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ThinkDox Inc. Privacy Policy

Policy Statement

ThinkDox Inc. is committed to protecting the privacy of all our stakeholders, including our clients, job candidates, employees, and others. To comply with the Personal Information and Protection of Electronic Documents Act, 2000 and other applicable privacy legislation, ThinkDox Inc. will protect the privacy and confidentiality of our stakeholders through the appropriate, secure collection and storage of personal information at all times.

Description

The Personal Information and Protection of Electronic Documents Act, 2000 (PIPEDA) establishes rules of private organizations to govern the collection, use and disclosure of personal information in a manner that recognizes the right of privacy of individuals with respect to their personal information.

The Freedom of Information and Protection of Privacy Act, 1990 (FIPPA) sets out regulations for protecting the privacy of individuals’ personal information held in government records. As ThinkDox Inc. is a service provider organization within the meaning of section 17.1 of the Ministry of Government Services Act, 1990, ThinkDox Inc. is subject by applicable regulations of FIPPA.

The Policy outlines the procedures for ThinkDox Inc.’ protection, retention, and release of personal information, including the appointment of a Privacy Officer, the handing of complaints and corrections, accessing personal information, and procedures for addressing confidentiality breaches.

Definitions

“Personal Information”

Under PIPEDA, “personal information” means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.

“Privacy Officer”

Under PIPEDA, a Privacy Officer is a designated official of an organization who is responsible for personal information under the organization’s control and is accountable for the organization’s compliance with the 10 principles of PIPEDA (accountability; identifying purposes; consent; limiting collection; limiting use, disclosure, and retention; accuracy; safeguards; openness; individual access; challenging compliance).

Questions and Complaints: The ThinkDox Inc. Privacy Officer

ThinkDox Inc. takes responsibility for protecting all personal information under our control, including information transferred to a third party for processing.

Questions about ThinkDox Inc. Privacy Policy, requests for access to personal information, or to file a complaint regarding the collection, use, and disclosure of personal information, should be directed to Human Resources.

Collecting Personal Information

Identifying Purposes

The purposes for which personal information is collected will be identified, disclosed, and documented by ThinkDox Inc. at or before the time the information is collected.

When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless the new purpose is required by law, the consent of the individual to authorize the collection of information is required before ThinkDox Inc. can use the information for its new purpose.

ThinkDox Inc. on the Web

Visitors to thinkdox.com may, at times, be asked to provide personal information to increase functionality of the site, when filling out application forms and when submitting inquiries, comments, and/or complaints. Individuals may be asked to provide contact and identifying information for the purposes of facilitating correspondence and to provide prompt replies to inquiries, such as name, email, location (i.e., city, province, postal code), street address, telephone number and resume information. This information may be retained for customer service and internal purposes and to provide future correspondence/assistance as necessary.

How we collect, use, and disclose individuals’ personal information when they visit thinkdox.com:

Third party links: We provide links to third party sites that we do not own or operate. ThinkDox Inc. will not share any personal information provided on our website with these third-party websites without individual consent. ThinkDox Inc. is not responsible or liable for third party links or the ways in which these third-party sites collect, use and disclose personal information, which are subject to their own privacy and security measures and policies.

IP addresses: ThinkDox Inc. does not track IP addresses of visitors to thinkdox.com. However, our Internet Service Provider tracks the service provider IP addresses affiliated with visitors to our site. IP addresses are used to compile statistical summaries and traffic reports and are only disclosed to ThinkDox Inc. in aggregate form.

Consent

ThinkDox Inc. will obtain consent from individuals for the collection of their personal information and the subsequent use or disclosure of this information. ThinkDox Inc. will advise individuals the purpose for which the information will be used. Personal information will not be released to third parties without written consent of the individual, unless the release is subject to exceptions including: if the information is required to investigate, prevent, or take action regarding illegal activities, a breach of an agreement or other contravention of law.

Limiting Collection

The collection of personal information will be limited to that which is necessary for the purposes identified by ThinkDox Inc., including the amount and type of information collected. ThinkDox Inc. will only receive and store the information that is voluntarily supplied by the individual with their knowledge and consent of the purpose for which it is being supplied. When information is no longer required to fulfill its intended purpose, ThinkDox Inc. will render the information anonymous, will delete, or destroy the information in a way which is non-reversible to prevent further access or use of the information.

Limiting Use, Disclosure, and Retention

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. If ThinkDox Inc. uses the personal information for a new purpose, we will document this purpose and will ask individuals for their authorization/consent to use their information for the new purpose, unless the release is subject to exceptions (refer to the Consent section above).

Ensuring Accuracy of Personal Information

Personal information collected by ThinkDox Inc. will be as accurate, complete, and up-to-date as is necessary for the purpose for which it is to be used. Individuals may request to update their personal information we have on file by contacting our office.

Securing Personal Information

Personal information collected by ThinkDox Inc. is protected by security safeguards appropriate to the sensitivity of the information. To prevent unauthorized parties from gaining access to personal information, we take measures to destroy/delete information including regular shredding of documents and deleting electronic files. We only retain information for the maximum retention rates as required by law.

Being Open about our Privacy Policies and Practices

ThinkDox Inc. will make readily available to individuals’ specific information about its policies and practices relating to the management of personal information. Individuals can acquire information about ThinkDox Inc. policies and practices related to privacy by contacting ThinkDox Inc. Human Resources.

Providing Access to Personal Information

Upon request, ThinkDox Inc. will inform an individual of the existence, use, and disclosure of his or her information and the individual will be given access to that information. The individual will be able to challenge the accuracy and completeness of the information and ThinkDox Inc. will amend it as appropriate. To request individual access, written requests should be forwarded to ThinkDox Inc. Human Resources.

Freedom of Information and Protection of Privacy Act Requests

ThinkDox Inc. will comply with the Freedom of Information and Protection of Privacy Act with regards to written requests for access to information for which ThinkDox Inc. maintains the custody and control, and for which are covered by the Act. Requests for access to information must be filed with ThinkDox Inc. in accordance with the access procedures under section 24 of FIPPA.

Individuals may request to update their personal information we have on file by submitting a request in writing to Human Resources.