ACCOUNTABILITY
PLC is accountable for all personal information in its possession or control. This includes any personal information that PLC has collected about website visitors.
PLC has:
- Established and put into effect policies and procedures aimed at properly protecting personal information.
- Educated its staff and volunteers regarding such policies and procedures and their roles and responsibilities in protecting personal information.
IDENTIFYING PURPOSES
We generally identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.
Some of the primary purposes for which we collect and use your Personal Information include:
- to send you electronic newsletters that may be of interest to you or to which you have subscribed.
- to respond to inquiries you submit.
We may also use your Personal Information as otherwise permitted or required by law.
CONSENT
We explain your options and obtain your implicit or explicit consent at the time of or prior to collecting, using or disclosing your Personal Information. We will always collect your Personal Information by fair and lawful means (for example, when you complete an inquiry form). We also collect your Personal Information where we have obtained your consent to do so or as otherwise permitted or required by law.
Where is it reasonable to do so or permitted by law, we may rely on implied consent.
Except to fill forms or as required or permitted by applicable law, providing us with your personal information is voluntary. You may withdraw or modify your consent at any time, subject to legal and contractual restrictions, provided that reasonable notice is given to us. If you withdraw your consent to receive information regarding certain publications, services or events being offered by us, you may not be made aware of same.
Personal Information is any information that is identifiable to you. This information may include, but is not limited to, your name, mailing address, phone numbers and email address. Personal Information, however, generally does not include information that PLC collects, uses or discloses solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession such as the individual’s name, position name or title, work address, work telephone number, work fax number or work electronic address.
LIMITING COLLECTION
We identify to whom, and for what purposes, we disclose your Personal Information, at the time of or prior to collecting such information from you and obtain your consent to such disclosure. For example, we may:
- transfer your Personal Information to our staff, for the purposes of the staff performing work functions;
- disclose your Personal Information to such persons and for such purposes for which you provide your consent; and
- disclose your Personal Information as otherwise permitted or required by law.
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected and as permitted or required by law.
From time to time we may disclose or hold your Personal Information outside of Canada, and while outside of Canada it may be subject to access by regulators in accordance with the laws of those jurisdictions.
LIMITING USE
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible based on information provided to us by you. We expect you, from time to time, to supply us with written updates to your Personal Information, if applicable.
DISCLOSURE AND RETENTION
We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
You can visit our Web Site without telling us who you are or revealing any information about yourself, including your email address. However, our web server may collect the IP address and domain you used to access our Web Site, the type and version of web browser and operating system you are using, the number, duration and frequency of visits to our Web Site and the web site you came from and visited next. This anonymous information cannot be traced to a specific individual User – it is used by us simply for the purposes of analytics – for example, to measure the number of visits, average time spent, page views, most popular preferences and other statistics about visitors to the Web Site and to determine the characteristics in which users use our Web Site and services. We may use this data to monitor Web Site performance for systems administration purposes, to make our Web Site easier and more convenient to use, to improve our services and to track information in aggregate form (e.g. how many visitors use the Web Site). This helps us better understand our Web Site traffic, visitor behavior and the impact of campaigns, content and email-driven traffic. By having access to such deeper data insights, we are able to measure, re-evaluate content offerings, map customer buying journeys and provide you with a more personalized visitor site experience, enabling demographic and interest reporting.
We make use of Google Analytics. A description of how Google Analytics collects and processes data is set out in “How Google uses data when you use our partners’ sites or apps”, (located at https://www.google.com/policies/privacy/partners/).
Please note that we have also implemented the following specific Google Analytics Advertising Features:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- Google Analytics Demographics and Interest Reporting
- Integrated services that require Google Analytics to collect data via advertising cookies and identifiers.
We use cookies, that is, small files that your Web browser places on your computer’s hard drive, to remember a User’s code, and preferences while the User is using our Web Site, to facilitate navigating different pages on the Web Site, to personalize the users experience when returning to our Web Site, to monitor progression through our Web Site, to identify opportunities to improve the user experience, and to customize ads you see when visiting the Web Site, and third party sites. Also, as a result of us enabling the Advertising Reporting Features, in addition to collecting the information it normally does, Google Analytics collects information via its Google advertising cookies.
Should you wish to opt out of the Google Analytics advertising features, you may do so at https://tools.google.com/dlpage/gaoptout/.
Our web site contains security mechanisms that protect against the loss, the misuse and the modification of information under our control.
Our web site provides links to third party web sites. Our Privacy Policy does not extend to these third party web sites and it is recommended that Users read the privacy policies of these web sites. We are not responsible for the content of, or the privacy practices employed by, third party web sites..
ACCURACY AND SAFEGUARDS
Up-to-date information on PLC’s privacy policies can be obtained from info [at] plvan.com.
OPENNESS, INDIVIDUAL ACCESS AND CHALLENGING COMPLIANCE
We will generally make available to you any Personal Information that we have collected about you, utilized or disclosed, upon your written request, to the extent permitted or required by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes.
You can at any time, challenge the accuracy or completeness of the Personal Information we have which is related to you. Where we validate your identity, and you successfully demonstrate the inaccuracy or incompleteness of your Personal Information, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.
We will not assess any costs to you for access to your Personal Information or to our Privacy Policies or Practices without first providing you with an estimate of the approximate costs, if any. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such information shall be used only for this purpose.
All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and Practices, should be forwarded by e-mail to: info@plvan.com
We will inform you of the relevant procedures when you make an inquiry or lodge a challenge or complaint.
Last revised: 4 April 2017