• how and why we collect, use, and sometimes disclose your Personal Information;
• how and when your informed consent will be requested (along with certain exceptions);
• how you can access your Personal Information that we hold; and
• who to contact if you have questions or concerns about your privacy.
5. Is all information that identifies me considered protected Personal Information? Not necessarily. When certain Personal Information, such as your name, address, telephone number and e-mail address, is listed in a public directory, it is not protected by privacy laws. Your business contact information, such as name, title, business address, telephone number and business e-mail address used in relation to your employment or business, is also exempt. Information about you, but which cannot be associated with you as an identifiable individual, is not considered to be Personal Information. For example, information about you that has been de-identified so that it doesn’t identify you as an individual is not Personal Information.
Consent and Your Personal Information:
6. Does The Source need my consent to collect, use or disclose my Personal Information? It depends on the type of Personal Information and the particular circumstances. When it is reasonable in the circumstances, we will imply consent from your actions. For example, if you give us your address we may use it to send you important notices related to products and services purchased from The Source on the basis that your consent can be reasonably implied. In other situations, we may need your express consent before we collect, use or disclose your Personal Information. For example, we would first get your express consent before using your Personal Information to perform a credit check. Express consent is when you explicitly consent verbally, or by signing a document, or ticking a box or performing a similar act demonstrating your consent. Sometimes it may be impossible or inappropriate to obtain your consent, and in those cases, we may collect, use or disclose your information without your consent. For example:
(a) if it is clearly in your interests (such as a medical emergency or a threat to your safety);
(b) to comply with a warrant or other court order;
(c) to collect a debt;
(d) to investigate the breach of an agreement or applicable law; or
(e) as otherwise legally required or allowed.
7. How does The Source obtain my consent? It depends on the circumstances, including the type of Personal Information collected, used or disclosed. We may imply your consent if it is reasonable in the circumstances. We may ask for your express consent when our collection, use or disclosure of Personal Information is more sensitive or not necessarily expected. Here are examples of implied and express consent: As a customer of The Source, we rely on implied consent to send you product shipment tracking information via email to the email address you provide after you make a purchase online. However, we would request your express consent before we would use your Personal Information to enable individual location-based marketing for a third-party (unless you have already provided such consent to the third-party).
8. Does The Source need consent to use de-identified information? No. The Source may de-identify your Personal Information so that you cannot be identified as an individual, and use that de-identified information to improve The Source’s operations, and to develop analytic marketing reports for our use and for the use of our partners.
Collection, Use, Disclosure and Your Personal Information:
9. When does The Source collect my Personal Information? It depends on the purpose for collection and the product or service involved. Below are some examples of when we collect Personal Information:
(a) when you provide your Personal Information, during the inquiry, activation or purchase process for a product or service sold by The Source or when you apply for a job;
(b) when The Source provides service to our customers, including technical support or during the warranty, repair claims and service process;
(d) from third-parties, such as credit reporting agencies, or other third-parties with whom you have had a payment relationship.
10. How does The Source use my Personal Information? The Source uses your Personal Information to provide you with our products or services. The Source may also use your Personal Information to:
(a) establish and maintain responsible commercial relations with you and to provide ongoing service;
(b) understand the needs and preferences of our customers, and determine your eligibility for products and services;
(c) recommend products and services to meet your needs;
(d) develop, enhance, market or provide products and services;
(e) manage and develop business operations; or
(f) meet our legal and regulatory requirements.
Where necessary, we will request your further consent before using your Personal Information for any new purpose(s) beyond those described above.
11. When is my Personal Information disclosed? We may disclose some of your Personal Information in a variety of circumstances, such as when we have your express or implied consent. Your Personal Information will also be shared between the Bell companies and brands as they exist over time, including Bell Aliant, Bell Canada, Bell Mobility, Bell ExpressVu LP (Bell TV), Bell Media, Bell Mobility, Cablevision du Nord, DMTS, KMTS, NorthernTel, Ontera, Virgin Mobile, Solo Mobile and Telebec. We may also disclose your Personal Information:
(a) to a person acting as your agent (such as a legal representative or authorized user) if we are reasonably satisfied that the person is authorized to receive your Personal Information;
(b) to our suppliers and authorized agents who assist with activities such as providing The Source branded credit cards and fulfilling elements of our product care plans, subject to strict security safeguards;
(c) to a communications service provider in order to facilitate the provision of your communications services (for example, to activate your mobile device purchased at The Source);
(d) to third-party collection agencies for the purpose of collecting amounts owed to The Source which are past due;
(e) to third-parties, such as credit reporting agencies or anyone you have had a payment relationship with, to assess creditworthiness or assist with the collection of amounts owed to The Source which are past due and delivery organizations to ship you products and/or services you have ordered;
(f) to a government institution or another organization if reasonably necessary to establish your identity or to investigate the contravention of a law or an agreement or to prevent fraud;
(g) to an appropriate public authority in an emergency situation where there is imminent danger to life or property;
(h) as you have otherwise given us, or a third-party (like a financial institution, government agency, or on-line site) your consent to do so; or
(i) as otherwise allowed or required by law. Where necessary, we will request your further consent before disclosing your Personal Information for any new purpose(s) beyond those described above. Withdrawing Your Consent:
12. Can I opt-out of the collection, use or disclosure of my Personal Information by The Source? Sometimes. You can withdraw your consent, or opt-out, of the collection, use or disclosure of your Personal Information in certain situations. For example, where you have provided express consent to receive commercial electronic messages, you can opt-out later if you wish. Similarly, you can opt-out of your Personal Information being used for a variety of marketing communications by The Source, including telemarketing or addressed marketing mail. But where your Personal Information is reasonably necessary to provide you with the services you requested (such as product care plans) or to manage The Source business operations, you cannot opt-out of the collection, use and disclosure of your Personal Information because it is a condition of service. To stop the collection, use and disclosure of your Personal Information in these circumstances, you must terminate your services.
Accuracy and Safeguarding of Your Personal Information:
13. How do I learn more about my Personal Information and if it is accurate? Just ask us by contacting The Source Privacy Officer (see section 19 for contact information). We will give you the opportunity to review the Personal Information in your file, subject to certain restrictions and exceptions, within a reasonable time after receiving a request in writing from you. If we cannot provide you with access to your Personal Information (for example, if it would involve the disclosure of someone else’s Personal Information or other confidential or privileged information), then we will advise you of the reason why. Our goal is to keep the Personal Information we hold about you accurate, up-to-date and complete. If you find an inaccuracy let us know and we will correct it.
15. Will my Personal Information ever be transferred, stored or processed outside of Canada? Yes, sometimes. But your Personal Information is only provided to The Source’s suppliers and authorized agents operating outside of Canada in accordance with safeguards no less rigorous than those that we apply in Canada. Personal Information processed outside of Canada may only be used by such third parties for the purposes we set. In such cases, however, your Personal Information may be subject to the legal jurisdiction of foreign countries.
16. How long is my Personal Information kept? Only as long as reasonably necessary or relevant for the identified purposes or as required by law. Once Personal Information is no longer reasonably necessary or relevant for the identified purposes, or required by law to be retained, such information is destroyed, erased or de-identified. Changes, Questions and Contact Information:
18. Which laws apply to The Source’s collection, use and disclosure of my Personal Information? We design our privacy practices to comply with applicable Canadian Federal, provincial and territorial laws, including the Personal Information Protection and Electronic Documents Act.
19. Questions or concerns about The Source’s privacy practices? Please visit our privacy pages at thesource.ca/privacy for additional information or contact Customer Care at 1-866-515-5855. If one of our service representatives cannot address your concerns to your satisfaction, contact:
The Office of The Source’s Privacy Officer
The Source (Bell) Electronics Inc.
279 Bayview Dr
L4M 4W5 or via email at email@example.com.
20. What if I still have concerns after contacting The Source’s Privacy Officer? If The Source’s Privacy Officer does not resolve your concern to your satisfaction, you can contact:
Office of the Privacy Commissioner of Canada
30 Victoria Street
The Source Privacy Team