Privacy Statement & Policy
Thinkwell Shift will obtain clients’ understanding and informed consent before collecting, using, or disclosing any Personal Information as and when required by PIPEDA. In addition, a customer may withdraw his or her consent at any time upon notifying Thinkwell Shift subject to any legal or contractual obligations of the customer and as provided for in PIPEDA.
2. Purposes of collection, use, and disclosure
2.1 Thinkwell Shift will identify the purposes for collecting Personal Information at the time or before the information is collected. Thinkwell Shift collects personal information from its clients for the following purposes:
To recommend products and/or services to clients and potential clients;
To market or provide energy saving products and services;
To manage and develop Thinkwell Shift business and operations;
To meet legal and regulatory requirements;
To provide clients and potential clients with information regarding Thinkwell Shift’s products and services; and
2.2 Thinkwell Shift will only use clients’ Personal Information for the above-stated purposes unless the client consents to another purpose or as is required by law. The types of Personal Information that Thinkwell Shift may collect, retain, and disclose may include, but are not limited to, the following:
Notice of Assessment (income)
Proof of Home Ownership
Utility Account Number and Service Provider
Other Personal Identifiers, such as Household Identification Number
Other information relating to building/household characteristics such as age of building, size, number of occupants
Thinkwell Shift will occasionally collect Personal Information through its website(s). This Personal Information will be collected, used, and disclosed according to the same policies and procedures as any other Personal Information provided to Thinkwell Shift
not sell clients’ Personal Information to third parties.
Thinkwell Shift EfficiencyOne has a Personal Information and Privacy Program in place that lays out physical and technological security safeguards and procedures in place to protect clients’ Personal Information from unauthorized access, disclosure, use, or modification. These safeguards include, for example: privacy training for employees, physical access controls to our premises, and standards and procedures for storing and safeguarding paper and electronic Personal Information. Additionally, Thinkwell Shift has Information Technology policies, procedures and logical controls in place to ensure the Thinkwell Shift information technology environment maintains Personal Information in safe and secure manner. Thinkwell Shift audits its procedures and security measures regularly to ensure that they are appropriate and that all Personal Information is protected.
Thinkwell Shift acknowledges that it is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. The organization shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
Thinkwell Shift will ensure that client Personal Information is accurate and updated, when necessary. EfficiencyOne relies on its clients to inform of any changes to Personal Information.
6. Access and correction
Clients may access their Personal Information, subject to the exceptions listed in PIPEDA, or request a correction of Personal Information. The request must be made in writing and contain sufficient detail to enable Thinkwell Shift to identify the client’s Personal Information to either provide the information or to make the correction(s). A minimal fee may be charged for providing access to Personal Information; however, the client will be informed of any applicable fee(s) when the request is received. In most cases, a response will be provided within 30 business days, however, if a longer time is needed, Thinkwell Shift will provide the client with written notice stating the reasons for the extension.
7. Retention and destruction
Thinkwell Shift will retain Personal Information provided by clients no longer than is necessary for legal or business purposes. When this Personal Information is no longer required, it shall be destroyed, erased, or made anonymous pursuant to the requirements of PIPEDA.
8. Breaches of security safeguards
In the event a breach ofThinkwell Shift security safeguards involving Personal Information creates a real risk of significant harm to an individual, Thinkwell Shift will provide a report to the Privacy Commissioner and will notify the individual(s) involved (unless otherwise prohibited by law) as soon as feasible after Thinkwell Shift determines that the breach has occurred. Thinkwell Shift will also maintain internal records of every breach of its security safeguards involving Personal Information.
Questions about the Personal Information in Thinkwell Shift custody or requests to withdraw consent for the collection of Personal Information should be directed to Privacy Officer by email email@example.com
This policy will be amended from time to time as Thinkwell Shift regularly reviews and updates its policies and procedures.