RV Park & Go – Privacy Policy
Purpose
W.J. Braden & Co. LTD. o/a RV Park & Go (hereinafter called “RVPG”), maintains the principles of integrity and trust with respect to the privacy of personal information. As part of this commitment, RVPG will use reasonable efforts to protect the privacy of personal information collected from its customers, suppliers, and any other sources.
RVPG will comply with the principles of the federal Personal Information Protection and Electronic Documents Act, and to respect any other personal information and data protection laws which may be applicable.
The purpose of this Privacy Policy (the “policy”) is to set out rules to govern the collection, use and disclosure of personal information by RVPG, in a manner that balances an individual’s right to privacy with the need of RVPG to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances, in accordance with applicable privacy laws and regulations.
Definitions
“Personal Information” is information about an identifiable individual, not including the name, title or business address or telephone number of an employee of an organization, where the purpose of using that information is to contact that individual at their place of business.
Privacy Officer
Our Privacy Officer may be contacted as follows: In writing: Attention: Privacy Officer, RV Park & Go, PO Box 1140, Waterdown, ON L0R 2H0; Telephone: 1-888-785-6596; E-mail: [email protected]
Collection, Use and Disclosure
RVPG will obtain the informed consent of its customers, suppliers, employees and any other individuals from whom it may collect personal information, to its collection, use or disclosure of their personal information, unless collection, use or disclosure without consent is permitted or required by law. “Informed consent” means that RVPG: will inform these individuals of the purposes for its collection, use and disclosure of their personal information, and obtain their consent to collection, use and disclosure for these purposes, prior to, or at the time of, the collection of their information. RVPG will only collect, use and disclose the information necessary for its identified purposes. If RVPG wishes to collect, use or disclose an individual’s personal information for a new purpose, RVPG will inform the individual of this new purpose and obtain his/her consent to this, except where such collection, use or disclosure without consent is permitted or required by law.
Customers, Suppliers and Other Individuals
RVPG may collect, use and disclose personal information in respect of customers, suppliers, and other individuals who are not employees, from and to the persons and for the purposes set out below: (a) For the purpose of providing storage services and satisfying contractual obligations in respect of those services; (b) To banks, trust companies, credit unions and credit card companies for the purposes of authenticating account information and processing payments; (c) From and to collection agencies for the purposes of skip tracing and administering debt collection; (d) For the purpose of protecting and monitoring RVPG’s assets and properties, which includes, but is not limited to, using video surveillance at the entrances and exits to RVPG’s properties; (e) Such other collections and uses of personal information from such persons and for such purposes for which RVPG may obtain consent from time to time; and (f) As otherwise required or permitted by law. RVPG may also transfer personal information of the above-named individuals to third party service providers to the extent required and for the purpose of providing administrative or technological support services to RVPG. An example of such a service provider includes (but is not limited to) website support companies.
Withdrawal of Consent
An individual may withdraw his/her consent at any time, on reasonable notice, subject to legal or contractual restrictions. RVPG will inform the individual of the implications of such withdrawal. For example, where an individual withdraws consent to the uses of his or her personal information as set out in the foregoing section “Customers, Suppliers and Other Individuals”, such withdrawal may result in RVPG being unable to provide its services to such individual.
Security
RVPG will use reasonable and appropriate measures to ensure the confidentiality and protection of personal information against loss, theft, unauthorized access, collection, use, disclosure, copying, modification, disposal, destruction or similar risks. The methods of protection used include: Physical measures such as locked filing cabinets, Technological measures, such as the use of passwords and encryption. RVPG expects all of its employees to follow established guidelines in order to ensure the security of personal information in circumstances where they have access to such information. These guidelines include those set out in the Operations Manual regarding systems security and communications technology use. Personal information of customers, suppliers, and other individuals will only be accessed by RVPG’s employees on a need-to-know basis. RVPG is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. Therefore, if RVPG transfers personal information to third party contractors, it will require those contractors to covenant with it that they will provide the same security protection over the information as RVPG.
Accuracy
RVPG will use reasonable efforts to ensure that personal information is as accurate, complete and up-to-date as is necessary for identified purposes. This is to minimize the possibility that inaccurate information could be used to make a decision about an individual. To ensure the foregoing, RVPG requires each individual who provides RVPG with personal information to ensure that that information is accurate, complete and up-to-date. If the personal information of an individual changes we expect that the individual or employee will make RVPG aware of those changes so that we can update the personal information in question.
Access
Upon written request by an individual, complete with sufficient detail of the information being requested, RVPG will, within the time limits as set out in the applicable legislation, do the following: Inform the individual of the existence, use and disclosure of his or her personal information, (including a list of the organizations to which RVPG has, or may have, disclosed the individual’s personal information), and Provide the individual with access to that personal information, Except where RVPG is permitted or prohibited by law from doing so. In certain circumstances, RVPG is required by law to remove certain types of personal information from a document that contains personal information about the individual applicant, and then provide the individual access to this document. In those circumstances, RVPG will comply with this obligation. In certain circumstances, RVPG is required by law to deny access to personal information.
RVPG will comply with this obligation where applicable.
Correction Requests
An individual may request RVPG, in writing, to correct personal information about the individual that is under RVPG’s control, if the individual believes that this information contains an error or an omission. If the information is subject to interpretation or is an opinion RVPG is not required to change the record but will annotate the record to indicate the individual’s request. RVPG will make a reasonable effort to assist access and correction applicants and to respond to them as accurately and as completely as possible.
Retention
RVPG will keep all personal information that has been used to make a decision about an individual long enough to allow the individual access to the information after the decision has been made or, in any case, for at least one year after such decision has been made. Where the personal information is the subject of a request from an individual, RVPG will retain the information for as long as is necessary to allow the individual to exhaust any recourse under the applicable privacy laws. RVPG will destroy or anonymize personal information when it no longer needs to retain the information for the purpose for which it was collected, and retention is no longer necessary for legal or business purposes. When destroying or anonymizing this information, RVPG will use appropriate security measures to ensure that the confidentiality of this information is maintained.
Training
RVPG will train the necessary personnel with respect to their obligations regarding the privacy policy.
Complaints
An individual may direct a complaint concerning the collection, use or disclosure of his or her personal information, or about the application of the Policy, to the attention of the Privacy Officer. The complaint must be writing. Within a reasonable time of receipt of the complaint, the Privacy Officer will conduct an investigation into the complaint. The format of this investigation will vary, depending on the circumstances, and may or may not involve an interview of the complainant and/or RVPG employees. Within a reasonable time of conclusion of the investigation, the Privacy Officer will inform the complainant, either verbally or in writing, of the outcome of the complaint. If a complaint is found to be justified, RVPG will take appropriate measures necessary to rectify the complaint. Other comments and questions regarding this Policy or its administration should be forwarded to the attention of the Privacy Officer.