Last updated on September 15, 2017.
At SPR Management Inc. (operating SPR and hellomynameisoliver.com) the protection of your personal information has always been a top priority. SPR’s Policy regarding the collection, use and disclosure, if any, of personal information can be broken down into the 10 principles covered in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).
- SPR is responsible for personal information under its control.
- We have designated a Privacy Officer who is accountable for our compliance with this Policy and all applicable privacy laws.
- All SPR employees are responsible for day-to-day compliance.
- When we use trusted third parties to act on our behalf by performing such functions as fulfilling orders, delivering packages, processing credit card payments or providing customer service, contractual or other appropriate means are used to ensure compliance by such third parties with this Policy and all applicable privacy laws.
- IDENTIFYING PURPOSES
- Unless the purpose is self-evident due to the nature of the transaction in question, SPR will identify the purposes for which personal information is collected at or before the time the information is collected.
- The proposed purposes will be described in a reasonably understandable manner.
- An example of a self-evident purpose is requesting the name and address of the person placing an order in order to ensure proper delivery.
- We will collect, use or disclose your personal information only with your knowledge and consent, except where required or permitted by law.
- SPR will not make your consent a requirement to the supply of a product or a service other than required to be able to supply the product or service.
- Consent can be express or, in some circumstances, implied, and given in writing, by using or not using a check-off box, electronically, orally (in person or by telephone), or by your conduct, such as use of a product or service.
- In determining the type of consent to obtain, SPR will consider all relevant factors, including the sensitivity of the information and your reasonable expectations.
- You may withdraw your consent at any time, on reasonable notice, subject to legal or contractual restrictions. SPR will inform you of the implications of doing so.
- CHILDREN’S PRIVACY
- Protecting children’s privacy is important to us. It is not our intent to collect or solicit personal information from anyone under the age of sixteen. If you are under the age of sixteen, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from an individual under the age of sixteen, we will remove that information as quickly as possible.
- Parents and legal guardians can withdraw consent to their child’s participation and use of their personal information at any time by contacting us at firstname.lastname@example.org
- LIMITING COLLECTION
- The collection of personal information by SPR will be limited to what is necessary for the purposes which it identifies.
- We will collect personal information by fair and lawful means.
- 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 your consent or as required or permitted by law.
- It will be retained only as long as necessary for these purposes or as required by law.
- We may disclose your personal information to: (i) parties in the context of a sale, financing or reorganization or potential sale, financing or reorganization of our business, provided that they agree to be bound by this Policy with respect to your personal information, (ii) parties to whom we have agreed to provide anonymized and/or aggregated data, though we will remove personal identifiers before we do so, and (iii) parties with whom we have contracted to process data, including parties who are located in countries or jurisdictions other than the one in which you reside (when this occurs, your personal information becomes subject to the laws of those jurisdictions).
- We will keep your personal information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.
- SPR will protect personal information by security safeguards appropriate to the sensitivity of the information, including through the use of the following measures: physical (e.g., locked filing cabinets, restricted access, appropriate disposal of personal information), organizational (e.g., security clearances, access only on a “need to know” basis), technological (e.g., passwords, encryption) and training of employees.
- Information about our policies and practices relating to the management of personal information will be made readily available to individuals.
- INDIVIDUAL ACCESS
- Upon request, SPR will inform you of the existence, use and disclosure of personal information relating to you, and give you access to that information. You have the right to challenge the accuracy and completeness of your information and have it amended as appropriate.
- However, in certain circumstances permitted by law, this information will not be disclosed to you. Some examples of these circumstances are information that contains references to other individuals, that cannot be disclosed for legal, security or commercial proprietary reasons, or that is subject to solicitor-client or litigation privilege.
- CONTACTING US AND/OR CHALLENGING COMPLIANCE
- For anything to do with this Policy, including questions or comments, or to challenge our compliance with this Policy, please contact us as follows:
SPR Management Inc.
PO BOX 18112 Heritage Mountain
Port Moody BC V3H 4H2 Canada
- SPR will inform individuals who make enquiries or lodge complaints about its enquiry or complaint procedures, as applicable. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices.
- Of course, this Policy is subject to PIPEDA and/or any other applicable privacy laws and SPR’s right to change it at any time.