Privacy and Security

GreenSaver Privacy
Policy Statement 
Effective Date: 2012-01-01
Version: 3.0

 

1. Accountability
2. Identifying Purposes
3. Consent, Limiting Use, Disclosure and Retention
4. Limiting Collection
5. Limiting Use, Disclosure and Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance

Preface
GreenSaver is committed to protecting the personal information in its custody or control in accordance with applicable privacy laws, such as the Personal Information Protection and Electronic Documents Act (Canada)(PIPEDA) and the Municipal Freedom of Information and Protection of Privacy Act (Ontario) (MFIPPA).

Contents
This Privacy Policy addresses personal information about customers or members of the public and how GreenSaver collects, uses, discloses, handles and protects the privacy of such personal information. It addresses the reasons why such information is collected, used, or disclosed, how the information is safeguarded, and outlines the individuals’ rights in respect of this information. This Privacy Policy incorporates principles for the protection of personal information, as established by the Canadian Standards Association (CSA) and as adopted and amended by PIPEDA. This Privacy Policy gives details with respect to your use of GreenSaver’s Website.
For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual, but does not include an individual’s business contact information or work product. Personal information does not include information that has been aggregated or de-identified, such that an individual’s information cannot be identified.
In this Privacy Policy, “GreenSaver”, “we”, “us” or “our” means Urban Environment Centre and its wholly owned subsidiaries, including House Masters Limited, and “customer”, “you”, and “your” means an individual customer, prospective customer, or other individual member of the public whose personal information is in our custody or control. This Privacy Policy does not apply to information about businesses, it applies to individuals only. GreenSaver does, however, protect the confidentiality of business customer information in accordance with applicable law, including regulatory codes of conduct issued by the Ontario Energy Board, and contractual arrangements. By accepting service from us, visiting or using our Website, or otherwise providing us with your personal information after having been given notice of this Policy, you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time. We will endeavour to bring any policy changes to your attention, but you should periodically review the Policy for changes on our Website.

1. Accountability

GreenSaver is accountable for the protection of personal information within its custody or control, including any personal information that GreenSaver has transferred to a third party for processing purposes. GreenSaver may engage third parties from time to time to perform services for GreenSaver that involve access to personal information. GreenSaver shall use contractual or other means to provide a comparable level of protection of this information while the information is being processed by such third parties.
GreenSaver’s CEO as the Chief Privacy Officer is accountable for GreenSaver’s compliance with this Privacy Policy. The Chief Privacy Officer may be contacted at:

74 Six Point Road
Toronto, Ontario
M8Z 2X2
Tel: 416.203.3106
Fax: 416.203.3121

 

2. Identifying Purposes

GreenSaver will identify the purposes for which it collects personal information at or before the time the information is collected, such as when you apply for service from us (for example, purposes may be identified on GreenSaver forms or by reference to this Policy). GreenSaver collects, uses and discloses personal information as authorized or required by applicable law (including PIPEDA and MFIPPA) and for purposes such as:

  • To authenticate identity;
  • To contact customers (at mailing and/or service address), respond to customer inquiries or service issues, and to otherwise maintain business relations with customers;
  • To monitor and assess quality of service (for example, GreenSaver may monitor and/or record telephone communication with you for quality assurance and training purposes);
  • To bill and collect payment and maintain records of same (including arrangements for pre-authorized payments through bank account or credit card);
  • To determine account eligibility and creditworthiness (for example, through employment and reference checks);
  • To provide information to third party service providers
  • To assist GreenSaver with legal matters or proceedings, including preparation for same;
  • To request customer or public participation in surveys, contests or other similar activities and initiatives;
  • To notify customers or members of the public about events, causes or programs sponsored by GreenSaver and to keep track of participation levels and interest in such events;
  • To provide individuals with information they have requested, such as financial quarterly reports or news releases;
  • To prepare financial records for GreenSaver; and
  • To meet other legal and regulatory authorizations and requirements.

The above collections, uses and disclosures, which are not exhaustive, are a necessary part of your relationship with GreenSaver.

3. Consent, Limiting Use, Disclosure and Retention

GreenSaver will obtain your consent before, or when, it collects, uses or discloses your personal information, except where collection, use or disclosure is authorized or required by law. For example, by accepting services from us, your consent to the collection, use and disclosure of your personal information for the purposes of providing you with such services is implied.
Consent may be provided orally, in writing, electronically, or implied (such as when you fail to notify GreenSaver that you do not consent to collection/use/disclosure for certain purposes after you have received notice of those purposes, for example, through this Policy) or otherwise.
Consent may be obtained directly from you or from a third party that has obtained your consent to disclose your personal information to GreenSaver. Consent may also be given by an authorized representative such as a legal guardian or person with power of attorney.
Subject to certain legal and contractual restrictions and reasonable notice, you can refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time. However, refusal to provide such consent, or withdrawal of such consent, may prevent us from providing you with certain products or services for which information is necessary.
In certain circumstances under the laws of Canada and Ontario, GreenSaver may have a duty or right to collect, use or disclose your personal information without your knowledge or consent.

4. Limiting Collection

GreenSaver will not collect personal information indiscriminately and will limit collection of personal information to that which is reasonable and necessary for the purposes outlined above or as otherwise consented to by you, and as authorized or required by applicable law.

5. Limiting Use, Disclosure and Retention

GreenSaver will use and disclose personal information as reasonable and necessary for the purposes outlined above as otherwise consented to by you, and as authorized or required by applicable law.
For example, MFIPPA lists general categories of circumstances where the use and disclosure of personal information is permitted by law under sections 31 and 32 of that statute.
GreenSaver will retain personal information only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. GreenSaver will not trade, rent or sell your personal information. However, in the course of a business transaction, such as a proposed sale of GreenSaver’s business or assets (or a part thereof), or a merger or amalgamation of GreenSaver with another company, we may disclose (with appropriate safeguards) your personal information to third parties such as prospective purchasers of GreenSaver, business or assets, and to their lawyers, accountants, financial advisors, agents and other representatives as necessary for the purposes of such transaction.

6. Accuracy

GreenSaver maintains procedures to ensure personal information we collect, use and disclose is kept as accurate, complete and up-to-date as necessary for the purpose for which it is to be used. However, we rely on you to disclose all material information to us and to inform us of any errors or changes in such information.
Individuals may challenge the accuracy and completeness of personal information about them and have it amended or annotated, as appropriate, as set out in Section 9 below.

7. Safeguards

In fulfilling its responsibilities with respect to the confidentiality of personal information, GreenSaver will employ a number of safeguards, appropriate to the sensitivity of the specific information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, such as locked filing cabinets, restricted access to offices, security clearances, limiting access on a “need to know” basis, use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and relevant third parties to ensure compliance. It is also important for you to take precautions to protect your personal information such as keeping your user name and passwords confidential.

8. Openness

This Privacy Policy is effective as of the Effective Date set forth at the beginning of this Privacy Policy. GreenSaver will from time to time review and revise its Privacy Policy and will endeavour to bring such revisions to the attention of its customers and the public by such means as GreenSaver’s Website and bill inserts.

9. Individual Access

Upon request and with satisfactory proof of the customer’s identity, any customer of GreenSaver may obtain information regarding the type, use and disclosure, of his, or her, personal information that GreenSaver has in its custody or control. Any customer may request that his, or her, personal information be amended for purposes of accuracy and completeness. Where a disagreement regarding the accuracy of a customer’s information cannot be resolved, GreenSaver will annotate the information to reflect the disagreement. GreenSaver may require the customer to provide access or correction requests in writing. We may also charge a nominal fee for responding to such requests, and, if so, will advise you in advance of such costs. This right of access, however, is not absolute. For instance, GreenSaver may refuse to provide you with access to your personal information where such refusal is authorized or required by law or regulatory authorities.
Customers can make their requests by contacting GreenSaver by telephone at 416-203-3106, by fax to 416-203-3121, by online form at www.greensaver.org/contact or in writing to GreenSaver, 74 Six PointRoad, Toronto, Ontario M8Z 2X2, and our Client SupportRepresentatives will assist you. Response to a customer’s request will be made within a reasonable time provided the request is made in writing and the customer provides satisfactory proof of the customer’s identity.

10. Challenging Compliance

Any customer of GreenSaver may challenge GreenSaver’s compliance with this Privacy Policy in respect of your personal information by contacting GreenSaver’s Chief Privacy Officer, in writing, at the address set forth in Section 1.
If the Chief Privacy Officer does not resolve the issue to the customer’s satisfaction, the customer may contact the Privacy Commissioner of Ontario.

11. GreenSaver Website

(a) Visiting the GreenSaver Website
GreenSaver may collect Personal Information that you voluntarily provide to us when you visit our Website. Personal Information provided by visitors to GreenSaver’s Website will be collected, used and disclosed in the same manner as information collected by other means, and in a manner consistent with this Privacy Policy. Since this Privacy Policy may be amended from time to time, we recommend that you check the latest version of our Privacy Policy each time you visit our Website.

(b) Security
Personal information submitted through GreenSaver’s Website will be encrypted using a minimum 128 bit encryption with 1024 bit public key technology to help protect and enable its arrival in an unread and unaltered state to GreenSaver’s technology infrastructure. However, users should be aware that personal information could be intercepted over the Internet. GreenSaver is not responsible for the interception, collection, use or alteration of information transmitted over the Internet, such as by email.

(c) Automatic Data Collection
As is the case with Websites generally, when visitors access the GreenSaver Website, the site software automatically collects the internet protocol (IP) address of the computer through which the user is connected to the Internet. The GreenSaver Website also automatically collects information about the user’s Internet browser software, operating system, the date and time of the user’s visit, the URL of the last page visited by the user before entering the GreenSaver Website, and the pages accessed while on our site. This information is not used to gain personal information on individual users but is aggregated with that of other visitors to help us understand how the site is being used and how to make it better.

(d) Cookies
When a visitor accesses the GreenSaver Website, a cookie is automatically installed on the visitor’s computer hard-drive. A cookie is a small text file that contains a unique identification number, which can be used to identify the user’s browser, but not the user. Cookies form an essential part of the Internet today by allowing Websites to recognize users’ browsers when the users return to previously visited Websites. Since cookies are only text files, they cannot “run” on your computer and have no ability to search your computer for information or to transmit information to anyone. GreenSaver uses cookies to provide certain features on its Website. We do not use cookies to retain personal information. Users are free to prevent the installation of cookies on their computer hard-drive, including the GreenSaver cookie, by simply disabling the feature in their browser’s options. Some browsers allow users to accept or reject cookies as they are presented to the user. Please note that users will not be able to access some features and services of the GreenSaver Website if they disable cookies.

(e) E-Mail Communications
GreenSaver adheres to a no spam policy. Therefore, you will not receive regular, unsolicited e-mail communications from GreenSaver unless you have agreed otherwise or such communications are required for the purposes identified in Section 2 above or to otherwise provide a product, service or information to you that you have requested.
Please note that GreenSaver reserves the right to contact you, by e-mail or otherwise, if permitted or required by law or regulatory authorities or if there has been a violation of GreenSaver Website Terms of Use.

(f) Response Tracking
GreenSaver uses Website usage information about visitors to our Website who have responded to a promotional campaign about GreenSaver’s services for the purpose of future promotional campaigns, and evaluating usage statistics. For this purpose, we collect information about the campaigns and some of the pages you visit on our Website through the use of tracking numbers passed through URL’s transferred to our information technology as well as pixels tags (also known as clear GIFs).
As well, GreenSaver may use third-party companies to host and serve online advertisements for GreenSaver promotional campaigns. Pixel tags may be used in connection with online advertisements, for example, to allow us to count the number of times the advertisement was viewed versus the number of individuals who enrolled in the product or service advertised.
Personal information about you is not collected by any such third-party companies, nor is any tracking information generated from the pixel tag used by them for any other purpose than to report advertising response and Website activity to us.

(g) Links to Third-Party Sites
GreenSaver’s Website contains links to third-party Websites. GreenSaver is not responsible for (a) any information you provide to other Websites outside of GreenSaver domain that you access through a link on our Website or (b) the privacy practices or the content of such Websites outside of GreenSaver’s domain.

(h) Questions
Questions about personal information collected through GreenSaver Website should be submitted belowand will be addressed in accordance with this Privacy Policy.

Privacy Policy Questions and Feedback. We would love to hear from you! If you have any questions or concerns regarding GreenSaver’s Privacy Policy, please contact us and let us know.

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