privacy policy
Confidentially yours...
OUR COMMITMENT
VaDa Inc. and all subsidiaries and affiliates (collectively referred to as “VaDa”) has a definite and ongoing commitment to protecting your privacy. The privacy and security of our employees’ and customers’ personal information (information that can identify you as an individual) is understood and respected by VaDa.
This Privacy Policy describes the commitments of VaDa and the rights of our Customers regarding personal information. It complies fully with the Personal Information Protection and Electronic Documents Act (the “Act”) and is based on the Canadian Standards Association Model Code for the Protection of Personal Information.
The Privacy Policy applies to the collection, storage, use, disclosure, protection, and accuracy of Personal Information collected and controlled by VaDa.
Definitions:
Collect - to gather, acquire, or obtain Personal Information from any source, including third parties.
Consent - voluntary agreement with what is being done or proposed. Consent can either be express or implied. Express consent is given explicitly, either orally or in writing. Implied consent may reasonably be inferred from the action or inaction of the Customer.
Direct marketing - direct communications targeted to Customers, including mail, telemarketing, fax or electronic mail.
Personal Information - information about an identifiable Customer recorded in any form.
Supplier - a company under contract to provide services, data collection, or processing services to VaDa.
SUMMARY OF PRINCIPLES
PRINCIPLE 1: Accountability
VaDa is responsible for the Personal Information under its control, including Personal Information disclosed by VaDa to a third party for data and list processing and shall designate one or more persons who are accountable for compliance with the Privacy Policy.
1.1 The Executive Management is accountable for VaDa’s compliance with the Privacy Policy.
1.2 VaDa has appointed an internal Chief Privacy Officer and this person oversees VaDa’s compliance with the Privacy Policy.
E-mail the Chief Privacy Officer.
1.3 VaDa uses legal agreements to provide a comparable level of protection for Personal Information while the information is being processed by an authorized third party.
1.4 The Management of VaDa has developed procedures to implement the Privacy Policy, such as the following:
- Procedures to protect Personal Information;
- Procedures to receive and respond to complaints and enquiries;
- Procedures to inform and train our employees on privacy policies and procedures; and,
- Making available information about the Privacy Policy to Customers.
PRINCIPLE 2: Identifying Purposes
VaDa shall identify the purposes for which Personal Information is collected at or before the time the information is collected.
2.1 VaDa provides Customers with information that explains why the Personal Information is needed and how the Personal Information will be used or disclosed.
2.2 VaDa obtains consent of Customers before using Personal Information for a purpose that has not been specified, unless the new purpose is required by law.
2.3 VaDa collects Personal Information for the following purposes:
- to communicate information and offers to Customers;
- to understand and analyze Customer sales, needs and preferences;
- to develop, enhance, market and provide products and services to meet Customer’s needs;
- to enable Customers to participate in promotions and contests;
- to enable Customers to participate in Customer research or focus groups;
- to process exchanges or product returns;
- improve our stores; and
- to respond to requests or complaints.
2.4 Customers can opt out of receiving direct marketing and promotional communications in electronic, printed or verbal format by writing to:
Chief Privacy Officer
VaDa Inc.
870, 736-8th Avenue SW
Calgary, AB T2P 1H4
PRINCIPLE 3: Consent
Every reasonable effort is made by VaDa to ensure that the Customer understands the purpose of the Personal Information. A Customer’s consent is obtained as required for the collection, use or disclosure of his or her Personal Information, except where it is inappropriate to do so.
3.1 VaDa obtains consent for the collection, use or disclosure of Personal Information. This consent is usually obtained verbally, or written registration form or on electronic enrollment forms, survey forms and/or during telephone conversations with Customers.
3.2 Consent to provide Personal Information is not a condition for VaDa selling a product to Customers, unless the information requested is required to fulfill an explicitly specified and legitimate purpose.
3.3 A Customer may withdraw their consent at any time per section 2.4 above and VaDa makes them aware of the implications of their withdrawal.
PRINCIPLE 4: Limiting Collection
VaDa limits the amount and type of information it collects to what is necessary for the identified purposes.
4.1 VaDa does not collect Personal Information indiscriminately. The amount and type of Personal Information collected are limited to that which is necessary to fulfill the purposes identified.
4.2 Although the kind of Personal Information depends largely on the specific purpose, VaDa may typically collect the following Personal Information from its Customers:
- Name;
- address;
- phone number;
- date of birth;
- e-mail address;
- credit card number;
- gender;
- language preference; and
- merchandise category preferences.
4.3 VaDa may collect Personal Information from the Customer:
- in-store;
- through online and electronic sales transactions with VaDa;
- through interaction with our Customer Service Representative;
- through telephone, paper and online surveys and contests;
- through exchange and refunds of product transactions;
- through mail or phone orders.
PRINCIPLE 5: Limit Use, Disclosure and Retention
VaDa does not use or disclose Personal Information for purposes other than those for which it is collected, except with the consent of the Customer or the use or disclosure is authorized by the Act or as required by law. VaDa only keeps Personal Information for as long as is necessary to satisfy those purposes.
5.1 VaDa does not give, rent or sell Customer lists to any organization or individual other than the business units of VaDa, agents, and companies contracted to process and manage Customer transactions, analyze data, handle direct mailings or telemarketing, or arrange Customer research and focus groups.
5.2 As VaDa develops its business, it might sell or buy stores or assets. In such transactions, Personal Information may be one of the transferred business assets. Also, in the event that VaDa or substantially all of its assets are acquired, Personal Information will be one of the transferred assets.
5.3 VaDa retains Personal Information in accordance with guidelines and procedures established by VaDa. The Personal Information is collected and retained for as long as is necessary to satisfy identified purposes.
VaDa has procedures to govern the destruction of Personal Information that is no longer required to fulfill the identified purposes.
PRINCIPLE 6: Accuracy
VaDa keeps Personal Information as accurate, complete and up-to-date as necessary, taking into account its use and the interests of the Customer.
6.1 VaDa updates Personal Information as it is made available by Customers.
6.2 Customers are responsible for informing VaDa about changes to their Personal Information, as appropriate.
6.3 VaDa does not normally update Personal Information unless such a process is necessary to fulfill the purposes for which the Personal Information is collected.
PRINCIPLE 7: Use of Safeguards
VaDa protects Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held.
7.1 The methods of protection for Personal Information, depending on the type of personal information, include:
- physical measures, for example: locked filing cabinets, restriction of access to offices, and company alarm systems.
- technical tools, for example: passwords and encryption, using PGP encryption software.
- organizational controls, for example: confidentiality agreements, limiting access on a “need-to-know” basis, staff training and security clearances.
7.2 When VaDa uses a third party to process information on its behalf, legal agreements require the third party to protect the privacy and confidentiality of the Personal Information. Further, these agreements ensure that the Personal Information is retained only as long as necessary to complete the assigned task and that the third-party organization only uses it for the specified purposes for which it is given.
7.3 VaDa has appropriate training programs and provides employees with information about its policies and procedures for protecting Customers’ Personal Information and the importance of maintaining the confidentiality of Personal Information.
7.4 Personal Information is disposed of or destroyed with care to prevent unauthorized parties from gaining access to the information.
PRINCIPLE 8: Openness
VaDa makes specific information about its policies and practices relating to the management of Personal Information readily available to its Customers.
8.1 VaDa is open about its policies and practices with respect to the management of Personal Information.
8.2 VaDa makes information about its privacy policies and practices available to its Customers through written materials (a copy of this Policy is available upon request) and its Web Site, www.vadaworld.com.
PRINCIPLE 9: Individual Access
Upon request, VaDa gives Customers access to their Personal Information and an account of its use and disclosure.
9.1 All Customer requests for access to Personal Information held by VaDa must be in writing and directed to: Chief Privacy Officer, VaDa Inc., 870, 736-8th Avenue SW, Calgary, AB T2P 1H4.
Upon request, VaDa informs the Customer whether or not it holds Personal Information about that Customer, and discloses details of that Customer’s Personal Information, including, where available, the source, its use, and third parties to which it has been disclosed.
9.2 VaDa may request sufficient information from the Customer including adequate identification to verify the identity of the Customer when requesting the existence, use and/or disclosure of Personal Information held by VaDa. VaDa will assist any Customer who informs VaDa that he or she needs assistance in preparing a request for access.
9.3 VaDa responds to a request for information within thirty (30) business days of receipt of request.
9.4 Responding to a Customer request for information will usually be done at no or minimal cost to the Customer. However, a fee for reasonable costs incurred may be charged in responding to more complex requests, provided the Customer is informed of the fee in advance. The Personal Information requested is provided to the Customer in a form that is generally understandable.
9.5 VaDa amends the Personal Information contained in VaDa Customer data bases or elsewhere, as required, when an individual successfully demonstrates the inaccuracy or incompleteness of the Personal Information. An amendment may involve the correction, deletion or addition of information. However VaDa is unable to amend purchase information or return transaction information.
9.6 When it is not possible to provide a list of third parties or agents to which VaDa has disclosed Personal Information about a Customer, VaDa provides a list of the third parties or agents to which it may have disclosed such Personal Information about the Customer.
9.7 A Customer has the opportunity to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate. When a challenge is not resolved to the satisfaction of the Customer, VaDa will keep a written record of the challenge, and the existence of the challenge is transmitted to third parties as appropriate.
9.8 If VaDa is unable to provide access to all the Personal Information it holds about a Customer, the reasons for denying access are provided to the Customer.
PRINCIPLE 10: Challenging Compliance
A Customer is able to address a challenge concerning VaDa’s compliance with the above principles with the individual identified in Section 1.2.
10.1 VaDa has procedures in place to receive and respond to inquiries about VaDa’s policies and practices relating to its handling of Personal Information.
10.2 VaDa investigates all complaints and responds within ninety (90) business days after receipt of written correspondence. If the complaint is found to be justified, VaDa takes appropriate measures to resolve the complaint, including, if necessary, amending its policies and practices.