Privacy Policy
In accordance with the Personal Information Protection and Electronic Documents Act of Canada, the Personal Information Protection Act of British Columbia and other applicable privacy laws of Canada, iMemorized Inc. (iMemorized) as a covered organization, is required to ensure that appropriate security measures and management processes regarding the personal information under its control are instituted. As part of the same laws, iMemorized must designate a Privacy Officer and establish a complete and compliant privacy policy.
For the purposes of this Policy, “personal information” means information about an identifiable individual and includes employee personal information but does not include contact information or work product information.
Subscribers have highly-secure encrypted mobile access 24/7 to all their user names, passwords, pin numbers and other important information. Electronic copies of important documents like passports, drivers license, credit cards, investments, wills, living will and even voice memos and videos diaries can be permanently stored.
Principles of iMemorized’s Privacy Policy
Accountability. iMemorized is accountable and responsible for personal information under its control. iMemorized has designated a Privacy Officer who is accountable for iMemorized’s privacy compliance. To ensure accountability, iMemorized has informed its employees about this Privacy Policy and practice.
Identifying Purposes. iMemorized will identify the purposes for which personal information is collected before, or at the time it collects the personal information, as required by law. The purpose will be identified in plain language. Personal information will not be used or disclosed for any new purpose without first identifying the new purpose and providing notice to the employee or obtaining the consent of the individual, as applicable, unless permitted by law.
Notice and Consent. iMemorized may provide notice to its employees before collecting, using or disclosing personal information reasonably necessary for establishing, managing or concluding the employment relationship. Notice may be express, constructive or implied in the circumstances. In all other cases, iMemorized will obtain consent from individuals regarding the purpose for collection, use or disclosure of personal information. Consent may be express, deemed or implied. In determining the appropriate form of notice or consent, iMemorized will consider the sensitivity of the personal information and the reasonable expectations of the subject individual.
In some circumstances, iMemorized may collect, use or disclose personal information without notice or consent when:
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seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or law;
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it is clearly in the individual’s best interest and the appropriate notice or consent cannot be obtained in a timely manner;
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in the reasonable judgment of iMemorized it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information to a public authority or agent of a public authority; and
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it is to a lawyer representing iMemorized, to comply with a subpoena, warrant or other court order or as may be otherwise required or authorized by law.
Limiting Collection. iMemorized will limit its collection of personal information to that which is necessary. iMemorized will collect personal information by fair and lawful means.
Limiting Use, Disclosure and Retention. iMemorized will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of an individual or as required by law. iMemorized will retain personal information for only as long as necessary for the fulfilment of those purposes. If personal information has been used to make a decision about an employee or another individual, iMemorized will keep the personal information for a reasonably sufficient period to allow the individual to have access to it after the decision has been made. iMemorized will maintain controls, schedules, practices and procedures for retention and destruction of personal information.
Accuracy. iMemorized will take actions to ensure that the personal information it is using or disclosing is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Safeguards. iMemorized will protect personal information by using security safeguards appropriate to the sensitivity of the personal information.
Openness. iMemorized will make this privacy policy available to employees and other individuals.
Individual Access. Upon request, an individual will be informed by iMemorized of the existence, use, and disclosure of his or her personal information and will be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Recourse. An individual will be able to address a challenge concerning compliance with the above principles to iMemorized’s Privacy Officer.
The Privacy Officer will document all verbal and written communications pertaining to privacy issues. If a contact is made verbally, the Privacy Officer may record the conversation or a third party may be present to act as a witness to ensure accuracy of documentation.
Permitted by law, iMemorized will provide an individual with access to his or her own personal information requested, with information about how it has been used and is being used by iMemorized. Where reasonably possible, iMemorized will identify from whom the personal information was collected, to whom it has been disclosed, and how and when disclosure took place.
To make a request for your personal information, send a written request to access your personal information that contains at a minimum the following:
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your full name, mailing address and telephone phone number; and
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the information requested.
The Privacy Officer will respond to you within 30 days. The Privacy Officer may ask you identity-related questions and/or use signature comparison or other documents to verify your identity.
The Privacy Officer will provide you access or a copy of the requested information if permissible. A request for access to personal information may be refused if:
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disclosure of the requested information is protected by solicitor-client privilege;
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the information relates to existing or anticipated legal proceedings against the individual making the request;
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it is work product information and/or disclosure could reveal confidential commercial or corporate information;
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disclosure of the requested information could reasonably be expected to threaten the life or security of another individual;
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disclosure would reveal personal information concerning another individual;
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disclosures would reveal the identity of an individual who has provided personal information concerning another individual, such as reports, assessments and reviews, and the individual providing the personal information does not consent to disclosure of his or her identity;
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the requested information was lawfully collected by iMemorized to ensure its availability and accuracy and the collection of the requested information by iMemorized was required for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
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the information was generated in the course of a formal dispute resolution process; or
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the request is frivolous or vexatious.
If an individual is not entitled to access to personal information on the above or other grounds and that information is severable from the record containing any other requested information, iMemorized will give the individual access after severing. In the event that iMemorized refuses access to any personal information requested by that individual, iMemorized would advise the individual of the refusal as well as the grounds for the refusal.
Upon a written request from an individual, iMemorized’s Privacy Officer will, as permitted by law, make any corrections requested or annotate personal information. To request a correction or annotation with respect to your personal information, send a written request to correct your personal information that contains at a minimum the following:
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your full name, mailing address and telephone phone number; and
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a complete listing of the personal information with error or omission and correction clearly noted.
The Privacy Officer will review your request. The Privacy Officer will obtain clarifications from you, if necessary. The Privacy Officer may ask you identity-related questions and/or use signature comparison or other documents to verify your identity. The Privacy Officer will respond to you within 30 days and will ensure the correction is made or may refuse to have the correction made if no error or omission can be confirmed. However, if the Privacy Officer refuses to have the correction made, the Privacy Officer will annotate the record indicating that you requested the correction and that it was not made.
iMemorized takes any complaint about its privacy practices seriously. iMemorized will investigate any complaint and will take all reasonable steps to resolve it. IMemorized will not dismiss, suspend, demote, harass or otherwise disadvantage an employee or other individual because the individual, acting in good faith, has invoked or may invoke, the provisions of this policy or any applicable federal or provincial privacy legislation.
To make a complaint, send a written complaint to iMemorized’s Privacy Officer that contains at a minimum the following:
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your full name, mailing address and telephone phone number; and
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he subject of your complaint including a detailed description of the issue including the date and location of the incident giving rise to the complaint.
The Privacy Officer will obtain clarifications from you if necessary and may ask you identity-related questions and/or use signature comparison or other documents to verify your identity. The Privacy Officer will manage your complaint according to applicable regulatory requirements. The provisions of this Privacy Policy are subject to change pursuant to the needs of iMemorized Inc. and any additional requirements mandated by law.
Contact Information
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Do not use electronic mail (e-mail) for confidentiality and security reasons.
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Privacy Officer:
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Mail: iMemorized Inc., 6459 Pat Bay Hwy, Victoria BC V8Y 1T8
Phone: (250) 479-0195
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Privacy Commissioner of Canada:
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Mail: 112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario, K1A 1H3
Phone: (613) 995-8210, Toll-free: 1-800-282-1376
Fax: (613) 947-6850
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Office of the Information and Privacy Commissioner for British Columbia:
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Mail: PO Box 9038, Stn. Prov. Govt., Victoria, BC V8W 9A4
Phone: (250) 387-5629, Toll-free: 1-800-663-7867
Fax: (250) 387-1696
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