PRIVACY POLICY
Last Revision Date: February 21, 2008
Our Commitment
junctionj.commerce limited (junctionj) is committed to protecting the privacy and security of our customers' Personal Information. This Privacy Policy ("Policy") explains junctionj's Personal Information handling policies procedures. We encourage you to also read junctionj's Terms of Use, as it works in conjunction with, and is a part of this Policy.
Definitions:
Collection - the act of gathering, acquiring, recording or obtaining Personal Information from any source, including third parties, by any means.
Consent - a voluntary agreement for the collection, use and disclosure of personal information for identified purposes. To ensure meaningful consent is obtained from the individual (or authorized representative), junctionj will provide the individual with reasonable notice ensuring that the individual's consent is provided on an informed basis. Consent can be either express or implied.
Express consent is clear, definite, explicit, direct and unmistakable; it does not require any inference on the part of the organization seeking consent. Express consent is given explicitly, either orally or in writing.
Implied consent is reasonably inferred from the circumstances and is manifested by signs, actions, inaction, facts or silence which gives rise to a presumption or inference that consent has been given. Such presumption or inference arises from a course of conduct or relationship between the parties, in which there is mutual acceptance or a lack of objection under the circumstances signifying assent.
Customer - an individual who
(a) uses, or applies to use, the services of junctionj; or
(b) corresponds with junctionj.
Disclosure - making Personal Information available to a third party.
Employee - a person employed by junctionj.
Personal Information - information about an identifiable individual but not aggregated information that cannot be associated with a specific individual. Such information may include, but is not limited to a customer's credit card information, work and personal email addresses, home address, home telephone number, personal cell phone number and resume information. Note: Information such as business contact information (except business email addresses) and information available in public directories are not Personal Information.
Third Party - an individual or organization other than the customer, his agent or junctionj.
Transfer - unlike disclosure of Personal Information to a Third Party for that Third Party's use, the transfer of information involves an agency relationship where the Third Party steps into the role of junctionj to carryout what would have otherwise been performed by junctionj.
Use - the treatment, handling and/or management of Personal Information by junctionj.
Personal Information Handling Practices
Management
junctionj defines, documents, communicates and assigns accountability for its privacy policies and procedures. junctionj takes responsibility for Personal Information under its custody and/or control and has designated an individual as the Privacy Officer who is accountable for the junctionj's compliance with this Policy. junctionj will make readily available to individuals specific information about its policies and procedures relating to the management of Personal Information. If you have any questions relating to the handling process of Personal Information by junctionj and/or this Policy, please contact:
privacy@junctionj.com
junctionj has implemented policies and procedures to give effect to this policy, including training and communicating to Employees about the company's policies and procedures.
junctionj Transfers Personal Information to Third Parties for processing and storage purposes. Such information may be transferred across provincial and national borders, in which case, the information becomes subject to the legislation of that jurisdiction. junctionj will only Transfer Personal Information upon Third Parties executing contracts requiring them to protect the privacy and confidentiality of the Personal Information provided to them for purposes of performing their functions for junctionj.
junctionj web sites may contain links to Third Party sites that are not governed by this Policy. Although we endeavour to only link to sites with high privacy standards, this Policy does not apply once you leave junctionj's Web sites. Additionally, we are not responsible for the privacy procedures employed by Third Party Web sites. Therefore, it is suggested that you review the privacy policies of Third Party sites to learn how your information may be collected, used and disclosed.
Children Under Age 13
junctionj does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not attempt to register for junctionj or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to or on junctionj. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at info@junctionj.com.
Children Between the Ages of 13 and 18
We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.
Notice
junctionj provides notice about its privacy policies and procedures and identifies the purposes for which Personal Information is Collected, Used, Retained, and Disclosed. junctionj will, at or before the time Personal Information is collected, identify the purposes for which the information is collected.
junctionj collects Personal Information only for the following purposes:
To establish and maintain responsible commercial relations with customers.
To understand customer needs and preferences.
To develop and enhance market services. For example, based on your site activity, junctionj may notify you about services that may be of interest to you.
Unless required or permitted by law, junctionj shall not Use or Disclose Personal Information for a new purpose that has not been identified and Consented to by the Customer.
junctionj may share your information with third party organizations so that they may offer goods and services that may be of interest to you. You may modify or withdraw your consent to this practice at anytime.
junctionj may update this Policy, including the Terms of Use and Disclaimer from time to time. As such, junctionj encourages you to review these documents periodically. You may determine when this Policy was last updated by referring to the "revision date" found at the top of this web page.
Choice and Consent
Prior to obtaining the individual's Consent, junctionj shall describe the choices available to the individual and obtain implicit or explicit Consent with respect to the Collection, Use and Disclosure of Personal Information except in special circumstances, such as during a fraud investigation, an investigation by the police or in situations otherwise permitted by the law.
In most circumstances, junctionj relies on express Consent received directly from the Customer to Use his or her Personal Information.
Express Consent: If any of the Personal Information that we collect is sensitive, such as financial information, junctionj shall obtain written, electronic or oral Consent from you before collecting, using or disclosing the information.
Implied Consent: junctionj may rely on implied Consent when Consent may reasonably be inferred from the action or inaction of the customer.
junctionj will only require customers to Consent to the collection, use or disclosure of Personal Information as a condition to the supply of a product or service if such collection, use or disclosure is required to fulfill the identified purposes. junctionj will not unreasonably withhold products, services or information from Customers who refuse or withdraw their Consent.
You may withdraw or modify your Consent at any time, subject to legal and contractual restrictions, provided that reasonable notice is given to junctionj. If you have your name removed from junctionj's telephone, mail or email marketing lists, you will not be made aware of certain products, services, events and promotions offered by junctionj.
Consent may be withdrawn or modified by simply contacting junctionj's Privacy Officer at privacy@junctionj.com. Please allow us 30 days to complete your request. Some of our promotions may already be in progress when you submit your request, therefore you may be contacted during this time.
Collection
junctionj collects Personal Information only for the purposes identified in this Policy. junctionj shall only collect Personal Information by fair and lawful means.
Except as required to process a transaction, providing junctionj with your Personal Information is voluntary. You may choose whether or not to give us your Personal Information, and if you do, how we use it.
Clickstreaming is a technology that allows a web site operator to track the paths that visitors take as they access a web site and look at the site's pages, and as they use links to other sites. junctionj collects such information from visitors to junctionj's web sites.
Use and Retention
junctionj limits the Use of Personal Information to the purposes identified in this Policy and for which the individual has provided implicit or explicit Consent. In accordance with established policies and procedures, junctionj retains Personal Information for only as long as necessary to fulfill the stated purposes, except with the Consent of the individual or as required by law.
In accordance with established policies and procedures, junctionj will destroy or erase any Personal Information that is no longer needed. When Personal Information is destroyed or erased, junctionj takes reasonable steps to prevent unauthorized access.
Access
junctionj provides individuals with access to their Personal Information for review and update. Upon request, junctionj will inform an individual of the existence, Use, and Disclosure of his or her Personal Information and shall give access to that information. An individual may challenge the accuracy and /or completeness of the information and have it amended as appropriate.
An individual may access his or her Personal Information in the custody and/or control of junctionj by emiling junctionj's Privacy Officer at privacy@junctionj.com. Access to Personal Information shall be provided in accordance with junctionj's established policies and procedures.
There is no cost for reasonable access to Personal Information, unless, for example, you require copies of records. junctionj shall advise you of the cost, if any, prior to satisfying your access request. Prior to providing you with access to your Personal Information, junctionj may require additional forms of information, including your Personal Information to validate your entitlement to the information being requested. Information collected for identification purposes will only be used to process your access request and for no other purpose.
junctionj will assist any individual who needs help in preparing an access request to Personal Information. If you have a sensory disability, upon request, we will give you access to your Personal Information in an alternative format that is more suitable for you.
junctionj will provide a response within 30 days of receiving an access request to Personal Information. In the event access to Personal Information is denied, junctionj will explain the reasons for this lack of access and any recourse the Customer may have, except where prohibited by law.
Upon written request for access to Personal Information, junctionj shall provide an account of the use and disclosure of Personal Information and where reasonably possible, shall state the source(s) of the information. In providing an account of disclosure, junctionj shall provide a list of organizations to which it may have disclosed Personal Information about you when it is not possible to provide an actual list.
Under certain circumstances, such as when junctionj is unable to separate your Personal Information from that of another individual, junctionj will not be able to provide you with access to your Personal Information.
If you notify junctionj of inaccuracies contained in our records about you and we do not agree to change your Personal Information, you may challenge our decision. We will make a record of your challenge by documenting the requested changes to the copies of your Personal Information; and if necessary, disclose the challenge to Third Parties who also may have previously received your Personal Information from junctionj.
Depending on the circumstances, where Personal Information has been used to make a decision about a Customer, junctionj shall retain the Personal Information for a period of time that is reasonably sufficient to allow the Customer to access his or her Personal Information.
Disclosure to Third Parties
junctionj Discloses Personal Information to Third Parties only for the purposes identified in this Policy and with the implicit or explicit Consent of the individual, except where required or permitted by law.
Although very unlikely, in some instances, such as a legal proceeding or court order, junctionj may be required to disclose certain information to authorities. Only the information specifically requested is disclosed and junctionj shall take precautions to satisfy ourselves that the authorities who are making the request have legitimate grounds to do so.
In the event junctionj is merged with or is acquired by another organization, junctionj will make every reasonable effort to notify you if junctionj shares with the merging or acquiring organization some or all of your Personal Information.
Security for Privacy
junctionj protects Personal Information against unauthorized access. In accordance with established policies and procedures, junctionj has security safeguards in place to protect Personal Information. Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.
Security safeguards implemented by junctionj include:
Technological - Password-protected computer systems and files.
Notwithstanding that junctionj has security safeguards in place to protect Personal Information, Customers are always encouraged to take measures to protect themselves against unintended intrusions to their personal privacy (i.e., maintain access pass codes and/or PINs in a confidential manner)
Quality
junctionj maintains accurate, complete and relevant Personal Information for the purposes identified in this Policy. In this regard, accuracy of Personal Information will be maintained so as to minimize the possibility that inappropriate information may be used to make a decision about an individual.
In accordance with established policies and procedures, if you believe that your Personal Information in our records may be inaccurate, junctionj will make it easy for you to access, verify, update and correct your Personal Information. Simply contact junctionj's Privacy Officer at the contact information provided in the Management section of this Policy. junctionj encourages its Customers to keep us posted with any changes to their Personal Information that is relevant to junctionj for the purposes for which it was collected.
If your Personal Information has been provided to Third Parties by junctionj, junctionj will convey the corrected information to them, if necessary.
In accordance with established policies and procedures, junctionj does not routinely update your Personal Information unless such a process is necessary to fulfill the purposes for which the information was collected.
Monitoring and Enforcement
junctionj monitors compliance with its privacy policies and procedures and has procedures to address privacy-related complaints and disputes. In this regard, individuals may address their privacy related concerns by contacting junctionj's Privacy Officer who is accountable for junctionj's compliance with this Policy.
junctionj shall respond to all inquiries, concerns and/or complaints about its Personal Information handling practices. The regulatory body that oversees junctionj's handling of Personal Information is the Office of the Privacy Commissioner of Canada. For more information, please visit http://www.privcom.gc.ca.
Every privacy related complaint will be acknowledged, recorded and investigated, and the results of the investigation will be provided. If a complaint is found to be justified, appropriate measures will be taken including, if necessary, amending our privacy policies and procedures.