Q. What is personal information?
A. Personal information is information about an identifiable individual. This includes information about your product and service subscriptions and usage.
Q. Why does TekSavvy collect information?
A. Collecting information helps us serve you better. The TekSavvy Companies collect personal information only for the following purposes:
· to establish and maintain responsible commercial relations with you and provide you with ongoing service;
· to understand your needs and eligibility for products & services;
· to recommend particular products & services to meet your needs;
· to develop, enhance, market or provide products and services;
· to manage and develop the business and operations of the TekSavvy Companies, including personnel and employment matters; and
· to meet legal and regulatory requirements.
Your personal information will not be used for any other purpose without your consent.
Q. Where does TekSavvy store personal information that it has collected?
A. Our general policy is to store personal information within Canada. However, some personal information stored in third-party systems is accessed or stored outside of Canada, particularly where the third-party provider is not Canadian. Where this occurs, it is our policy to inform you wherever possible, generally at the point at which the information is collected or used. Third-party systems for which we currently provide such notification include Zendesk, which we use for customer support; Zopim, the chat functionality built into Zendesk; and SmartFocus, which we use to handle large-scale email, track responses, and enable one-click opt-outs. All of these use servers located in the United States. Some also may use servers located in Europe.
Contractually, we require the parties to whom we transfer personal information to provide an equivalent level of protection. However, they -- both abroad, and also in Canada -- are subject to the laws of the countries in which they are located or headquartered. In the United States, this means that your information may be subject to U.S. disclosure obligations.
Q. Why do we share information among the TekSavvy Companies?
A. Sharing information among the TekSavvy Companies helps us understand your full needs and serve you better. Such sharing helps us identify your information, communication, and entertainment needs, and provide you with relevant information, advice, products and services. In some cases, certain products and service are available only from some of the TekSavvy Companies and not others. Therefore, in such cases, the sharing of information may also be necessary for the provision of certain bundles of products and/or services. Should you identify incorrect or outdated information to us, we will make the necessary changes promptly.
Q. Can I withdraw my consent to the sharing of information among the TekSavvy Companies when such sharing is for the purpose of promoting products and services?
A. You may decide that you prefer us not to share your personal information among the TekSavvy Companies to promote products and services. If this is the case, you may advise us by calling us at 1.877.779.1575 in English or 1.800.368.6909 in French.
Q. Do you share personal information with any other parties, and if so, who?
A. We understand “personal information” broadly: customer name & address, payment information, and account activity like volume of data transferred, to be sure; but also identifiers like IP addresses, MAC addresses, and anything else that, when added to what many third parties already know, could identify you personally.
We do not share personal information with anyone outside the TekSavvy Companies where we can avoid it. However, there are contractual, court-ordered, and emergency circumstances when we have to do so. When we do, we limit it to the information required in the circumstances, inform you where allowed, provide it only for the purpose stipulated, and make it subject to strict terms of confidentiality. Contractually, we require the parties to whom we transfer personal information to provide an equivalent level of protection; we require their employees of the companies to adhere to our privacy standards. When a court orders us to provide personal information, we tell you about it unless we have been ordered by law not to, and we follow up regularly to question whether non-disclosure orders ought to remain in force.
Third parties to whom we provide personal information, and are held to the above standards, include:
· Service providers acting on behalf of a TekSavvy Company. This, notably, includes wholesale network access providers. But it may also include other service providers: those hired to perform installation or maintenance on our behalf; a collection agency, for the express purpose of collecting past due bills; an emergency services provider (9-1-1); and providers of certain software we use (customer support, via Zendesk; customer chat, via Zopim; and SmartFocus, which we use to handle large-scale email, track responses, and enables one-click opt-outs).
· Other communications service providers, to offer efficient and effective communications services. For instance, we participate in CRTC-mandated number portability and other activities which require providing clearly-identified information elements to your new provider.
· Where required by law, such as by court order or warrant; in exigent circumstances, where the law would have required it were there time; and for internal security matters. These have almost always been law enforcement or emergency services, but from time to time, third parties have gone to court to seek pre-trial “Norwich Orders” compelling us to provide information in our possession. Where they have, we have always insisted on providing our end-users with as much notice as is feasible in order to give them the opportunity to oppose such motions.
Third parties to whom we may have to provide personal information include:
· An agent acting on behalf any one of the TekSavvy Companies, such as an entity hired to perform installation or maintenance on our behalf;
· Another communications service provider, in order to offer efficient and effective communications services (e.g., to provide dialup Internet services while outside our coverage area for Internet services);
· A collection agency, for the express purpose of the collection of past due bills;
· Law enforcement agencies, in emergencies, for internal security matters, or where required by court order or search warrant; and
· Emergency services, in emergency situations.
Q. How do the TekSavvy Companies safeguard personal information?
A. We take all of the necessary precautions to ensure the safeguarding of your information, whether it is stored electronically or in paper format. In all cases, information is retained in secure facilities, protected from unauthorized access and kept only as long as is reasonably required. For example, our electronic files are backed up for redundancy, password protected and accessible only by authorized employees, on a need-to-know basis.
Q. How long does TekSavvy store IP address log information?
A. Log information remains within the database system for 30 days after a session is terminated. We have no purpose for that information beyond that point, so it is automatically deleted, on a rolling basis. However, end-users have the ability to maintain a single session indefinitely through persistent use. IP address log information is only deleted 30 days after the session has ended, whether through inactivity, the most common reason a session ends; a modem power-cycle; or some other external event.
In isolated cases, we are required to extract certain information from that system in order to preserve it for longer than 30 days. Occasionally we are required to do this by a court order in a criminal matter: see our transparency reporting and our Law Enforcement Guide for more details.
The most common reason for a mandated longer preservation period is to comply with the Copyright Act. Since January 2, 2015, we have been required to forward notices of claimed copyright infringement to the account information that matches the IP address and timestamp indicated on the notice. When we do so, we are also required to retain that IP-address-to-account correlation information, and the associated accountholder’s identity, for six months. If the copyright owner who sent the notice commences court proceedings, we may be required to retain it for more than six months.
Q. What are "cookies" and do the TekSavvy Companies use them?
Q. Do you route personal information through another country, even where it is destined to a Canadian endpoint?
A. Yes. We place a special emphasis on preferring in-country interconnection for domestic traffic. We route domestically wherever possible, are very active in major Canadian Internet exchange point communities (including TORIX and QIX), peer wherever feasible, and do what we can to keep data within Canada. In fact, we are very active on this front. We peer openly with Canadian peers, and conditionally with international peers. At the same time, the United States has always been the major Internet hub: part of delivering an excellent experience to our end-users is ensuring excellent connectivity to key U.S. Internet traffic exchanges, and we maintain active routes between our Canadian network and California (the San Francisco and Los Angeles regions), Seattle, New York, and Chicago. We maintain publicly-available information on our traffic routing at PeeringDB (AS5645).
Q. Do you advocate for and defend your users' privacy rights?
A. Yes. Much of this is behind the scenes, in our contract negotiations and procurement processes, where we have become well-known for always pushing for more privacy protection. However, we also show up in court where doing so is the best way to make sure our users' privacy rights can be asserted, whether on large-scale matters like the well-known Voltage case; more day-to-day matters, like defamation cases that have the appearance of being strategic lawsuits against public participation ("SLAPPs"); or regulatory proceedings, such as the CRTC.
Q. What do I do if I have further questions or concerns?
A. If you have further questions or concerns about your privacy, you can contact us at 1.877.779.1575 in English or 1.800.368.6909 in French, or by sending an email containing such a request in English or French to firstname.lastname@example.org. Our customer service representatives will assist you in this regard
You should write to:
Data Protection Office
TekSavvy Solutions Inc.
800 Richmond Street
Chatham, Ontario N7M 5J5
Please note that complaints to the Data Protection Office must be in writing and may be delivered by mail, fax, or email.
Q. Is there a further complaint procedure?
A. If the TekSavvy Data Protection Office does not resolve a privacy issue to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada through their website at website at http://www.priv.gc.ca/. or by writing to:
Privacy Commissioner of Canada
30, Victoria Street