EMS Ltd. understands that privacy is an important issue for our clients, and one that we have taken steps to protect. This Policy outlines the principles and procedures we apply in protecting the confidentiality and security of personal client information. It is based on the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information, and designed to comply with the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") as well as applicable Provincial privacy legislation (the "Act"). In doing so we have tailored our own privacy principles to meet the specific needs and expectations of our business.
This Policy applies to personal information collected about EMS Ltd. clients and individual representatives of corporate clients. "Personal Information" is information about an individual that is connected to that person as an individual. It does not include the name, title or business address or telephone number of an employee of an organization.
EMS Ltd. is responsible for all Personal Information under its control.
Accountability for our compliance with privacy principles rests with our Privacy Officer or Officers as named on this website, even though other individuals within EMS Ltd. have responsibility for the day-to-day collection and processing of Personal Information and may be delegated to act on behalf of the Privacy Officer.
EMS Ltd. is responsible for Personal Information in our possession or custody, including information that has been transferred to a third party for processing. We will use contractual or other means to provide a comparable level of protection when the information is being processed by a third party.
EMS Ltd. will identify and document the purposes for which we collect, use, or disclose Personal Information at or before the time of collection.
The purposes will be limited to those which are related to our business and which a reasonable person would consider are appropriate in the circumstances. We collect, use, and disclose Personal Information concerning our customers for the following reasons:
- To provide timely, reliable and value-added services to customers including domestic and international shipping, shipment tracking, customs brokerage, account management and billing, global logistics, supply chain management, information management and technical support, e-commerce, and related services;
- To establish a customer relationship and to communicate with customers;
- To develop, implement, market, and manage services for customers;
- To assist in law enforcement purposes, to collect unpaid debts, for credit reporting and rating purposes, and to protect the business interests of EMS Ltd. and its customers;
- To manage and promote the business activities of EMS Ltd.; and
- To meet requirements imposed by law.
We collect, use, and disclose Personal Information concerning our employees for the following reasons:
- To recruit, train, recognize, and retain a highly qualified and motivated workforce;
- To establish and maintain harmonious employer-employee relations;
- To administer EMS Ltd. policies and procedures, including investigations related thereto;
- To manage and promote the business activities of EMS Ltd.;
- To administer compensation and benefits;
- To develop, manage, and promote employee services; and
- To meet requirements imposed by law.
If EMS Ltd. plans to use Personal Information we have collected for a purpose not previously identified, we will identify and document this purpose before such use.
We will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the Personal Information is collected either at the time of collection or after collection but before use. We will state the identified purposes in such a manner that an individual can reasonably understand how the information will be used or disclosed.
Personal Information will only be collected, used, or disclosed with the knowledge and consent of the individual, except where inappropriate.
The way in which EMS Ltd. seeks consent, including whether it is express or implied, may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. An individual can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. We will inform individuals of any implications of withdrawing consent.
Typically, we will seek consent for the use or disclosure of information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (such as where we want to use information for a purpose not previously identified).
EMS Ltd. will not, as a condition of the supply of services, require an individual to consent to the collection, use, or disclosure of Personal Information beyond that required to fulfill the explicitly specified and legitimate purposes.
In certain circumstances, as permitted or required by law, we may collect, use or disclose Personal Information without the knowledge or consent of the individual. These circumstances include: Personal Information which is subject to solicitor-client privilege or is publicly available as defined by regulation; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to investigate a breach of an agreement or a contravention of a law; to act in respect to an emergency that threatens the life, health or security of an individual; for debt collection; or to comply with a subpoena, warrant or court order.
EMS Ltd. will only collect personal information for the purposes identified, and only use methods that are lawful. We do not collect information indiscriminately.
Limiting Use, Disclosure, and Retention
Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information will be retained only as long as necessary to fulfill the identified purposes.
Personal Information which has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law. Where Personal Information is no longer required to fulfill the identified purposes, it will be destroyed, erased, or made anonymous.
EMS Ltd. will use our best efforts to ensure that Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
We will use our best efforts to ensure that Personal Information that is used on an ongoing basis, including information that is disclosed to third parties and information that is used to make a decision about an individual, is accurate, complete, and up-to-date.
EMS Ltd. will protect Personal Information with safeguards appropriate to the sensitivity of the information.
Our safeguards will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We will make our employees aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information.
Our methods of protection will include physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example, security clearances and limiting access on a "need-to-know" basis), and technological measures (for example, the use of passwords and encryption).
EMS Ltd. will make specific information about our policies readily available, except to the extent this is confidential commercial information.
The information we will make available will include: how to gain access to Personal Information; the type of Personal Information held by us, including a general account of its use; general information concerning our Code and policies; what Personal Information is made available to related companies; and how to contact our Privacy Officer.
Upon written request, EMS Ltd. will inform an individual of the existence, use, and disclosure of his or her Personal Information and we will give the individual access to that Personal Information. An individual can challenge the accuracy and completeness of his or her Personal Information and have it amended as appropriate.
EMS Ltd. will respond to an individual's written request within a reasonable time (generally within 30 days) unless we require additional time to fulfill the request. In such cases, we will send a notice of extension advising of the new time limit and the reasons for extending it so that the client may properly consider his/her remedies. We will assist any individual who informs us that they need assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use, and disclosure of Personal Information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is generally understandable. Where possible, we will indicate the source of the information.
In providing an account of third parties to which we may have disclosed Personal Information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed Personal Information, we will provide a list of organizations to which we may have disclosed the information.
If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.
In certain situations, we may refuse a request or not be able to provide access to all the Personal Information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.
Any individual can address a challenge concerning our compliance with any of the privacy principles to our Privacy Officer.
EMS Ltd. will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.
EMS Ltd. Privacy Officer
Michel Avoine Phone: 604-538-1566 firstname.lastname@example.org 101 - 17637 1st Avenue Surrey, BC V3Z 9S1
If our Privacy Officer is unable to satisfactorily address individual concerns, the issue may be referred to our Legal Department:
Heidi Telstad, Corporate Counsel Phone: 604-538-1566 email@example.com 101 - 17637 1st Avenue Surrey, BC V3Z 9S1
Of course, at any point in that process the individual may also write to the Privacy Commissioner.
Information captured on EMS Ltd. Website
Every computer that connects to the Internet has an IP (Internet Protocol) Address which is an unique number for identification purposes. IP addresses of computers used to visit our Website may be logged. In addition, we automatically collect other information such as email addresses, browsers types, operating systems and the URL addresses of sites clicked to and from our Website.
We receive and store information you enter. You can choose not to provide certain information, but then you might not be able to take advantage of some of our features. We use the information that you provide for such purposes as responding to your requests, customizing future services for you.
Use of Information
We may use your information to help us identify the type of Website content our customers value most and to provide a customized experience. We then use this information to improve the services we offer and to improve the Website. We also use this information to be able to communicate with you, including by sending you e-mail notifications about updates to the Web site, and for marketing purposes.
We may send you special offers from time to time, unless you choose to opt-out of receiving such offers. In addition, we may also send you special offers from other companies. Again, you may opt-out. If we send information from other businesses, we do not share your personal information with them. The offers come directly through us.
As we continue to develop our business, we might sell or buy business assets. In the unlikely event EMS Ltd. is acquired (purchased) by another company, then customer information will be one of the acquired business assets.
Links to Third Parties
Parts of our Website consist of products and services hosted by business partners and other third parties. When you leave our Website to visit one of their sites, the only information transferred to the third part is the fact that you came from our Website. This practice allows the third party to monitor its own Website traffic, but does not provide them with any information about you. EMS Ltd. is not responsible or liable for the privacy policies or content of third party sites. You should consult the privacy policies at those sites to determine how your information may be used.
Like many websites, we may use "cookies". Cookies are small files that we transfer to your hard drive in order to provide EMS Ltd. with the capability to customize information for certain segments of its customer base and in some instances, cookies are used to allow EMS Ltd. the opportunity to associate individual customers with their information profiles.
A cookie is a series of data characters that, when programmed into a Website, is placed by the Web Server into the browser's application folder on your computer. Once placed onto your machine, the cookie will allow the Website to "recognize" you as a unique individual.
It is your choice whether you want to receive emails or special offers from EMS Ltd. Our default settings are as follows:
- Please send me email or other mail informing me of special offers of your products or services;
- Please send me email or other mail informing me of special offers of related products or services from other companies.
You may choose to opt-out of receiving email or other mail from us by providing us with your Full Name and E-mail address to allow us to identify you correctly for removal.
Protection of Your Personal Information
We protect your personal information by encryption through SSL (Secure Sockets Layer) software, firewall protection and taking every reasonable precaution to assure that your personal information is secure. We also limit access to your personal information within EMS Ltd. on a "need to know" basis.
You can also take steps to protect your personal information by protecting unauthorized access to your password and to your computer. Be sure to sign off your computer when you are finished, especially if it is a shared computer.
Amendments to Policy
Last Updated: February 23, 2015