At Huddol, we are committed to providing our subscribers with exceptional service. As providing this service involves the collection, use, and disclosure of some personal information about our subscribers, protecting their personal information is one of our highest priorities.
We will inform our subscribers 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.
Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our subscriber’s personal information and allowing our subscribers to request access to, and correction of, their personal information.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the subscriber 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.
2.2 We will only collect subscriber information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify subscriber preferences;
- To open and manage an account;
- To deliver requested programming;
- To enroll a subscriber in an event;
- To send out information;
- To contact our subscribers for fundraising;
- To ensure a high standard of service to our subscribers;
- To provide our subscribers information from our Network Partners.
Policy 2 – Consent
2.1 We will obtain subscriber 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 or in writing or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the subscriber voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a subscriber is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, email send outs, the marketing of new services or products, fundraising and the subscriber 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), subscribers can withhold or withdraw their consent for Huddol to use their personal information in certain ways. A subscriber’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 subscriber in making the decision.
2.5 We may collect, use or disclose personal information without the subscriber’s knowledge or consent in the following limited circumstances
- 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;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose subscriber 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 subscriber surveys in order to enhance the provision of our services;
- To contact our subscriber directly about products and services that may be of interest.
3.2 We will not use or disclose subscriber personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell subscriber lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use subscriber personal information to make a decision that directly affects the subscriber, we will retain that personal information for at least one year so that the subscriber has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain subscriber 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 subscriber’s personal information is accurate and complete where it may be used to make a decision about the subscriber or disclosed to another organization.
5.2 Subscribers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made via our website or Info-line and provide sufficient detail to identify the personal information and the correction being sought.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of the subscriber’s 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 subscriber’s personal information is appropriately protected:
- The use of the use of user IDs, passwords and encryption;
- Restricting employee and Network Partner access to personal information as appropriate.
6.3 We will use appropriate security measures when destroying subscribers 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 – Questions and Complaints: The Role of the Privacy Officer
7.1 The Privacy Officer is responsible for ensuring Huddol’s compliance with this policy.
7.2 Subscribers should direct any complaints, concerns or questions regarding Huddol’s compliance in writing to the Privacy Officer.