Confidentiality and Privacy
AirSprint Inc. (in this Privacy Policy referred to as “AirSprint”, “we”, “our” or “us”) has always been committed to maintaining the confidentiality and security of personal information entrusted to us by our customers (in this Privacy Policy referred to as “you” or “your”). We are well aware of the concerns regarding the collection and protection of such information. As part of our continued commitment to excellence and quality for our customers, we have established this Privacy Policy relating to our collection, use and disclosure of personal information.
Our Privacy Policy has been developed on the principles and values defined in the Canadian Personal Information and Electronic Documents Act (“PIPEDA”) and The Personal Information Protection Act (Alberta) and their related regulations. As part of AirSprint’s continued commitment to privacy we have adopted a privacy code consisting of ten principles as a guide to our actions as they relate to the collection, use and disclosure of Personal Information in the course of our business operations. A summary of our privacy code’s ten principles is included at the end of this Privacy Policy.
If you have any questions regarding this Privacy Policy, please direct your questions to our Privacy Officer indicated below.
Personal Information Collection
Under Canadian privacy legislation, “Personal Information” is defined broadly as information about an identifiable individual and would include information such as your name, address, and your product and service purchases from our business. However, Personal Information does not include what is generally referred to as business contact information which consists of the name, title, business address and business telephone numbers of employees of an organization.
The extent and type of Personal Information collected from you depends on the nature of your business dealings with us. Personal Information may be collected when you purchase products or services, when you finance the purchase of products or services from us, you participate in one of our surveys, contests or promotions or if you contact our staff.
The types of Personal Information collected in the course of conducting our business may consist of:
- Contact and identification information such as your name, address, telephone number, and email address, facsimile number, driver’s license number, passport number and your occupation.
- Financial and credit information such as banking, credit report and credit card information.
- Property information such as details of your product purchases from us.
- Information about your product and service preferences.
We do not seek “sensitive information” (e.g., data relating to race or ethnic origin, religious beliefs, physical or mental health or sexual orientation) from our customers or Website visitors.
Use of Collected Personal Information
In connection with the operation of our business, the Personal Information which we collect may be used for one or more of the following purposes:
- To provide products and to perform services as may be requested by you;
- To analyze the suitability of our products or services for your needs;
- To determine your eligibility for some of our products and services, such as financing products and services;
- To notify you if you are a selected entrant in one of our contests or promotions;
- To provide you with information about promotions, special offers and programs or services which may be of interest to you;
- To respond to your specific questions or concerns;
- To maintain a customer contact database;
- To provide ongoing service to you;
- To assist us with our marketing programs to identify broad market groups for specific promotional opportunities;
- To invoice customers, process payments and collect accounts;
- To resolve disputes;
- To comply with applicable legal and regulatory requirements, such as tax law requirements; or
- For any other use authorized or permitted by law.
Disclosure of Personal Information
AirSprint does not share, sell, trade or transfer your Personal Information which we collect to third parties, for their own marketing efforts without your consent. Internally, we limit access to your Personal Information to those of our employees who need to have access to it for the performance of their duties. Like most businesses, we use third party service providers in connection with our provision of products and services to you. We disclose certain Personal Information to these third parties when they require the information to work with us. These third parties include service providers, credit report agencies, financial institutions and computer consultants and technicians.
Where applicable, we also require that they follow appropriate privacy and security measures. We may also disclose your Personal Information where we are required or permitted to do so by law.
Consent
Generally speaking, we will not collect, disclose or use Personal Information without your consent. Despite this general rule, there are certain circumstances where the collection, use or disclosure of your Personal Information without your consent may occur. For example, these circumstances would include:
- Collection, use or disclosure where it is clearly in the best interest of the customer and his/her consent cannot be obtained in a timely way (for example, in the case of a medical emergency);
- Disclosure for the purpose of collecting a debt owed to us;
- Collection, use and disclosure in investigating a breach of an agreement or a contravention of law;
- Disclosure to our legal counsel;
- Disclosure to comply with a subpoena or warrant; and
- Collection, use or disclosure where we are required or permitted by law or court order to do so.
Your consent can be expressed or implied or may also be given through an authorized representative. It may be given verbally or in writing. If you voluntarily provide Personal Information to us, about you or any other individual, we will interpret this as consent for the collection, use and disclosure of such information in the manner described in this Privacy Policy. If you do not have the authority to consent on behalf of another individual to the collection, use and disclosure of such information in the manner described in this Privacy Policy, do not provide us with any Personal Information about that individual. If you choose not to provide your consent, you may refuse to give us your Personal Information, however, most of the Personal Information which we collect is necessary to provide you with the products or services which you have requested from us and without this Personal Information, we cannot do this.
Subject to applicable legal or contractual restrictions, you also have the right to withdraw your consent to our collection, use and disclosure of your Personal Information on reasonable notice. In certain situations, withdrawing your consent could mean that we would not be able to provide you with some product or service you have requested. For example, if you make a credit account application, however, do not allow us to obtain a credit history report, we may not be able to approve your application and arrange for your requested financing. In some cases, you can choose to opt out of receiving certain communications and offers by declining special offers or promotions where indicated. In addition, some of AirSprint’s email offers/correspondence may contain unsubscribe instructions outlined in the email.
If, at any time, you wish to discontinue receiving any further emails of this nature, simply follow the unsubscribe instructions as described in the email. To be removed from any marketing lists on which you have agreed to be placed, please contact our Privacy Officer indicated below for further information.
Security, Accuracy, Access and Retention
AirSprint uses I.D.s, passwords and other security measures to protect your Personal Information. You should be aware that no electronic transmission over the Internet can be guaranteed to be completely secure. Therefore, AirSprint does not represent, warrant or guarantee that Personal Information sent via email or via the Internet will be protected against loss, misuse or alteration and does not accept any responsibility or liability for any intercepted Personal Information sent by email or via the Internet, nor for any third parties’ use or misuse of the same.
All employees, contractors and partners of AirSprint are responsible for the security and confidentiality of all personal and business information to which they have access.
We take reasonable efforts to maintain the accuracy and completeness of the Personal Information which we have collected, however, we rely on our customers to provide us with accurate Personal Information and advise us of any changes to the same, such as address changes. We urge you to notify us promptly, in writing, of any changes to your Personal Information.
Subject to certain exceptions, as permitted or required by law, you have the right to access, verify and amend your Personal Information collected by us. Upon your written request, subject to various exceptions, we will advise you of the existence, use and disclosure of your Personal Information and will provide you with access to the information. Examples of when we would not be able to provide you with access to your Personal Information include when the information is protected by solicitor-client privilege, the information would reveal confidential commercial information, the information contains Personal Information about a third party which cannot be severed or where the information has been collected in the course of investigating the breach of an agreement or contravention of law. Depending upon the volume of the Personal Information requested, we may charge a reasonable fee for the provision of the same.
We keep your Personal Information only for as long as needed to fulfill the purposes for which it was collected, to fulfill our obligations under this Privacy Policy and as may be required to comply with applicable laws. To access or amend your Personal Information, please contact our Privacy Officer described below.
Website
Internet users can visit our Website without telling us who they are or revealing any Personal Information about themselves. AirSprint does not collect information through our Website that personally identifies individuals except when individuals provide such specific information voluntarily by email. In such cases, we may collect, store and use such information in the same manner as we do other correspondence sent to us and in the manner described in this Privacy Policy.
In administering our Website AirSprint may use a browser feature called a “cookie” to provide our customers with added convenience while navigating through the Website. Cookies are small data files that websites write to your hard drive when you visit them in order to “track” your visit to a site. By themselves, cookies cannot be used to disclose Personal Information. Cookies identify your browser – but not you – to our server when you visit the Website. Most browsers automatically accept cookies, but some browsers can be set to reject all cookies.
We may use your Internet Protocol Number (“IP” - the number assigned to your computer while it is on the Internet) to assist us with diagnosing problems with our server, and to administer our Website.
We will not attempt to link or match cookies, IP number or other anonymous information that your web browser or client software may transmit to the servers that host our Website, with any Personal Information unless:
- We have your consent;
- We are investigating detected or suspected security breaches, and need to do so in order to carry out the investigation;
- We are required by law to do so.
Our Website contains links to other sites, which are provided for your convenience. Please note that operators of linked websites may collect Personal Information about you when you link to their websites or click on their advertisements. This Privacy Policy does not cover the privacy practices of such third parties.
Contacting Us
If you have any questions, concerns or complaints regarding our policies and procedures regarding your privacy, please contact our Privacy Officer at:
Via email:
Via mail:
Privacy Officer
AirSprint Inc.
1910 McCall Landing NE
Calgary, AB T2E 9B5
Modifications to this Privacy Policy
This Privacy Policy may change at any time. When any changes are made, we will provide you with notice on our Website. Changes will be effective once posted.
Summary of the 10 Principles of the AirSprint Privacy Code for the Protection of Personal Information
Accountability
AirSprint and all its employees are responsible for Personal Information under their control. AirSprint has designated a Privacy Officer to oversee AirSprint compliance with the applicable privacy legislation.
Identifying Purposes
The purposes for which Personal Information is collected shall be identified before or at the time the information is collected.
Consent
The prior knowledge and consent of the individual are required for the collection, use or disclosure of Personal Information, except where required or permitted by law.
Limiting Collection
The collection of Personal Information shall be limited to that which is necessary for the purposes identified. Personal Information shall be collected by fair and lawful means.
Limited Use, Disclosure and Retention
Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except under the consent of the individual or as permitted or required by law.
Accuracy
Personal Information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.
Safeguarding Information
Personal Information will be protected by safeguards appropriate to the sensitivity of the information.
Openness
AirSprint will make readily available to customers specific information about our use of and our procedures relating to the management of their Personal Information.
Individual Access
Upon written request, an individual will be informed of the existence, use and disclosure of his or her Personal Information and will be allowed access to it. By written request an individual will be able to inquire into the accuracy and completeness of the information and have it amended as appropriate.
Challenges to Compliance
Individuals can address any concerns regarding compliance with AirSprint’s privacy practices to our Privacy Officer.
This Privacy Policy and our Privacy Code are made in respect of PIPEDA and the Personal Information Protection Act (Alberta). This legislation is complex and provides some additional exceptions to the general privacy principles that are set out in this Privacy Policy and our Privacy Code. This Privacy Policy and our Privacy Code are intended to be general statements of our privacy principles, however, do not contain a full detailed list of the exceptions to the privacy policies and our code permitted by the legislation.