Privacy is important!

UR CSI is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.

UR CSI may change this policy from time to time by updating this page, if you are registered on this website you will be sent an email to notify you if changes occur.

Unless indicated otherwise, this privacy policy applies to all our website, domains, apps, products, services, and features.

What is UR CSI?

UR CSI is a private network platform for residents of condos and apartment buildings.

We use “UR CSI” to refer to the UR CSI websites that provide you with access to that platform. We also use “UR CSI”, “we”, “us” and “our” to refer to the companies operating our Services.

We may collect the following information:
• Name
• Contact information including email address
• Demographic information such as postal code, preferences and interests
• Other information relevant to customer surveys and/or offers

If you use Facebook or other social networking sites to log in to UR CSI (or later connect your Facebook etc. account to your account) you authorize these social networking companies to share your personal information with us, including your name and email address.

What we do with the information we gather:

We require this information to understand your needs and provide you with a better service, and for the following reasons:
• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional emails about new products

At UR CSI, we are committed to providing our clients, customers, and vendors with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers, and vendors, protecting their personal information is one of our highest priorities.

While we have always respected our clients, customers, and vendors privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of our government Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients, customers, and vendors of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients, customers, and vendors’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients, customers, and vendors personal information and allowing our clients, customers, and vendors to request access to, and correction of, their personal information.

Definitions

Personal Information –means information about an identifiable individual [E.g., including name, age, home address and phone number, marital status, credit history. Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that Name of organization complies with this policy and PIPA.

Policy 1 - Collecting Personal Information

1.1- Unless the purposes for collecting personal information are obvious and the client, customer, and vendors voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 - We will only collect client, customer, and vendor information that is necessary to fulfill the following purposes:

  • To verify identity
  • To identify [client, customer, and vendors] preferences
  • To understand the needs of our client, customer, and vendors
  • To open and manage an account
  • To deliver requested products and services
  • To provide concierge services
  • To enrol the client in a program
  • To send out information
  • To contact our client, customer, and vendors for fundraising
  • To ensure a high standard of service to our client, customer, and vendors
  • To meet regulatory requirements
  • To collect and process payments

Policy 2 Consent

2.1 We will obtain client, customer, and vendors consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent)

2.2 Consent can be provided electronically, through an authorized representative] or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer, and vendors voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client, customer, and vendors is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer, and vendors does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), client, customer, and vendors can withhold or withdraw their consent for UR Concierge Services Inc.to use their personal information in certain ways. A client, customer, and vendors decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a service or product. If so, we will explain the situation to assist the client, customer, and vendors in making the decision.

2.5 - We may collect, use or disclose personal information without the client, customer, and vendors’ knowledge or consent in the following limited circumstances:
In an emergency that threatens an individual's life, health, or personal security
When the personal information is available from a public source (e.g., a telephone directory)
When we require legal advice from a lawyer
For the purposes of collecting a debt
To protect ourselves from fraud
To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 Using and Disclosing Personal Information

3.1 We will only use or disclose clients, customer, and vendor personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
To pass on important contact details to our service providers such as address, email and phone to allow the vendors to carry out the services ordered by members
To conduct client, customer and vendor surveys in order to enhance the provision of our services
To contact our clients, customers, and vendors directly about products and services that may be of interest

3.2 We will not use or disclose client, customer or vendor personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client, customer or vendor lists or personal information to other parties [unless we have consent to do so].

Policy 4 - Retaining Personal Information

4.1 If we use client, customer, member personal information to decide that directly affects the client, customer or vendor, we will retain that personal information for at least one year so that the client, customer or vendor has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client, customer and vendor personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 - Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that client, customer and vendor personal information is accurate and complete where it may be used to make a decision about the client, customer or vendor, or disclosed to another organization.

5.2 Clients, Customers and vendors may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the client, customer, and vendors correction request in the file.

Policy 6 - Securing Personal Information

6.1 We are committed to ensuring the security of client, customer, and vendors personal information to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that client, customer, and vendors personal information is appropriately protected: The use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate. Contractually requiring any service providers to provide comparable security measures].

6.3 We will use appropriate security measures when destroying client, customer, and vendors personal information such as shredding documents, deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 - Providing Client, Customer, and Vendor Access to Personal Information

7.1 Clients, customers, and vendors have a right to access their personal information, subject to limited exceptions. A full listing of the exceptions to access can be found in section 23 of PIPA. Some examples include: solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns]

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell a client, customer or vendor how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. 7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client, customer, and vendors of the cost and request further direction from the client, customer, and vendors on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the client, customer or vendor in writing, providing the reasons for refusal and the recourse available to them.

Policy 8 - Questions and Complaints:

8.2 Clients, customers, and vendors should direct any complaints, concerns or questions regarding UR Concierge Services Inc. compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer or vendor may also write to the Information and Privacy Commissioner of Ontario. Contact information for UR Concierge Services Inc. Contact Privacy Officer: Jennifer Mulholland.

Last updated: May 2019.

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