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CoopMembers.com
Privacy Policy

COOPMEMBERS.COM

CONFIDENTIALITY AND PRIVACY POLICY

I. INTRODUCTION

CoopMembers.com (“CoopMembers.com”) is committed to protecting and maintaining the privacy of our customer’s confidential information. In the course of delivering our goods and services to our customers CoopMembers.com, often has access to, or comes into possession of, our customer’s information. It is of paramount importance to CoopMembers.com that such information remains confidential. This is a responsibility that CoopMembers.com takes seriously.

CoopMembers.com is also committed to ensure that it complies with all its legal obligations with respect to the privacy of confidential information whether it belongs to customers or non-customers. CoopMembers.com is committed to ensuring compliance with the Personal Information Protection and Electronic Documents Act (Canada) and any similar provincial privacy legislation.

II. SCOPE

This policy applies to all officers, employees, agents and subcontractors of CoopMembers.com in relation to any confidential customer information or personal information obtained by CoopMembers.com whether from an individual, corporation, partnership, association or other entity.

In this policy, “Confidential Information” means any and all confidential, private or secret information of a person in all forms however stored or expressed but does not include information that is in the public domain, or subsequently becomes part of the public domain not due to any act or omission of CoopMembers.com. It includes personal information about an identifiable individual, but does not include the name, title, or business address or telephone number of an employee of an organization.

III. CUSTOMER INFORMATION CONFIDENTIALITY RULES

In order to ensure the protection of Confidential Information, CoopMembers.com has adopted the rules of customer confidentiality set out below. Where the confidentiality rules speak about “CoopMembers.com”, “you”, “us” or “we”, this means each and every agent, officer, employee and subcontractor of CoopMembers.com. The following rules are always subject to any rules of confidentiality imposed by statute or contract. Where there is a conflict or inconsistency between these general rules and any statutory or contractual obligation, CoopMembers.com shall abide by and adhere to the most onerous or strict rule.

All persons engaged in the business and affairs of CoopMembers.com must strictly adhere to the following confidentiality rules (the “Confidentiality Rules”):

 

1. Duty of Confidentiality

(a) You shall, at all times, hold in strict confidence all confidential information concerning the business and affairs of our customers (i.e. Customer Information) acquired in the course of CoopMembers.com’s professional relationship with customers, regardless of the nature or source of the information or of the fact that others may share the knowledge.
(b) You shall not divulge any information concerning the business or affairs of our customers unless disclosure is expressly or impliedly authorized by the customer, or is required by law or by a court.
(c) You shall take all reasonable steps to ensure the privacy and safekeeping of Customer Information.
(d) You shall preserve the secrecy of Customer Information even after the termination of the customer’s relationship of CoopMembers.com, whether or not differences have arisen between CoopMembers.com and the customer.

2. Confidential Information Not to be Used

(a) You shall not use any Customer Information for the benefit of any person (including yourself), or to the disadvantage of the customer.

(b) You shall at all times avoid indiscreet conversations or gossip, and shall not repeat gossip or information, about a customer's affairs, even though the customer is not named or otherwise identified.

3. Disclosure Authorized by Customer

(a) CoopMembers.com may, with the express or implied authority of the customer, disclose a customer’s confidential information.

(b) Unless the customer directs otherwise, you may disclose the Customer Information to other CoopMembers.com staff to the extent necessary to carry out the service to be supplied to the customer.

4. Disclosure to Prevent a Crime

(a) Where necessary, CoopMembers.com may disclose Customer Information if there is reasonable grounds to believe that the disclosure is necessary to prevent a crime.

5. Disclosure Required by Law

(a) If you are required by law or by order of a court to disclose Customer Information you shall immediately advise CoopMembers.com Compliance Officer of such requirement.

(b) If you are required by law or by order of a court to disclose Customer Information you shall not divulge more information than is necessary.

6. Disclosure to Collect Fees

(a) CoopMembers.com may disclose Customer Information where necessary to establish or collect its invoices for good services supplied by CoopMembers.com to the customer, but shall not divulge more information that is necessary to do so.

7. Confidentiality and the Internet

(a) When using electronic means to communicate in confidence with a customer or to transmit confidential messages regarding a customer:

(i) you shall use appropriate technical means minimize the risks of such communications being disclosed, discovered or intercepted, including, where appropriate, encryption software;

(ii) you shall maintain such practices as offer reasonable protection against inadvertent discovery or disclosure of electronically transmitted confidential messages.


III. PERSONAL INFORMATION – GENERAL PRIVACY PRINCIPLES

The Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) sets out ten (10) personal information protection principles. These principles generally apply to Personal Information collected by CoopMembers.com about an individual.

Personal Information - Ten (10) Privacy Principles:

The following principles MAY NOT apply to Customer Information which shall be subject always to the stricter duty of confidentiality set out above.

The following ten (10) interrelated principles form the basis of this Policy as it relates to the protection of Personal Information under PIPEDA.

1. Accountability

We are responsible for Personal Information under our control, whether such Personal Information is Customer Information or otherwise. CoopMembers.com will use contractual or other means to provide a comparable level of protection while information is being processed by a third party.

2. Identifying Purposes

Where possible, the purposes for which Personal Information is collected shall be identified and documented when or before the information is collected.

3. Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in specific circumstances. We may collect the Personal Information of individuals without their knowledge or consent if:
(a) the information is publicly available and specified in the regulations promulgated under PIPEDA;

(b) the collection is clearly in the interest of the individual and consent cannot be obtained in a timely way;

(c) the information is disclosed to CoopMembers.com by a customer in the course of CoopMembers.com’s professional relationship with the customer; or

(d) the individual’s knowledge or consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of law.

CoopMembers.com may be required to collect, use, or disclose Personal Information without an individual’s consent for certain purposes, including the collection of overdue accounts owed to CoopMembers.com or a customer.

4. Limiting Collection

We shall limit our collection of Personal Information to that which is necessary for the purposes we have identified. We shall always use fair and lawful means to collect Personal Information.

5. Limiting Use, Disclosure, and Retention

Except as follows, we shall not use or disclose Personal Information for purposes other than those for which it was collected, without the consent of the individual. We may, without the knowledge or consent of an individual, use the individual’s Personal Information if:

(a) we have reasonable grounds to believe that the information could be used in the investigation of a contravention of law and the information is used for that purpose;

(b) the information is used for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual; or

(c) CoopMembers.com collected the information pursuant to the exceptions listed under Principle 3 above.
Any new purpose for using Personal Information should be documented.

We may disclose Personal Information, without the knowledge or consent of the individual, if the disclosure is:

(a) made to, in the Province of Quebec, an advocate or notary or, in any other province, a barrister or solicitor that acts for CoopMembers.com or a customer of CoopMembers.com;

(b) for the purposes of collecting a debt owed by the individual to CoopMembers.com;

(c) required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records;

(d) made to a government institution or part of a government institution that has made a request for the information and identified its lawful authority to obtain the information;

(e) requested for the purpose of enforcing any law of Canada, a province or a foreign jurisdiction, carrying out an investigation relating to the enforcement of any such law or gathering intelligence for the purpose of enforcing any such law;

(f) requested for the purpose of administering any law of Canada or a province;

(g) made on to an investigative body, a government institution or a part of a government institution and the organization;

(h) made to a person who needs the information because of an emergency that threatens the life, health or security of an individual and, if the individual whom the information is about is alive, CoopMembers.com informs that individual in writing without delay of the disclosure;

(i) for statistical, or scholarly study or research, purposes that cannot be achieved without disclosing the information, it is impracticable to obtain consent and we inform the federal Privacy Commissioner of the disclosure before the information is disclosed;

(j) made to an institution whose functions include the conservation of records of historic or archival importance, and the disclosure is made for the purpose of such conservation;

(k) made after the earlier of:

(i) one (100) hundred years after the record containing the information was created, and

(ii) twenty years after the death of the individual whom the information is about;

(n) information that is publicly available and is specified by the regulations promulgated under PIPEDA; or

(o) required by law.

We shall retain Personal Information only as long as necessary for the fulfilment of identified purposes or as may be required by law.

6. Accuracy

We shall endeavour to ensure that all Personal Information retained by CoopMembers.com is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. The extent to which personal information shall be accurate, complete, and up-to-date will depend upon the use of the information. Information shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an individual. CoopMembers.com endeavours to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any unauthorized access, disclosure, copying, use, or modification.

7. Safeguards

We shall protect Personal Information by using security safeguards appropriate to the sensitivity of the information. The security safeguards must protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. CoopMembers.com shall protect Personal Information regardless of the format in which it is held. CoopMembers.com shall periodically remind its lawyers and staff of the importance of maintaining the privacy of Personal Information.

8. Openness

We shall make this Policy readily available to customers and to any individuals about whom CoopMembers.com has personal information.

9. Individual Access

Upon written request, an individual shall be informed of the existence, use, and disclosure of their Personal Information by CoopMembers.com, and shall be given access to that information. An individual is entitled to question the accuracy and completeness of his or her Personal Information and have it amended as appropriate. Any refusal of access shall be accompanied by the reason for refusal. An individual’s request shall be refused if compliance would likely reveal Confidential Information about a customer or other third party or could reveal confidential commercial information.

10. Compliance

In order to ensure compliance with this Policy, CoopMembers.com shall appoint a compliance officer who will have responsibility for supervising compliance with this Policy.

Any questions regarding this Policy or the handling of any confidential or personal information by CoopMembers.com may be addressed to the compliance officer at the following address: