Colibri Solutions Inc., divisions of Colibri Solutions Corporation (collectively, “Colibri”) is committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information (“Personal Information”). As part of this commitment, the following Ten Privacy Principles govern our actions as they relate to the collection, use and disclosure of Personal Information. The principles have been built upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act.
Principle 1 – Accountability
Colibri is responsible for maintaining and protecting the Personal Information under its control. Colibri has designated an individual or individuals who is/are accountable for compliance with the Ten Privacy Principles.
Principle 2 – Identifying Purposes
The purposes for which Personal Information is collected will be identified before or at the time the information is collected.
Principle 3 – Consent
Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law.
Principle 4 – Limiting Collection
The Personal Information collected will be limited to those details necessary for the purposes identified by Colibri.
Principle 5 – Limiting Use, Disclosure and Retention
Personal Information may only be used or disclosed for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by law. Personal information will only be retained for the period of time required to fulfill the purpose for which it was collected or as required by law.
Principle 6 – Accuracy
Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.
Principle 7 – Safeguarding Personal Information
Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information.
Principle 8 – Openness
Colibri will make information available to our customers concerning the policies and practices that apply to the management of their Personal Information.
Principle 9 – Customer Access
Upon request, a customer shall be informed of the existence, use and disclosure of their Personal Information, and shall be given access to it. Customers may verify the accuracy and completeness of their Personal Information, and may request that it be amended, if appropriate.
Principle 10 – Handling Customer Complaints and Suggestions
Customers may direct any questions or enquiries with respect to the privacy principles outlined above or about our practices by contacting:
Colibri Solutions Privacy Officer
What Information is Collected?
At Colibri, we collect, use and disclose Personal Information to provide you with the services you have requested and to offer you additional products and services we believe you might be interested in. Providing us with your Personal Information is always your choice.
The types of Personal Information we may ask for depends on the nature of the services we provide you and typically includes your name, address, telephone number and e-mail address. When you visit the Colibri websites, Personal Information is not collected unless you choose to provide it voluntarily. You are welcome to browse the websites at any time anonymously and privately without revealing any personal information about yourself.
For purposes of maintaining quality service, calls to any of our customer service lines may be recorded. A recorded message given prior to your call being answered will let you know if your call may be the subject of our random call recording quality assurance program.
Types of Information We Collect
Most of the Personal Information we collect comes to us directly from you, and only with your consent. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, the Internet, or from referrals by third parties such as your financial institution.
When you visit the Giftcertificates.ca website, we may also collect from you Personal Information about another individual in order to send them a gift certificate. As noted, the choice to provide us with Personal Information is always yours. However, your decision to withhold particular details may limit our ability to provide you with any of our services.
If we are unable to accommodate your request based on the information that has been provided to us, we may ask for additional details in order to identify other ways to be of assistance. Colibri also maintains a file containing contact history that is used for customer inquiry purposes.
At Colibri, we also collect anonymous/non-personal information. Anonymous/non-personal information is information that we do not associate with or trace back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically when you visit one of our websites. Gathered electronically, this information may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internet Protocol address. The anonymous/non-personal information collected may be used for research and analytical purposes and occasionally for security investigations.
To help us better understand our markets, we may also gather information for analytical purposes by conducting customer surveys, and by extracting demographic information from existing files.
Your provision of Personal Information to us means that: (a) you agree and consent that we may collect, use and disclose your Personal Information in accordance with this policy; and (b) you or your representatives are authorized to provide us with your Personal Information. If you do not agree with these terms, you and your representatives are requested not to provide any Personal Information to Colibri. Certain services can only be offered if you provide Personal Information to Colibri. Consequently, if you and your representatives choose not to provide us with any required Personal Information, we may not be able to offer you certain services
How Your Information is Used
We use your Personal Information to communicate with you, effectively provide the services you have requested and safeguard your interests. We may also send you information about other products and services in which we believe you may be interested. Additionally, if you are a Colibri merchant client, we will keep you informed about your merchant account activities, send you important notices, and respond to any special needs or enquiries you may have.
In particular, if you are a Colibri merchant customer, our merchant agreement with you authorizes us to use and disclose the Personal Information that you provide to us to:
If you are an individual who is using our other services, we may use and disclose Personal Information to provide the services that have been requested, as well as in the following ways:
We only use Personal Information for the purposes that we have disclosed to you. If for any reason your information is required to fulfill a different purpose, we will obtain your consent before we proceed.
The anonymous/non-personal information gathered from the Colibri websites is used primarily for technical, research and analytical purposes like evaluating the various sections of the websites. This information does not include any personal information and it is only retained until its intended purpose is fulfilled.
It is our goal to continuously improve our service offerings to you. Therefore, we use anonymous/non-personal information collected from surveys, from public archives and by extracting information from existing files to better understand our customers’ interests, priorities, and satisfaction levels.
When Information May be Disclosed to Outside Parties
We are obliged to keep your Personal Information confidential except when authorized by you, when required by law and when permitted by law.
At Colibri, we sometimes contract outside organizations to perform specialized services such as terminal delivery and repair, and shipping and fulfillment services. Our trusted service suppliers may at times be responsible for processing and handling some of the information we receive from you.
When we contract our suppliers to provide specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. Furthermore, as part of our agreements, our suppliers and their employees and representatives are required to protect your information in a manner that is consistent with the privacy policies and practices that we have established.
When Required by Law
The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.
When Permitted by Law
There are some situations where we are legally permitted to disclose personal information such as employing reasonable and legal methods to enforce our rights under our agreements, to collect a delinquent account or investigate suspicion of illegal activities.
With Whom We May Share Your Information
Our Employees and Contractors
In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. For example, when you call us, our designated employees will access your information to verify who you are and to assist you in fulfilling your requests.
As a condition of their employment and their independent contractor agreement respectively, all employees and independent contractors of Colibri are informed about the importance of privacy and are required to abide by the privacy standards we have established. They are also required to work within the principles of ethical behavior as set out in the relevant Code of Conduct and must follow all applicable laws and regulations.
Unauthorized access to and/or disclosure of customer information by an employee of Colibri is strictly prohibited. All employees and independent contractors are expected to maintain the confidentiality of customer information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
How We Safeguard Your Information
We use state-of-the-art technologies and maintain current security standards to ensure that your Personal Information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are also appropriate to the sensitivity level of your information.
Electronic customer files are kept in a highly secured environment with restricted access. Paper-based files are stored in locked filing cabinets. Access is also restricted.
We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.
The Colibri websites use Secure Socket Layer (SSL) and 128 bit encryption technologies to enhance security when you visit the secured areas of these sites. SSL is the industry standard tool for protecting and maintaining the security of message transmissions over the Internet. When you access your accounts or send information from secured sites, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.
To safeguard against unauthorized access to your accounts, you may be required to “sign-on” using a user id and a password to certain secured areas of the Colibri websites. Both user id and password are encrypted when sent over the Internet. If you are unable to provide the correct password, you will not be able to access these sections.
When you call our customer service centre you will be required to verify your identity by providing some personally identifying information.
How You Can Protect Your Information
We do our utmost to protect and safeguard your Personal Information. We believe there are measures you should take as well. The following is a list of things you can do to protect yourself against fraud and uninvited intrusion.
Passwords are necessary to identify you and authenticate your permission to access your online accounts. The passwords you use are encrypted. Encryption is presently the most effective way to achieve data security. Just as it is important for us to employ strict procedures to safeguard your information, you also should take precautions in handling your passwords. When selecting a password, we suggest that you use a combination of letters and numbers and do not use words that can be easily associated with you such as the name of a family member, a pet or the street on which you live. We also suggest that you change your password regularly
You should not share personal information with others unless you clearly understand the purpose of their request and you know who you are dealing with.
Your Online Security
To make sure your connection to the protected areas of the Colibri websites is secure, look for either a ‘closed lock’ or an ‘unbroken key’ icon located at the bottom right hand side of your browser’s task bar. You may also check the Address bar to determine if SSL (Secure Socket Layer) is active by looking at the beginning of the address. If it starts with “https” rather than the standard “http”, then SSL is operating.
Accessing and Amending Your Information
At Colibri, decisions are made based on the information we have. Therefore, it is important that your Personal Information is accurate and complete. As a customer, you have the right to access, verify and amend the information held in your personal and financial files.
Last Modified: November 5th, 2014
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