Elements Squared Inc.
Personal Information Protection Policy
Personal Information Protection Policy
At Elements Squared Inc., we are committed to providing our customers and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers and members, protecting their personal information is one of our highest priorities.
While we have always respected our customers and members privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act
(PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our customers and members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ and members’ personal information and allowing our customers and members to request access to, and correction of, their personal information.
Personal Information –
means information about an identifiable individual which might include name, age, home address and phone number, marital status, income, education, and occupation.
Personal information does not include contact information (described below).
– 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.
– means the individual designated responsibility for ensuring that Elements Squared Inc. complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer and member 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.
1.2 We will only collect customer and member information that is necessary to fulfill the following purposes:
Policy 2 – Consent
- To verify identity;
- To identify customer and member preferences;
- To understand the hair care needs of our customers and members;
- To open and manage a customer or member account;
- To deliver requested products and services;
- To enrol the customer and member in a program;
- To ensure a high standard of service to our customers and members and
- To meet regulatory requirements.
2.1 We will obtain customer and member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, 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 and member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer and member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the customer and member does not opt-out.
2.4 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, members can withhold or withdraw their consent for Elements Squared Inc. to use their personal information in certain ways. A customer’s or member’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer, member in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s, member’s knowledge or consent in the following limited circumstances:
Policy 3 – Using and Disclosing Personal Information
- 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 personal information is available from a public source (e.g., a telephone directory);
- 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
3.1 We will only use or disclose customer or member 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 client, customer and member surveys in order to enhance the provision of our services;
- To contact our customers and members directly about products and services that may be of interest;
3.2 We will not use or disclose customer and member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer and member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use customer and member personal information to make a decision that directly affects the customer and member, we will retain that personal information for at least one year so that the customer and member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer and member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer and member personal information is accurate and complete where it may be used to make a decision about the customer and member or disclosed to another organization.
5.2 Customers and Members 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.
5.3 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’ and members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer and member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer and member personal information is appropriately protected:
- The use of user IDs and passwords to restrict access to the personal information database;
- The use of encryption, firewalls on our website, database and eCommerce hosting servers;
- 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.
6.3 We will use appropriate security measures when destroying customer’s and member’s personal information such as
- deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customers and Members Access to Personal Information
7.1 Customers and Members have a right to access their own personal information.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell customers and members how we use their personal information and to whom it has been disclosed if applicable.
7.4 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.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer and member of the cost and request further direction from the customer and member on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer and member in writing, providing the reasons for refusal and the recourse available to the customer and member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Elements Squared Inc. compliance with this policy and the Personal Information Protection Act.
8.2 Customers and Members should direct any complaints, concerns or questions regarding Elements Squared Inc. compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer and member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Elements Squared Inc. Privacy Officer or designated individual: