Pursuant to PIPEDA, Personal Information means information about an identifiable Individual, but does not include the title or business address or telephone number of an employee of an organization.
INEX Inc. (“INEX”) believes that protecting the privacy of Individuals disclosing Personal Information to INEX is paramount. Therefore INEX is committed to safeguarding the privacy rights of its users, clients, and customers, by adhering to the principles and requirements of the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
INEX is responsible for Personal Information under its control and has designated a Privacy Officer to be accountable for INEX’s compliance with these principles. The Privacy Officer can be reached by emailing firstname.lastname@example.org or by mail at the following address:
1-2627 Edinburgh Place
INEX is also responsible for Personal Information that has been transferred by INEX to a third party for processing. INEX will use contractual or other means to provide a comparable level of protection while the Personal Information is being processed by a third party.
INEX has implemented policies and practices to give effect to the principles and requirements of PIPEDA, including implementing procedures to protect Personal Information, establishing procedures to receive and respond to complaints and inquiries, training staff and communicating to staff information about INEX’s policies and practices, and developing information to explain INEX’s policies and procedures.
Using the website requires you to enter an Access Code, which in itself does not identify you personally (you will be asked only to enter a username of your choosing and a password of your choosing when you register your Access Code). However, if you choose to use the pre-populate function for letters on the website, then you will need to provide the name and details of the deceased as well as your name and contact information. The collection of this Personal Information is required in order to provide the requested service.
If express consent is provided by an Individual, their executor, or their legal representative, INEX may collect and disclose Personal Information, such as date of birth, date of death, and social insurance number, to one or more credit bureaus in the relevant jurisdiction. INEX will not collect, use or disclose Personal Information for this purpose without the express consent of the Individual, their executor, or their legal representative.
If collected Personal Information is to be used for a purpose not identified herein, the new purpose will be identified prior to its use.
INEX is committed to identifying and disclosing the purposes for which Personal Information is collected. INEX requires that an Individual provide Personal Information necessary for certain purposes (“Identified Purposes”), specifically: Personal Information collected for the purposes of establishing and maintaining responsible customer relations and for providing ongoing services to clients and customers.
INEX does not collect Personal Information, as defined by PIPEDA, when you visit its websites.
INEX uses aggregated site visitorship data and “cookies” to improve the content and services offered to its site visitors. “Cookies” are small text files that a website transfers to a site visitor’s hard disk or browser for added functionality or for tracking website usage.
In order to measure the effectiveness of INEX’s online presence, INEX uses visitorship data and cookies to identify repeat visitors to INEX’s website, to determine the path visitors take on INEX’s website, and to identify visitors who came to one of INEX’s website as the result of a link.
The information collected for visitorship data and cookie purposes is compiled on an aggregate, anonymous basis and therefore does not meet PIPEDA’s definition for personal information as the specific person is not identifiable.
The knowledge and consent of the Individual is required for the collection, use, or disclosure of Personal Information, except where such consent is not required by law. Therefore, INEX shall make all reasonable efforts to ensure that the Individual is advised of the purpose(s) for which the Personal Information will be used. INEX will not, as a condition of the supply of a product or service, require an Individual to consent to the collection, use, or disclosure of Personal Information beyond that required to fulfill the Identified Purposes.
Consent may be provided by an Individual via express or implied consent depending on the nature of the Personal Information. INEX may use an application form to seek consent, collect Personal Information, and inform the Individual of the use that will be made of the Personal Information. By completing and signing the form, the Individual is giving consent to the collection of the Personal Information and to the Identified Purposes. Consent can also be given by a person’s authorized representative.
An Individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. INEX shall inform the Individual of the implications of such withdrawal.
INEX limits both the amount and the type of Personal Information collected to that which is necessary for INEX to fulfill the Identified Purposes.
INEX will not use or disclose Personal Information for purposes other than the Identified Purposes, except with the consent of the Individual or where required by law. For example, where an executor provides explicit consent to share the deceased’s Personal Information with a credit bureau.
INEX will retain Personal Information only as long as necessary for the fulfillment of the Identified Purposes.
INEX has developed guidelines and implemented procedures with respect to the retention of Personal Information. For more information about these guidelines and procedures, please contact INEX’s Privacy Officer at the contact email address or mailing address above.
INEX shall ensure that Personal Information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. INEX will update Personal Information about Individuals when necessary to fulfill the Identified Purposes or upon notification by the Individual.
If you believe INEX retains Personal Information which is incorrect or outdated, please contact our Privacy Officer. When an Individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, INEX will amend the Personal Information as required. Depending upon the nature of the Personal Information challenged, amendment may involve the correction, deletion, or addition of Personal Information. Where appropriate, the amended Personal Information shall be transmitted to third parties having access to the Personal Information in question.
When a challenge is not resolved to the satisfaction of the Individual, the substance of the unresolved challenge shall be recorded by INEX. When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the Personal Information in question.
INEX has implemented safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. INEX shall protect Personal Information regardless of the format in which it is held.
INEX uses advanced technology to ensure that Personal Information and billing information is handled with the highest level of security and confidentiality. When an Individual submits information using online forms, INEX utilizes SSL (Secure Socket Layer) encryption technology to protect the information they submit. This technology protects an Individual from having their Personal Information or billing information intercepted by anyone other than INEX while it is being transmitted.
INEX Inc. strives to ensure that all systems are secure and meet industry standards. Where appropriate, INEX employs firewalls, encryption technology, user authentication systems (e.g., usernames and passwords) and access control mechanisms to control access to systems and data.
Upon request, an Individual will be informed of the existence, use, and disclosure of his or her Personal Information and shall be given access to that Personal Information. An Individual can challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.
Upon request, INEX will inform an Individual whether or not INEX holds Personal Information about that Individual. INEX shall allow the Individual access to this Personal Information. However, an Individual may be required to provide sufficient Personal Information to permit INEX to provide an account of the existence, use, and disclosure of Personal Information. The information provided shall be used only for this purpose.
INEX will respond to an Individual’s request within a reasonable time and at minimal or no cost to the Individual. The requested Personal Information shall be provided or made available in a form that is generally understandable.
It is intended that Individuals be able to acquire the information about INEX’s policies and practices without unreasonable effort. If access to the internet is not available a hard copy can be requested by contacting the Privacy Officer.
An Individual can address a challenge concerning compliance with the above principles to the Privacy Officer at the email address or mailing address listed above. INEX has put procedures in place to receive and respond to complaints or inquiries about their policies and practices relating to the handling of Personal Information.
INEX will inform Individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures. INEX will investigate all complaints. If a complaint is found to be justified, INEX will take appropriate measures, including, if necessary, amending its policies and practices.