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RFA LABS CUSTOMER PRIVACY POLICY

Our Privacy Philosophy

We are committed to fairly and lawfully collecting and maintaining accurate personal information and to protecting the confidentiality of all personal information that we collect, retain, use, or disclose to others during our business activities.

Our Continuing Commitment to our Customers

Protecting the privacy and confidentiality of personal information is fundamental to the way we do business. We strive to meet or exceed all the privacy standards established by federal, provincial and industry authorities in all our dealings with past, current and prospective customers.

We Live by It, Everyday

As a condition of their employment, every employee acknowledges their agreement to be bound by the Code of Conduct, which refers to policies, such as this Privacy Policy (the “Policy”), including a confidentiality section obligating them to maintain the confidentiality of information both during and after their employment with us. RFA Labs has appointed a Privacy Officer to ensure compliance with this Policy.

What Is Personal Information?

Personal information is information that identifies you as an individual. It includes your name and address, age, and gender, also your personal financial records, identification numbers including your social insurance number, personal health information, personal references, and employment records.

What is in this Policy?

This policy has been developed to meet the standards set out in Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and similar provincial legislation. The policy describes the principles RFA Labs will use to protect the privacy of personal information we possess about our clients, including sole proprietors and individuals carrying on business in a partnership, and establishes ethical and fair information management practices with respect to personal information collected, used or disclosed by RFA Labs. The policy informs customers how personal information is handled by RFA Labs.

Application of This Policy

This policy applies to all RFA Labs directors, officers, and employees with respect to any personal information in its possession or control. This policy does, however, apply to information about officers, staff, or principals of corporate clients, such as those providing personal guarantees of corporate loans.

RFA Labs Relationships

RFA Labs is in the business of providing various technical services to its customers. This includes information security, IT infrastructure and changes management including software development.

The Reasonable Person Approach

PIPEDA is about sound information management practices. It requires an ethical, common sense, “reasonable person” approach to requesting, validating, and maintaining personal information as a part of our business activities. Confidentiality is a sensitive topic.

Principles

RFA Labs endorses and has adopted the privacy principals set out in full in Schedule 1 of the PIPEDA. These privacy principles embody sound and prudent information management practices. These practices will provide the necessary assurances that personal information obtained and utilized by RFA Labs during its business activities will be accurate, held in confidence and be retained in a secure environment. Below is a summary of how RFA Labs will adhere to the PIPEDA Principles.

Principle 1: Accountability

RFA Labs takes responsibility for protecting and maintaining personal information under its control and has appointed a Privacy Officer to ensure compliance with these principles and PIPEDA.

Principle 2: Identifying the Purposes for Collecting Personal Information

RFA Labs collects data solely from business customers with whom we have a contract. The collector is responsible for obtaining proper consent, providing access to data, and determining retention periods

Principle 3: Consent

RFA Labs does not collect any information from the “public", but only as part of its IT management of contractual business partners.
We may collect, use, and disclose personal information without consent in limited cases as permitted by applicable law.

Principle 4: Limits to the Collection of Personal Information

RFA Labs does not collect any information from the “public", but only as part of its IT management of contractual business partners.
Individuals may visit our website without revealing any personal information. We do not collect personal information from visits to the website unless the information is provided to us voluntarily.

Principle 5: Limits to the Use, Disclosure and Retention of Personal Information

RFA Labs will use or disclose personal information only for the reasons it was collected and for which the customer has obtained and provided consent.
Occasionally we may choose to store or process personal information in countries other than Canada. Our privacy obligations continue to apply to this information, even when it is in other countries. However, as is the case in Canada, government authorities may be able to access this personal information as permitted by applicable law of those countries.

Principle 6: Ensuring Accuracy

RFA Labs will manage its IT processes such that data is not rendered inaccurate (for instance, data will be verified when transferred).

Principle 7: Safety & Security

RFA Labs will safeguard the privacy of personal information through organizational, physical, and technological security measures appropriate to the sensitivity of the information and protect the personal information from loss, theft, unauthorized access, disclosure, copying, use or modification.

Principle 8: Openness

Customers will ensure issues related to privacy are handled according to their privacy frameworks.

Principle 9: Individual Access

Customers will ensure issues related to privacy are handled according to their privacy frameworks.

Principle 10: Handling Inquiries

RFA Labs will respond to questions, concerns, and complaints about the privacy of personal information in a timely manner. Any individual who has questions or concerns about privacy can direct them to the Privacy Officer.
If any concerns remain unresolved by the Privacy Officer, an individual may contact the Office of the Privacy Commissioner of Canada (OPC). The OPC oversees compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s private sector privacy law. Individuals have the right to complain at any time to the OPC about any alleged mishandling of personal information under PIPEDA.

Office of the Privacy Commissioner of Canada
3rd Floor, Place de Ville
112 Kent Street
Ottawa, Ontario K1A 1H3 Call:
1-800-282-1376
Visit: www.priv.gc.ca

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