At adasThink, we are dedicated to protecting your privacy and safeguarding your personal, business, and financial information. In fact, it is one of our highest priorities and remains the cornerstone of our commitment to you. However you choose to provide information to us, we use vigorous security safeguards and adhere to Ten Privacy Principles to ensure your personal and financial information is protected.

We are committed to meeting or exceeding the privacy standards established by federal and provincial regulations and industry bodies. All of our information handling practices comply with federal and applicable provincial laws including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

Our Ten Privacy Principles

adasThink is committed to maintaining the accuracy, confidentiality, and security of your personal and financial information. As part of this commitment, we have established Ten Privacy Principles to govern our actions as they relate to the use of client information. We invite you to review our principles, which have been built upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and PIPEDA.

Principle 1: Accountability: We are responsible for maintaining ad protecting client information under our control. In fulfilling this mandate, we designate an individual or individuals who is/are accountable for our compliance with this Privacy Policy.

Principle 2: Identifying Purposes: The purposes for which client information is collected shall be identified before or at the time the information is collected.

Principle 3: Consent: The knowledge and consent of the client is required for the collection, use or disclosure of client information except where required or permitted by law.

Principle 4: Limiting Collection: The client information collected must be limited to those details necessary for the purposes identified by adasThink. Information must be collected by fair and lawful means.

Principle 5: Limiting Use, Disclosure and Retention: Client information may only be used or disclosed for the purpose for which it was collected unless the client has otherwise consented, or when it is required or permitted by law. Client information may only be retained for the period of time required to fulfill the purpose for which it was collected.

Principle 6: Accuracy: Client information must 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 Client Information: Client information must be protected by security safeguards that are appropriate to the sensitivity level of the information.

Principle 8: Openness: We are required to make specific personal information available to clients concerning the policies and practices that apply to the management of their information.

Principle 9: Client Access: Upon request, clients shall be informed of the existence, use and disclosure of their information, and be given access to it. Clients may verify the accuracy and completeness of their information, and have it amended, if appropriate.

Principle 10: Handling Complaints and Access: Clients may direct any questions or inquiries with respect to the privacy principles outlined above or about our privacy practices by contacting the designated person accountable.

Types of Information We Collect

Account Information

We gather your personal information to provide you with services you have requested. Most of the information we collect comes to us directly from you, and only with your express consent. All the information you provide to us is securely maintained and is kept strictly confidential.
Having up-to-date and accurate information helps us provide you with the best possible service and to offer the right products and services we believe will be of the most benefit to you.

In order to use our services, clients are required to create an account on our website. During the account registration, client may be asked to provide the following information:

• Business Name
• Business Address
• Business Telephone Number
• Business E-mail Address
• Name(s) of Owner(s), Officer(s), Director(s), and Employee(s)
• Industry Type

The choice to provide us with personal and financial information is always yours. However, your decision to withhold particular details may limit our ability to offer you services we are able to provide.

If we are unable to accommodate your request based on the information that has been provided, we may ask for additional details in order to identify other ways to be of assistance. In some instances, we may also maintain a file containing contact history that is used for client inquiry purposes.

Anonymous Information

We will routinely collect anonymous information. Anonymous information cannot be associated with or traced back to a specific individual or business entity. This could include, for example, pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internal Protocol address. The anonymous information collected may be used for research and analytical purposes.
To improve our services we offer to you, we may also gather information for analytical purposes by conducting anonymous client surveys.

Information Required for Common Activities

Depending on how you choose to interact with our website, you may be required to provide information.

Using our Services

If you choose to use our services, you will be asked to create an account in which you will provide information such as your business name, business address, business telephone number, business e-mail address, name of owner(s)/employee(s), and industry type.

Browsing our Web Site

You may browse our web site anonymously and privately, even if you do not wish to interact with our site or use our services. No personal or financial information will be collected from you without your knowledge and consent.

How Your Information is Used

At adasThink, we use three primary types of information:

• We use personal information to communicate with you and ultimately to provide you with the services you have requested;
• We use transactional information to keep track of and report back to you on your dealings with us; and
• We use anonymous information to improve our services to you.

Personal Information

We will use the personal information you have provided us to communicate with you and to safeguard your interest. We will authenticate your identity, send you important notices, and respond to any enquiries you may have. With your express consent, we may also send you information about other products and services in which we believe you may be interested.

We only use personal information for the purpose that we have disclosed to you, with the following exceptions as permitted under PIPEDA:

• The organization has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
• An emergency exists that threatens an individual’s life, health or security;
• The information is for statistical study or research;
• The information is publicly available;
• The use is clearly in the individual’s interest, and express consent is not available in a timely way;
• Knowledge and express consent would compromise the availability or accuracy of the information, and
• Collection is required to investigate a breach of an agreement.

Transactional Information

The majority of information we retain about you is in the form of transactional records that reflect your business dealings with us. We are required by law to update and maintain this information on an ongoing basis.

Anonymous Information

The anonymous information we gather is used primarily for technical, research and analytical purposes. We may use anonymous information collected from surveys to better understand your interests and needs and ultimately, provide better service to you.

When Information May be Disclosed to Outside Parties

We are obliged to keep your personal information confidential except under the following circumstances:

• When Authorized by You
• When Required by Law
• When Permitted by Law
• When Authorized by You

Terms of Service

As a client, the Terms of Service outlines the terms and conditions associated with use of our services. In general, it establishes the rights and obligations of both parties as they relate to the provision of that product or service.

With respect to the matter of privacy, the Terms of Service authorize us to use personal or business information to provide the services you have requested, to share with our businesses, affiliates and subsidiaries, and to offer additional products and services that might benefit you.

We will never sell your information to vehicle history reporting companies, and will only share data with third parties in aggregated, anonymized form, or in accordance with other sections of the Privacy Policy or Terms of Service.

When Required by Law

We will respond, as required by law, to any valid requests from Canadian authorities. In some instances, such as a legal proceeding or court order, we may also be required to disclosed information to authorities. Only the information specifically requested is disclosed and we exercise due diligence to ensure this information is requested on legitimate grounds.

When Permitted by Law

There are some situations where we are legally permitted to disclose your personal information, such as to our lawyers representing us in a legal matter, and in using reasonable and legal methods to collect a delinquent account.

With Whom We May Share Your Information

We are governed by strict standards and policies to ensure your information is secure. Client information is strictly confidential. With your consent, we will share information with our businesses, affiliates, subsidiaries, and our employees to provide services to you. As well, we may from time to time contract outside service suppliers for certain tasks, in which we will share your information for market research, information technology, or data processing. Unless you authorize us to release it, or release is required by law, we never sell, lease or trade information about you to other parties.

adasThink’s Businesses, Affiliates, Subsidiaries, and Employees

Access to private, sensitive and confidential information is restricted to authorized personnel who have a legitimate busines purpose and reason for accessing it. For example, when you call us, or e-mail us, our designated employees will access your information to verify that you are the account holder and assist you in your requests.

As a condition of their employment, all of our employees are required to abide by the privacy standards we have established. Employees are well informed about the importance of privacy and they are required to sign a confidentiality agreement that prohibits the disclosure of any client information to unauthorized individuals or parties.

Outside Service Suppliers

We will sometimes contract outside organizations to perform specialized services such as market research, information technology, or data processing. When we contract suppliers, they are only given the necessary information and prohibited from storing, analyzing or using that information for purposes other than to carry out the service for which they have been hired. They are also under a strict contractual obligation to protect the privacy of your information.

Retention of Personal Information

If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client, customer, member has a reasonable opportunity to request access to it.
We will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Accuracy

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

Clients may request correction to their personal information for 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.

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 clients’ correction request in the file.

Safeguards

Use of Safeguards

We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. We have implemented these security measures so that client personal information is appropriately protected:

• Physically securing offices where personal information is held;
• The use of user IDs, passwords, encryption, or firewalls;
• Contractually requiring any service providers to sign confidentiality agreements and provide comparable security measures; and
• Employees are required to sign a confidentiality agreement binding them to maintaining the confidentiality of all personal information to which they have access.

We will use appropriate security measures when destroying client’s personal information such as shredding documents and deleting electronically stored information. We will continually review and update our security policies and controls as technology changes regarding ongoing personal information security.

Breaches of Security Safeguards

If there is a breach of our security safeguards that leads to a loss of your personal information, and it is reasonable in the circumstances for us to believe that the breach creates a real risk of significant harm to you, we will promptly inform both you and the Office of the Privacy Commissioner (“OPC”). In determining the real risk of significant harm, we will consider:

• The sensitivity of the personal information involved in the breach;
• The probability that the personal information has been, is being or will be misused; and
• Any other prescribed factor.

Record Keeping of Breaches

We will keep and maintain a record of every breach involving personal information under our control, even if there is no obligation to report or give notice of the breach (i.e. the breach does not create a “real risk of significant harm” to an individual). We will keep those records for 24 months following the date of the breach.



Accessing and Amending Your Information

We make decisions based on the information we have. Therefore, it is important that your information is accurate and complete. As a client, you have the right to access, verify, and amend the information held by us. You may access and change any of your regular account information whenever you wish by logging into your account and editing the information. Should you identify any incorrect or out-of-date information in your file(s), we will make the proper changes and provide you with a copy of the corrected information.

If you are having troubles making changes online, please contact us by email at info@adasthink.com and one of our employees will be happy to assist.

Questions, Concerns and Complaints

If you have any questions about the Privacy Policy on this site, please send an email to info@adasthink.com

Updating this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of the Privacy Policy on our website.