Phase 4 Films (“Phase 4”) has developed the following policy pursuant to Canada's "Personal Information Protection and Electronic Documents Act, 2000 c.5" (the "Privacy Act").
We're Here To Protect You - What This Policy Is About:
What is Personal Information?
Personal information is any piece of information about an identifiable individual. Personal information does not include the name, title, business address, or business telephone number of an employee of an organization ("Personal Information"). The terms "we", "us" and "our" means Phase 4 Films Inc. and its affiliated and subsidiary companies ("Phase 4 Films") which are involved in the distribution of filmed entertainment, and our authorized contractors, consultants and suppliers. "You" and "your" means the individual who is a customer (by virtue of viewing our materials or using our online services), employee or arm's length contractor of Phase 4 Films. Our family of websites may contain links to other sites that are provided and maintained exclusively by third parties. Websites provided and maintained by third parties are not subject to this Privacy Code. Please review the privacy policies on those websites to determine their information handling practices.
What Information Is Collected?
We collect three kinds of information from our websites:
(1) your voluntarily provided Personal Information;
(2) anonymous information about your visit; and,
(3) "cookie" based information to help us track which pages on our websites you're most interested in. (1) Your Personal Information: During normal website usage, you can visit our site without communicating any personal information. However, to make use of certain features on our site, such as contests, quizzes, promotions, personalized services, subscriptions or newsletters, users may be asked to register with the Phase 4 Films website. As part of this voluntary registration, we may request contact information (such as name, mailing address, e-mail address, etc.) and other data required for operating these services. We may only collect personal information from you if you voluntarily provide it. By voluntarily providing this personal information to us, by sending us a comment or suggestion, by entering a chatroom or bulletin board, or by entering a contest that is posted on our web site(s), you will be consenting to the collection, use and distribution of your personal information by us for the purposes set out herein. You are under no obligation to provide us with personal information, and may access and enjoy many parts of our website without providing us any personal information. Among other things, the following is a representative list of reasons we may ask for your personal information:
• To run contests, select entrants, and choose prize winners;
• To respond to your questions or the comments that you e-mail to us;
• To provide you with newsletters or other information about our films, special offers or services;
• To distribute to sponsors and advertisers who run the contests and/or for purposes of marketing by our sponsors and advertisers;
• To run chatrooms, discussion groups and bulletin boards;
• To gather aggregate information on website use. You should be aware that when you share personal information in public areas of our website(s), such as chat rooms, discussion groups or bulletin boards, this information might be seen and used by other members of the public. We urge you to exercise good judgment when sharing personal information in these forums. (2) Anonymous Information About Your Visit: When you visit our site, information about your visit (e.g. how you navigate the site) may be collected and stored. This information may include the length of your visit, the date and time of your visit, the pages you look at and the sites you visit before and after leaving our site. It does not include personally identifiable information such as your name, mailing or e-mail address or telephone number. We use this non-identifiable and aggregate information to better design our Web site(s). We also may share this information with our affiliates, suppliers, sponsors and advertisers. We collect the following non-identifiable information when you visit our web site(s): • Your IP address
• Your Internet Service Provider (ISP)
Children should always get permission from their parents before sending information about themselves (such as their names, e-mail addresses, and phone numbers) over the Internet. We will not knowingly encourage any minor to register with our site or to access those features which require registration. If a child has provided us with personal information, we ask that any concerned parent or guardian of the child contact us.
Protecting the privacy and confidentiality of Personal Information has always been an important aspect of our business operations. As a distributor of filmed entertainment, the proper collection and use of Personal Information is fundamental. We have implemented a complementary protocol we call our Privacy Code, which applies to any individuals about whom we collect, use or disclose personal information. It also sets out our respective rights and obligations as they relate to privacy laws and Phase 4’s own policies. Our Privacy Code informs you of our commitment to protecting Personal Information in our possession and control. It tells you the ways we ensure that Personal Information is protected. This Privacy Code applies to all employees, individuals using our products and services and to certain persons with which Phase 4 has contracted. Each of our employees must abide by our commitment to privacy in the handling of Personal Information.
The Ten Privacy Principles of the Privacy Code
Our Privacy Code includes the following ten principles, as set out in the Privacy Act:
1. We are Accountable
We take our commitment to securing privacy very seriously. Each employee and representative of Phase 4 Films is responsible for the Personal Information under his, her or its control. They are informed about the importance of privacy and are updated about our Privacy Code and related policies. We have appointed a member of our senior management team to be our Privacy Officer. Our Privacy Officer is responsible for reviewing and approving all Personal Information handling practices, and ensuring that our policies and practices are up-to-date. Our Privacy Officer may be contacted at firstname.lastname@example.org.
2. We will identify how Personal Information will be used
Whenever we collect information about you, we will explain how we intend to use it. We will limit the information we collect to what we need for those purposes, and for no other purpose. We will always seek your consent.
3. We will confirm your Consent
We will confirm your consent to the collection, use or disclosure of Personal Information at the time of collection or in advance. Consent may be expressed in writing or implied and, in some cases, you may provide it verbally, electronically or through your authorized representative. You will always have an opportunity to "opt-out". Upon request, we will explain your options regarding refusal or withdrawal of consent to the collection, use and disclosure of Personal Information, and we will record and respect your written choices. Your decision to withhold particular details, however, may limit the services we are able to offer to you. Any refusal or withdrawal of consent may be subject to any overriding legal requirements or commitments.
4. We will limit the collection of Personal Information
Personal Information is collected by Phase 4 only for specific, limited purposes (see the section: "We will identify how Personal Information will be used"). When you visit our websites, information is not collected that could identify you personally unless you choose to provide it.
5. We will limit Use, Disclosure and Retention
The information we request from you is used only in accordance with purposes set out and in accordance with legislative requirements. If necessary, we will seek your consent before using the information for purposes beyond the scope of your original consent. In the case of contests and promotions, we will occasionally ask if you consent to the forwarding of Personal Information to our promotional and advertising partners. You may confirm or decline your consent. As a function of our fulfilling certain legal requirements, we may disclose Personal Information without consent. We will retain Personal Information only as long as is required for the purposes we describe and as is required under law. Once Personal Information is no longer required (or if you have opted-out or withdrawn your consent), it is our practice that it is destroyed, deleted or made anonymous.
6 We will strive to have accurate records
All decisions we make involving Personal Information are based on accurate, complete and up-to-date information. We rely on you, however, to disclose all material information and to inform us of any relevant changes or corrections as they may relate to you. We encourage you to contact us as soon as possible, and we will make the appropriate reasonable corrections or amendments, upon receipt of appropriate evidence.
7. We will protect Personal Information
We will protect Personal Information with appropriate safeguards and security measures. We utilize a combination of physical, administrative and electronic measures to ensure Personal Information is adequately protected on a day-to-day basis, for storage and disposal. Access to Personal Information is limited to those authorized by us. Our computer systems are password-secured or firewall protected and constructed in such a way that only authorized individuals may access these systems. To safeguard against unauthorized access to Personal Information via the Internet, you may be required to sign-on and go through a security protocol. If you send us an e-mail message that includes Personal Information, we will use that information to respond to your inquiry. Please note that email is not necessarily secure against interception.
8. We will keep you informed
We want to keep you informed. Our Privacy Code is transparent and it is made available to the public at www.phase4films.com.
9. We will provide you with Access to the information we retain about you upon written request, satisfactory identification and proof of entitlement. We will respond to you within thirty (30) days of receiving your proper written request. In some very limited circumstances, we may deny you access to Personal Information. If we deny your individual request for access to your Personal Information, we will advise you in writing of the reason for the refusal, subject to any legal requirements.
10. We will be in Compliance
We encourage you to contact us with any questions or concerns you might have about Personal Information or this Privacy Code. You can reach us by email or by mail at the following address:
Phase 4 Films Inc.
20 Eglinton Avenue West, Suite 603
Toronto, Ontario, Canada