PRIVACY POLICY

At Thinknology, we are committed to meeting our privacy commitments to our clients and in complying with the requirements of the federal Protection of Personal Information and Electronic Documents Act (“PIPEDA”) and the B.C. Personal Information Protection Act (“PIPA”).

This Privacy Policy sets out the principles and procedures that Thinknology Innovations Inc. (“Thinknology”, “we” and “our”) follows in meeting its privacy commitments to its clients and in complying with the requirements of the federal Protection of Personal Information and Electronic Documents Act (“PIPEDA”) and the B.C. Personal Information Protection Act (“PIPA”).

DEFINATION OF PERSONAL INFORMATION

“Personal information” means all information about an identified or identifiable individual. In some jurisdictions, the term “personal data” is used in local privacy laws rather than the term “personal information”. Thinknology uses the terms “personal information” and “personal data” interchangeably.

ACCOUNTABILITY

Thinknology is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.

We collect personal information from our clients and use and disclose such personal information only for the purposes of providing requested professional services to our clients. We identify the purpose for which we collect personal information from our clients before it is collected.

CONSENT

As a general principle, Thinknology will obtain your consent before collecting, processing, storing, using or disclosing your personal information for any purpose other than as identified in this Privacy Policy. We collect only that personal information required to perform our professional services and to operate our business. This personal information is collected by fair and lawful means. Our principals and employees involved in a particular engagement will access only the information required to complete that engagement or to deal with other matters such as invoicing and general correspondence.

LIMITED COLLECTION

Thinknology will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified. Thinknology will not collect excessive personal information, and will limit the purposes of collection to what a reasonable person would consider fair and appropriate in the circumstances.

Thinknology will collect personal information only by fair and lawful means, will be transparent, up front and open with you, and will communicate in a manner that is clear and reasonably understood.

LIMITED USE, DISCLOSURE AND RETENTION

Thinknology will use and disclose personal information only as described in this Privacy Policy, or for the purposes for which it was collected, or as agreed by you, or without your consent for the limited circumstances listed above in the section titled “Consent”. We will not use or disclose personal information for any additional purpose that is incompatible with the original purpose unless we obtain consent to do so. We will not sell your personal information to other parties

Thinknology may share personal information with our employees, contractors, consultants, affiliates, service providers, business partners and other parties who require such information to assist us with providing you with the Services.

Thinknology will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for Thinknology’s legitimate business purposes, or to comply with applicable legal, tax or regulatory requirements. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous.

ACCURACY

Thinknology will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. Thinknology does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. Thinknology therefore relies on you to keep your personal information accurate and current.

You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Thinknology and must provide sufficient detail to identify the personal information and the correction being sought.

If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.

SAFEGUARDING PERSONAL INFORMATION

Thinknology will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Thinknology as well as within. Thinknology’s security safeguards include locked filing cabinets, physically secured offices where personal information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.

Thinknology trains all staff who handle personal information on the importance of and procedure for maintaining confidentiality. All employees, contractors, consultants and service providers of Thinknology who are provided access to personal information on behalf of Thinknology are required to be familiar with and comply with the provisions of this Privacy Policy and applicable laws.

Thinknology will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Thinknology will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Thinknology and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a Privacy Commissioner or similar regulatory body in any relevant jurisdiction.

COMPLAINT PROCEDURE

All complaints, concerns or inquiries about Thinknology’s privacy policies and practicesshould be made in writing to:

THINKNOLOGY INNOVATIONS INC.
79 5750 TYNE STREET
VANCOUVER, BC. V5R 4L6
E-mail: privacy@thinknology.ca