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Privacy Policy


Introduction

World-Link Communications Inc. ("World-Link") is committed to maintaining the accuracy, confidentiality, security and privacy of visitor to the Website and its customer personal information. Our Privacy Policy has been designed to inform employees, customers, and third parties of World-Link of our commitment to abide with the terms and the Personal Information Protection and Electronic Documents Act.

The Personal Information Protection and Electronic Documents Act (the "Act") governs the collection, use and disclosure of personal information in the commercial sector. World-Link adheres to the ten stated privacy principles as set out in the National Standard of Canada, Model Code ("CSA Code") for the protection of personal information.

This Policy describes World-Link's collection, use and/or disclosure of personal information.

Summary of Principles

This World-Link Privacy Policy is set out along the ten privacy principles in the CSA Code, which are:

Principle 1 - Accountability

Principle 2 - Identifying Purposes

Principle 3 - Consent

Principle 4 - Limiting Collection

Principle 5 - Limiting Use, Disclosure and Retention

Principle 6 - Accuracy

Principle 7 - Safeguards

Principle 8 - Openness

Principle 9 - Individual Access

Principle 10 - Challenging Compliance

Definitions

Collection - the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.

Consent - voluntary agreement of an individual to the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or through an authorized representative of the individual. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of World-Link. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.

Customer - an individual who uses or applies to use the services of World-Link.

Disclosure - making personal information available to a third party.

Personal Information - information about an identifiable individual. For a customer, personal information includes a customer's name, date of birth, social insurance number, drivers license number, credit card information, payment and banking information, billing records, internet user names, password and PIN numbers, ethnic origin, opinions, evaluations, social status, disciplinary actions, credit records, loan records, service and equipment, medical reports and any recorded complaints. Personal information does not include the name, title, address and telephone number of an employee of an organization.

Third Party - an individual other than the customer or his agent, or an organization other than World-Link.

Use - the treatment, handling and management of personal information by World-Link.

PRINCIPLE # 1 ACCOUNTABILITY

World-Link is responsible for personal information under its control and will designate an individual or individuals who are accountable for the organization's compliance with the following principles.

1.1. Accountability for World-Link's compliance with the principles rests with the senior management of World-Link and the person or persons designated by senior management as Privacy Officer, even though other individuals within the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within the organization may be delegated to act on behalf of senior management or the Privacy Officer.
1.2. World-Link's senior management has designated a Privacy Office to oversee compliance with World-Link's Privacy Policy. World-Link shall provide, upon request, the name and contact information of the Privacy Officer.
1.3. World-Link is responsible for personal information in its possession, control or custody, including any personal information that has been transferred to a third party for processing. World-Link shall use contractual or other means to provide a comparable level of protection of personal information while a third party is processing such information.

1.4. World-Link shall implement policies and procedures to give effect to the World-Link's Privacy Policy, including:

1.4.1. implementing procedures to protect personal information

1.4.2. establishing procedures to receive and respond to complaints and inquiries with respect to an individual's personal information;
1.4.3. training and communicating to staff information about World-Link's privacy policies and procedures; and
1.4.4. developing information to explain World-Link's policies and procedures.
PRINCIPLE # 2 IDENTIFYING PURPOSES

The purposes for which personal information is collected shall be identified by World-Link at or before the time the information is collected.

2.1. World-Link collects personal information only for the following purposes ("identified purposes"):

2.1.1. To verify the customer's identity;
2.1.2. To determine the customer's eligibility for products and services;
2.1.3. To provide service(s) and/or products to its customers;
2.1.4. To assist us in updating the customer's creditworthiness and the collection of accounts;
2.1.5. For pre-authorized payments for services;
2.1.6. To prevent fraud with respect to both the customer and our company;
2.1.7. To maintain commercial relations and to communicate with customers, include, but not be limited to: billing, collection, advertising, promotion, account verification;
2.1.8. To administer and manage its business operations;
2.1.9. To meet legal, regulatory and settlement requirement;
2.2. World-Link shall specify, either orally, in writing or electronically all identified purposes for the collection, use and disclosure of personal information to the customer at the time such personal information is collected.

2.3. Those responsible for collecting personal information shall be able to explain to individuals the purposes for which the information is being collected, or shall refer the individual to a designated person at World-Link who will explain the purposes.
2.4. Unless required by law, World-link shall not use or disclose, for any new purpose, personal information that has already been collected without first identifying and documenting the new purpose and obtaining the consent of the customer.
Occasionally, World-Link will communicate to their customer special promotion, bonus and new product offers that World-Link thinks may be of value to their customer. If the customer wishes to opt-out of receiving targeted communications from World-Link in electronic, printed or verbal format (other than information included with the monthly bills), simply inform World-Link in writing at 340 Ferrier Street, Suite 200, Markham ON, L3R 2Z5 or by sending email to unsubscribe@wlink.ca.

PRINCIPLE # 3 CONSENT

The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate.

3.1. In certain circumstances, personal information may be collected, used, or disclosed without the knowledge and consent of the individual. For example, some legal, medical or security reasons may make it impossible or impractical to seek consent.
When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when there is an emergency threatening the individual's life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available. Moreover, World-Link may provide personal information to its lawyer or agent to collect a debt, comply with a subpoena, warrant or other court order, government institution requesting the information upon lawful authority, or as may be otherwise required by law.

3.2. Generally, World-Link shall seek an individual's consent for the use or disclosure of personal information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use for a purpose not previously identified.

3.3. World-Link shall make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used. To make the consent meaningful, the purposes will be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.

3.4. World-Link shall not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes.

3.5. The form of consent sought by World-Link may vary, depending upon the circumstances and the type of information disclosed. In determining the form of consent to use, World-Link shall take into account the sensitivity of the personal information and the reasonable expectations of the individual. An authorized representative (such as a legal guardian or a person having power of attorney) can also give consent.

World-Link shall seek express consent when the information is likely to be considered sensitive.

Implied consent will generally be appropriate when the information is less sensitive. The use of services or products by a customer or the acceptance of employment by an employee will be considered implied consent to collect, use and disclose personal information for all identified purposes.

3.6. A customer may refuse or withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. World-Link shall inform the customer of the implications of such withdrawal. In order to withdraw consent, a customer must provide notice to World-Link in writing.

3.7. With respect to personal information already collected by World-Link prior to the publication of this Privacy Policy, this Policy will constitute reasonable notice to World-Link's current customers and employees of the purposes and uses for which such personal information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to World-Link in writing.
PRINCIPLE # 4 LIMITING COLLECTION

The collection of personal information shall be limited to that which is necessary for the purposes identified by World-Link. Information will be collected by fair and lawful means.

4.1. World-Link collects personal information from its customers and employees for the purposes described under 2 above.

4.2. World-Link may also collect personal information from such third parties as credit bureaus, employers or personal references or other third parties that represent that they have the right to disclose the information.

4.3. In connection with its Internet business, World-Link may use a 'Cookie' to collect certain information which it uses to track user patterns on its website(s). A Cookie is a text file containing a unique identification number that identifies a user's browser, but not a particular individual. A Cookie does not identify an individual. Furthermore, World-Link does not use Cookies in combination with other information to obtain personally identifiable information. If an individual does not wish to use Cookies, he or she can re-set their browser to either provide notification or refuse to accept Cookies.
PRINCIPLE # 5 LIMITING USE, DISCLOSURE, AND RETENTION

World-Link shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

5.1. World-Link may collect, use or disclose personal information without the individual's knowledge or consent in certain circumstances as described in Principle #3.

5.2. World-Link may disclose a customer's personal information to:

5.2.1. another telecommunication company for the provision of telecommunications services to that customer;
5.2.2. a company involved in providing communications directory services;
5.2.3. a person involved in the development, promotion, marketing or enhancement of World-Link services;
5.2.4. a credit collections agency;
5.2.5. emergency services in an emergency situation;
5.2.6. a person, who, in the reasonable estimation of World-Link, is an agent of the customer;
5.2.7. any other third party or parties, where the customer has provided consent to such disclosure or disclosure as required by law.

5.3. World-Link may disclose an employee's personal information in the following circumstances:

5.3.1. in the administration of that employee's benefits;
5.3.2. in providing references to prospective employers, upon receiving the consent of the employee;
5.3.3. as may be required by law.

5.4. Certain World-Link employees may be given access to customer and/or employee information in so far as their duties require access for business purposes. World-Link employees are governed by an Agreement of Confidentiality and Non-Competition prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated business purposes.

5.5. World-Link will keep personal information only as long as necessary for the identified purposes or as required by law.

5.6. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous. World-Link will develop guidelines and implement procedures to govern the destruction of personal information.
PRINCIPLE # 6 ACCURACY

World-Link shall keep the personal information in its possession or control accurate, complete, current and relevant based on the most recent information provided to World-Link.

6.1. Personal information used by World-Link shall be sufficiently accurate, complete, current and relevant to minimize the possibility that inappropriate information may be used to make a decision about a customer.

6.2. World-Link will not routinely update personal information unless such a process is necessary to fulfill the purposes for which the information was collected.

6.3. Personal information that is used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.

PRINCIPLE # 7 SAFEGUARDS

World-Link shall protect personal information with security safeguards appropriate to the sensitivity of the information.

7.1. World-Link shall protect personal information from loss or theft, unauthorized access, disclosure, copying, use, or modification.

7.2. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage.

7.3. World-Link exercises its best and reasonable efforts in the protection of all personal information regardless of the format in which it is held. The methods of protection may include:

7.3.1. physical measures, such as locked filing cabinets and restricted access to offices;
7.3.2. organizational measures, such as security clearances and limiting access on a "need to know" basis;
7.3.3. technological measures, such as the use of passwords and encryption

7.4. World-Link will make all its employees aware of the importance of maintaining the confidentiality of personal information. World-Link employees are governed by an Agreement of Confidentiality and Non-Competition prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated business purposes.

7.5. World-Link will use reasonable care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
PRINCIPLE # 8 OPENNESS

World-Link shall make readily available to customers specific information about its policies and practices relating to the management of personal information.

8.1. World-Link will make its policies and practices with respect to the management of personal information easily comprehensible and accessible, by providing upon request:

8.1.1. the name, title, and address of the Privacy Officer accountable for World-Link's privacy policies and practices and to whom complaints or inquiries can be forwarded;
8.1.2. the means of gaining access to personal information held by World-Link; and
8.1.3. a description of the type of information held by World-Link including a general explanation of its use.

8.2. World-Link may make information on its privacy policies available online, by mail, or in a brochure format at its place of business. Furthermore, World-Link's Customer Services Representatives will be trained to answer requests at World-Link's toll-free customer service telephone number 1-877-513-3087.

PRINCIPLE # 9 INDIVIDUAL ACCESS

Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information in World-Link's possession and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended where necessary.

9.1. Upon request, World-Link shall inform an individual whether or not the organization holds personal information about the individual, and will provide that individual with a reasonable opportunity to review the personal information in his or her file.

9.2. World-Link shall allow the individual access to his or her personal information once the individual has provided World-Link with a written request application. World-Link shall make the application available to customers through Customer Service Representatives and to employees through the Human Resources Department. The application will include sufficient information to permit World-Link to provide an account of the existence, use, and disclosure to any third parties of this personal information. World-Link shall use the application only for this purpose.

9.3. World-Link shall respond to an application for individual access to personal information within a reasonable time and at minimal or no cost to the individual. The requested information shall be provided or made available in a form that is generally understandable.

9.4. World-Link shall be as specific as possible in providing an account of third parties to which it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, World-Link shall provide a list of organizations to which it may have disclosed information about the individual.
9.5. In certain situations, World-Link may not be able to provide the individual access to his or her personal information. Exceptions may include information that is prohibitively expensive to provide, information that contains references to other individuals and information that cannot be disclosed for legal, security or commercial proprietary reasons; where the information is subject to solicitor-client or litigation privilege; or where the information can best be available from another source (for example, through a medical practitioner). In each case, World-Link shall provide reasons for denying any access to personal information.

9.6. When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, World-Link shall amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.

9.7. When a challenge is not resolved to the satisfaction of the individual, World-Link shall record the substance of the unresolved challenge. When appropriate, the existence of the unresolved challenge will be transmitted to third parties having access to the information in question.

PRINCIPLE # 10 CHALLENGING COMPLIANCE

A customer shall be able to address a challenge concerning compliance with the above principles to World-Link's Privacy Officer.

10.1. World-Link shall maintain procedures for receiving, addressing and responding to all inquiries or complaints from its customers relating to its handling of personal information. World-Link shall make every effort to ensure that its procedures are easily accessible and simple to use.

10.2. World-Link shall inform its customers who make inquiries or lodge complaints of the existence of relevant complaint procedures.

10.3. The person or persons accountable for compliance with this Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4. World-Link shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, World-Link shall take appropriate measures, including, if necessary, amending its policies and procedures.
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