Privacy Policy
PRIVACY POLICY, Pino’s Salon Inc.
TO: All customers, potential commercial contacts and other individuals involved commercially with Pino’s Salon Inc. (the “Corporation”)
As of January 1, 2004, the Personal Information Protection and Electronic Documents Act (“PIPEDA”) applies to the Corporation. The legislation applies whenever “personal information”, as that term is defined in PIPEDA, is used for commercial purposes. To comply with PIPEDA, we have prepared this Privacy Policy and Plan which we intend to follow.
As a customer, you now have rights relating to a) the collection, b) the use of and c) the disclosure of what is termed “personal information”. The Corporation intends to in all respects follow the “Model Code” prepared by the Canadian Standards Association with respect to the treatment and handling of personal information. A copy of the Model Code is available from our Privacy Officer, whose identity at the present time Pino Cherubino is who can be reached at 519-578-8898. In short, the Model Code requires the following:
- the Corporation must have a Privacy Officer;
- the purposes for collecting personal information must be communicated to you;
- you must first consent before any of your personal information can be collected, used or disclosed;
- the Corporation can only collect personal information for necessary purposes;
- the Corporation can only use personal information for disclosed purposes;
- the Corporation must ensure that the information collected is complete and accurate;
- the Corporation must take adequate measures to preserve the security and confidentiality of the personal information;
- the Corporation must be open about all of its privacy policies under PIPEDA;
- if requested, the Corporation must (i) inform you that it does or does not possess the individual’s personal information, (ii) inform you that it has disclosed personal information to any third party and the identity of that third party (or parties), and (iii) allow you access to the individual’s personal information; and
- the Corporation must communicate clearly that you have a right to challenge the Corporation’s privacy policies.
For the purposes of this Policy, the Corporation anticipates collecting, using and/or disclosing the following types of personal information:
- Your Name, Home Address, Home email and Home Phone Number
- Your day and month of birth
- Your Credit Card Information
- In certain cases, Your Height, Weight and medical history as specified in our Client History Form (for Massage Consult), Compu-lift Client Consultation
Form or Facial Consult Form, or any of our Medical Spa Services, all that is applicable to you.
We want you to understand first and foremost that we already treat this type of information with the highest degree of confidentiality and security. We have collected, used and/or disclosed and anticipate collecting, using and/or disclosing personal information for the following potential and actual purposes:
- With respect to Credit Card Information, confirmation of your appointment with us.
- Entry of information in the Corporation’s database to track your purchases and services requested in order to provide optimum level of service to you.
- In-house marketing, survey, data collection and other activities, specifically excluding any sale or disclosure to any third-party marketing company;
- Disclosure on an as-necessary basis to the solicitors and accountants of the Corporation;
- Any future contemplated sale, purchase or change in ownership or structure of the Corporation to which our client list and knowledge thereof will represent a significant asset, with the understanding that any purchaser or new owner will be subject to the same strictures and need to abide by the same privacy policies as we have in place or are subject to at that time;
If any other purposes manifest, the Corporation will provide notice of these to you and will request consent at that time.
There are certain exceptions for which consent is not required. For collecting personal information they are:
- it is clearly in your interest and there is not enough time to get your consent;
- it is required by law;
- the information is already publicly available (such as in a business directory or telephone directory)
- collecting the information with consent will taint or distort the accuracy of the collected information;
- it is for journalistic, artistic or literary purposes only.
For using personal information they are:
- it is clearly in your interest and there is not enough time to get your consent;
- it is required by law;
- the information is already publicly available;
- to prevent an unlawful act from taking place to which the information is relevant;
- in an emergency situation, where your life or health is at stake;
- for statistical, scholarly or research purposes, within the parameters specified by PIPEDA.
For disclosing personal information they are:
- to a solicitor representing the Corporation;
- to assist in collecting a debt owed by you to the Corporation;
- to an archival institution for the purpose of preserving records, within parameters specified by PIPEDA;
- all of the reasons stated above for using personal information.
PIPEDA will be enforced by the Privacy Commissioner of Canada. The Model Code details how you can lodge a complaint and the various steps to take. Should the Privacy Commissioner choose to conduct an investigation, we wish to assure you that everyone associated with Pino’s Salon & Spa will cooperate to the fullest extent possible.
We will also be taking measures to safeguard personal information, including keeping separate limited-access files and records (both manual and within our IT hierarchy/file structure), ensuring that the Privacy Officer will have primary control over and discretion within the Corporation regarding any consented-to collection, use or disclosure of personal information and other measures similar to those used for the protection of our own proprietary confidential information. Please be assured that only reception and management will have access to the bulk of personal information collected and that other staff will only be able to access your name and the services and products that appear on your client file.
Please also note that you are able to withdraw or withhold your consent at any time. We must, however, inform you that withholding or withdrawing consent may hamper or impair our ability to effectively provide service to you as a client. In keeping with the policies set down thus far by the Privacy Commissioner’s office, we are requesting that you actively grant your consent by completing the portion of this letter below and returning this portion to us by mail in the enclosed envelope or by fax transmission.
We wish to thank you for your continued patronage as our client and we look forward to continuing our relationship with you.
Sincerely,
Pino Cherubino