Privacy Policy

Contrast Web provides a full range of services to meet the web needs of consumers including digital strategy, online branding, user experience design, visual design, usability design, responsive design, client side development, server side development and online marketing services.

Contrast Web have long been committed to maintaining the accuracy, confidentiality, security and privacy of customer and employee personal information. This is reflected in existing privacy and confidentiality provisions found in various Contrast Web policies, agreements and in applicable service rules approved by regulatory agencies over the years. It is also reflected in the high regard and trust with which customers and employees view the management of personal information by Contrast Web.

In March 1996, the new Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96 (the “CSA Code”), was published as a National Standard of Canada. In November 2012, Contrast Web revised Contrast Web Privacy Policy, to describe in detail how we subscribe to the principles of the CSA Code and the requirements of the Personal Information Protection and Electronic Documents Act, which came into force in 2001.

Contrast Web's Privacy Policy is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided by Contrast Web to our customers and employees. The objective of Contrast Web Privacy Policy is responsible and transparent practices in the management of personal information, in accordance with the National Standard and federal legislation.

Contrast Web will continue to review Contrast Web Privacy Policy and privacy-related information made publicly available to make sure it is relevant and remains current with changing technologies and laws and the evolving needs of Contrast Web, our customers and employees. This version of Contrast Web Privacy Policy was updated in August 2014.


Scope and Application

The 10 principles that form the basis of Contrast Web Privacy Policy are interrelated and Contrast Web shall adhere to the 10 principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the CSA Code, the commentary in Contrast Web Privacy Policy has been tailored to reflect personal information issues specific to Contrast Web.

The scope and application of Contrast Web Privacy Policy are as follows:


Definitions

Collection - the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.

Consent - voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of Contrast Web. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

Customer - an individual who • uses, or applies to use, the products or services of a Contrast Web;

Disclosure - making personal information available to a third party.

Employee - an employee or pensioner of Contrast Web.

Personal information - information about an identifiable individual but not aggregated information that cannot be associated with a specific individual.

Third party - an individual other than the customer or his agent, or an organization other than Contrast Web or their agents.

Use - the treatment, handling, and management of personal information by Contrast Web and their agents.


Principle 1 - Accountability

Contrast Web are responsible for personal information under their control and shall designate one or more persons who are accountable for the companies’ compliance with the following principles.

1.1 Responsibility for ensuring compliance with the provisions of Contrast Web Privacy Policy rests with the senior management of Contrast Web, which shall designate one or more persons to be accountable for compliance with Contrast Web Privacy Policy. Other individuals within Contrast Web may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.

1.2 Contrast Web shall make known, upon request, the title of the person or persons designated to oversee the companies’ compliance with Contrast Web Privacy Policy.

1.3 Contrast Web are responsible for personal information in their possession or control, including information that has been transferred to a third party for processing. Contrast Web shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7).

1.4 Contrast Web have implemented policies and procedures to give effect to Contrast Web Privacy Policy, including:


Principle 2 - Identifying Purposes for Collection of Personal Information

Contrast Web shall identify the purposes for which personal information is collected at or before the time the information is collected.

2.1 Contrast Web collect personal information only for the following purposes:

Further references to “identified purposes” mean the purposes identified in this Principle 2.

2.2 Contrast Web shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Contrast Web who shall explain the purposes.

2.3 Unless required by law, Contrast Web shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer or employee.


Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

3.1 In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, Contrast Web may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.

Contrast Web may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.

Contrast Web may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.

Contrast Web may disclose personal information without knowledge or consent to a lawyer representing the companies, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.

3.2 In obtaining consent, Contrast Web shall use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer or employee.

3.3 Generally, Contrast Web shall seek consent to use and disclose personal information at the same time it collects the information. However, Contrast Web may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.

3.4 Contrast Web will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.

3.5 In determining the appropriate form of consent, Contrast Web shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees.

3.6 In general, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for Contrast Web to collect, use and disclose personal information for all identified purposes.

3.7 A customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and employees may contact Contrast Web for more information regarding the implications of withdrawing consent.


Principle 4 - Limiting Collection of Personal Information

Contrast Web shall limit the collection of personal information to that which is necessary for the purposes identified by the company. Contrast Web shall collect personal information by fair and lawful means.

4.1 Contrast Web collect personal information primarily from their customers or employees.

4.2 Contrast Web may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.


Principle 5 - Limiting Use, Disclosure and Retention of Personal Information

Contrast Web shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Contrast Web shall retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected.

5.1 In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. (see Principle 3.1)

5.2 In addition, Contrast Web may disclose a customer’s personal information to:

5.3 In some cases, personal information collected by Contrast Web may be stored or processed outside of Canada to provide you with service or to support Contrast Web operations, and may therefore be subject to the legal jurisdiction of these countries. The information is provided only after detailed contracts are set out with the companies that provide us with these services. Moreover, the information may only be used for the purposes of providing the services in question. When outsourcing certain functions, Contrast Web strive to minimize the personal information stored or processed outside of Canada. Wherever possible, Contrast Web anonymize any personal information stored or processed outside Canada, such that the data cannot be associated with identifiable individuals. (See Principle 7 Security Safeguards)

5.4 Contrast Web may disclose personal information about its employees:

5.5 Only those employees of Contrast Web who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about customers and employees.

5.6 Contrast Web shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, Contrast Web shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.

5.7 Contrast Web shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.


Principle 6 - Accuracy of Personal Information

Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

6.1 Personal information used by Contrast Web shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee.

6.2 Contrast Web shall update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual.


Principle 7 - Security Safeguards

Contrast Web shall protect personal information by security safeguards appropriate to the sensitivity of the information.

7.1 Contrast Web shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Contrast Web shall protect the information regardless of the format in which it is held.

7.2 Contrast Web shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information, the purposes for which it is to be used, limits on the number of persons whose job function requires access to the information, and the physical and procedural security measures required to safeguard that information.

7.3 All employees of Contrast Web with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.


Principle 8 - Openness Concerning Policies and Practices

Contrast Web shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.

8.1 Contrast Web shall make information about its policies and practices easy to understand, including:

8.2 Contrast Web shall make available information to help customers and employees exercise choices regarding the use of their personal information and the privacy-enhancing services available from the company.


Principle 9 - Customer and Employee Access to Personal Information

Contrast Web shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

9.1 Upon request, Contrast Web shall afford to a customer or an employee a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in understandable form within a reasonable time and at minimal or no cost to the individual.

9.2 In certain situations, Contrast Web may not be able to provide access to all of the personal information that they hold about a customer or employee. For example, Contrast Web may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Contrast Web may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, Contrast Web shall provide the reasons for denying access upon request.

9.3 Upon request, Contrast Web shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Contrast Web shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.

9.4 In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit Contrast Web to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

9.5 Contrast Web shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Contrast Web shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

9.6 A customer can obtain information or seek access to his or her individual file by contacting a designated representative at one of Contrast Web’ business offices.

9.7 An employee can obtain information or seek access to his or her individual file by contacting his or her immediate supervisor within the applicable Contrast Web company.


Principle 10 - Challenging Compliance

A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of Contrast Web with Contrast Web Privacy Policy.

10.1 Contrast Web shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and employees about the companies’ handling of personal information.

10.2 Contrast Web shall inform their customers and employees about the existence of these procedures as well as the availability of complaint procedures (see "How to Contact Us" below).

10.3 The person or persons accountable for compliance with Contrast Web Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4 Contrast Web shall investigate all complaints concerning compliance with Contrast Web Privacy Policy. If a complaint is found to be justified, the company shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.


Questions or concerns about your privacy?

For more information on Contrast Web’ commitment to privacy, contact any of Contrast Web at the number shown on your bill.

If you have questions or concerns about your privacy, feel free to contact us and our customer service representatives will be delighted to speak to help you.

If you have questions or concerns about your privacy, feel free to contact us and our customer service representatives will be delighted to speak to help you.

Contrast Web Inc.
16 Westminster Ave N. Suite 304B
Montreal-Ouest, QC, Canada, H4X 1Z1

For copies of the CSA Model Code for the Protection of Personal Information contact:

Canadian Standards Association
5060 Spectrum Way, Suite 100
Mississauga, Ontario L4W 5N6
www.csa.ca

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