Personal Information Protection

Personal Information Policy

This policy pertains to the collection, use and disclosure of all “personal information” exchanged during the course of a commercial activity (but does not include ECLA’s employee personal information).

PIPEDA defines “personal information” as “information about an identifiable individual.”

The type of personal information protected by this policy includes (but is not limited to):

• An individual’s name
• Address
• Age
• Telephone number
• Occupation
• Financial information
• Payment history
• Account activity

Notwithstanding the above, PIPEDA does not apply to business contact information that is collected, used or disclosed solely for the purpose of communicating with that person in relation to their employment or profession.

ECLA is responsible for all personal information which it collects, uses and discloses in the course of commercial activity. ECLA is also responsible for all information it discloses to third parties in the course of commercial activity and wherever necessary, will use contractual means to protect personal information which has been transferred to third parties or other service providers.

Privacy Officer

ECLA has designated a Privacy Officer (esther@gogogym.com) to administer this policy and ensure compliance with PIPEDA. The Privacy Officer is also responsible for receiving and responding to questions and complaints and dealing with requests for access to personal information in our possession. Other employees within ECLA may be responsible for the day to day collection and processing of information and may be designated to act on behalf of the Privacy Officer.

Consent

As required, ECLA will obtain consent of individuals prior to or at the time that the personal information is collected and/or disclosed.

ECLA will make reasonable efforts to ensure that at the time the personal information is collected, the individual understands the purposes for which it will be used.

An individual’s consent to collection, use and disclosure of personal information may be withdrawn at any time..

Purposes for Which Individual Information is collected:

• Employment consideration
• Permission based communications
• Business history for analysis of business results
• Financial processing
• Banking information for payroll or payment processing
• Information related to transactions such as accounts balance and payment history.

Limiting the Collection of Personal Information

ECLA limits the collection of personal information to that which is required to provide the necessary service or conduct the necessary activity and will only collect personal information through a fair and open means.

Limiting Use, Disclosure or Retention of Personal Information

• ECLA shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
• Personal information shall be maintained for as long as necessary for the fulfillment of the service or activity in question, or as otherwise required by law.
• When personal information is no longer required it shall be destroyed in a manner that preserves confidentiality.

Accuracy

ECLA shall take all reasonable steps to ensure that personal information collected, used and disclosed is accurate and as up to date as necessary for the purposes for which it is to be used. We request that if personal information changes, you let us know as soon as possible.

Safeguards

ECLA shall implement security safeguards which are designed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

• Employees of ECLA shall be trained with respect to the importance of maintaining confidentiality of personal information and compliance with PIPEDA and this policy.
• ECLA shall use care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to information.

Providing Information Regarding Privacy Policies and Practices

Upon request, ECLA will make the following information readily available to individuals:

• Name, title and address of the person(s) who is (are) accountable for ECLA’s policies and practices and to whom complaints and inquiries can be forwarded.
• The means of gaining access to personal information
• Description of the type of personal information held by ECLA, including a general account of its use and disclosure
• Copies of any documents which describe ECLA’s policies and procedures relating to privacy issues.

Providing Individual Access to Personal Information

• Upon written request and subject to exemptions stipulated by law, ECLA shall inform individuals of the existence, use and disclosure of their personal information and provide access to that information.
• Individuals have the right to challenge the accuracy and completeness of personal information maintained by ECLA and request rectification of any personal information which may be obsolete, incomplete or incorrect.
• An individual requesting disclosure of his or her personal information may be required to provide sufficient information to permit ECLA to provide account of the existence, use or disclosure of the information.
• ECLA shall validate the identity of anyone making a request of personal information to ensure that the information is not provided to anyone who does not have the right to that information.
• ECLA may charge an administration fee for providing access to the personal information in accordance with the individual’s request.
• ECLA shall respond to requests for personal information within thirty (30) days and if ECLA is not able to produce the information within this time frame will provide an explanation and will indicate when the information will be produced.
• Individuals may also have recourse to the Office of the Privacy Commissioner of Canada at the following address:

Privacy Commissioner of Canada
112 Kent Street
Ottawa, Ontario K1A 1H3
Email: http://www.privcom.gc.ca