DIGICOM is a corporation that carries out telecommunications and broadcasting activities within the framework of which it provides wireless internet services primarily, to residential and commercial customers.
DIGICOM knows how important it is to you that your personal information is protected. For this reason, it has taken the necessary measures to ensure that the personal information you provide to it is protected by administrative methods and adequate security mechanisms that ensure that your information remains confidential and is used exclusively for the purposes which they were collected.
DIGICOM has also drafted the DIGICOM Personal Information Protection Commitment, which summarizes the main points of this policy, as well as a series of answers to questions that its clients frequently ask about the protection of their personal information.
DIGICOM will review and update its privacy documents as necessary to reflect rules and regulations, new technologies, standards and customer concerns.
APPLICATION AND SCOPE
In general, this policy applies to personal information (as defined below) that DIGICOM collects or produces, in any form whatsoever; however, it does not impose any restrictions on the collection, use or disclosure of the following information :
- information to which the public has access, within the meaning of PIPEDA and its regulations, such as the name, address, telephone number and e-mail address of a person that is displayed in a directory ;
- business contact details, including the name, title, address or work telephone number of a company employee.
The application of this policy is further subject to obligations established by applicable laws, regulations or agreements (such as collective agreements) or orders of a court or public authority.
Whenever you do business with DIGICOM or with any of its representatives, or participate in any competition organized or promotion offered by such a company or such representative, you are protected by the rights and mechanisms described in these documents and you expressly agree to their terms.
DEFINITION OF THE TERM “PERSONAL INFORMATION” »
The term “personal information” within the meaning of this policy and of PIPEDA means any information about an identifiable individual. This could therefore include information about your account, including your identity and the services you use and subscribe to, as well as information about your creditworthiness, your billing file and the complaints documented in your file.
Aggregate personal information that cannot be associated with an identifiable individual is not considered personal information.
FIRST PRINCIPLE – RESPONSIBILITY
DIGICOM is responsible for the personal information under its management and has appointed its Chief Privacy Officer as the person responsible for ensuring compliance with this policy :
- Christine Marion
- DIGICOM Inc.
- 395, Scott Ouest
- G8B 1R1
- Téléphone : 418-668-9999
- Courriel : email@example.com
DIGICOM is responsible for the personal information it has in its possession or which it manages, including that which it has entrusted to a third party for processing. DIGICOM provides, by contract or otherwise, a comparable degree of protection to information that is being processed by a third party.
DIGICOM has implemented the following policies and practices in order to comply with this policy :
- it has implemented business practices and rules to protect personal information and to ensure that it complies with this policy and applicable privacy laws;
- she trained staff and provided them with information on its policies and practices;
- It has procedures in place to receive and respond to complaints and inquiries.
SECOND PRINCIPLE – DETERMINATION OF PURPOSES FOR COLLECTING INFORMATION
DIGICOM determines the purposes for which personal information is collected at the latest when the collection is made.
DIGICOM collects personal information only for the following purposes :
- establish, grow and maintain business relationships with clients and other people with whom it deals;
- understand and assess the interests, expectations and needs of its customers in order to improve the products and services it already offers, or to offer new products and services;
- provide the products or services it offers or receive the products or services it requests and ensure that all related operations receive the necessary support and are implemented;
- verify the identity of customers who communicate with her by telephone, electronic means or other means and protect their personal information;
- if necessary, establish or verify the credit worthiness of the persons who use, or intend to use, one or more of the products or services it offers;
- manage its businesses and ensure that its systems are efficient, reliable and secure;
- comply with the obligations provided for by laws and regulations.
At the client’s request, DIGICOM employees or representatives who collect personal information must explain to the latter why they are doing so, or transfer the client to another employee or representative who will be able to give him more information. or give him the contact details of such an employee or representative.
Unless required by law, DIGICOM will not use or disclose personal information for any new purpose without obtaining the customer’s consent again.
THIRD PRINCIPLE – CONSENT
The customer must be informed and consent to any collection, use or disclosure of personal information about them, unless it is not appropriate to do so. In certain circumstances, it is possible to collect, use or disclose personal information without the customer’s consent, as follows :
- when it is clearly in their best interests and it is not possible to obtain their consent in a timely manner, such as in an emergency situation which endangers their life, health or safety;
- when, for legal, medical or security reasons, it is impossible or unrealistic to obtain consent;
- when information is collected for the purpose of detecting or preventing a breach of a convention, fraud or other unlawful activity and obtaining consent would be counterproductive ;
- as part of the recovery of a debt;
- in accordance with a subpoena, warrant or order of a court or as otherwise required by law.
DIGICOM obtains consent to the collection, use or disclosure of personal information by various means, verbally or in writing, including through individual or collective agreements, forms, welcome kits or printed or communications electronic.
The form of consent that DIGICOM requests varies according to the degree of sensitivity of the personal information, the reasonable expectations of the person concerned and the obligations or standards established by law. Generally, if you use DIGICOM products and services, you implicitly consent to the collection, use and disclosure of your personal information as set out in this policy and in the DIGICOM Terms and Conditions.
DIGICOM does not require the customer to consent to the collection, use and disclosure of personal information before providing a product or service, unless the collection, use or disclosure in question is necessary for the purposes set out in this policy. The customer may withdraw consent at any time, subject to restrictions provided for by law or contract and reasonable notice.
However, DIGICOM may no longer be able to provide all products and services to the customer who withdraws his consent. Customers may contact DIGICOM for information on the consequences of such withdrawal.
DIGICOM will ask the customer to consent to the collection, use or disclosure of their personal information that would serve a purpose other than those set out in this policy.
FOURTH PRINCIPLE – LIMITATION OF COLLECTION
DIGICOM limits collection to personal information that is necessary for the purposes established.
Personal information should always be collected in a fair and lawful manner and, in general, directly from the individual concerned. DIGICOM may also obtain credit information on a confidential basis from credit reporting agencies; however, it must first obtain the consent of its clients.
FIFTH PRINCIPLE – LIMITATION OF USE, COMMUNICATION AND STORAGE
DIGICOM does not use or disclose personal information for purposes other than those for which it was collected, unless the person concerned consents or the law requires. As indicated in Principle 3, in certain circumstances, it is possible to collect, use or disclose personal information without the knowledge of the person concerned or without their consent. In addition, DIGICOM may communicate customer information to the following persons :
- another company in the DIGICOM group (subject to CRTC requirements);
- a person who, in DIGICOM’s reasonable opinion, represents the client, for example as a proxy holder;
- a person for whom DIGICOM retains the services and who is responsible, among other things, for collecting the accounts of the client and checking and assessing the solvency of the latter on his behalf;
- another communications service provider or a company involved in providing communications or directory services to customers;
- another communications company, in order to ensure the efficient delivery of communications services;
- credit providers and reporting agencies;
- a company to which DIGICOM might wish to sell part of its business or its assets or a company seeking to grant a loan that would be guaranteed by the assets of DIGICOM;
- Law enforcement agencies and emergency service providers, in an emergency or as required or permitted by law.
This information is communicated on a confidential basis, with the understanding that it should be used only for the intended purposes. Access to personal information about customers is reserved for DIGICOM employees or trusted third parties with whom DIGICOM concludes contracts and who need it in the performance of their duties or the exercise of their activities. , within reasonable limits.
In some cases, personal information may be stored or processed abroad, in which case it will be subject to the applicable laws of those countries.
No other form of communication may be made without the consent of the client, except in an emergency or as required by law.
Personal information is kept only for the period necessary to fulfill the purposes for which it was collected and consent has been obtained, unless otherwise required by law. Personal information used to make a decision about an individual is retained long enough to allow that person to exercise their right of access to information in a reasonable manner after the decision has been made.
Personal information that DIGICOM no longer needs for the established purposes is destroyed, erased or de-identified. DIGICOM has developed and implemented formal and explicit guidelines for retention and destruction.
SIXTH PRINCIPLE – ACCURACY
Personal information must be as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. It must be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information will be used in making a decision about an individual.
DIGICOM updates personal information to the extent that this is necessary for the established purposes or at the request of the person concerned.
SEVENTH PRINCIPLE – SECURITY MEASURES
The personal information that DIGICOM holds or keeps is protected by security mechanisms corresponding to its degree of sensitivity.
DIGICOM protects personal information against loss or theft as well as against unauthorized viewing, communication, copying, use or modification, regardless of the form in which it is stored. The methods of protection include material means and administrative and technical measures, as appropriate. All DIGICOM employees who have access to personal information are made aware of the importance of protecting the confidentiality of such information and are required to comply with DIGICOM’s privacy principles and security standards.
DIGICOM protects personal information communicated to third parties by means of contractual agreements which require these third parties to adopt methods and measures in terms of confidentiality and security at least equivalent to those it uses.
EIGHT PRINCIPLE – TRANSPARENCY
DIGICOM provides its customers with specific information on its policies regarding the management of personal information.
NINTH PRINCIPLE – ACCESS TO PERSONAL INFORMATION
DIGICOM informs the customer of the existence of personal information about him, the use made of it and the fact that it has been communicated to third parties and, as a general rule, it allows him to consult it on request, unless prohibited by law.
In certain exceptional cases, for example when the information refers to other persons or cannot be communicated for legal reasons, security reasons or commercial reasons, DIGICOM could refuse to allow its customers to ” access all their personal information.
Personal information must be provided in a form that is understandable and easy to view, within a reasonable time and free of charge, or at minimal cost to the client. DIGICOM informs the customer, on request, of the use it makes or has made of its information. The customer can challenge the accuracy and completeness of the information and, if necessary, request that it be amended.
The customer can access his personal information by contacting the head of personal information protection of DIGICOM, whose contact details are indicated in this policy.
TENTH PRINCIPLE – POSSIBILITY TO MAKE A COMPLAINT ABOUT NON-COMPLIANCE WITH THE PRINCIPLES
The customer may complain of non-compliance with the principles set out above by contacting the person responsible for enforcing this policy within DIGICOM, namely the head of personal information protection.
DIGICOM has established the necessary procedures to receive and respond to complaints or inquiries about its personal information management policies and practices, and will advise those submitting them of the relevant course of action.
DIGICOM must investigate all complaints. If DIGICOM determines that a complaint is valid, it will take appropriate action, including amending its policies and practices, as necessary.
Revised in septembre 2023