Effective April 20, 2010
This Privacy Policy explains the privacy practices of the Partner Rewards Plan. The Partner Rewards Plan is a referral rewards program administered by Maritz Canada Inc. on behalf of Partners who provide Partner Rewards Plan reward points or other benefits to Partner Rewards Plan members ("Members") in Canada.
TABLE OF CONTENTS
- Your Privacy Is Protected
- Our Privacy Principles
- Identifying Purposes and Obtaining Your Consent (Part 1)
- Limiting the Collection, Use and Disclosure of Your Information (Part 2)
- Keeping Your Information Accurate and Providing Access to Your Information (Part 3)
- Protecting Your Information (Part 4)
- Addressing Your Concerns (Part 5)
- Important Terms Used in this Policy
1. Your Privacy Is Protected
At the Partner Rewards Plan, an important part of our commitment to you is respect for your right to privacy. Keeping your information and affairs in strict confidence is a cornerstone of our business and an integral part of our commitment to service excellence. This policy will help you better understand how the Partner Rewards Plan protects, collects, uses and discloses your personal information and your right to access your information. This policy applies to Members (including Member applicants) and individuals whose information has been provided as part of a referral in connection with the Partner Rewards Plan. To understand the meaning of "personal information" and other terms used throughout this policy, please refer to the Important Terms section. Copies of this policy are available online under the Privacy Policy section of www.partnerrewardsplan.com. We may amend this policy from time to time. For the most up to date version, please visit www.partnerrewardsplan.com.
2. Our Privacy Principles
The Partner Rewards Plan respects the following principles when collecting, using, disclosing and protecting your personal information.
1. Identifying Purposes and Obtaining Your Consent
o We identify the purposes for collecting personal information at or before the time it is collected.
o We obtain your consent before collecting, using or disclosing personal information, except where permitted or required by law.
2. Limiting the Collection, Use and Disclosure of Your Information
o We limit the personal information we collect to what is necessary for the purposes we have identified. We collect information only by fair and lawful means.
o We do not use or disclose personal information for purposes other than those for which it was collected, except with your consent, or where permitted or required by law. We retain personal information only as long as necessary for these purposes.
3. Keeping Your Information Accurate and Providing Access to Your Information
o We take care to keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
o Upon request, we provide you with access to your personal information. You can ask how your information is used or disclosed, can ensure it is accurate and complete, and can update it if necessary.
4. Protecting Your Information
o We safeguard the privacy of personal information through security measures appropriate to the sensitivity of the information.
5. Addressing Your Concerns
o We are responsible for personal information under our control. There are designated individuals within the Partner Rewards Plan who are accountable for compliance with these privacy principles.
o We make available to you, information about our policies and practices related to managing your personal information.
o We address your concerns. We have steps you can follow if you have questions or concerns about your privacy.
3. Identifying Purposes and Obtaining Your Consent (Part 1)
We identify why we collect personal information and how we use it
We collect, use and disclose personal information about you throughout our relationship so we can:
- administer the Partner Rewards Plan, including establishing and managing Member accounts
- promote, manage and process Member redemptions
- invoice Members and suppliers of products or services for the Partner Rewards Plan
- enable Members to participate in marketing promotions and contests
- understand and analyze the Partner Rewards Plan and our business
- detect and protect against error, fraud and other business risks
- comply with legal and regulatory requirements
If we need your information for any other purpose, we will identify that purpose. We obtain personal information through various sources including directly from you, through your participation in the Partner Rewards Plan, and from others with your consent.
We may review and analyze your Member application, transactions and other personal information. We may do this to offer solutions that help meet your needs, and to develop new products and strategies to meet the needs of our clients. We may also do this to help us identify various types of risks such as fraud.
We share information with our affiliates
We may share information about you with our affiliates for legal and regulatory purposes, to manage fraud and other business risks, and to ensure we have correct and up to date information about you, such as your current address.
We may monitor and record telephone calls
We may monitor and record telephone calls between you and our representatives to ensure service quality and security and to confirm our discussions with you.
Your information is collected, used or disclosed with your consent
When you apply to be a Member, we tell you about this policy and will obtain your consent. Members are responsible for obtaining consent from individuals whose information has been provided as part of a referral in connection with the Partner Rewards Plan.
If your Membership or other participation in the Partner Rewards Plan requires approval by an employer or other third party, we may share your information with them in connection with your participation in the Partner Rewards Plan. Except as explained in "There are exceptions to obtaining consent" under Part 2 of this policy, we don't disclose information about you to anyone outside of Partner Rewards Plan without your consent. Similarly, if we intend to use your information for a purpose we didn't tell you about previously, we will obtain your consent.
There are many ways we may obtain your consent
We may obtain your express consent in writing, through electronic means, or verbally.
Alternatively, your consent may be implied through an action you've taken or when you continue to participate in the Partner Rewards Plan after we've posted a change.
Consent and your options
You may refuse or withdraw your consent to our use of your information at any time with reasonable notice. For example, as described below you may choose not to receive direct marketing offers or promotions.
If you refuse or withdraw your consent for any purpose that is required by us to fulfill our Partner Rewards Plan relationship with you, we will not be able to provide you, or continue to provide you, with the Partner Rewards Plan. We'll explain the impact on you at the time, to help you with your decision.
In some cases, certain consents are mandatory and cannot be withdrawn. For example, once you become a Member you cannot withdraw your consent on matters that are essential to the management of our business. Further, a referral consent cannot be withdrawn once the referral has taken place.
You can choose not to receive direct marketing
From time to time, we may offer Members products and services - including special promotions - that we believe will be of interest to them through direct mail, telephone, e-mail or other means. This consent is optional and you can decide to withdraw it at any time. If you withdraw your consent to receive direct marketing, this will not limit the information provided to you through discussions with a Partner Rewards Plan representative or information we may send you that is permitted or required by law or related to your existing Membership.
To withdraw your consent:
Call us at 1-866-877-5688. When you withdraw your consent, we will update your file as quickly as possible. Your choice may not be captured for a promotion already in progress.
4. Limiting the Collection, Use and Disclosure of Your Information (Part 2)
We limit the personal information we collect
While we collect various types of personal information from you and other sources, we limit the information to what is necessary for the purposes we've identified. The nature of the information we collect includes details such as a Member's name, postal and e-mail address, telephone number, occupation, employer, and credit card number and details relating to a mortgage referral including customer name and mortgage amount.
Using, disclosing and retaining your personal information
We do not use or disclose personal information for purposes other than those for which it was collected, except with your consent, or as described below. We retain personal information only as long as necessary for these purposes.
There are exceptions to obtaining consent
There are exceptions where we may collect, use or disclose information without consent:
1. If we use an outside supplier to do work for us.
At times we may use outside suppliers to do work for us involving some of your information. For example, we may use suppliers to conduct telemarketing or process transactions on our behalf. We select suppliers carefully and insist they have privacy and security standards that meet the Partner Rewards Plan's strict requirements. Similarly, your payment transactions will be processed through payment systems or networks operated by others. We may share your information with these operators on a confidential basis to process transactions, provide customer service, promote the service and for other reasonable purposes.
2. If we are permitted or required by law.
We may be compelled to release information by a court or other legal or regulatory authority. If so, our policy is to release information only to the extent that we are required to do so. We may also collect, use or disclose information without consent where permitted by law. For example, we may collect and use publicly available information like information in the telephone book for marketing or customer service purposes. Further, for legal, medical or security reasons, it may be impossible or impractical for us to obtain your consent.
3. If we have to protect our interests.
In certain circumstances, we may have to collect, use or release information without consent for our protection. For example, we may do so when collecting an overdue account or to detect or prevent fraud.
We may share information for business transactions
From time to time, we may sell parts of our business, insure, sell or securitize assets, or merge or amalgamate parts of our business with other parties. Since Partner Rewards Plan information may be a part of the transaction, we may disclose this information to other parties in the transaction, as part of due diligence and on completion of the transaction. We require that the other parties keep this information confidential and limit its use to the purposes of the transaction.
Information may be located outside of Canada
We, our outside suppliers and other third parties to whom we disclose information under this policy may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries.
We retain your information
The length of time we keep your information will vary depending the nature of the personal information and why it was collected. We have retention standards that meet customer service, legal and regulatory needs. For these reasons, we may keep your information beyond the end of your relationship with us.
When your information is no longer required, we securely destroy it or delete personally identifiable information.
5. Keeping Your Information Accurate and Providing Access to Your Information (Part 3)
We work with you to keep your information accurate
We take care to keep the information in our records as accurate, complete and up to date as necessary for the purposes for which it is used. However, we also rely on you to tell us when your personal information changes.
It is important to ensure your personal information at the Partner Rewards Plan is accurate and complete. To update your address and other personal information sign on to your online Member account and edit your information.
You can access your information
Much of your personal information is available to you by accessing your Member account online.
If you require other information, please request this by contacting us at 1-866-877-5688. We will ask that you put your access request in writing and that you provide us with details to help us understand your request and conduct our search for your information. We will need you to verify your identity before searching for or providing you with access to your information. We will respond to your access request within 30 days upon receiving all necessary information, or advise you in writing if we require additional time.
We may charge a fee to provide access to your information. We will let you know in advance if there is a charge.
If you have a sensory disability you may request your information to be made available in an alternative format. If we already have that format, we will provide it. Otherwise we will convert the information into the requested format if it is reasonable and necessary under legislation to enable access.
There may be limits on your right to access your information
It may not be appropriate for us to release certain types of information to you. For example, our records may contain information about other individuals, information that is confidential or proprietary to us, or information that is subject to legal privilege. Because we must protect everyone's confidentiality and legal rights, we cannot make this information available to you. However, where possible, we will suppress this information and provide you with access to the remaining records.
If we are unable to provide access or disclose information to you, we will explain why, subject to any legal or regulatory restrictions.
Your information and other parties
If we have obtained information about you from others, you can ask us for the source of that information.
On request, and where legally permitted, we'll provide you with the names of outside companies or organizations to whom we've given or may have given your personal information. However, this won't include outside suppliers we've used to do work for us, such as conducting telemarketing or processing information for us. This also won't include information that has been provided for legal or regulatory reasons.
You can have your information corrected
If you tell us that we have information about you that is obsolete or incorrect, we will update our records with the proper information. When appropriate, we'll correct any information which we may have given to an outside organization.
6. Protecting Your Information (Part 4)
How we protect your information
We limit access to your personal information and store it securely. In addition to the physical and electronic security devices we use to protect your information, we have security standards to protect our computer systems and your information from unauthorized use or access.
Our systems also protect your information when it is electronically transmitted. We regularly audit our information security procedures and assess that they remain effective and appropriate.
Employees who have access to your information are made aware of how to keep it confidential. We use contracts and other measures with our outside suppliers to maintain the confidentiality and security of your personal information and to prevent it from being used for any unauthorized purpose.
Access to your personal information is only given to those who require it to provide our products or services, or where permitted or required by law.
How you can protect your privacy
There are some simple yet very important steps you can take to protect your privacy:
Notify us immediately if:
You believe someone has obtained your password.
Protect your Password
You are the only person who should know the password to your online Member account.
Regularly monitor your Member account activities
Check your account activities to verify all transactions have been properly recorded. If entries do not accurately reflect your transaction activities (e.g. if there are missing or additional transactions), contact us immediately.
Ensure your contact information is up-to-date
Making sure that Partner Rewards Plan has your most up-to-date address or contact information will help protect your personal information from being misdirected. In "We work with you to keep your information accurate" under Part 3 of this policy, we explain how to check and update your personal information.
Protect your privacy online
To protect your privacy online, you should clear your browser's cache after each session, use a firewall, and use up to date software to protect your computer from viruses and spyware.
7. Addressing Your Concerns (Part 5)
We are accountable for our compliance with this policy
We have procedures in place to assist our employees in complying with this policy, as well as the federal Personal Information Protection and Electronic Documents Act and applicable provincial privacy legislation.
We regularly monitor our procedures and security measures to ensure that they remain effective and that they are being properly administered. . The Privacy Office and Chief Privacy Officer for the Program Partners are accountable for overseeing compliance with this policy.
If you have any questions about our policies and practices related to managing your personal information that have not been answered in this policy, please let us know so that we may provide further information.
Resolving your privacy concerns are important to us
We are committed to treating you with the greatest respect and consideration and providing the highest level of service. Even so, there may be a misunderstanding or times where you may feel you have been dealt with unjustly. Whatever the circumstances, our primary objective is ensuring your privacy concerns are addressed.
How to resolve privacy concerns and complaints at the Partner Rewards Plan
We are committed to upholding this policy. If you have any questions or complaints about this policy or about how we are living up to this policy, let us know right away.
Step 1: Talk to us
In most cases, a privacy complaint or concern is resolved simply by talking to us about it. You should be able to get swift results by talking to a Partner Rewards Plan representative by calling 1-866-877-5688.
Step 2: Write to the Partner Rewards Plan Customer Privacy Centre
If the problem is not resolved to your satisfaction, you can contact the Partner Rewards Plan Customer Privacy Centre:
Partner Rewards Plan Customer Privacy Centre
800 Bay Street, 5th Floor
Toronto, ON
M5S 3A9
Be sure to include:
- your name and contact information where you prefer to be reached
- the nature of your privacy complaint or concern
- details relevant to the matter and with whom you have already discussed the issue
If the above steps fail to resolve your concern you may also contact the Office of the Privacy Commissioner of Canada:
Place de Ville
112 Kent Street, 3rd Floor
Ottawa, ON
K1A 1H2
Call toll free at 1 800 282-1376
www.priv.gc.ca
8. Important Terms Used in This Policy
When reading this policy you should be aware of the meanings we give to the following terms.
When we refer to "personal information" or "information" it means information about an identifiable individual. This includes details such as a Member's name, postal and e-mail address, telephone number, occupation, employer, and credit card number and details relating to a mortgage referral including customer name and mortgage amount. Personal information does not include most of the information that appears on a business card.
When we refer to "we", "our" or "us" it means each of Maritz Canada Inc. (as administrator of the Partner Rewards Plan on behalf of the Partners) and the Partners who Partner Rewards Plan reward points or other benefits to Members. A current list of Partners is available at www.partnerrewardsplan.com.
When we refer to "permitted or required by law", and "legal and regulatory" requirements, authority or restrictions, this includes law, regulation, rules or requests of the regulators or self-regulatory organizations which apply to a Member or us.