Two Hat Security Ltd. DBA Community Sift
Updated: August 4, 2016
At Two Hat Security Ltd. dba Community Sift (Community Sift), we are committed to providing our customers (“Customer”) and users of our website (each, a “User”) with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our Customers and Users, protecting their personal information is one of our highest priorities.
While we have always respected our Customers and Users privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our Customers and Users of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting the personal information of our Customers and Users. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of that personal information and allowing our Customers and Users to request access to, and correction of, their personal information.
Scope of this Policy
Personal Information – means information about an identifiable individual, which may include such information as name, age, gender, home address and phone number, e-mail address and credit card information. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated by Community Sift from to time to be responsible for ensuring that Community Sift complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1. Unless the purposes for collecting personal information are obvious and the Customer or User voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2. We will only collect personal information of Customers and Users that is necessary to fulfill the following purposes:
- To verify identity;
- To identify Customer and User preferences;
- To understand the needs of our Customers and Users with respect to our products and services and enhance their experience using our products and services;
- To deliver requested products, services and/or information;
- To deliver notices, updates, alerts and other information concerning our products and services that may be of interest to our Customers and Users;
- To ensure a high standard of service to our Customers and Users;
- To meet regulatory requirements; and
- To enable related entities and third party service providers to deliver requested products, services and/or information.
1.3. We may also collect information related to your use of our services, where applicable, including, without limiting the generality of the foregoing:
- Device-specific information (e.g. hardware model, operating system information, unique device identifiers and mobile network information, including phone number) which we may associate with your Community Sift account (where applicable); and/or
- Log information (e.g. details of how you use our service, internet protocol address, system and device event information such as crashes, system activity, hardware settings, browser type, browser language and the date and time of use of our service, and cookies that may uniquely identify your browser or your Community Sift account).
1.4. Web Analytics and Cookies - We may use (third party) services and tools to analyze non-identifiable web traffic data with the purpose of improving the services we offer. We own and store the data that is generated on our secure web server. The collected data will not be shared with any other party for any other purpose.
We may collect the following information to assist us with improving the website:
- The pages accessed on our site and links you clicked on
- The date and time you visited the site
- If you use our advanced search tool, the search terms you used
- The referring site (if any) through which you arrived at this site
- Your operating system (e.g. Windows XP, Mac OS X)
- The type of web browser you use (e.g. Internet Explorer, Mozilla Firefox)
IP addresses are anonymized so that they cannot be used to identify individuals. Our web analytics will also respect any "do not track" setting you might have set on your browser.
Our website may use session cookies which are stored in temporary memory and are not retained after you sign out or close the browser session.
A cookie is a small file containing certain pieces of information that a website creates when you visit the site. It can track how and when you use a site, which site you visited immediately before, and it can store that information about you. Cookies cannot be used to run programs or deliver viruses to your computer. There are two types of cookies, session cookies and persistent cookies. Our website may use session cookies which are stored in temporary memory and are not retained after you sign out or close the browser session.
Policy 2 – Consent
2.1. We will obtain the consent of our Customers and Users to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2. Consent can be provided orally, in writing, electronically and/or through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the Customer or User voluntarily provides personal information for that purpose.
2.3. Consent may also be implied where a Customer or User is given notice and a reasonable opportunity to opt-out of his or her personal information being used for direct marketing of our services or products and the Customer or User does not opt-out.
2.4. Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), Customers and Users can withhold or withdraw their consent for Community Sift to use their personal information in certain ways. A Customer’s or User’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the Customer or User in making the decision.
2.5. We may collect, use or disclose personal information without the Customer’s or User’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- To protect ourselves from fraud; or
- To investigate an anticipated breach of an agreement or a contravention of law.
Policy 3 – Using and Disclosing Personal Information
3.1. We will only use or disclose Customer or User personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To conduct Customer and User surveys in order to enhance the provision of our services;
- To contact our Customers and Users directly about products and services that may be of interest to them; and
- To enable related entities and third party service providers to deliver requested products, services and/or information.
3.2. We will not use or disclose Customer or User personal information for any additional purpose unless we obtain consent to do so.
3.3. We will not sell, lease or rent Customer or User lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1. If we use Customer or User personal information to make a decision that directly affects the Customer or User, we will retain that personal information for at least one year so that the Customer or User has a reasonable opportunity to request access to it.
4.2. Subject to policy 4.1, we will retain Customer and User personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1. We will make reasonable efforts to ensure that Customer and User personal information is accurate and complete where it may be used to make a decision about the Customer or User or disclosed to another organization.
5.2. Customers and Users may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer identified below.
5.3. If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the Customer’ or User’s correction request in the file.
Policy 6 – Securing Personal Information
6.1. We are committed to ensuring the security of Customer and User personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2. The following security measures will be followed to ensure that Customer and User personal information is appropriately protected:
- Physically securing offices where personal information is held;
- The use of User IDs and passwords (where applicable);
- The use firewalls for stored personal information;
- Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access and such access will require a password);
- Contractually requiring any service providers to provide comparable security measures.
- Regularly training and reminding employees so that they know our privacy policies and PIPA’s requirements for protecting personal information, and the disciplinary consequences of not following them.
- Having employees enter into confidentiality agreements regarding personal information.
- Conducting regular privacy audits to ensure employee compliance with our privacy policies.
- Positioning computer monitors so that personal information displayed on them cannot be seen by unauthorized personnel or by visitors.
- Using password-protected computer screensavers so unauthorized personnel or visitors cannot see personal information.
- Ensuring your computers and network are secure from intrusion by using firewalls, intrusion detection software, antivirus software, and by encrypting personal information.
- Using strong and secure passwords to make sure that only authorized employees have access to computer storage devices or to the network. Changing those passwords on a regular basis.
- Encrypting personal information stored on mobile electronic devices such as laptops and USB flash drives.
- Securely wiping all personal information from hard drives before they are discarded, sod or donated. Deleted files can be recovered while wiped files cannot. Wiping may require specialized software.
6.3. We will use appropriate security measures when destroying Customer’s and User’s personal information such as shredding documents and deleting electronically stored information.
6.4. We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customers and Users Access to Personal Information
7.1. Customers and Users have a right to access their personal information, subject to limited exceptions outlined in section 23 of PIPA.
7.2. A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer identified below.
7.3. Upon request, we will also tell Customers and Users how we use their personal information and to whom it has been disclosed, if applicable.
7.4. We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the Customer or User of the cost and request further direction from the Customer or User on whether or not we should proceed with the request.
7.6. If a request is refused in full or in part, we will notify the Customer or User in writing, providing the reasons for refusal and the recourse available to the Customer or User.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
8.1. The Privacy Officer is responsible for ensuring Community Sift’s compliance with this policy and the Personal Information Protection Act.
8.2. Customers and Users should direct any complaints, concerns or questions regarding Community Sift’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, Customer, member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Community Sift’s Privacy Officer:
500-554 Leon Ave
Kelowna, BC, Canada V1Y 6J6
email: firstname.lastname@example.org Tel: 1-855-407-0889 FREE
8.3. We may designate another individual other than the Privacy Officer as the person to contact for any requests related to this Personal Information Protection Policy by updating the contact information in policy 8.2.
Policy 9 – Changes
9.1. We may change our Personal Information Protection Policy from time to time and any such changes will be posted in this Personal Information Protection Policy. We will not reduce your rights under this Personal Information Protection Policy without your express consent.