introduction
circus strategic communications inc. believes the protection of personal information is an important priority. We are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as doing our part to inform our clients of the privacy issues surrounding online projects. The following is our privacy policy, which outlines how we will comply with PIPEDA and the ten founding principles contained in Schedule 1 of PIPEDA. This privacy policy governs wearecircus.ca.
1. accountability
circus strategic communications inc. understands it has a responsibility to protect the personal information under its control. We have implemented several personal information handling policies and procedures to ensure this protection. We will also use contractual or other means, to ensure any third party we share information with has adopted appropriate measures, or better, procedures and policies in place to handle its information protection responsibilities. To oversee compliance with PIPEDA, circus strategic communications inc. has designated Cheryl Cardon, President as its Privacy Officer. She can be contacted as follows:
- circus strategic communications inc.
- Cheryl Cardon
- 14 Wesleyan St
- Georgetown, ON
- Canada
- L7G 2E1
- (905) 873-8426
- cheryl@wearecircus.ca
Any questions, comments, requests, or complaints regarding our privacy policy, personal information handling procedures, or our compliance with PIPEDA and Schedule 1 of PIPEDA should be directed to the Privacy Officer.
2. identifying purposes
contact forms
circus strategic communications inc. collects personal information through its website contact form. Information collected from this form is used for such things as marketing, business development, and customer relationship management. Participants who fill out this form can select a checkbox to indicate that they are interested in joining our mailing list for future mailings. Individuals may choose to unsubscribe from this mailing list from an unsubscribe email link in the actual mailing or by calling or emailing circus strategic communications inc. Privacy Officer. Information that is collected is kept in electronic form on our servers. This information is only disclosed to the owners and employees of circus strategic communications inc.
cookies
As most of the online services, wearecircus.ca uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.
log file
Our web servers use log files to analyze trends, administer our site, track users’ movements on an aggregate basis, and gather broad demographic information for aggregate use. The log files include things such as Internet Protocol addresses (IP addresses), browser types and versions, Internet service providers (ISPs), referring/exit pages, platform types, date/time stamp, and number of clicks. We currently use Google Analytics as our primary statistics systems.
notice of collection
Individuals will be informed of the purpose of this information collection before or at the time we collect it. If a new purpose(s) for the information arises after it has been collected, explicit permission to use the information for the new purpose(s) will be obtained from the individuals to whom the information belongs, prior to its use.
third parties
circus strategic communications inc. does not sell its information with third parties.
3. consent
circus strategic communications inc. will obtain consent from an individual to collect, use, and/or disclose their personal information. Consent will be obtained either before or at the time of collection and in cases where a new purpose(s) has been identified after collection, consent will be obtained for the new purpose prior to use. We also recognize that the principle of obtaining consent is dependent on the level of sensitivity of the information and the reasonable expectations of the individual. Given this, circus strategic communications inc. will take reasonable efforts to consider these things, in accordance with PIPEDA whenever necessary. We will also never use deception to obtain information. Honesty is circus strategic communications inc. strongest founding principle.
withdrawing consent
Any time an individual wishes to withdraw consent they can contact circus strategic communications inc.’ Privacy Officer and the procedures and consequences of withdrawal will be explained. After such discussion and the identity of the individual and/or group has been verified, circus strategic communications inc. Privacy Officer will be more than happy to take the necessary and requested actions required to handle withdrawal of consent.
4. limiting collection
circus strategic communications inc. will only collect information for the purposes stated before or at the time of collection of that information from an individual. We will specify the amount and type of information that is being collected and limit collection to those specifications.
5. limiting use, disclosure, and retention
circus strategic communications inc. will only use and disclose personal information for the purposes stated before or at the time of collection of that information. We will specify the amount and type of information that is being collected and limit use and disclosure to those specifications.
retention
circus strategic communications inc. will retain information collected, used, and disclosed for a client project for a maximum period of two years from the latest date of either project completion, training completion, or final invoicing, unless otherwise agreed upon by circus strategic communications inc., the client, and/or the individual. Personal information collected through our online contact form becomes part of a contact list and is kept until the individual unsubscribes themselves. When personal information has been used to make a decision about a specific individual, that information will be available to the individual for a maximum of one year from the date of the decision. In the event a request for personal information has been refused, the personal information relating to that request shall be retained for a maximum of two years from the date refusal was delivered, not received. Once collected information has expired, it will be destroyed, erased, or made anonymous.
legal disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law when we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order, or legal process served on wearecircus.ca. circus strategic communications inc. does not assume nor is liable for content that is shared by non-employees across social media or other digital platforms. Therefore, circus strategic communications inc. will not be held responsible in any form of misconduct, slander, misrepresentation, or illegal actions taken by non-employees.
business transitions
In the event circus strategic communications inc. goes through a business transition, such as a merger, being acquired by another entity or selling a portion of its assets, users’ information will, in most instances, be part of the assets transferred.
6. accuracy
circus strategic communications inc. will make sure information is as accurate, complete, and up-to-date as is necessary for the purpose(s) that it was collected, used, and/or disclosed. We do not routinely update personal information that is submitted through our online forms. In the event an individual would like to add, edit, or delete their information, circus strategic communications inc. Privacy Officer would be happy to assist after verifying the individual’s identity.
7. safeguards
circus strategic communications inc. protects the personal information it collects, uses, and discloses. Physical methods of protection include office alarms and locks on appropriate cabinets and doors. Organizational methods of protection include internal policies and procedures for information use, collection and disclosure. Technical methods of protection include data encryption, firewalls and password access controls. We make our employees aware of these safeguards and take care when disposing of personal information.
8. openness
circus strategic communications inc. primary method of communication in its line of business is by digital means. Therefore its policies and procedures are primarily made available digitally, namely online via the Internet. In the event that digital access requires unreasonable effort on behalf of the individual, circus strategic communications inc. would be happy to send a package on our policies and procedures to requesting individuals, provided the cost of doing so is not prohibitively expensive. Questions, comments, and requests regarding our privacy policies and procedures can be forwarded to our Privacy Officer.
9. individual access
circus strategic communications inc. will give an individual access to their personal information upon request, provided none of the exceptions noted in Paragraph 4.9 of Schedule 1 of PIPEDA apply. We must receive a request for access to personal information in writing, as per Paragraph 8(1) of PIPEDA and we will assist anyone in doing so, if required, as per Paragraph 8(2) of PIPEDA. If an individual would like their information added to, edited, or deleted after gaining access, circus strategic communications inc. Privacy Officer will be happy to comply, if possible. circus strategic communications inc. requires verification of an individual’s identity prior to releasing any personal information. Certain circumstances may require us to refuse to provide a visitor with a copy of their information, but we will provide reasons for our refusal. For example, if you request access to your information and it contains information belonging to another individual, we will not grant permission unless both parties agree for its release.
complaints regarding access
Requests for access to information are recorded in our Information Log. If an individual feels a request for information has not been handled satisfactorily, the individual should notify circus strategic communications inc. Privacy Officer in writing by email or regular mail. Dissatisfaction will also be noted in the Information Log and the Privacy Officer will take reasonable efforts to remedy the complaint, if found justified.
10. challenging compliance
If an individual has a challenge regarding circus strategic communications inc. compliance with PIPEDA and Schedule 1 of PIPEDA, they must contact circus strategic communications inc. Privacy Officer. The complaint must contain the date, individuals involved, explicit statement of the events that occurred, and contact information for the individual submitting the complaint. The Privacy Officer will investigate the complaint to the best of their abilities and with reasonable effort. The individual filing the complaint will be notified of the actions taken to remedy the complaint. The complaint will also be noted in the Information Log. In the event an individual is dissatisfied with the remedy for the complaint they may contact the Privacy Commissioner of Canada.
11. links
The circus strategic communications inc. website may contain links to other sites. Please be aware that circus strategic communications inc. is not responsible for the privacy practices of these other sites. We recommend site visitors make themselves aware of the policies of these other sites. Our privacy statement only applies to wearecircus.ca.
12. notification of changes to our policies
circus strategic communications inc. will notify individuals of changes by updating the date on our current privacy policy and any other method deemed appropriate. As noted in section 2. Identifying Purposes, if the intended purpose for information collection changes, the individual to which the information belongs will be notified via email or other method of communication indicated at the time the information was originally collected prior to its use for the new purpose.
13. children’s privacy
The circus strategic communications inc. site does not knowingly collect children’s information nor does it target children. In the event we discover we have collected, used, or disclosed children’s information through the site we will take immediate action to discontinue such activity. circus strategic communications inc. will not be held accountable for any misconduct, misrepresentation, and or illegal action committed by any employee outside of circus strategic communications inc.
14. express consent
circus strategic communications inc. will at times collect the following information from individuals who participate in our events with partners and suppliers:
contact information may include:
- Name
- Address
- Postal Code
- Phone Number
- Email Address
customer demographics may include:
- Date of Birth/Age
15. implied consent
Due to the nature of our business at circus strategic communications inc., we cannot process some web transactions unless certain information is provided by the participant. Participants will be made aware of their option to opt-in at the time of participating. An opt-out option is provided with all marketing communication.
16. resources
Several resources were used in the creation of this privacy policy. Organization for Economic Co-operation and Development: Privacy Policy Generator, Privacy Commissioner of Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and Your Responsibilities: A Guide for Businesses and Organizations
Last updated: January 26, 2022