Privacy Laws define personal information as information about an identifiable individual, or as information that allows an individual to be identified. Generally speaking, personal information does not include:
(a) anonymous or aggregated information that does not allow an individual to be identified;
(b) information regarding companies and other “legal persons”; or
(c) business contact information such as your name, title or position, business address, telephone number, fax number or email address.
The types of personal information that JCAC may collect from you from time to time include: your home address, home telephone number, personal email address, your forwarding address (e.g. during a vacation), previous address(es), billing and account information (such as credit card, or bank account number), your mailing preferences, delivery instructions, and customer service preferences. In addition, from time to time, we may ask you to provide us with more detailed information regarding your interests, occupation, preferences, evaluations and background. For example, we sometimes ask our customers to complete surveys in order to get a better sense of who they are and what issues, products or services may be of interest to our clients.
JCAC collects, uses and discloses your personal information by employing “fair information practices” as described in the following ten privacy principles and embodied in Privacy Laws:
Principle 1 – Accountability
(a) accountability for JCAC’s compliance with the principles rests with the Privacy Officer, even though other individuals within JCAC may be responsible for the day to day collection and processing of personal information. In addition, other individuals within JCAC may be delegated to act on behalf of the Privacy Officer;
(b) JCAC is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. JCAC shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party; and
(c) JCAC shall implement policies and practices to give effect to these principles, including:
(ii) establishing procedures to receive and respond to inquiries or complaints; and
(iii) training and communicating to staff about JCAC’s policies and practices.
Principle 2 – Identifying Purposes for Collection of Personal Information:
In general, JCAC collects, uses and discloses personal information about you in order to provide our customers with our goods and services. More specifically, JCAC collects, uses and discloses your personal information for the following purposes:
(a) to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual and legal obligations;
(b) to develop and manage our business and operations. This may include the sharing of personal information by and between JCAC personnel and affiliated companies, and with third party service providers and agents, for such purposes;
(c) to detect and protect JCAC and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with JCAC’s policies and contractual and legal obligations;
(d) to distribute our newsletters and other material to individuals on our mail and e mail lists, including via third party mailing houses and e mail service providers;
(e) to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving JCAC;
(f) to understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
(g) to develop, enhance, market, sell or otherwise provide JCAC’s products and services and those of third parties with whom JCAC has a commercial relationship;
(h) as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
(i) for any other purpose to which you consent.
JCAC will collect, use and disclose only that personal information necessary for the purposes that have been identified.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
Principle 4 – Limiting Collection of Personal Information
The collection of personal information shall be limited to that which is necessary for the purposes identified by JCAC. Information shall be collected by fair and lawful means and may be collected from other sources including but not limited to credit bureaus or other third parties who represent that they have the right to disclose the information. In most cases, collection shall be pursuant to appropriate contractual arrangements.
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Personal information shall not be used or disclosed for purposes other than those for which is was collected, except with the consent of the individual as stated above, or as required or permitted by Privacy Laws. Personal information shall be retained only as long as necessary for the fulfillment of those purposes or as required by law.
JCAC may collect from and/or disclose your personal information to:
(a) a person who, in the reasonable judgment of JCAC, is providing or seeking the information as your agent;
(b) any of the companies and business entities that form part of JCAC, as defined below;
(c) an organization or individual retained by JCAC to perform functions on its behalf, such as contractors, consultants, auditors, software developers (including web site developers and hosts), data processing, document management and office services;
(d) an organization or individual retained by JCAC to evaluate your creditworthiness or to collect debts outstanding on an account;
(e) a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;
(f) our auditors and legal representatives;
(g) another person or corporation as part of conducting business together or pursuant to the sale of all or substantially all of JCAC’s assets related to one or more specific lines of business, subject to the other person or corporation agreeing to manage personal information in accordance with Privacy Laws;
(h) another company or person for the development, enhancement, marketing or provision of any of JCAC’s products or services;
(i) an agent or third party retained by JCAC in connection with JCAC’s administration or the provision of JCAC’s products or services;
(j) credit grantors and reporting agencies; and
(k) as otherwise permitted by applicable Privacy Laws.
Except as permitted in this principle, JCAC does not provide or sell its customer lists to any outside company for use in marketing or solicitation.
Principle 6 – Accuracy of Personal Information
Personal information shall be as accurate, complete, and up to date as is possible. JCAC will update personal information as and when necessary to fulfill the identified purposes or upon notification from you. JCAC will not routinely update personal information, unless such process is necessary to fulfill the identified purposes. If ever your contact and/or other personal information changes, please feel free to contact us so that we can update our records.
Principle 7 – Security Safeguards
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. The security safeguards are designed to 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. 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; and
(c) technological measures, such as the use of passwords, firewalls and encryption.
Principle 8 – Openness Concerning Policies and Practices
(b) the information made available shall include:
(i) the name or title, and the address, of the Privacy Officer to whom complaints or inquiries can be forwarded;
(ii) the means of gaining access to personal information held by JCAC;
(iii) a description of the type of personal information held by JCAC, including a general account of its use;
(iv) a copy of any brochures or other information that explain JCAC’s policies, standards, or codes; and
(v) what personal information is made available to related organizations, affiliated companies or service providers; and
Principle 9 – Individual Access to Personal Information
Upon request, subject to certain exceptions under Privacy Laws, you shall be informed of the existence, use, and disclosure of your personal information and shall be given access to that information. You may wish to challenge the accuracy and completeness of the personal information and have it amended as appropriate.
NOTE: In certain situations, under Privacy Laws, JCAC may not be able to provide access to all of your personal information it holds. The reasons for denying access will be provided to you upon request. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor client or litigation privilege.
Principle 10 – Challenging Compliance
E mail Communications – Occasionally, we may send marketing or promotional e mail communications to you with information that may be useful, including information about the services of JCAC and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e mails from JCAC.
Links – Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than JCAC, and JCAC has no responsibility for such third party websites.
For information on JCAC’s privacy practices, please contact our Privacy Officer at:
• Evan Hansen
• 200-8 Manning Close NE, Calgary AB T2E 7N5, CANADA
• e mail: email@example.com
• phone: +1.403.203.2018
• fax: +1.403.398.1463
References to JCAC refer to: JCAC Technologies Inc. and its affiliates and subsidiaries from time to time including but not limited to:
• Evtech Solutions Ltd.
• 3D-P Australia Pty Ltd.
• 3D-P Peru SAC
• 3D-P Chile SPA