to refrain from using or sharing information in the ways described above at any time by providing written notification to the Men In Kilts Privacy Officer.
- Men In Kilts acknowledges that the sharing of information in the ways described above is at your option and you will not be refused credit or services merely because you advised Men In Kilts to stop using or sharing information in these ways.
- When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified prior to use and consent for same shall be obtained from you unless the use is authorized or required by PIPA or other laws in Canada or the USA.
Men In Kilts will obtain your consent to collect, use or disclose personal information except where Men In Kilts is authorized or required by PIPA or other law to do so without consent. For example, Men In Kilts may collect, use or disclose personal information without your knowledge or consent where:
·Men In Kilts is collecting or paying a debt; or
·Men In Kilts is obtaining legal advice; or
·Men In Kilts reasonably expects that obtaining consent would compromise an investigation or proceeding; or
·Men In Kilts is obtaining information under circumstances where a person is seriously ill or mentally incapacitated.
Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify Men In Kilts that you do not wish your personal information collected/used/disclosed for optional purposes following reasonable notice of same), action, or otherwise. For example, oral consent could be expressed over the telephone when information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application form.
You may withdraw consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is given to Men In Kilts. On receipt of notice of withdrawal of consent, Men In Kilts will inform you of the likely consequences of the withdrawal of consent, which may include the inability of Men In Kilts to provide certain products or services for which that information is necessary.
5. Limits On Collection Of Personal Information
Men In Kilts will limit collection of information to that which is reasonable and necessary to provide a product or service and which is reasonable and necessary for the purposes consented to by you. Men In Kilts will also collect information as authorized by PIPA or other law.
6. Limits For Using, Disclosing And Retaining Personal Information
Your personal information will only be used or disclosed for the purposes set out above and as authorized by PIPA and other law.
Men In Kilts will keep personal information used to make a decision affecting an individual for at least one year after using it to make the decision.
Men In Kilts will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
Men In Kilts will take due care when destroying personal information so as to prevent unauthorized access to the information.
Men In Kilts will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. In some cases, Men In Kilts relies on you to ensure that certain information, such as your address or telephone number, is current, complete and accurate.
If you demonstrate the inaccuracy or incompleteness of personal information, Men In Kilts will amend the information as required. If appropriate, Men In Kilts will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, Men In Kilts will annotate the personal information under its control with a note that the correction was requested but not made.
8. Safeguarding Personal Information
Men In Kilts protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
Men In Kilts will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to you. Some specific safeguards include:
·physical measures such as locked filing cabinets;
·organizational measures such as restricting employee access to files and databases as appropriate;
·electronic measures such as passwords and firewalls;
·regular reviews of processes in place to safeguard personal information; and
·investigative measures where Men In Kilts has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Men In Kilts will not be responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when you transmit information to Men In Kiltsby e-mail or other wireless communication or when Men In Kilts transmits such information by such means at your request.
Men In Kilts is open about the policies and procedures it uses to protect your personal information. Information about these policies and procedures will be made available in writing and electronically. However, to ensure the integrity of our security procedures and business methods, Men In Kilts will not disclose sensitive information about its policies and procedures.
Men In Kilts will make available a description of the type of personal information held by Men In Kilts, and a general description of its use and disclosure.
10. Providing Access
You have a right to access your personal information held by Men In Kilts.
Your information, such as copies of statements, transaction slips and account agreements will be provided upon request and authentication of identity.
Upon written request and authentication of identity, Men In Kilts will provide you with your other personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed.
Men In Kilts may charge a reasonable fee for providing information in response to a PIPA access request and will provide an estimate of any such fee upon receiving an access to information request. Men In Kilts may require a deposit for all or part of the fee.
Men In Kilts will make the information available within 30 days or provide written notice where additional time is required to fulfill the request.
In some situations, Men In Kilts may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm the competitive position of Men In Kilts. Men In Kilts may also be prevented by law from providing access to certain personal information.
Where an access request is refused, Men In Kilts will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
Men In Kilts will, on request, provide information regarding its complaint procedures.
Any inquiries, complaints or questions regarding this Policy should be directed in writing to the Men In Kilts Privacy Officer.
Men In Kilts will give appropriate notice of any amendments to this Policy.
Men In Kilts Franchise Services Inc.
210 – 12371 Horseshoe Way,
Richmond, BC, V7A 4X6, Canada.
Tel: 1. 877. 777. KILT, 604. 638. 0753 [Head Office]
Fax: 604. 638. 5210
E-mail: info @ meninkilts.com or customerservice @ meninkilts.com
Subject line – ATTN PRIVACY OFFICER