STATEMENT OF PURPOSE
This notice is meant to inform you about the Xinflix policy with regard to how we use, collect, or disclose personal information.
If you have any general questions concerning access to or use of your personal information, you should contact our customer service team at 1-888-946-3549.
If you have any unresolved concerns or wish to make a privacy related complaint, you may contact the Privacy Office directly at 1-888-946-3549.
Write to us by email: firstname.lastname@example.org
Or by regular mail at:
Xinflix Privacy Officer
Unit 7 421 Bentley St. Markham, On, L3R 9T2
Personal Information Protection and Electronic Documents Act: You can download and print the act in its entirety at www.priv.gc.ca
In accordance with PIPEDA, we define personal information as any information (in any format) that is about an identifiable individual. This may include information such as, but not limited to:
- Names, addresses (even electronic ones), telephone numbers, age, date of birth, ethnic origin.
- Social Insurance Number, credit card or bank account numbers, credit, billing or call history.
- Opinions, evaluations, comments, disputes, intentions, activities or meta-data.
- Identifiers* (account number, order numbers, services, SIP user ID, IP Addresses, MAC addresses, usernames, passwords, configurations, security questions and answers).
This does not include business contact information or other instances where PIPEDA does not apply to personal information such as personal information collected, used or disclosed by federal government organizations under the Privacy Act, Provincial or territorial governments and their agents.
Permission given by a customer where the customer provides:
- written consent;
- oral confirmation by an independent third party
- electronic confirmation through the use of a toll-free number; or
- electronic confirmation via the Internet.
- oral consent, where an audio recording of the consent is retained by the carrier; or
- consent through other methods, as long as an objective documented record of customer consent is created by the customer or by an independent third party.
An assumption of permission inferred from the actions or statements of the customer. For clarity, it is an understanding that is not directly stated. For example, to subscribe to any of our services we need some basic information from you to set up your account.
Xinflix has designated privacy officers to respond to any complaints or inquiries with regards to how we use your personal information. These officers are responsible for overseeing our compliance with PIPEDA. All Xinflix employees are trained to follow our policy and procedures.
When subscribing to any of our services, you are providing implied consent for us to collect personal information like your name, phone number, and billing information.
We will obtain your express consent prior to using or disclosing your personal information for a purpose that is not described within this policy, or that we did not identify to you at the time of collection.
When dealing with certain emergencies or legal issues, Xinflix may be required by law to disclose your personal information without seeking or obtaining your consent.
Xinflix may collect and retain your personal information:
- To meet legal and regulatory requirements.
- To establish and provide you with ongoing service.
- To help us understand and determine which of our services might better suit your needs.
- To manage, protect and improve our business operations.
In instances where we require your personal information for a purpose that is not listed above, Xinflix will identify the purpose at the time of collection.
Xinflix shall limit the type and quantity of personal information collected to the amount necessary to carry out the identified purpose(s). Whenever feasible, our representative will explain why the information is needed at the time of collection.
LIMITING USE, DISCLOSURE, AND RETENTION
Unless we obtain your express consent or a disclosure is pursuant to a legal process, any personal information held by Xinflix is kept confidential and will not be used or disclosed to anyone other than:
- the customer;
- a person who, in the reasonable judgment of Xinflix, is seeking the information as an agent of the customer;
- another telecommunications company, provided the information is required for the efficient and cost-effective provisioning of telecommunications service**
- Another telecommunications company or other service provider **
Any publicly available information, such as a listed name, address or telephone number (411 or white pages listings) is not kept as confidential. You should also be aware that the fact that you are a Xinflix customer may be revealed to others when using the Service.
We will retain your personal information only long enough to satisfy the purpose(s) to which you have already consented. Within a reasonable time after the purpose has been satisfied, your sensitive information will be destroyed or made anonymous.
** In order to establish and provide you with ongoing service, Xinflix must work with various third parties. These disclosures are made on a confidential basis with requirements to ensure that your information is safeguarded and only used for the specific purpose it was disclosed. These purposes may include, but are not limited to:
- supplying telecommunications, directory, equipment or other related services
- manage, protect and improve our business operations
- billing or collection of your account
- help us understand and determine which of our services might better suit your needs.
Keeping in mind the purpose of its use, we will make every reasonable effort to keep your personal information as accurate and complete as possible. We encourage your participation by helping us correct anything you feel we may have missed.
Xinflix is working hard to keep your personal information protected from unauthorized access and any other type of misuse. Access to your personal information is restricted and only made available to authorized personnel with a need-to-know. We are continuously looking to improve our physical and technological security controls in order to meet or exceed industry standards.
When it is no longer needed, we make sure that your information is securely destroyed or made anonymous.
You are entitled to have access to or challenge the accuracy of your personal information that is under our care. Upon your written request, Xinflix will promptly inform you of the existence, use, or disclosure of your personal information.
In some limited circumstances, if the information you requested is too costly to collect or if it conflicts with any legal or commercial proprietary obligations, Xinflix may withhold access or charge a reasonable fee. In the event that Xinflix does withhold access, you will be notified of the reason(s) no later than 14 days after your request was submitted.
We are committed to being as receptive and accommodating as possible in responding to any issues you may have about the handling of your personal information. Any customer complaints received by Xinflix about our compliance with PIPEDA will be acknowledged, investigated, and documented.
If you feel that the Xinflix Privacy Officer has not adequately resolved your issue, you may challenge our compliance with the Privacy Commissioner of Canada. Please consult their Guide to the Complaint Process, call them toll free at 1-800-282-1376 or visit their website at www.priv.gc.ca for more information.
Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec, K1A 1H3
OUR RIGHT TO UPDATE THIS POLICY
Xinflix reserves the right to add, modify, or remove any section of this document in order for it to remain representative of Xinflix business operations and continue to be compliant with PIPEDA.
This policy was last updated: 06/13/2016