gatopretohosting-privacy policy

Gato Preto Hosting Privacy Policy
Last updated: December 3, 2006 Our Commitment to You Gato Preto Hosting is a diversified Canadian company whose core business is providing products and Internet services. Gato Preto Hosting has always been and will continue to be, committed to maintaining your Personal Information and as part of our commitment, we have established our Privacy Policy using the following ten principles. These principles are: Principle 1 - Gato Preto Hosting's Accountability Principle 2 - Identifying the purposes for Personal Information collection Principle 3 - Obtaining Consent Principle 4 - Limiting the collection of Personal Information Principle 5 - Limiting the use, disclosure and retention of Personal Information Principle 6 - Keeping Personal Information accurate Principle 7 - Safeguarding Personal Information Principle 8 - Being open about policies and practise Principle 9 - Providing access to Personal Information Principle 10 - Challenging compliance and offering suggestions Gato Preto Hosting relies on these Ten Principles to protect the Personal Information provided to us by our Customers and our employees. Our Privacy Policy complies with the provisions set out in the Personal Information Protection and Electronic Documents Act, as well as the Canadian Standards Association Model Code for the Protection of Personal Information. Reminder to our Customers Please remember that Gato Preto Hosting’s Privacy Policy and our use of your Personal Information only applies to the information you provide to us and we caution you to be sure that if you disclose personally identifiable information or personally sensitive data through use of the Internet such as through chat rooms, communities, bulletin boards or other public online forums, this information is not collected by or for Gato Preto Hosting and is being collected and used by other persons or companies over which Gato Preto Hosting has no control. It is your responsibility to review the privacy statements of any person or company to whom you choose to link, from or through the use of any Gato Preto Hosting Internet services. Gato Preto Hosting is not responsible for privacy statements or compliance or other content of any web site not owned or managed by Gato Preto Hosting. Customer Choice If you prefer that Gato Preto Hosting does not share your Personal Information among the Gato Preto Hosting companies to promote our products and services, please advise us in writing or call us at the number shown on your bill or by using the Contact Us section of our Web site at http://www.GatoPreto Hosting.com/contact_us.php. General Definitions used in our Privacy Policy Collect - when we Collect Personal Information we mean to gather, acquire, or obtain such Personal Information from any source available to Gato Preto Hosting and may also include Personal Information provided to us from third parties. Consent - means your voluntary and informed agreement with what is being done or proposed. Your Consent can be either expressed or implied. Express Consent is given explicitly, either orally, electronically or in writing. Express Consent is unequivocal and does not require any inference on the part of Gato Preto Hosting seeking Consent. Implied Consent arises where Consent may reasonably be inferred from the action or inaction of the Customer or the employee. Customer - is you and means any individual who has an account with Gato Preto Hosting and/or uses, has used, or applies to use Gato Preto Hosting’s products and/or services. Use – to use Personal Information within Gato Preto Hosting for a specified purpose. Disclose - to make Personal Information available to others outside Gato Preto Hosting. Personal Information - means any information that can identify a Customer or Gato Preto Hosting employee and may be recorded in any form. For a Customer, the term includes, but is not limited to the Customer’s name, address, telephone number, gender, payment records, and correspondence sent by the Customer to Gato Preto Hosting. In the case of employees or job applicants, it may include, where applicable, employment history, performance reviews, salary, benefits, compensation or other information relating to an employee's past, current or future employment, but does not include the employee’s name, title, business address (including e-mail address) or business telephone or fax numbers. Commonly asked Questions: Why does Gato Preto Hosting Collect Personal Information? Gato Preto Hosting Collects Personal Information and other information from its Customers so that it is able to maintain a responsible commercial relationship with its Customers and may include purposes for billing and account collections or evaluation. Gato Preto Hosting wants to ensure that it continues to provide you with the products and/or services you have asked for as well as to improve upon those products and services by using information our Customer’s have provide that shows their interests and needs. In addition, Gato Preto Hosting studies this information to help it market, manage and develop its business, including its networks and facilities to plan for future growth. What type of Personal Information does Gato Preto Hosting Collect? The types of Personal Information Collected by Gato Preto Hosting depends on the nature of your request and may include your name, mailing address, e-mail address, phone number(s), and account numbers(s). We may also request anonymous/non-personal information, which information cannot be associated with or traced back to a specific individual, to help us provide you with advice and information about other products and/or services that we believe would be of interest to you. Anonymous/non-personal information helps Gato Preto Hosting better understand its markets. How does Gato Preto Hosting use Personal Information? Gato Preto Hosting uses Personal Information to communicate with its Customers to process its Customers orders for products and/or services, to verify Customer identity and protect their account information, for account billing and collections purposes, and ultimately provide our Customers with the product/services they have requested. Gato Preto Hosting may also use Personal Information to keep track of and report back to its Customers on their dealings with Gato Preto Hosting. Anonymous/non-personal information is generally used by Gato Preto Hosting to improve its products and services to its Customers. When does Gato Preto Hosting disclose Personal Information? Gato Preto Hosting is obligated to keep Personal Information confidential except under the following special circumstances: (a) when a Customer Consents; (b) when required by law; or (c) permitted by Law. The details of when Gato Preto Hosting may disclose Personal Information can be viewed in our Principle 5.3. Who does Gato Preto Hosting share Personal Information with? Gato Preto Hosting does not share personal information with any outside organization or third parties. Additional Information: Tips to protect your Personal Information Gato Preto Hosting does its best to protect and safeguard Personal Information and we believe there are measures you should take as well. Do not share your Personal Information such as bank and credit card account numbers or their associated pin numbers or your social insurance number with others unless you clearly understand the purpose of their request and you know with whom you are dealing. If you are asked to assign passwords to connect you to your Personal Information, you should use a combination of letters and numbers and do not use words that can be easily associated with you (example: do not use the name of a family member or pet), we also suggest you change your password regularly. If ever you are suspicious of any telephone, mail or email promotional campaigns or you suspect fraudulent activity is occurring please contact us to verify that the campaign is a legitimate Gato Preto Hosting activity. Accessing and Amending your Personal Information You may access and verify your Personal Information held by Gato Preto Hosting by contacting us during our regular office hours MST. About Cookies A Cookie is s small text file that contains a unique identification number that Web sites send to your computer’s Web browser. If you receive a Cookie from a Web site you have opened the Cookie will store on your computer so that the next time you try to connect to that Web site your computer’s browser will search your hard drive for a Cookie and if a Cookie is found, the browser will send the information gathered from a previous visit to that Web site and if a Cookie is not found then the browser will know you have not visited the Web site before. A Cookie can be used to track the activities of your browser and provide you with a consistent Web experience. Cookies were originally used to maintain relevant information such as the number of visitors who viewed various pages of a Web site. Gato Preto Hosting uses Cookies to increase the robustness of its Web sites and to provide more efficient navigation. Use of 'Cookies' During a Customer’s interaction with one of Gato Preto Hosting’s Internet sites, Gato Preto Hosting may use a browser feature called a ‘cookie’ to collect information anonymously and track user patterns on Gato Preto Hosting’s Web sites. A cookie is a small text file containing a unique identification number that identifies a Customer’s browser – but not the Customer itself – to Gato Preto Hosting’s computers each time a Customer visits one of the Gato Preto Hosting Web sites that uses cookies. Cookies tell Gato Preto Hosting which pages of its sites are visited and how many people visited such Web sites. This helps Gato Preto Hosting to enhance the on-line experience of visitors to the Gato Preto Hosting Web sites. The use of cookies may help Gato Preto Hosting’s Customers to personalize their online experience. Unless a Customer specifically advises Gato Preto Hosting, however, Gato Preto Hosting will not know who the Customer is, even though Gato Preto Hosting may assign such Customer’s computer a cookie. Gato Preto Hosting cannot use cookies, by itself, to disclose the individual identity of any Web site user. If a Customer provides Personal Information (such as like the Customer’s name, telephone number, or even its e-mail address) through or from the Customer’s browser, that Customer is Consenting to Gato Preto Hosting combining that Personal Information with information gathered by a cookie. Customers will find that most major Web sites use cookies and most major browsers are set up to accept them. If a Customer wishes, it can reset its browser either to notify such Customer when it has received a cookie, or to refuse to accept cookies. Customers do not need cookies to visit Gato Preto Hosting sites. However, if a Customer refuses to accept cookies, it may not be able to use some of the features available on Gato Preto Hosting’s Web sites such as personalization features. Updating this Privacy Policy Any changes to Gato Preto Hosting’s Privacy Policy shall be acknowledged in this Policy in a timely manner. Gato Preto Hosting may modify or remove portions of this Privacy Policy when it feels it is necessary and appropriate. You may determine when this policy was last updated by referring to the date found at the top left hand corner of this Privacy Policy page. The Privacy Principles Principle 1 - Gato Preto Hosting's Accountability Gato Preto Hosting is responsible for all Personal Information under its control, including Personal Information disclosed to third parties for processing. Gato Preto Hosting will designate an individual or individuals who will be accountable for Gato Preto Hosting’s compliance with Gato Preto Hosting’s Privacy Policy. 1.1 Gato Preto Hosting’s senior management is responsibility for ensuring compliance with the provisions of this Privacy Policy. Gato Preto Hosting’s senior management may designate one or more individuals to be accountable for fulfilment of Gato Preto Hosting’s day to day collection and processing of Personal Information and may also appoint other individuals within Gato Preto Hosting to be responsible for compliance with this Privacy Policy, in respect of its Customers and in respect of its employees. 1.2 The identity of the individual(s) designated by Gato Preto Hosting to oversee the compliance with this Privacy Policy are made known internally and will also be made available to our Customers upon their request. 1.3 Gato Preto Hosting has implemented policies and practices to give effect to this Privacy Policy. Some of these policies and practices are listed below: 1. implementing procedures to protect Personal Information; 2. procedures to receive and respond to inquires and complaints from Customers and/or employees; 3. communicating to the Gato Preto Hosting employees and providing them ongoing training and the proper tools required to understand and adhere to Gato Preto Hosting’s policies and procedures; and 4. providing public information to our Customers and our employees to explain Gato Preto Hosting’s policy and procedures. Principle 2 - Identifying the Purposes for Personal Information Collection Gato Preto Hosting will identify the reasons for which Personal Information is Collected and/or required at or before the time such information is Collected by Gato Preto Hosting. 2.1 Gato Preto Hosting collects Personal Information for the following purposes: to establish and maintain responsible commercial relations with our Customers and provide each Customer with continued service; to understand your needs as our Customer and your eligibility for products and services; to develop, enhance, market or provide products and services to our Customers; to manage and develop Gato Preto Hosting’s business and operations, including personnel and employment matters; to process billing and collection of the fees for the Gato Preto Hosting products and services it has purchased and/or subscribed to; to perform credit checks and references, if deemed necessary by Gato Preto Hosting; and to meet Gato Preto Hosting’s legal and regulatory requirements. Personal Information will not be used for any other purpose without your Consent. 2.2 As part of Gato Preto Hosting’s information management policies and procedures, Gato Preto Hosting will specify either verbally, electronically or in writing the purposes for which it collects Personal Information. Some of the reasons Gato Preto Hosting may need to collect Personal Information may be for other services including products, and for such other purposes as may be required or permitted by law. The purposes will be stated in a clear and understandable manner to ensure that the Customer can reasonably understand how the Personal Information will be used or disclosed in order that the Consent made is informed and meaningful. 2.3 When Gato Preto Hosting wishes to use Personal Information for a purpose not previously identified to the Customer, Gato Preto Hosting will identify the new use, in the manner set out in 2.1 above. Unless the new use of the Personal Information is required by law, the Consent of the Customer or employee is required before the Personal Information can be used for that new purpose. (See Principle 3 – Consent) 2.4 Any time Gato Preto Hosting asks a Customer for Personal Information, the Customer may request Gato Preto Hosting to explain the reason the Personal Information is being collected. Principle 3 - Obtaining Consent Consent will be obtained from Customers and employees before or when they Collect, Use, or disclose the Personal Information, except where inappropriate. When Gato Preto Hosting is required to ask for Consent Gato Preto Hosting will make reasonable efforts to ensure that the Customers and employees understand how the Personal Information may be Used or how it may be disclosed by Gato Preto Hosting. 3.1 Consent is required for the collection of Personal Information and the subsequent use or disclosure of the Personal Information. In most cases, Gato Preto Hosting seeks Consent for the Use or disclosure of the information at the time Gato Preto Hosting Collects it. When Gato Preto Hosting wants to use Personal Information for a purpose which it has not previously identified to the Customer, Gato Preto Hosting may seek Consent with respect to the Use or disclosure after the Personal Information was collected, but before it is Used. 3.2 Gato Preto Hosting may Collect, Use, or disclose Personal Information without a Customer’s or employee’s knowledge or Consent in instances where it is deemed a legal or security reason, or for the welfare of an individual where it might make it impossible or impractical to seek Consent. For example, when Personal Information is being collected for the detection or prevention of fraud, seeking Consent may defeat the purpose of collecting the information. All of the circumstances where Gato Preto Hosting may Collect, Use, or disclose Personal Information without a Customer’s or employee’s knowledge or Consent are as specified and permitted by legislation. 3.3 Gato Preto Hosting will ensure that a Customer applying for service is informed why Gato Preto Hosting needs the Personal Information and how the Personal Information will be Used. To make Customer’s Consent informed and meaningful, the purposes must be clearly stated so that a Customer can reasonably understand how the Personal Information will be Used or disclosed. 3.4 Gato Preto Hosting may not, as a condition of providing any product and/or service, require a Customer to Consent to the Collection, Use or disclosure of Personal Information beyond that required to provide the product and/or service itself. 3.5 Consent can be either expressed or implied. The form of Consent sought by Gato Preto Hosting may vary, depending upon the circumstances and the type of Personal Information. In determining the form of Consent to use, Gato Preto Hosting takes into account the sensitivity of the information and the reasonable expectations of the Customer. Gato Preto Hosting generally seeks express Consent when the Personal Information is likely to be considered sensitive. Implied Consent is typically appropriate when the Personal Information is less sensitive. 3.6 A Customer may withdraw its Consent at any time, subject to legal or contractual restrictions and upon providing Gato Preto Hosting reasonable notice. A Customer wishing to withdraw should contact Gato Preto Hosting by clicking here. 3.7 In general, the use of products and services by a Customer, or the acceptance of employment or benefits by an employee, will constitute implied Consent required by Gato Preto Hosting to Collect, Use and/or disclose Personal Information for all identified purposes. Principle 4 - Limiting the Collection of Personal Information The Collection of Personal Information by Gato Preto Hosting will be limited to only that information which is necessary for the purposes identified by Gato Preto Hosting. All Personal Information collected Gato Preto Hosting will be by fair and lawful means. 4.1 Gato Preto Hosting will only Collect the amount and type of Personal Information needed for the specified purposes that have been documented by Gato Preto Hosting and identified to Customers and employees. 4.2 Gato Preto Hosting will not mislead or deceive Customers or employees about the purposes for which Personal Information is being collected. Principle 5 - Limiting Use, disclosure, and retention of Personal Information No Personal Information will be used, disclosed or shared for purposes other than those for which it was Collected by Gato Preto Hosting unless Gato Preto Hosting has the Consent of the Customer or employee, or as may be required by law. Gato Preto Hosting will keep Personal Information only as long as it is necessary for Gato Preto Hosting to fulfill the purposes for which Personal Information was Collected. 5.1 Gato Preto Hosting will keep Personal Information only as long as it is necessary or relevant for the identified purposes or as may be required by law. Personal Information that has been used to make a decision about a Customer or an employee will be kept by Gato Preto Hosting for a period of time that is reasonably sufficient to allow the Customer or employee access to the Personal Information. In the event a Customer has lodged a complaint about Gato Preto Hosting’s compliance with this Privacy Policy the Personal Information shall be kept until a decision has been made to resolve such complaint and then only to permit any questions under this Privacy Policy and the applicable privacy legislation. 5.2 Gato Preto Hosting may destroy, erase, or make anonymous Personal Information that is no longer required to fulfill the identified purposes. 5.3 Gato Preto Hosting may disclose a Customer’s Personal Information to: 1. a public authority or agent of a public authority, if in the reasonable judgment of Gato Preto Hosting, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the Personal Information; 2. a third party or parties, where the Customer has given Gato Preto Hosting Consent to such disclosure or if disclosure is required by law; and 5.4 Gato Preto Hosting may disclose personal information about its employees: 1. for normal personnel and benefits administration; 2. in the context of providing references regarding current or former employees in response to requests from prospective employers; or 3. where disclosure is required by law. 5.5 Only Gato Preto Hosting’s employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information Gato Preto Hosting’s Customers and employees. Principle 6 - Accuracy of Personal Information Gato Preto Hosting will keep all Personal Information provided to it accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. 6.1 The level to which Personal Information will be accurate, complete, and up-to-date depends on how Gato Preto Hosting uses the Personal Information and Gato Preto Hosting will take into account the interests of the Customer or employee. Personal Information will also be sufficiently accurate, complete, and up-to-date in order to minimize the possibility that inappropriate information is used to make a decision about the Customer or employee needs or interests. 6.2 Gato Preto Hosting will update Personal Information that it Collects and Uses on an on-going basis to fulfill the identified purposes. 6.3 Gato Preto Hosting will not update Personal Information unless updated information is needed to fulfill the purposes for which it was collected. Principle 7 - Safeguarding Personal Information Gato Preto Hosting will protect Personal Information by security safeguards that are appropriate for the level of sensitivity of the Personal Information. 7.1 The security safeguards used by Gato Preto Hosting will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which the information is held by Gato Preto Hosting. 7.2 The nature of the safeguards will vary depending on the sensitivity of the Personal Information that has been Collected, the scope of the information, and the method of storage of that information. More sensitive types of Personal Information will be safeguarded by a higher level of protection. 7.3 The methods of protection may include: 1. physical measures, for example, locked filing cabinets and restricted access to offices; 2. organizational measures, for example, security clearances and limiting access on a “need to know” basis; 3. technological measures, for example, the use of passwords and encryption; and 4. investigative measures where required to safeguard the interests of Gato Preto Hosting, its Customers or its employees. 7.4 Gato Preto Hosting will make its employees aware of the importance of maintaining the confidentiality of Personal Information. 7.5 Gato Preto Hosting will dispose of Personal Information in a manner that prevents unauthorized parties from gaining access to the Personal Information. Principle 8 - Openness about Gato Preto Hosting’s Policies and Procedures Gato Preto Hosting will make readily available to Customers and employees specific information about its policies and procedures relating to the management of Personal Information. 8.1 Gato Preto Hosting will be open about its policies and procedures with respect to the management of Personal Information. Customers and employees will be able to acquire their Personal Information and about Gato Preto Hosting’s Privacy Policies and procedures at minimal cost and without unreasonable efforts on their part. This information will be made available in a form that is generally understandable. This information is available by writing to Gato Preto Hosting, to the attention of the Privacy Officer. Contact details are available below. 8.2 The Personal Information made available by Gato Preto Hosting will include: 1. the name, title and address of the individual who is accountable for Gato Preto Hosting’s Privacy Policies and its procedures and to whom complaints or inquiries can be forwarded; 2. the means of gaining access to the Personal Information held by Gato Preto Hosting; 3. a description of the Personal Information held by Gato Preto Hosting, including a general account of its Use; 4. a copy of any documents that describe Gato Preto Hosting’s policies, standards, and/or policies; and 5. a description of Personal Information made available to related organizations, including subsidiaries, affiliates or agents. Principle 9 - Providing Access to Personal Information Upon a Customer’s or an employee’s request, and unless prohibited by law, Gato Preto Hosting will inform such Customers and employees of the existence, Use, and disclosure of the Personal Information specific to them and provide them access to that information. Any Customer may challenge the accuracy and completeness of their Personal Information and have it amended as appropriate. 9.1 Upon request, Gato Preto Hosting will inform a Customer or employee whether or not Gato Preto Hosting holds Personal Information about them, and will indicate the source of this information. If Gato Preto Hosting possesses any such information, it will allow the Customer or employee access to the Personal Information specific to that person. In addition, Gato Preto Hosting will provide an account of how that Personal Information has been Used or is being Used along with any Uses by any third parties to whom it has been disclosed. 9.2 A Customer or employee may be required to provide sufficient information to identify for Gato Preto Hosting what Personal Information such Customer or employee is enquiring about. The required information provided to Gato Preto Hosting for this purpose shall only be used for this purpose. 9.3 In certain situations, Gato Preto Hosting may not be able to provide access to all the Personal Information it holds. Exceptions to the access requirement will be limited to those allowed or required under law. 9.4 In providing an account of third parties to which Gato Preto Hosting has disclosed Personal Information, Gato Preto Hosting will attempt to be as specific as possible. When it is not possible to provide a list of the actual organizations to which it has disclosed Personal Information, Gato Preto Hosting will provide a list of organizations to which it may have disclosed Personal Information. 9.5 Gato Preto Hosting will respond to a Customer or employee request within a reasonable period of time and at minimal or no cost to the Customer or employee. The requested information will be provided or made available to the Customer or employee in a form that is generally understandable. 9.6 When a Customer or employee successfully challenges the accuracy or completeness of Personal Information, Gato Preto Hosting will correct, delete, or add additional information as required. Where appropriate, the amended Personal Information will be transmitted to third parties having access to the corrected, deleted, or additional Personal Information. 9.7 When a challenge is not resolved to the reasonable satisfaction of the Customer or employee, Gato Preto Hosting will record the substance of the unresolved challenge in the Personal Information relating to the Customer or employee. Where appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question. Principle 10 - Challenging compliance and offering suggestions A Customer or employee of Gato Preto Hosting may direct any questions or inquires with respect to the Privacy Principles outlined above or about Gato Preto Hosting’s practices used in its Privacy Policy to the designated individual accountable for Gato Preto Hosting’s compliance. 10.1 Gato Preto Hosting has put procedures in place to receive and respond to complaints or inquiries about the policies and procedures relating to the handling of Personal Information. The complaint process used by Gato Preto Hosting is easily accessible and simple to use. 10.2 Gato Preto Hosting will investigate all complaints and respond to all questions asked by its Customers and/or employees. If a complaint is found to be justified, Gato Preto Hosting will take appropriate measures to resolve the complaint, which may include amending its policies and procedures if necessary. 10.3 Gato Preto Hosting will inform Customers who lodge complaints, or inquire about complaint procedures. To contact the Office of Gato Preto Hosting Gato Preto Hosting Privacy 424 Homestead Trail , High River, Alberta T1V 1J9 Telephone: Contact us by clicking here To contact the Office of the Privacy Commissioner of Canada Privacy Commissioner of Canada 112 Kent Street Ottawa, Ontario K1A 1H3 Phone (613) 995-8210 Toll-free 1-800-282-1376 Fax (613) 947-6850 E-mail: info@privcom.gc.ca (complaints must be submitted in writing) Web site: http://www.privcom.gc.ca