Personal information is information about an identifiable individual. This includes information about your product and service subscriptions, usage, billing records, credit information and any recorded complaints. Please note that, pursuant to federal privacy legislation, publicly available information – including a directory listing of your name, address, telephone number and electronic address – may be collected, used and disclosed without your consent. The client’s contact information may be used to contact the visitor when necessary and may be shared with other affiliated companies within Pathway who may want to contact our visitors. Only Pathway has access to your personal information.
Collection and Use of Information
We collect and use personal information about you and your use of our products and services and our web sites (the “Information”) for the following purposes:
- To consider initiating and to establish, maintain and develop a responsible commercial relationship with you in connection with our offering and servicing of products and services.
- To administer billing and accounting services and security measures in relation to your business with us.
- To monitor your client history, evaluate your credit standing, to share or exchange credit reports and information with credit reporting agencies and credit bureaus and to collect any unpaid amounts owing to us.
- To promote and to market additional products, goods and services offered by us, including by means of direct marketing.
- To provide you with newsletters via email.
- To provide personalized features and services.
- To analyze traffic and use of the Pathway web sites in order to determine which features and services people like and don’t like so we can improve what we do.
- To prepare aggregated user statistics or information summaries in order to describe our services to third parties such as prospective business partners and advertisers and for other lawful purposes.
- To present web page advertisements that we hope will be of particular interest to you.
- To contact you to fulfill distribution of prizes if you win a promotion or contest.
- To comply with any legal and regulatory requirements, including requirements.
- To manage and develop our business and operations, including personnel and employment matters.
- Requests of government agencies or pursuant to a subpoena or other legal proceeding.
- To maintain the health and safety for all staff and visitors by confirming the lack of symptoms for illnesses which are deemed detrimental to general health and safety by Public Health Ontario or similar entities.
Withdrawal of consent or correction of information
We only collect, use or disclose your personal information if we have your consent, or in circumstances where your consent isn’t necessary. You may withdraw your consent at any time. However, doing so could potentially impact your service with the Pathway Group of Companies. For example, you can opt-out of a variety of marketing communications by us, including commercial electronic messages. If you would like to withdraw consent, or make updates or corrections to your personal information, please let us know either by phone, 416-214-6363 ext 2801, or email, email@example.com. Our customer service agents are available 24/7 to work with you to resolution. More information can be found here: https://www.pathcom.com/how-to-share-a-concern-with-pathway
Use of “Cookies”
Access to Information
We reserve the right to contact you regarding account status, billing notifications, account renewal, changes to any Pathway product and service offerings, and other matters relevant to the underlying service and/or the personal information collected. When your Internet account is established with us, your primary email address and subsequent email addresses created by you are automatically subscribed to the following mailing lists:
- Emergency systems status notifications, network alerts and virus warnings from Technical Support and Customer Services.
- Special offers, product upgrades, new service or product offerings and marketing newsletters from Pathway.
Our Chief Technical Officer (CTO) oversees privacy compliance and delegates duties as needed to the Governance and Compliance team.
Summary of Privacy Principles
In compliance with the Personal Information Protection and Electronic Documents Act that came into effect on January 1, 2001, Pathway has adopted for the management of personal information of its clients and employees that we collect, use or disclose. These principles are in accordance with the Personal Information Protection and Electronic Documents Act and the ten principles of Canadian Standards Association Model Code for the Protection of Personal Information (the “Privacy Principles”). Principle 1 – Accountability Pathway is responsible for personal information under their control and shall designate one or more persons who are accountable for compliance with the following principles. Principle 2 – Identifying Purposes The purposes for which personal information is collected shall be identified by Pathway at or before the time the information is collected. Principle 3 – Obtaining consent The knowledge and consent of a client or employee is required for the collection, use or disclosure of personal information, except where inappropriate. Principle 4 – Limiting Collection The collection of personal information shall be limited to that which is necessary for the purposes identified by Pathway. Pathway shall collect personal information by fair and lawful means. Principle 5 – Limiting use, disclosure and retention of personal information Pathway shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by the law. Personal information shall be retained only as long as necessary for fulfilment of those purposes. Principle 6 – Accuracy of personal information Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Principle 7 – Security safeguards Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Principle 8 – Openness concerning policies and Practices Pathway shall make readily available to clients and employees, specific information about its policies and practices relating to the management of personal information. Principle 9 – Client and employee access to personal information Pathway shall inform a client or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A client or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate. Principle 10 – Challenging compliance A client or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the Pathway’s compliance with the Code. To request access to your personal information please contact TSD@pathcom.com or call 416-214-6363 ext. 2801.
The policy is reviewed on an as needed basis. A formal annual review will also occur.