1. Privacy Statement
This privacy policy (“Privacy Policy”) discloses how KBS+P Canada LP KBS+P Canada Sec. ("KBS+P", or "we", or "our", or, as applicable, "us") with respect to this website "www.kbsp.ca" (the "Website") in Canada, will collect, protect, use, and share personal information you provide when using this Website.
KBS+P is committed to protecting the privacy and security of any personal information which we may collect from you through this Website. This Privacy Policy discloses how KBS+P collects, protects, uses and discloses personal information. Our privacy practices are in accordance with our obligations under the Personal Information Protection and Electronic Documents Act ("PIPEDA") as set out herein. For the purposes of this Privacy Policy, "personal information" means any information that can be used to personally identify you as an individual as described below in this Privacy Policy.
This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared. Should we ask you to provide any personal information when using this Website, you can rest assured that the personal information will only be used in accordance with this Privacy Policy.
2. KBS+P's Commitment: Adhering to the 10 Privacy Principles
This Website meets our obligations with respect to the collection, use and/or disclosure of personal information by KBS+P adhering to the 10 privacy principles set out in PIPEDA as further described below:
Principle 1- Accountability
- information is restricted to the listed administrative contact and protected via appropriate hardware and software;
- The Information Officer in all matters related to compliance with this PIPEDA can be contacted at:
Leigh.reynolds@kbsp.ca; and
- Our staff is aware of our policies and practices regarding personal information.
Principle 2- Identifying purposes
We have identified the purposes for which we collect personal information as reflected above. We require the consent of the individuals providing the personal information prior to using their personal information for any purpose other than that for which it was originally collected.
Principle 3- Consent
We are committed to ensuring that you are aware of how your personal information is used and that you have consented to provide this information. Where required by law we may disclose personal information without your knowledge and consent.
Principle 4- Limiting collection
We collect personal information to fulfill the purposes stated in this Privacy Policy as amended. We collect personal information only by lawful and fair means and not by misleading or deceiving you about the purpose for which information is being collected.
Principle 5 - Limiting use, disclosure and retention
We do not use and/or disclose your personal information for purposes other than those for which it was collected, unless we have first obtained your consent. We retain your personal information for only as long as is necessary to fulfill the identified purpose.
Principle 6- Accuracy
We are committed to maintaining accurate, complete, and up-to-date personal information about you, as is necessary for the purpose for which it is to be used. If any of your information changes, please inform us so that we can make any necessary changes or use our website forms to update the information.
Principle 7- Safeguards
We are committed to ensuring that your personal information is secure. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, technological and organizational measures to safeguard and secure the information we collect.
Principle 8- Openness
Through this Privacy Policy we provide information about our organization's policies and practices regarding the collection, use and/or disclosure of personal information held by us.
Principle 9- Individual access
You may request in writing, subject to certain exceptions, access to your personal information held by us. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access.
Principle 10- Challenging compliance
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. We are committed to resolving disputes in a timely manner. We will investigate your complaint and respond via email, fax or telephone.
3. Consent – Collection, Use and Disclosure of Personal Information
KBS+P collects personal information by lawful and fair means and only collects information which is required for a specific purpose. In all cases we will ask you to provide express consent if we collect, use or disclose your personal information.
BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW
Personal information collected by KBS+P will not be used or disclosed for purposes other than those for which it was collected, except with your consent or as required by law. This personal information is shared with our staff and personnel and our service providers for our internal business purposes and may be used for any of the purposes described in "Our Use of Your Information" paragraph of this Privacy Policy below, subject to the terms of your consent in respect to your personal information.
4. Type of Information we may collect
KBS+P may ask you to provide, or KBS+P may obtain from affiliates or third party service providers, personal information about you to allow us to communicate with you. Personal information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual subject to the qualifications set out in PIPEDA. An identifiable person is one who can be identified, directly or indirectly by reference to a Social Insurance Number and/or Identification Number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal Information may include, but is not limited to, your name, birth date, mailing address, email address, Social Insurance Number and/or Identification Number, telephone number, personal story, personal images, and videos.
5. Internet Users – Cookies, Internet Protocol (IP) Addresses
On the Website, we monitor traffic patterns, site usage and related site information which is gathered in our computer system log files. We use this information to administer the Website and learn, for example, which areas of the Website are most popular and which may have performance problems. This information does not include any personal information.
Cookies - The web pages on the Website use "cookies" which are small text files that may be used, for example, to collect information about the Website activity. A cookie does not give us access to your computer or any information about you other than the data you choose to share with us. This helps us to analyze data about the web page traffic and improve the Website to tailor it to users' needs. This information is shared with our staff and personnel and our service providers who assist us with our marketing efforts and business activities. Most web browsers automatically accept cookies. Depending on the browser, you may be allowed to remove or block cookies or set up notification if you receive a cookie.
Internet Protocol (IP) Address - An Internet Protocol (IP) Address is associated with your computer's connection to the internet. KBS+P may use your IP address to help diagnose problems with KBS+P’s server, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer's IP address also may be used to provide you with information based upon your navigation through the Website. KBS+P does not link IP addresses to any Personal Information.
6. Our use of your information
We may use your personal information for any of the following purposes:
- • To provide clients with access and information on our products and services
- • To help us respond and understand clients’ and prospective customers' needs and desires and to offer products and services to meet those needs and desires
- • To distribute marketing materials and carry out promotional programs
- • To respond to inquiries of visitors on the Website
- • To meet legal requirements
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We reserve the right to use, disclose, sell, trade or rent aggregated data, provided that the data is not linked to any identified or identifiable individual.
7. Marketing Promotions and Advertising
If you participate in any advertising or marketing promotions the information that you provide will be handled in accordance with the Privacy Policy specific to said promotion which cannot and does not apply to this Privacy Policy. In addition to complying with PIPEDA, we will comply with the terms of any engagement we may have with our customers in respect of any such advertising or marketing promotions.
8. Sharing of Personal Information
We may share personal information with our affiliates, employees, and our service providers for our internal business purposes. Except as described in this Privacy Policy, we will not share personal information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. We reserves the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. We also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of KBS+P or of any of the business or assets or limited partnership interest and/or units of KBS+P or a division thereof in order for a customer or our contracting parties to continue to receive the same products and services from the third party.
9. Security
We endeavor to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification. We maintain physical, electronic and procedural safeguards as we deem appropriate to protect your personal information.
We safeguard your personal information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your personal information.
Currently, our Website utilizes a variety of different security measures designed to protect Personal Information by users both inside and outside our business, including the use of various encryption mechanisms, password protection, and other security measures to help prevent unauthorized access to your personal information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information – such as, but not limited to, credit card numbers, online forms, and financial data from loss, misuse, interception and hacking.
10. Storage, Retention and Accuracy of Personal Information
KBS+P will use reasonable efforts to keep your personal information up to date and accurate and will, upon your request, update our records with current information or have personal information removed from our databases.
KBS+P will retain such personal information for the period as is reasonably required to complete its dealings with you or as otherwise required by law. KBS+P will take all reasonable precautions to ensure your personal information is kept safe from loss, or unauthorized access, modification or disclosure. If you request that we not retain any of your personal information or any personal information of any individual you are a guardian of, we will use reasonable efforts to promptly delete such information from our servers and databases thereon.
We may store your personal information in databases located in the United States of America or other jurisdictions outside of Canada. Additionally, some of the service providers may reside in the United States of America or other jurisdictions outside of Canada and will be subject to the laws of the local jurisdiction. Accordingly, personal information collected and held by us in respect of the Website may, in certain circumstances, be accessed by foreign governments, courts or law enforcement or regulatory agencies.
11. Access, Control and Update Information About You
KBS+P welcomes your comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy or if you wish to access, review or edit your personal information collected by KBS+P or if you choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send any notices or updates and elect not to receive correspondence from us, please contact us our Information Officer at rbrott@kbsp.ca or as described in the "Contact Information" section below of the Privacy Policy.
12. Contact Information
You may contact the Information Officer to access, correct or delete your personal information. If necessary, the Information Officer will contact another employee to assist in completing your requested task. If you have any questions or complaints, please contact us by e-mail to our Information Officer at rbrott@kbsp.ca or write to us at our principal address at:
Leigh Reynolds
Vice President, Director of Production
BABYROBOT
KBS+P Canada
2 Bloor Street East, 26th Floor
Toronto, Ontario, Canada M4W 3J4
Tel: 416.323.2544
Mobile: 416.721.2844
Facsimile: 416 260 7100
Leigh.reynolds@kbsp.ca
KBS+P may deny access where it is prohibitively costly to provide the information, or if it contains information to other identifiable individuals, or where it cannot be disclosed for legal, security or commercially proprietary reasons. We will advise you of the reason where such access is denied.
13. Links to Third Party Websites
This Website may contain links to other websites which are not governed by this Privacy Policy and KBS+P has no responsibility or liability for or control over other websites or their collection, use and disclosure of your personal information while you are visiting such websites. You should exercise caution and look at the privacy statement of the website you may be visiting.
14. Social Media
KBS+P, uses a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, KBS+P uses several third-party platforms including, but not limited to, Facebook, and Twitter. Third-party websites and applications (TPWA) are web-based technologies that are not exclusively operated or controlled by KBS+P or its affiliates. When interacting with our presence on those websites, you may reveal certain personal information to us, our affiliates or to third parties. We will not use, share, or retain your personal information without your express and voluntary consent.
At this time, KBS+P has two Social Media Accounts, Facebook.com/kbspcanada and Twitter.com/kbsp_agency.
Facebook: On the Facebook.com/kbspcanada Facebook page, the KBS+P staff posts news and other items of interest to individuals. If you have a Facebook account or 'Like' Facebook.com/kbspcanada Facebook page, you can post comments or click on the 'Like' option for individual entries. If you comment or click on the 'Like' button, personally identifying information will be visible to our staff and other Facebook site visitors. The amount of visible personal information will depend on your own Facebook privacy settings. You can completely avoid displaying any personally identifiable information by not creating an account, not posting comments and not clicking on the 'Like' options in Facebook. Our staff does not collect, use or disclose any information about visitors who comment or 'Like' the Facebook.com/kbspcanada Facebook page. Facebook collects and reports on non-personally identifiable information about activities on Facebook pages. This information is password protected and only available to our employees and other designated staff who require this information to perform their duties. The Facebook privacy policy is available at: http://www.facebook.com/policy.php.
Twitter: We use Twitter to send short messages (up to 140 characters) or 'Tweets' to share information about our services with visitors and respond to comments and inquiries sent via Twitter to us. While visitors may read our Twitter feeds without subscribing to them, visitors who want to subscribe to (or follow) our Twitter feeds must create a Twitter account at www.twitter.com. To create an account, you must provide some personal information, such as name, user name, password and email address. Visitors have the option to provide additional personal information including a short biography, location or a picture. Most information you provide for a Twitter account is available to the public, but you can modify how much of your information is visible by changing your privacy settings at the Twitter.com website. Our staff members monitor the number of subscribers and respond to comments and queries via Twitter, but the staff never takes possession of the personal information belonging to Twitter followers. We do not collect, maintain, disclose or share any information about people who follow us on Twitter. The Twitter privacy policy is available at: http://twitter.com/privacy.
15. Updates to our Privacy Policy
We may change this Privacy Policy by providing an update to it from time to time. When the Privacy Policy is changed a notice will be posted on this Website along with the updated Privacy Policy. You should check it from time to time to ensure that you are happy with such change in respect of any personal information that you may have provided.
16. Terms of Website Use
The terms governing your use of this Website located under the Terms of Use pages on the Website which are important provisions regarding your use of our Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding your use of this Website. Each of these provisions applies to any disputes that may arise in relation to this privacy policy and the collection, use and disclosure of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Policy.
This Privacy Policy was last updated February 8, 2012.
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