("Heaven’s Email" or "we", "us", "our", etc)
Departed Connections Inc. the operators of the Heaven’s Email Website (“Heaven’s Email”) is committed to respecting the privacy of individuals and protecting personal information in its custody or control and complying with applicable privacy legislation.
Our head office is located in Canada and, for this reason, this policy is focussed upon compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). In view of our international operations it is important to note that privacy laws vary by jurisdiction and the rights and obligations described in this policy may not be available to all persons or in all jurisdictions.
This policy applies to those accessing and using the Heaven’s Email website located online at the url: [NTD: insert] (the “Website”). When accessing and using the Heaven’s Email website you are also agreeing to the Website Terms of Service [insert hyperlink] and those Services are subject to the Disclaimer [insert hyperlink].
What is Personal Information
Personal information does not include information that has been de-identified or rendered anonymous so as to prevent tracing of such information back to an identifiable individual.
Method to opt-out
If you choose to voluntarily submit personal information to us by using our services and Website, we will consider that you have consented to our collection, use and disclosure of this personal information for purposes reasonably related to your providing the information including the provision of Heaven’s Email services, and for the purposes set out in this Policy.
Where your personal information is held by a third party (i.e. your chosen payment processor), and we require this personal information in order to accomplish a purpose for which you have previously given your consent or in order to perform services or provide products that you have requested, we will consider that you have consented to our collection of such personal information for such purpose. Where we use the services of third parties (i.e. for services related to payment processing) in our business they may provide us with your personal information and we will make reasonable efforts to confirm that such parties are permitted to provide such information.
You may modify or revoke your consent at any time, with reasonable notice, subject to applicable laws and existing agreements, by sending a written message to our Privacy Officer. In some circumstances, a modification or revocation of consent may limit or prevent us from providing products or services to you.
We assume, unless you tell us otherwise, that by continuing to deal with us after having had this Policy made available to you that you consent to the collection, use and disclosure of your personal information as set out and for the purposes described in this Policy, where such consent is required by law.
Collection, Use and Disclosure of Personal Information
Heaven’s Email does not collect personal information unless it is voluntarily provided to us and is reasonably necessary for the purposes for which it was collected (i.e. to provide for access and use of the Website and related services) unless a user has provided consent to use or disclose for another purpose, or if such use or disclosure is otherwise authorized or required by law. While we generally do not disclose personal information to third parties, there are certain limited circumstances in which it may be necessary to do so and only that information that is specifically needed to fulfill the purpose for the disclosure is provided. In any case we will only retain personal information for as long as it is required to fulfill the purpose for which it was collected or such time as required by law, following which we will securely dispose of the information by using such methods as secure shredding, deletion or data wiping.
For example, we may collect, use, disclose and retain information (including personal information) for the following purposes:
- to open an account with us;
- to offer and provide services, including transmission of messages which may contain personal information;
- to process orders or payments for our services;
- to improve our website or services or to carry out customer surveys, in order to evaluate the needs, wants and satisfaction levels of our customers and to analyze and manage our business;
- to provide and administer services and monitor your purchases, fees paid and payable, payment history, parties to transactions, payments and payment card usage;
- to verify your identity as an authorized user concerning any accounts, and to implement, carry out and maintain security measures aimed at protecting our users from identity theft, fraud and unauthorized access to accounts;
- where required by law such as to comply with legal or regulatory requirements, including those related to security and in some circumstances, without your consent if such consent may defeat the purpose of the disclosure (i.e. to investigate a contravention of a law or court order);
- to promote and market products and services offered by us;
- to recommend particular products and services offered by Heaven’s Email or its carefully screened business partners;
- to manage and develop our business and operations;
- to respond to inquiries from you, understand your needs and preferences; and
- to meet legal and regulatory requirements;.
Please note that personal information may be transferred to other entities in the event of a change of control or ownership of Heaven’s Email or through a business combination such as a merger or joint venture. In such cases, we will ensure that appropriate agreements are in place so that such other entities may only use and disclosed the personal information transferred to them in a manner consistent with this policy.
Information collected when you use the site
Heaven’s Email will limit the amount and types of personal information to that which is reasonably required to fulfill a business purpose, communicate with our users or satisfy legal requirements. For example, the types of information we may collect includes: your name, province of residence, IP address, email address or other information to contact or identify you; information about the services provided to you; information about your transactions with us, including bills, credit history and payment preference; information from communications with you, including your feedback and requests for customer care; Website activity information, including the site you came from and the site you will visit next; and cookies.
What are Cookies?: we use a browser feature called a cookie to collect information anonymously and track user patterns on the site. A cookie is a small text file that is placed on your hard disk by a web site and contain a unique identification number that identifies your browser, but not you, to our computers each time you visit the site. Cookies tell us which pages of our web site are visited and by how many people. The information that cookies collect includes the date and time of your visit, your registration information, session identification number, and your navigational history and preferences.
Accuracy and Completeness
When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate, up to date, and complete. This may involve requesting further information or updates from you. We do request that you advise us of changes to your personal information so that our records may remain current.
Retention and Destruction
Generally speaking, the law allows us, for legal or business purposes, to retain personal information for as long as is reasonably necessary which is normally subsequent to the conversion and transmission of emails sent via the Website, to fm radio waves; however, such deletion will not result if we are otherwise required by law to retain or disclose the information. Upon expiry of an appropriate retention period and/or legal requirements, personal information will either be destroyed in a secure manner or made anonymous.
Should any consent, where consent is required, to our collection, use, disclosure or retention of personal information be revoked, the law also allows us to continue to retain the information for as long as is reasonable for legal or business purposes. In the event that revocation of any required consent may have consequences to the individual concerned, we will advise the individual of the consequences of revoking their consent where it is reasonable in the circumstances to do so.
Security of Personal Information
We recognize our legal obligations to protect personal information collected during the course of carrying on business. We have therefore made reasonable arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information. We employ appropriate industry standards in information security to protect the personal information of our users as well as safeguards intended to protect against the loss, misuse or unauthorized alteration of user information. For example, individual user IDs and passwords, data encryption, and authentication tools.
Please note that our website and our online services may contain links to other websites which are provided as a convenience for visitors to our website or users of our services only. Any third party websites will have their own privacy policies and practices, and we cannot be responsible for such third parties or their websites.
Requests for Access to Personal Information
The law permits individuals to submit written requests to us to provide them with:
- access to their personal information, if any, under our custody or control;
- information about the purposes for which their personal information under our custody or control has been and is being used by us; and
- the names of persons or entities to whom, and the circumstances in which, their personal information has been and is being disclosed by us.
Your ability to access your personal information under our control is not absolute and we reserve all our legal rights to not disclose personal information should we be of the view that it is not appropriate or reasonable to do so.
Responses to Requests for Access to Personal Information
Our response to requests for access to personal information will in all cases be in writing, and will confirm whether we are providing all or part of the requested information, whether or not we are allowing access or providing copies, and, if access is being provided, when that will be given.
If access or copies are refused by us, we will provide written reasons for such refusal and the section of PIPEDA on which that refusal is based, along with the name of person at Heaven’s Email who can answer questions about the refusal, and particulars of how the requesting individual can ask the Information and Privacy Commissioner of Canada to review our decision.
Requests for Correction of Personal Information
The law permits individuals to submit written requests to us to correct errors or omissions in their personal information where that information is in our custody or control. We do require that all such requests be in writing, with no exceptions, and email is not considered to be in writing. We reserve the right to require sufficient information and detail from the individual in question in order to properly locate the information and provide a response.
In the event that an individual alleges inaccuracies, errors or omissions in the personal information in our custody or control, we will either:
- correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
- decide not to correct the personal information but annotate the personal information that a correction was requested but not made.
Corrections or amendments will not be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.
Amendment of Policy
We reserve the right to amend this Policy from time to time as required and without notice by posting an amended version on our website. Revisions are effective upon posting to the Website therefore this policy should be revisited and examined from time to time to ensure your awareness of any revisions to the policy.
Contacting or Communicating with Us
PO Box 38086
Fax: [NTD: inster fax here]
In the event that a user submits a written complaint regarding our compliance with this policy, Heaven’s Email will take appropriate steps to investigate and address such a complaint with a response provided to the complainant.
Last Updated: October, 2011