Merideth Bisiker, Certified Life Coach
Personal Information Protection Policy
At Merideth Bisiker, Executive Coach (referred to as “Merideth Bisiker” in this Policy) I am committed to providing my clients, website users and subscribers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about my clients, website users and subscribers, protecting their personal information is one of my highest priorities
I respect my clients’, website users’ and subscribers’ privacy and safeguard their personal information, and I have strengthened my commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, and sets out the ground rules for how businesses in British Columbia and not-for-profit organizations may collect, use and disclose personal information.
I will inform my clients, website users and subscribers of why and how I collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices I will follow in protecting clients’, website users’ and subscribers’ personal information. My privacy commitment includes ensuring the accuracy, confidentiality, and security of my clients, website users and subscribers’, and customers’ personal information, and allowing my clients, website users and subscribers to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Merideth Bisiker business operating as a sole proprietorship, and doing business as “Merideth Bisiker, Certified Life Coach.” This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Merideth Bisiker, such as contracted and employee administrative assistants, marketing consultants, for example.
Personal Information – means information about an identifiable individual, including name age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information]. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Merideth Bisiker complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client, website user, and subscriber voluntarily provides his or her personal information for those purposes, I will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 I will only collect client, website user, and subscriber information that is necessary to fulfill the following purposes:
To verify identity;
To identify client, website user and subscriber preferences;
To understand the financial needs of my clients, website users and subscribers;
To open and manage an account;
To deliver requested products and services;
To enroll the client in a program;
To ensure a high standard of service to my clients, website users and subscribers;
To meet regulatory requirements.
Policy 2 – Consent
2.1 I will obtain client, website user, and subscriber consent to collect, use or disclose personal information (except where, as noted below, I am authorized to do so without consent).
2.2 Consent can be provided orally, in writing, by subscription enrolment, electronically, and/or through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, website user, or subscriber voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client, website user and subscriber is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, website user, and subscriber does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, website users and subscribers can withhold or withdraw their consent for Merideth Bisiker to use their personal information in certain ways. A client’s, website user’s and subscriber’s decision to withhold or withdraw their consent to certain uses of personal information may restrict my ability to provide a particular service or product. If so, I will explain the situation to assist the client, website user, and subscriber in making the decision.
2.5 I may collect, use or disclose personal information without the client’s, website user’s and subscriber’s knowledge or consent in the following limited circumstances:
When the collection, use or disclosure of personal information is permitted or required by law;
In an emergency that threatens an individual’s life, health, or personal security;
When the personal information is available from a public source (e.g., a telephone directory);
When I require legal advice from a lawyer;
For the purposes of collecting a debt;
To protect myself from fraud;
To investigate an anticipated breach of an agreement or a contravention of law.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client, website user, and subscriber personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
To conduct client, website user, and subscriber surveys in order to enhance the provision of my services;
To contact my clients, website users and subscribers directly about products and services that may be of interest.
3.2 I will not use or disclose client, website user, and subscriber personal information for any additional purpose unless I obtain consent to do so.
3.3 I will not sell client, website user, and subscriber lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If I use client, website user, and subscriber personal information to make a decision that directly affects the client, website user, and subscriber, I will retain that personal information in digital format(s) for at least one year so that the client, website user, and subscriber has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, I will retain client, website user, and subscriber personal information in digital format(s) only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 I will make reasonable efforts to ensure that client, website user, and subscriber personal information is accurate and complete where it may be used to make a decision about the client, website user, and subscriber or disclosed to another organization.
5.2 Clients, website users and subscribers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, I will correct the information as required and send the corrected information to any organization to which I disclosed the personal information in the previous year. If the correction is not made, I will note the clients, website users and subscribers’, correction request in the file.
Policy 6 – Securing Personal Information
6.1 I am committed to ensuring the security of client, website user, and subscriber personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client, website user, and subscriber personal information is appropriately protected:
Storing all client data digitally using secure cloud storage application(s); When data cannot be stored digitally, making the use of locked filing cabinets; physically securing offices where personal information might be held;
the use of user IDs, passwords, encryption, firewalls;
restricting employee and contractor access to personal information as appropriate (i.e., only those that need to know will have access;
contractually requiring any service providers to provide comparable security measures.
6.3 I will use appropriate security measures when destroying clients’, website users’ and subscribers’ personal information such as shredding documents and deleting electronically stored information.
6.4 I will continually review and update my security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients, Website Users and Subscribers Access to Personal Information
7.1 Clients, website users and subscribers have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, I will also tell clients, website users and subscribers how I use their personal information and to whom it has been disclosed if applicable.
7.4 I will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, I will inform the client, website user, and subscriber of the cost and request further direction from the client, website user, and subscriber on whether or not I should proceed with the request.
7.6 If a request is refused in full or in part, I will notify the client, website user, and subscriber in writing, providing the reasons for refusal and the recourse available to the client, website user, and subscriber.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 I am responsible for ensuring Merideth Bisiker’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients, website users and subscribers should direct any complaints, concerns or questions regarding my compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, website user, and subscriber may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Merideth Bisiker’s Privacy Officer is:
PO Box 20081 Qualicum Centre PO
Qualicum Beach, V9K 0B1
Policy 1 – Personal Information We Collect
When you visit the Site, I automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, I collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
I collect Device Information using the following technologies:
“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally, when you make a purchase or attempt to make a purchase through the Site, I collect certain information from you, including your name, billing address, shipping address, payment information including credit card numbers, email address, and phone number. We refer to this information as “Order Information.”
When I talk about “Personal Information” in this Policy, I am talking both about Device Information and Order Information.
Policy 2 – Use of Personal Information
I use the Order Information that I collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, I use this Order Information to communicate with you:
Screen my orders for potential risk or fraud; and
When in line with the preferences you have shared with us, provide you with information or advertising relating to my products or services. We use the Device Information that I collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize my Site (for example, by generating analytics about how my customers browse and interact with the Site, and to assess the success of my marketing and advertising campaigns).
Policy 3 – Sharing Your Personal Information
I share your Personal Information with third parties to help us use your Personal Information, as described above. Our clients’ digital data is stored in Canada and the United States.
In addition, I use CoachAccountable as my Client Relationship Management (CRM) system. You can read more about how CoachAccountable uses your Personal Information here: www.coachaccountable.com/privacy.
We also use Google Analytics to help us understand how my customers use the Site. You can read more about how Google uses your Personal Information here:
https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, I may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information I receive, or to otherwise protect my rights.
Policy 4 – Behavioural Advertising
As described above, I use your Personal Information to provide you with targeted advertisements or marketing communications I believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
Policy 5 – Do Not Track
Please note that I do not alter my Site’s data collection and use practices when I see a Do Not Track signal from your browser.
Policy 6 – Your Rights
If you are a European resident, you have the right to access personal information I hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident, I note that I am processing your information in order to fulfill contracts I might have with you (for example if you make an order through the Site), or otherwise to pursue my legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
Policy 7 – Data Retention
When you place an order through the Site, I will maintain your Order Information for my records unless and until you ask us to delete this information.
Policy 8 – Minors
The Site is not intended for individuals under the age of 18 years old.
Policy 9 – Changes
Policy 10 – Payment Processing and Refunds
I use various types of payment processing tools which depend on the type of product sold. I collect payments four ways: E-transfer (Canadian clients), PayPal (Canadian and international clients, online sales), and Stripe (online sales).
Refund policies apply to each individual service and product agreement and will be available to read and acknowledge when making a purchase or entering into a contract.
For more information about my privacy practices, or if you have questions you would like to make a complaint, please contact me by e-mail at firstname.lastname@example.org or by mail using the details provided below:
PO Box 20081 Qualicum Centre PO
Qualicum Beach, BC V9K 0B1