COMPEL TECHNOLOGY INC. PRIVACY POLICY

At Compel Technology Inc., we have the commitment to protect the personal information we collect, use and disclose in the course of managing our Computer Company and providing technical support, products and services to our clients. Our clients include independent individuals, corporations, limited partnerships and self-proprietor companies. The following policy outlines our personal information practices in keeping with our obligations under the Personal Information Protection and Electronic Documents Act (PIPEDA).
Personal Information:
PIPEDA defines “personal information” as any information about an identifiable individual. This includes objective information such as salary ranges or ages. It also includes subjective information such as job evaluations. However, personal information does not include business contact information, including your name, title or position, business address, or telephone number.
Accountability:
Christopher Robitaille with Compel Technology Inc., is the Privacy Officer for the firm. He is responsible for ensuring compliance with PIPEDA and with this Privacy Policy. Although he is ultimately accountable for privacy compliance, other individuals such as the technical and administrative staff may be delegated to either act on behalf of the Privacy Officer or to take responsibility for occasional collection, use and disclosure of personal information.
Christopher Robitaille can be contacted by e-mail at [email protected] or by phone at (905) 307-9780 or by writing to:
Privacy Officer
Compel Technology Inc.
400 Esna Park Drive, Unit 8
Markham, On
L3R 3K2
Purposes for Collecting, Using or Disclosing Personal Information:
Our technical staff provides technical support, onsite services, product or licensing registration, network infrastructure deployment, setup and configuration of workstations and servers. Our sales and administrative staff provide proposals, invoices, statements and consulting. In order to meet our clients’ needs, we collect, use and disclose personal information for the following purposes:
• to establish and foster client relationships;
• to manage and maintain ongoing client relationships;
• to perform technical services, representing clients’ interests and provide technical services to third parties as required;
• to avoid infrastructure conflicts in technology and fulfill all other support duties;
• to distribute technical notices, quotations, invoicing and statements to companies that subscribe to our electronic and regular mailing processes;
• to exchange Company information with third parties in the context of, and preparation for, product deployment , including but not limited to building requirements, Internet services, Email and Web Services, consulting;
• to register licensing and agreements for products and extended warranties
• to issue invoices, administer accounts and accounts receivable, process payments, and to fulfill other contractual obligations;
• to maintain, develop and manage our customer management relations, technical knowledge-base and precedent systems and databases;
• to manage and maintain our information technology;
• to recruit potential employees;
• to manage our own human resources (payroll, benefits, and so on); and
• to comply with, applicable legal or regulatory requirements or provisions.
Consent:
Before we collect personal information, the purposes for the collection, as well as the purposes for its intended use or disclosure, will be clearly identified to the individual. We will then obtain consent from the individual. This consent will either be express, especially when the information is particularly sensitive, or it will be implied. For example, when someone contacts Compel Technology Inc. seeking technical advice and voluntarily provides us with their personal information, it is implied that the person wishes us to use that information for the purpose of providing the technical service. We will also imply consent for the collection, use and disclosure of personal information about individuals involved in matters in the interest of our clients.
Individuals can withdraw their consent at any time by contacting the Privacy Officer. In the case of our e-bulletins (Focus, Privacy Updates), we offer a simple and effective “opt-out” feature for individuals to withdraw their consent to the electronic mailings. Please note however, that due to our statutory, regulatory and professional obligations, withdrawing consent for certain uses and disclosures may affect our ability to continue to provide a client with the support or services he is receiving or would like to receive.
There are instances where we can or must collect, use or disclose personal information without consent. For example,
• if we need to collect or use information because it is clearly in the individual’s interest and consent is not available in a timely way;
• if we need to use or disclose information for an emergency that threatens an individual’s life, health or security;
• if we are investigating a breach of an agreement or contravention of federal or provincial law, and obtaining consent from the subject of the investigation would compromise the availability or accuracy of the information;
• if we need to disclose information to collect a debt a Client owes to Compel Technology Inc.;
• if we need to disclose information to comply with a subpoena, a warrant or an order made by a court or tribunal; and
• if we are required to disclose by law.

Limited Collection, Use, Disclosure and Retention:
We limit the collection, use and disclosure of personal information to that which is required to fulfill the purposes listed in this policy. As stated above, the purposes for the collection of personal information, as well as the purposes for its intended use or disclosure, will be clearly identified to the individual before we collect it. Should a new purpose arise for the use or disclosure of personal information, we will obtain fresh consent for that new purpose, unless one of the exceptions listed above applies to the situation.

All Employees of Compel Technology Inc. are obliged to sign a Non-Disclosure agreement based on our corporate privacy policy for the Personal Information Protection and Electronic Documents Act posted on our Web site at www.compeltechnology.com/PIPEDA.htm.

The retention of personal information is often governed by our statutory, regulatory or professional obligations. Even if this is not the case, we retain personal information only for as long as is required to meet its intended purposes. When personal information is no longer required to fulfil its intended purpose, it is either destroyed or rendered anonymous in such a way as to prevent accidental disclosure.

Accuracy:
We make every effort to ensure the personal information we collect, use and disclose is as accurate and up-to-date as is required to fulfill the purposes listed above. If an individual’s personal information requires amendment, she need only contact our Privacy Officer to ensure that the correction is made. Clients are encouraged to contact their lawyer to update their personal information. However, in order to provide individuals with a professional level of service and to maintain appropriate contact preferences, we may take the initiative and ask for updated personal information from time to time.

Safeguards:
We protect the personal information under our control from loss, misuse, prohibited access, and unauthorized alteration. This protection is provided by physically secure facilities, password protection, standard security practices and tools, and well-defined internal policies and practices.

Openness:
At Compel Technology Inc., we are committed to the protection of your privacy. It is important to us that our policies are clear and easily available. The most up-to-date version of our policy will always be posted on our Web site at www.compeltechnology.com/PIPEDA.htm or will be available by contacting our Privacy Officer, [email protected] or by phone at (905) 307-9780.

Access to Your Own Personal Information:
Clients may review any personal information concerning them-selves we have on file in our office by contacting us. Individuals who are not clients may request access to personal information we hold about them by e-mailing or writing your request to the Privacy Officer.
It is important to note that there will be instances when we can not provide access to your personal information. For example, if the information is secured upon the request of the Company’s management; if it is about another individual where disclosure would reveal confidential access to information; or if it was disclosed to the police or other lawful authorities and we are required to withhold the fact of the disclosure.
If you are concerned about the access we have provided or wish to advise us of inaccuracies in the information, you may contact our Privacy Officer.

Challenging Compliance with this Privacy Policy:
We will respond to complaints from individuals or questions about our compliance with this policy and with PIPEDA. We will investigate and attempt to resolve all complaints. To challenge our compliance with this policy please contact our Privacy Officer.
If you have any questions or concerns about your privacy and our role in protecting it, please contact our Privacy Officer.

If the Privacy Officer is unable to resolve the concern, individuals can contact the Privacy Commissioner of Canada at www.privcom.gc.ca or at:
112 Kent Street
Ottawa, ON
K1A 1H3
Tel: (613) 995-8210
Toll free: 1-800-282-1376
Fax: (613) 947-6850

We reserve the right to change our Privacy Policy at any time by posting a new Privacy Policy on our web site.